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.

July 16, 1985

The Honorable George M. O'Brien
House of Representatives
Washington, D.C. 20515

Dear Congressman O'Brien:

Thank you for your letter of May 17, requesting a review of the safety features and the technical capabilities of the "Isolation Transformer Electronically Controlled (ITEC)" invention on behalf of your constituent, Arthr A. Kraus.

The Occupactional Safety and Health Administration (OSHA) is a regulatory agency responsible for assuring safe nd healthful conditions in the workplace. OSHA does not test, evaluate, approve, endorse or promote goods or services of any kind. However, we would like to mention that Section 1910.399(a)(1) of OSHA's General Industry standards provides a definition for installations and equipment which are acceptable to OSHA. For your convenience a copy is enclosed.

As you can see in Section 1910.399(a)(1), if Mr. Kraus wants an assessment of the safety features of his device, he should contact a nationally recognized testing laboratory such as, but not limited to, Underwriters' Laboratories, Inc., and Factory Mutual Engineering Corporation. Their addresses and telephone numbers are:

Underwriters' Laboratories, Inc.
Public Information Office
333 Pfingsten Road
Northbrook, Illinois 60062
Telephone: (312) 272-8800


Factory Mutual Engineering Corporation
1151 Boston-Providence Turnpike
Norwood, Massachusetts 02062
Telephone: (617) 762-4300

In regard to the assessment of the technical capabilities of the device, we recommend that Mr. Kraus contact a private consultant.

We are sorry that we cannot be of more help to Mr. Kraus on the subject of his invention. If we can be of further assistance, please contact us.


Edward J. Baier
Directorate of Technical Support


May 17, 1985

Mr. Edward Bair
Director of Technical Support
Occupational Safety and Health Administration
200 Constitution Avenue, N.W.
Washington, D.C. 20210

Dear Mr. Baier:

Mr. Arthur Kraus, one of my constituents, has requested an OSHA review of the particular safety features of his proposed electronic home control unit model 1075 which is designed to protect against fire and help prevent electrical shock.

I would appreciate your reviewing this proposal and providing your assessment of its technical capabilities and safety features and any other comments on it you might have.


George M. O'Brien
Member of Congress