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 https://www.osha.gov.

February 3, 1977

Mr. Donald A. Duncan,
CSP Director,
Safety and Environmental Controls Otis
Elevator Company 750 Third Avenue
New York, New York 10017

Dear Mr. Duncan:

This is in reply to your letters dated December 22, 1976, and January 18, 1977, addressed to the Occupational Safety and Health Administration (OSHA), concerning two different subject matters. Namely, Otis Elevator signs for elevator maintenance room doors and OSHA's requirements of the Ground Fault Protection Standard, 29 CFR 1926.400(h), as it relates to double insulated tools.

The National Office has investigated the situation concerning OSHA's requirements for signs posted on the doors of the elevator maintenance rooms. Both of the concerned parties in Florida have been contacted and it has been decided that Otis Elevator signs for elevator maintenance rooms meets the intent to the standard. The problem appears to be that unauthorized and/or unqualified personnel have access to the elevator maintenance room, which in itself is a violation of NEC 110.17(a)(1). The additional wording as proposed in Mr. Kelly's departmental letter would have little or no effect on unauthorized and/or unqualified persons entering the room.

As for as the use of double insulated tools on construction sites, as they relate to the recently published Ground Fault Protection Standard, the following information is offered.

The Standard addresses two separate methods of ground-fault protection, of which the employer must chose one. If the ground- fault circuit interrupter (GFCI) option is chosen, all 120-volt, 15- and 20-ampere receptacle outlets, which are not part of the permanent wiring and which are in use by employees must be protected regardless of the type of tools that are plugged into them. If the assured equipment grounding conductor program is the chosen option, them all cord sets, receptacles which are not part of the permanent wiring, and cord and plug-connected equipment (including double insulated tools) must be covered by the program. Although tools that are not required to grounded (e.g., double insulated tools) are not required to be tested, all applicable requirements of the program (such as daily inspections) must be complied with.

If I can be of any further assistance, please feel free to contact me.


John K. Barto,
Chief Division of
Occupational Safety Programming