| OSHA requirements are set by statute,
standards and regulations. Our interpretation letters explain
these requirements and how they apply to particular
circumstances, but they cannot create additional employer
obligations. This letter constitutes OSHA's interpretation of
the requirements discussed. Note that our enforcement guidance
may be affected by changes to OSHA rules. Also, from time to time
we update our guidance in response to new information. To keep
apprised of such developments, you can consult OSHA's website
at http://www.osha.gov. |
June 17, 2002
| MEMORANDUM TO: |
Michael G. Connors,
Regional Administrator, Region V
|
| FROM: |
Russell B. Swanson, Director
Directorate of Constructionm
Richard Fairfax
[Directorate of Enforcement Programs]
|
| SUBJECT: |
Flexible Corrugated Plastic Covers for Temporary Use to Cover Live Electric Parts in Switch and Panel Boxes |
This is in response to your May 21, 2001, memo
addressed to the [Directorate of Enforcement Programs (DEP)], in
which you ask for clarification on the use of a temporary
electrical panel box cover manufactured by SP Products Inc. In
a
June 28, 2000 interpretation memorandum addressed to Mr. Kenneth Gerecke of Region III (revised), DEP stated that the use
of corrugated plastic "switchbox" covers that have not
been approved in accordance with general industry standards was
prohibited. However, you ask if their use is also prohibited in
construction.
The SP Products Inc. temporary box cover ("temporary
cover") is basically a warning sign made of high-visibility
corrugated plastic, and similar to plywood or heavy cardboard in
physical appearance. The temporary cover, which attaches to the
panel or switch box by two nonconductive magnetic strips, is
rated for 600 volts, and is advertised as durable and being
water, puncture, and tear resistant. The temporary cover is
intended to be used when frequent access is needed to the live
electrical parts of a panel box. During those times (involving
both construction and general industry activities), the temporary
cover would be used in lieu of the permanent (approved) covers
provided by switch and panel box manufacturers. SP Products Inc.
says the ease with which the temporary cover can be installed and
repeatedly moved or removed is a significant advantage over the
common practice of using cardboard or plastic sheeting. That
practice is common because of the time and effort needed to
remove and replace the manufactured cover repeatedly, which
typically requires screws or nuts and bolts for its removal and
re-installation.
Sections 1926.405(d) and 1910.305(d) require that:
Switchboards that have any exposed live parts shall
be located in permanently dry locations and accessible only to
qualified persons. Panelboards shall be mounted in cabinets,
cutout boxes, or enclosures designed ["approved" for
§1910.305] for the purpose and shall be dead front. However,
panelboards other than dead front externally operable type are
permitted where accessible only to qualified persons...
[emphasis added]
Both standards define "accessible" and "readily
accessible" as follows:
Accessible (as applied to equipment):
Admitting close approach; not guarded by locked doors, elevation,
or other effective means. (See "Readily
accessible").
Readily accessible: Capable of being reached quickly for
operation, renewal, or inspections, without requiring those to
whom ready access is requisite to climb over or remove obstacles
or to resort to portable ladders, chairs, etc.
In essence, the temporary cover is designed to make the live
parts of the panel box "readily accessible." With the
temporary cover installed, anyone, including unqualified
personnel, can readily obtain access to those parts. In contrast,
the standards indicate that inaccessibility requires obstacles
that are not easily/readily overcome to block access to the live
parts. For example, the original, manufacturer-supplied panel box
covers can only be removed by first removing screws. Therefore,
the temporary cover violates these standards.
|
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