Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

November 30, 1977

Mr. K. J. Millerv
Gilbert Associates, Inc.
P. O. Box 1498
Reading, Pennsylvania 19603

Dear Mr. Miller:

This is in response to your letter to Mr. Bunton Nichols, Occupational Safety and Health Office, Houston, Texas, dated September 1, 1977, which was referred to this office for reply. Your letter concerned the applicability of the Occupational Safety and Health Administration's requirement for ground-fault circuit interrupter (GFCI) protection to the Ship Repairing Industry.

The OSHA Standards 29 CFR 1910.309(c) and 1926.400(h), as well as the 1971 National Electric Code, Article 210-7, refer to the requirement of the GFCI at construction sites. It is not the intent of these standards that ship repairing in itself be interpreted as producing a construction site. A "construction site", is to be interpreted in its usual denotation of a location where a building, highway, or the like, is, for example, being constructed, and is not to be construed in any general connotation as a place where a product, such as a boat, is being repaired or built or constructed or manufactured. However, in special cases, such as when a building, for example, is being constructed at the ship repairing site, the GFCI standards would apply but, then, only to the operation of constructing the building. The above rationale also applies to the Shipbuilding Industry.

Nevertheless, the use of either GFCI's or an assured equipment grounding conductor program as specified in these standards is recommended in the construction and repair of maritime vessels since electrical hazards may appear there in the same way as at construction sites. Furthermore, a copy of this correspondence is being forwarded to the Office of Maritime Safety Standards for their consideration in the development of similar standards for the maritime industries.

I hope this information will be helpful. If I may be of any further assistance, please contact me.


John K. Barto, Chief
Division of Occupational
Safety Programming