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.

September 17, 2004

Mr. Richard Hope
Engineer, Maintenance Department
Klickitat Valley Health Services
Post Office Box 5
310 S. Roosevelt Street
Goldendale, WA 98620

Re: Protection of employees from exposure to live electrical parts under 29 CFR 1926.405(j)(1)(i).

Dear Mr. Hope:

This is in response to your May 10, 2004, fax to the Occupational Safety and Health Administration (OSHA) regarding protection of employees from exposure to live (electrical) parts.

We have paraphrased your question below:

Question: For workers engaged in construction activities, does 29 CFR 1926.405(j)(1)(i) require plastic switch plates or receptacle covers and non-conductive (e.g., nylon) screws to hold those switch plates or covers on?

Answer:
No. Title 29 CFR 1926.405(j)(1)(i) states:

(j) Equipment for general use-
(1) Lighting fixtures, lampholders, rosettes, and receptacles-
(i) Live parts. Fixtures, lampholders, lamps, rosettes, and receptacles shall have no live parts normally exposed to employee contact. However, rosettes and cleat-type lampholders and receptacles located at least 8 feet (2.44 m) above the floor may have exposed parts. [Emphasis added.]

The provision does not specifically state that switch plates or receptacle covers be made of non-conductive material or that the screws to hold those switch plates or covers on be non-conductive, and there is no indication in the preamble to the standard reflecting an intent to create such an obligation.

Switch plates and receptacle covers are designed to prevent people from coming into contact with (that is, touching) properly installed live electrical parts that are inside the switch/receptacle box. When the live parts inside the box are properly installed and the cover is on, those parts will not be "normally exposed to employee contact." Therefore, under §1926.405(j)(1)(i), covers are not required to provide an insulating barrier in the event a live part inside the box comes in contact with the back of the cover. Similarly, there is no requirement that the screws that affix the covers to the box be of a non-conductive material.1

Note that, if a faulty switch or receptacle has caused the cover or screws to become energized, construction employees working in proximity to it must be protected. Title 29 CFR 1926.416(a)(1) states:

No employer shall permit an employee to work in such proximity to any part of an electric power circuit that the employee could contact the electric power circuit in the course of work, unless the employee is protected against electric shock by deenergizing the circuit and grounding it or by guarding it effectively by insulation or other means.

 

 

The precautions required by §1926.416(a)(1) would have to be met if the employer knew or had reason to believe that the cover or screws may have become energized.

If you need any additional information, please contact us by fax at: U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Guidance, fax # 202-693-1689. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail.

Sincerely,


Russell B. Swanson, Director
Directorate of Construction

 

 

1 Note that, under §1926.404(f)(7)(i) (grounding requirements for metal enclosures), metal covers, if used, must be grounded. [ back to text ]