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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 http://www.osha.gov.
September 28, 2015
Mr. Stephen W. Almony
153 Drifting Sand Court
Henderson, NV 89074
Dear Mr. Almony:
Thank you for your May 5, 2015, letter to the Occupational Safety and Health Administration (OSHA), Directorate of Construction. You have a specific question regarding OSHA's enforcement policy of 29 CFR 1926.403(b)(2) - Installation and use. This letter constitutes OSHA's interpretation of only the requirements discussed and may not be applicable to any question not delineated in your original correspondence.
Background: Your letter states that some extension cord manufacturers attach a warning tag to the cords they manufacture with a small zip-tie and that identical tags seem to be affixed to all such cords, no matter the length (i.e., 25, 50 or 100 feet). You note that one bullet point on the tag provides, "Do not plug one extension cord into another." You provided an example of such a tag with your letter.
Your question is summarized below with OSHA's response.
Question: To be in compliance with 29 CFR 1926.403(b)(2), must an employer use an extension cord in accordance with the warnings contained in a warning tag attached to the cord by the manufacturer?
Answer: Yes, OSHA will continue to enforce the listing, labeling, or certification requirements as outlined in 29 CFR 1926.403(b)(2) - Installation and use. That provision requires that listed, labeled, or certified (i.e., approved) equipment be used in accordance with the instructions included in the listing, labeling, or certification. For the purpose of its response, OSHA assumes that the extension cords to which you refer in your letter were approved by a Nationally Recognized Testing Laboratory (NRTL). For an extension cord to be considered as being used in its intended application, and therefore NRTL-approved, the employer must follow all marked warnings and limitations associated with that cord, including a warning contained on a tag affixed to the cord that provides, "Do not plug one extension cord into another." If an employer disregards such a warning tag, it would be using the cord in a manner outside of its intended application. This would be a violation of 29 CFR 1926.403(b)(2). OSHA notes also that UL 817, Standard for Cord Sets and Power-Supply Cords, provides that an extension cord set be provided with a tear resistant warning tag that is substantially identical to the example you provided with your letter.
As you may know, the State of Nevada administers its own safety and health program under a plan approved and monitored by Federal OSHA. As part of that program, the Nevada Occupational Safety and Health Administration (NV/OSHA) is responsible for the enforcement and interpretation of occupational safety and health regulations in that State. You may reach NV/OSHA at:
1301 N. Green Valley Parkway, Suite 200
Henderson, NV 89074
Phone: (702) 486-9020
Fax: (702) 990-0365
Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations. Our 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 requirement discussed. Note that our guidance might be affected by changes to OSHA rules. To keep apprised of such developments and to view all OSHA standards, you can consult OSHA's website at http://www.osha.gov. If you have any further questions, feel free to contact the Directorate of Construction at (202) 693-2020.
James G. Maddux, Director
Directorate of Construction