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 http://www.osha.gov.

April 3, 1995

Mr. Bruce J. Borgerding
Associate General Counsel Tennant
701 North Lilac Drive
P.O. Box 1452
Minneapolis, MN 55440-1452

Dear Mr. Borgerding:

This is in response to your October 19, 1993 letter to Mr. Roger Clark requesting that the Occupational Safety and Health Administration (OSHA) to classify sweepers and scrubbers as specialized industrial trucks or allow the use of designations lesser than "EE" for Class I, Division 2, Group D designated locations covered by the powered industrial truck standard. I apologize for the delay in responding to your inquiry.

With regard to the classification of sweepers and scrubbers, please be advised that ANSI B56.1-1969, Standard for Powered Industrial Trucks, and NFPA No. 505-1969, Powered Industrial Trucks are the source standards for the OSHA powered industrial truck standard. Equipment, such as sweepers and scrubbers, which has been approved by an OSHA accepted Nationally Recognized Testing Laboratory (NRTL) for compliance with appropriate powered industrial truck standards will be accepted by the OSHA.

With regard to the use of designations lesser than "EE" for Class I, Division 2, Group D designated locations covered by the powered industrial truck standard, please refer to 29 CFR 1910.178(c)(2)(v) which allows the use of approved power-operated industrial trucks designated as DS, ES, GS, or LPS in locations used for the storage of hazardous liquids in sealed containers or liquefied or compressed gases in containers.

Sweeper and scrubber equipment which is not listed or labeled by a NRTL for use in hazardous locations covered by the powered industrial truck standard must comply with 29 CFR 1910.307. The acceptable use of such equipment would be dependent upon the classification of locations where the equipment will be utilized. For instance, where this equipment would be used in Hazardous (Classified) Locations, section 1910.307, which covers the requirements for electric equipment and wiring in locations which are classified depending on the properties of the flammable vapors, liquids or gases, or combustible dusts or fibers which may be present therein and the likelihood that a flammable or combustible concentration or quantity is present, would apply.

Specifically, Section 1910.307(b), Electrical Installations, requires that equipment, wiring methods, and installations of equipment in hazardous (classified) locations shall be intrinsically safe, approved for the hazardous (classified) locations (NFPA 70, the National Electrical Code, lists or defines hazardous gases, vapors, and dusts by "Groups" characterized by their ignitible or combustible properties.), or safe for the hazardous (classified) location (NFPA 70, the National Electrical Code, contains guidelines for determining the type and design of equipment and installations which will meet this requirement).

Section 1910.307 would not apply to sweepers and scrubbers used in nonhazardous (nonclassified) locations.

If we can be of any further assistance, please contact Mr. Wil Epps of my staff at (202) 219-8041.

Sincerely,



John B. Miles, Jr. Director
Directorate of Compliance Programs