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 9, 1993

                   Regional Administrator

FROM:               ROGER CLARK, Director
                   Directorate of Compliance Programs

SUBJECT:            Nationwide Inquiry Concerning a Specific Type of
                   Extension Cord

This memorandum is in response to your recently transmitted memorandum dated April 13 concerning the use of a specific type of extension cord in meeting our grounding continuity requirements.

We reviewed the enclosed letter which you forwarded to John Fauth Sales Company concerning this issue and found it to be correct. In addition, we made telephone contact with Mr. John D. Fauth and obtained information which confirmed that the LED light embedded in the female end of the "Yellow Jacket" cord set does not meet the intent of our assured equipment grounding conductor program requirements for testing all equipment grounding conductors for continuity. The cord set visual indicator provides an indication that the cord set is energized, but does not indicate whether the cord set has proper grounding continuity or correct wiring.

Any nationally recognized testing laboratory listed, labeled or certified ground continuity tester wired to a cord sets receptacle can be used to comply with the requirements to test the cord (1926.404(b)(1)(iii)(D) and (E)), and to mark the cord as having been tested (1926.404(b)(1)(iii)(G)). This is based on the assumption that all cord connectors used on the site would incorporate the tester or would otherwise be tested in compliance with the ground-fault protection standard. Additionally, this device can be used to test other equipment on the jobsite. However, because it neither identifies other equipment that has been tested nor checks for multiple wiring defects, it cannot be used in lieu of the marking required under 1926.404(b)(1)(iii)(G) for this other equipment. Paragraph (b)(1)(iii)(D)(2) specifically requires each receptacle and plug to be tested individually. Similarly, a ground continuity tester wired to the plug of a cord set or a power cord can be used only to test receptacles and cord sets to which the plug is connected. It does not test the cord set or power cord on which it is installed.

Thank you for providing the Directorate of Compliance Programs with information concerning this issue. If you have any questions or comments please contact Mr. Roy Gurnham or Mr. Dale Cavanaugh of my staff at (202) 219-8136.

DATE:               April 13, 1993



                   EXTENSION CORD

Enclosed is a copy of our response to an inquiry concerning a specific extension cord. The cord, manufactured by Wood Wire Works of Carmel, Indiana, is equipped with a built-in device which indicates if the cord is energized. The inquiry specifically related to whether OSHA would require "continuity" testing of this cord; however, OSHA's regulations dealing with "continuity" for extension cords relate to equipment grounding conductors and not to whether a cord is energized.

The letter, which was likely sent to all Regional Offices, could be misinterpreted. It could be read as indicating that the referenced built-in device is capable of indicating there is continuity of the equipment grounding conductor.

This information is being forwarded to you for any action you deem appropriate. If you require any additional information regarding the preceding, please contact John McFee at (215) 596-1201.

April 8, 1993

John D. Fauth
John Fauth Sales Company
P.O. Box 327
Orchard Park, New York 14127

Dear Mr. Fauth:

This is in response to your letter asking whether OSHA would require specific brand of extension cord, equipped with a built-in "continuity tester", be tested for continuity. The built-in "continuity tester" is in the form of a light embedded in the receptacle portion of the cord set. When the light is on, that means the cord is energized.

OSHA's concern for continuity, in so far as extension cords are concerned, relates to continuity of equipment grounding conductors. The built-in "continuity tester", in the cord in question, does not and cannot provide any information concerning the continuity of equipment grounding conductors.

If you require any additional information regarding the preceding, please contact John McFee of my staff at (215) 596-1201.


Regional Administrator

cc: r RAr ADs/DSs ARA/FSO Commissioners/State Plan States RAs R.Stroup/N.O. R.Gurnham/N.O. Jim Hale/Woods Wire Products, 510 Third Avenue, S.W. Carmel, Indiana 46032

March 10, 1993

Ms. Linda Anku
Regional Administrator
3535 Market Street Gateway Bldg.,
Rm. 2100
Philadelphia, PA 19104

Dear Ms. Anku:

I am writing at the request of O.S.H.A. and on behalf of Woods Wire Products with regards to a recently developed series of commercial extension cords.

The new "Yellow Jacket" series of cord sets, manufactured by Woods Wire, is designed with a 25,000 hour LED light in the female plug. The purpose of this feature is to meet the spirit and intent of O.S.H.A. jobsite continuity testing requirements. It serves as a continual visual indicator of unbroken continuity within the cord set.

Upon review of these products at O.S.H.A., they requested that each regional office be contacted in order that your inspectors, and our customers, may be assured that these cord sets do indeed meet the O.S.H.A. requirements for continuity testing both in letter and spirit.

Ms. Anku, we recognize that O.S.H.A. does not approve or list individual items or manufacturers. We also recognize that your recognition of this feature as a continual continuity tester does not release the user form other O.S.H.A. standards for use (ie: damage, etc.).

I am, however, hopeful that you may be able to respond in a written fashion that jobsite use of cord sets with this feature will not be subject to the periodic continuity test requirements without fear of encountering an O.S.H.A. fine. Please keep in mind that unlike the current O.S.H.A. testing periods, these items provide continuous proof of continuity and therefore a superior level of safety.

In order that you may further review these items, I have arranged to have several samples sent to your attention under separate cover. If you should have any questions with regards to this matter, I welcome the opportunity to speak with you. Please phone me at 716-662-4510 or 412-923-2244 ext. 358 whenever I may be of assistance.



John D. Fauth