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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.
February 20, 1981
MEMORANDUM FOR: GILBERT J. SAULTER REGIONAL ADMINISTRATOR ATTENTION: HERBERT M. KURTZ THRU: JOHN MILES FIELD COORDINATOR FROM: BRUCE HILLENBRAND DEPUTY DIRECTOR, FEDERAL COMPLIANCE AND STATE PROGRAMS SUBJECT: Citing of Reversed Polarity
This is in reference to our memorandum dated February 6, 1980, on the same subject.
Mr. John Miles informs us that you are not clear for our previous memorandum whether citations should be issued for reversed polarity and what standards to use.
Citations should be issued for reversed polarity since hazards do exist as pointed out in the two enclosures of the previous memorandum. A hazard which has the potential, under appropriate conditions, for an electrocution is a serious one.
The new OSHA electrical standard, "Design Safety Standards for Electrical Systems," has adopted as Subparagraph 1910.304(a)(2), the prohibition of reversed polarity contained in the new 1978 NEC Section 200-11; viz., "No grounded conductor may be attached to any terminal or lead so as to reverse designated polarity." The new standard, published in the Federal Register on January 16, 1981, is based on the NEC and revises 29 CFR 1910, Subpart S. It becomes effective on April 16, 1981, provided there is no legal stay.
In the interim, if the terminals and/or grounded conductor are not properly identified, then the employer could be cited for a violation of 29 CFR 1910.309(b) (i.e., if the terminals and/or grounded conductor were installed after March 15, 1972, or if their condition were affected by a "replacement, modification, repair, or rehabilitation" after March 15, 1972), predicated upon the applicable 1971 NEC Sections 200-2, 200-6, 200-7, 200-9, 200-10(a)&(b), and 210-5(a).