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.

December 9, 1993

Mr. Jack Wells
Vice President
Corporate Development
Pass & Seymour, Inc.
P.O. Box 4822
Syracuse, New York 13221

Dear Mr. Wells:

This is in response to your letter dated November 10, to Mr. David C. Zeigler, Acting Assistant Secretary, Occupational Safety and Health Administration (OSHA), concerning the use of proper equipment for testing ground-fault circuit interrupters (GFCIs) in accordance with 29 CFR 1926.404(b)(1)(ii). Your letter was forwarded to this office for response.

Please be advised that we will immediately begin gathering information regarding the type of GFCI testers presently being used by OSHA field personnel which may not be listed by a Nationally Recognized Testing Laboratory and which may not be properly designed to perform a valid test on GFCIs manufactured in accordance with UL standards for GFCIs.

We appreciate you bringing this matter to our attention and we will take the appropriate action.

If we can be of any further assistance, please contact Mr. Roy Gurnham or Mr. Dale Cavanaugh of my staff at (202) 219-8136.


Roger Clark
Directorate of Compliance Programs