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.

August 5, 1992

Mr. Melvin L. Henry
Electrical Supervisor
Gasbarre Products, Inc.
P.O. Box 1022
Dubois, Pennsylvania 15801

Dear Mr. Henry:

Thank you for your inquiry of May 4, addressed to Tony Rizzo, Assistant Area Director in Erie, Pennsylvania, asking if Presence Sensing Palm Button Devices (PSPBD) can be used in place of spring-loaded two-hand control devices.

The Occupational Safety and Health Administration (OSHA) does not approve or disapprove products. However, OSHA requires that all electrical products used by employees be tested and approved for their intended use by a testing laboratory approved by OSHA. The OSHA standard 29 CFR 1910.7 designates such laboratories as Nationally Recognized Testing Laboratories (NRTL's), and a list of them is enclosed.

If an electrical product, such as a PSPBD, has an NRTL approval for the intended use, for example replacing spring-loaded two- hand control devices, and a NRTL tests and approves the PSPBD's for that use, OSHA will accept the use of that product as a replacement for spring-loaded two-handed control devices.

Because PSPBD's are relatively new in the marketplace, we called Underwriters Laboratories Inc. (UL) and talked to Mr. Bob Florczyk, press control expert, about the kind of tests UL is running on PSPBD's. Mr. Florczyk said they are testing PSPBD's for electrical reliability, fire and shock hazards, possibilities of inadvertent activation, and instructing installation of PSPBD's in such a manner that the machine operator is not able to reach the point of operation while using them. The document for testing PSPBD's, which is now in development, is UL 491.

We appreciate your interest in employee safety and health. If we can be of further assistance, please do not hesitate to contact us.


Patricia K. Clark, Director
Directorate of Compliance Programs