GFCI Protection for Temp Power on Construction Sites

[spizeii]

Hello All,

I've got this safety inspector who's thick headed and won't listen. He has experience with OSHA and I heard has attended OSHA forums/classes etc. All I want is an answer from someone who really knows!

This is the situation:

I am the Electrical Foreman at a renovation of a sewage treatment plant in NYC. I provided a temp. panel consisting of 1P, SQ. D., 20A, QO, Class A, Ground-fault Circuit Interrupter (GFCI) Breakers for temp. power. I installed drops out of the bottom of the panel as well as a couple of 80' long romex streamers consisting of 5 or 6 laundry drops and different intervals (all panel drops and streamers on separate circuits).

This inspector is telling me that OSHA requires 'portable' GFCI protector cord sets (such as the types seen here: http://www.aiwc.com/catalogsection/catalogpdfs/Cordset/gfci.pdf ) to be plugged in at the end of an extension cord (cords which are plugged into the laundry drops) or if a tool is to be plugged in at the laundry drop (without an extension cord) - which is already a GFCI (breaker) protected line.

Let me state that again... the temp. circuit is wired to a 20A Class A - GFCI Circuit Breaker. I am being told that any trade who wishes to utilize that temp. streamer must provide a portable GFCI cord set at the end of the cord.

His reasoning, though may sound logical and may just be true, is that the portable GFCI will trip faster than the GFCI breaker since the portable is closer to the person using the temp. line. Hence, it takes longer for the breaker to trip because of its distance from the person to the panel which is no more than 150' away.

Doing some research I found that OSHA requires the following:

EMPLOYER'S RESPONSIBILITY

OSHA ground-fault protection rules and regulations have been determined necessary and appropriate for employee safety and health. Therefore, it is the employer's responsibility to provide either: (a) ground-fault circuit interrupters on construction sites for receptacle outlets in use and not part of the permanent wiring of the building or structure; or (b) a scheduled and recorded assured equipment grounding conductor program on construction sites, covering all cord sets, receptacles which are not part of the permanent wiring of the building or structure, and equipment connected by cord and plug which are available for use or used by employees.

GROUND-FAULT CIRCUIT INTERRUPTERS

The employer is required to provide approved ground-fault circuit interrupters for all 120-volt, single-phase, 15- and 20-ampere receptacle outlets on construction sites which are not a part of the permanent wiring of the building or structure and which are in use by employees. Receptacles on the ends of extension cords are not part of the permanent wiring and, therefore, must be protected by GFCIs whether or not the extension cord is plugged into permanent wiring. These GFCIs monitor the current-to-the-load for leakage to ground. When this leakage exceeds 5 mA ? 1 mA, the GFCI interrupts the current. They are rated to trip quickly enough to prevent electrocution. This protection is required in addition to, not as a substitute for, the grounding requirements of OSHA safety and health rules and regulations, 29 CFR 1926. The requirements which employers must meet, if they choose the GFCI option, are stated in 29 CFR 1926.404(b)(1)(ii). (See appendix.)


It clearly states that I have provided GFCI protection on the receptacle outlets which are not part of the permanent bldg wiring. The 'ends of the extension cords'..., as it reads, 'must be protected by GFCIs' (which the breaker is) which I have accomplished.

The inspector states that there is an OSHA "Interpretation" to this stating that the portable GFCI device/cord must be at the outlet and that the breaker is not sufficient for personal protection and is meant for equipment protection. I said he is incorrect since a Class A device will trip when a fault to ground is 6mA or more.

So we are butting heads right now until I am satisfied with a documented OSHA Interpretation or response stating he is correct.

Is anyone familiar with such an OSHA Interpretation which states that a Class A GFCI Breaker is insufficient for protecting my streamers and that portable GFCI cord sets are needed at the tool, please enlighten me!!

Thanks,

Chris - Local #3 NYC

 

[al hildenbrand]

His reasoning, though may sound logical and may just be true, is that the portable GFCI will trip faster than the GFCI breaker since the portable is closer to the person using the temp. line. Hence, it takes longer for the breaker to trip because of its distance from the person to the panel which is no more than 150' away.

This is simply not correct.

The GFCI breaker, 150' away from the outlet, will have a "bleed" current to ground coming from the capacitance and inductance in the NM. The bleed current uses up part of the trip current for the GFCI. If 3 mA ground leakage occurs along the NM, the load connected to the outlet can only have 1 to 2 mA leakage before the GFCI trips.

If the GFCI is local at the outlet, the load will have to "leak" the full 5 mA before the trip happens.

 

[pipemaster]

[

.





GROUND-FAULT CIRCUIT INTERRUPTERS

The employer is required to provide approved ground-fault circuit interrupters for all 120-volt, single-phase, 15- and 20-ampere receptacle outlets on construction sites which are not a part of the permanent wiring of the building or structure and which are in use by employees. Receptacles on the ends of extension cords are not part of the permanent wiring and, therefore, must be protected by GFCIs whether or not the extension cord is plugged into permanent wiring. These GFCIs monitor the current-to-the-load for leakage to ground. When this leakage exceeds 5 mA ? 1 mA, the GFCI interrupts the current. They are rated to trip quickly enough to prevent electrocution. This protection is required in addition to, not as a substitute for, the grounding requirements of OSHA safety and health rules and regulations, 29 CFR 1926. The requirements which employers must meet, if they choose the GFCI option, are stated in 29 CFR 1926.404(b)(1)(ii). (See appendix.)


It clearly states that I have provided GFCI protection on the receptacle outlets which are not part of the permanent bldg wiring. The 'ends of the extension cords'..., as it reads, 'must be protected by GFCIs' (which the breaker is) which I have accomplished.

The inspector states that there is an OSHA "Interpretation" to this stating that the portable GFCI device/cord must be at the outlet and that the breaker is not sufficient for personal protection and is meant for equipment protection. I said he is incorrect since a Class A device will trip when a fault to ground is 6mA or more.

So we are butting heads right now until I am satisfied with a documented OSHA Interpretation or response stating he is correct.



Thanks,

Chris - Local #3 NYC[/QUOTE]

Give this guy a gut shot. Tell him who cares or so what because you provided what was required

 

[Minuteman]

I think that he sees a AND where OSHA says OR.

 

[pipemaster]

I think that he sees a AND where OSHA says OR.

Very well put!

 

[NoVA Comms Power]

The inspector states that there is an OSHA "Interpretation" to this stating that the portable GFCI device/cord must be at the outlet and that the breaker is not sufficient for personal protection and is meant for equipment protection. I said he is incorrect since a Class A device will trip when a fault to ground is 6mA or more.

Although he doesn't appear to have done a very good job of expaining it ... I suspect that your inspector is thinking about this interpretation about how portable GFCIs are apparently required to provide open-neutral protection at the outlet:

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24542

"Regular" GFCIs -- the type normally permanently installed -- generally don't provide this feature as they assume that the building's permanent wiring remains intact.

Leviton also provides a better description of this feature on page 11 of http://www.leviton.com/pdfs/gfci/GFCI_Brochure.pdf

A "regular" GFCI (or GFCI breaker) won't provide the "open neutral" protection at the portable outlet which is apparently required. (that is if the OHSA interpretation and Leviton brochure are accurate)

 

[Minuteman]

Very well put!

Well, it's clear to me that you could use one OR the other.

 

[H.L.]

OSHA says that if the employer has safety rules that are more stringent than OSHA standards then those must be followed. This I believe would apply in this case if this rule is in writing. Further, OSHA could cite you on it if it is in writing.

H.L.

 

[thinfool]

Call his bluff...call OSHA, supposedly they will visit your jobsite and explain how/what you need to do to be in compliance. This is apart from their unannounced compliance visits.

If there is an OSHA determination about this, you should be able to have it in writing.

OSHA might find it amusing that a city electrical inspector is acting as an OSHA agent.

Finally, you are in NYC, where rules often appear as if by magic. Rules no one has ever heard of before.

 

[RayS]

NovaComms, thanks for the info and the effort to find and post the links- ya learn something everyday

 

[NoVA Comms Power]

... thanks for the info and the effort to find and post the links ...

Thanks.

From the reading, it appears that IF one elects to use a portable cord-connected GFCI, then it must have the open-neutral protection.

However, it's still sorta fuzzy to me if "temporary" construction installs -- using what are essentially permanent wiring methods (i.e. the OP's situation) -- require that same level of protection.

I've certainly not found any definititive wording to that effect -- at least not firm to the point where I'd call it a "requirement."

 

[Jljohnson]

"This inspector is telling me that OSHA requires 'portable' GFCI protector cord sets (such as the types seen here: http://www.aiwc.com/catalogsection/c...rdset/gfci.pdf ) to be plugged in at the end of an extension cord (cords which are plugged into the laundry drops) or if a tool is to be plugged in at the laundry drop (without an extension cord) - which is already a GFCI (breaker) protected line."

He is wrong. I have recently done a 10-Hour OSHA Cklass and this was discussed extensively(seemed like days). IF you are using the permanent building receptacle and they are NOT ground fault protected, then you must use portable GFI protection as your safety mans suggests. However, your romex streamers and laundry drops caught my attention. romex on a construction site that is being used as temporary wiring must be protected from physical damage unless it is 8' AFF. I assume yours is, but you didn't say so I thought I'd point it out just in case. Also, we were taught at OSHA 10-hour that all the boxes on the "laundry drops" must be weatherproof "Bell" style boxes as OSHA does not allow standard 4 square boxes to be used on temp receptacles. The reasoning is they believe the ko's are a safety concern and will be knocked out and left open.