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.

August 10, 1983

Mr. John Hopkins
Staff Executive
National Electrical
Manufacturers Association
2101 L Street, N.W.,
Suite 300
Washington, D.C. 20037

Dear Mr. Hopkins:

In accordance with the discussion between OSHA and NEMA representatives held July 26, 1983, in the OSHA National Office, this is an addendum to our previous letter of June 10, 1983, regarding the NEMA "Mr. Ouch" Labeling System.

OSHA believes that the "Mr. Ouch" label may enhance safety and can be used to supplement the requirements of the present OSHA standards, which are based upon the 1968 standard of the American National Standards Institute, adopted by OSHA in 1971.

For the NEMA system to meet the intent of OSHA's existing standards, the following alternatives are available:

* Incorporate NEMA's "Mr. Ouch" label on a "Caution" sign meeting the requirements of Section 1910.145; or

* Use the NEMA label in addition to labels specified in OSHA standards. For example, signs for transformers are addressed in 29 CFR 1910.303(h)(2)(ii), 1910.305(j)(5)(ii), and 1926.402(d)(3). These signs must meet the requirements of 1910.145 of the standards for general industry or 1926.200 of the standards for construction, as appropriate.

We sincerely appreciate NEMA's interest in safety and hope this information is helpful to you in your accident prevention efforts. If I may be of further assistance, please feel free to contact me.

Sincerely,



Bruce Hillenbrand
Director, Federal Compliance
and State Programs