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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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

February 21, 1986

Mr. Bruce R. Nelson
Nelson Lamp Lighters, Inc.
1811 Castle Gardens Road
Vestal, New York 13850

Dear Mr. Nelson:

In reply to your letter requesting an interpretation for the use of ground fault protection as related to extension cords being used between the permanent wiring of the building and the powered tool.

Under the standard, receptacle outlets which are part of the permanent wiring of the building or structure are not required to be protected by GFCI's. However, powering tools, such as saws, drills, etc., by means of "extension cords" (cord sets) is in violation of the standard. In this instance, the cord set is used as temporary wiring (i.e. a substitute for the fixed wiring of a structure) to provide power to areas remote from the permanent receptacle outlet. The receptacles (cord connectors) at the end of such cord sets are "receptacle outlets which are not part of the permanent wiring of the building or structure," and a GFCI or an assured grounding program must be in place. Instructions are enclosed to further define the above discussion.

It should be noted for consideration, when portions of the building(s) or structures(s) which have been completed and no longer expose employees to weather or damp and wet locations, or to other grounding hazards, GFCIs or an assured equipment grounding program may not be required when approved extension cords are plugged into the permanent wiring at construction sites.

If we can be of further assistance, please do not hesitate to contact this office.


John B. Miles, Jr., Director
Directorate of Field Operations