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.


This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any situation not delineated within the original correspondence.


July 1, 2005

Mr. Marvin B. Moore
Refining and Supply Company
2800 Decker Drive
P.O. Box 3950
Baytown, TX 77522-3950

Dear Mr. Moore:

Please note that the Occupational Safety and Health Administration (OSHA), from time to time, updates its public website. The purpose of this letter is to inform you that our posted interpretation to you, dated September 26, 2002, has been updated to more accurately reflect our policy regarding the Guarding of live parts, §1910.303(g)(2), electrical requirements.

Specifically, the statement that Note 2, to Table S-1 — WORKING CLEARANCE, applies to paragraph 1910.303(g)(2), is being stricken as it is inconsistent with the provisions of the standard. (See page three of the attached letter.) This note only applies to the working clearance provisions contained in §1910.303(g)(1) and not to the 1910.303(g)(2) provisions for guarding live parts.

Thank you for your interest in occupational safety and health. We apologize for any confusion the earlier documents may have caused. As this letter demonstrates, OSHA's re-examination of an issue may result in the clarification or correction of previously stated enforcement guidance. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov. If you have any further questions, please feel free to contact the Office of General Industry Enforcement at (202)693-1850.


Richard E. Fairfax, Director
Directorate of Enforcement Programs