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.

September 1, 1995

Raymond J. Callahan
S-B Power Tool Company
One Hundred Bosch Boulevard
New Bern, North Carolina 28562-6997

Dear Mr. Callahan:

This is in response to your August 16, 1995, letter regarding the Canadian Standards Association (CSA), a nationally recognized testing laboratory, marking and double insulated tools.

The Canadian Standards Association is a nationally recognized testing laboratory for portable electric power tools and double insulating mechanisms. The CSA marking on double insulated tools can be used for compliance with the requirements of Subpart S, of OSHA 1910. As with any approval, the marking and certification applies only to the conditions of use as specified in the testing protocol.

Enclosed is a listing of nationally recognized testing laboratories. Should you have further questions, please do not hesitate to call Ron Davies at (202) 219-8031.

Sincerely,



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