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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.
March 29, 2004
Mr. Steven R. Moses
Woods Industries, Inc.
510 Third Avenue, Southwest
Carmel, Indiana 46032
Re: Do type SJTW flexible cords comply with §1926.405(a)(2)(ii)(J) for their use on construction sites?
Dear Mr. Moses:
This is in response to your letter dated March 5, 2004, to the Occupational Safety and Health Administration (OSHA). We have paraphrased your question as follows:
Question: Do SJTW flexible cords comply with §1926.405(a)(2)(ii)(J) for their use on construction sites?
Section 1926.405(a)(2)(ii)(J) states:
Extension cord sets used with portable electric tools and appliances shall be of three-wire type and shall be designed for hard or extra-hard usage. Flexible cords used with temporary and portable lights shall be designed for hard or extra-hard usage.
Note: The National Electrical Code, ANSI/NFPA 70, in Article 400, Table 400-4, lists various types of flexible cords, some of which are noted as being designed for hard or extra-hard usage. Examples of these types of flexible cords include hard service cord (types S, ST, SO, STO) and junior hard service cord (types SJ, SJO, SJT, SJTO).
Type SJTW cords are classified as junior hard service cords and are approved for hard usage in table 400.4 of the 2002 National Electric Code Handbook. If your type SJTW cords are of the three-wire type and meet all other applicable requirements of the electrical standard, they may be used on construction sites.
Note, though, that any State (including Wyoming) that administers its own OSHA-approved State plan is required by law to have a program of standards and enforcement that is at least as effective as the Federal OSHA requirements. However, it may enact more stringent requirements. Employers in that State are then required to follow the State's more stringent requirements. You should contact Wyoming directly for specific information on their interpretation andenforcement policy with regard to this issue, at the following address:
Wyoming Department of Employment
Worker's Safety and Compensation Division
Cheyenne Business Center
1510 East Pershing Boulevard
Cheyenne, Wyoming 82002
Gary W. Child, Administrator
(307) 777-5524 FAX
Stephan R. Foster, OSHA Program Manager
(307) 777-3646 FAX
If you need additional information, please contact us by fax (202-693-1689) at: U.S. Department of Labor, OSHA, Office of Construction Standards and Guidance. You can also contact us by mail at U.S. Department of Labor, OSHA, Office of Construction Standards and Guidance, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail.
Russell B. Swanson, Director
Directorate of Construction