Standard Interpretations - (Archived) Table of Contents|
| Standard Number:||1926.405(d); 1926.305(d)|
|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.|
|MEMORANDUM TO:||Michael G. Connors,|
Regional Administrator, Region V
|FROM:||Russell B. Swanson, Director|
Directorate of Constructionm
[Directorate of Enforcement Programs]
|SUBJECT:||Flexible Corrugated Plastic Covers for Temporary Use to Cover Live Electric Parts in Switch and Panel Boxes|
Switchboards that have any exposed live parts shall be located in permanently dry locations and accessible only to qualified persons. Panelboards shall be mounted in cabinets, cutout boxes, or enclosures designed ["approved" for §1910.305] for the purpose and shall be dead front. However, panelboards other than dead front externally operable type are permitted where accessible only to qualified persons... [emphasis added]Both standards define "accessible" and "readily accessible" as follows:
Accessible (as applied to equipment): Admitting close approach; not guarded by locked doors, elevation, or other effective means. (See "Readily accessible").In essence, the temporary cover is designed to make the live parts of the panel box "readily accessible." With the temporary cover installed, anyone, including unqualified personnel, can readily obtain access to those parts. In contrast, the standards indicate that inaccessibility requires obstacles that are not easily/readily overcome to block access to the live parts. For example, the original, manufacturer-supplied panel box covers can only be removed by first removing screws. Therefore, the temporary cover violates these standards.
Readily accessible: Capable of being reached quickly for operation, renewal, or inspections, without requiring those to whom ready access is requisite to climb over or remove obstacles or to resort to portable ladders, chairs, etc.
|Standard Interpretations - (Archived) Table of Contents|