Osha on 70e

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jimbo123

Senior Member
Does anyone have an idea if a company called Osha and asked if their electrical panels should have electrical labels or 70e type labels on them what their response would be? Something more then an identifier of equipment.
 
eric9822

eric9822

Senior Member
Location
Camarillo, CA
Occupation
Electrical and Instrumentation Tech
Charlie, I think the OP is asking "If an unnamed company placed a telephone call to OSHA and asked OSHA if they needed labeling as specified in NFPA70E what would OSHA's response be."
 
raider1

raider1

Senior Member
Staff member
Location
Logan, Utah
OSHA can't enforce 70E directly, but can look to it as an industry standard practice for electrical safety.

Chris
 
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jimbo123

Senior Member
Thanks 9822 that is where I was going . Trying to get some information on the labeling end . Some people not related to electric industry feel ther eis not any reason to label. This same person is giving safety seminars about electrical safety . I don't know how it is done but he is the guy. I always though something as complexed as 70e would take an engineer to understand and communicate to the electricians.
 
zog

zog

Senior Member
Location
Charlotte, NC
jimbo123 said:
Thanks 9822 that is where I was going . Trying to get some information on the labeling end . Some people not related to electric industry feel ther eis not any reason to label. This same person is giving safety seminars about electrical safety . I don't know how it is done but he is the guy. I always though something as complexed as 70e would take an engineer to understand and communicate to the electricians.
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You can ask for a letter of interpretation, I have done it many times and the "OSHA cops" never have come knocking at my door.

70E is not complex at all, people just make it that way trying to avoid following it is the complex part. Labeling requirements in the 70E and very straight forward so nto sure how there can be confusion.
 
zog

zog

Senior Member
Location
Charlotte, NC
jimbo123 said:
Sorry not aware of the letter of interpertation . can someone expand on this?
Thanks to all.
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OSHA requirements are set by statute, standards and regulations. Iinterpretation 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 enforcement guidance may be affected by changes to OSHA rules. Also, from time to time they update thier guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.

You submit a letter in the proper format, an OSHA expert in that area will respond, good as gold when trying to clarify the standard or just prove a point :) Only problem here is OSHA does not address the labeling issue direct but they enforce 70E via general duty clause so you may not get a clear answer, or maybe you will.

Here is an example:

April 12, 2010

Letter # 20090606-9144

Re: Whether an employer can repair an extension cord under 29 CFR 1926, Subpart K.

Question: Under what circumstances may an employer located in Minnesota repair a damaged extension cord under 29 CFR 1926, Subpart K?

Answer: Paragraph 1926.405(g)(2)(iii) provides:

Flexible cords shall be used only in continuous lengths without splice or tap. Hard service flexible cords No. 12 or larger may be repaired if spliced so that the splice retains the insulation, outer sheath properties, and usage characteristics of the cord being spliced.
This standard permits you to repair an extension cord, under the conditions set forth, provided the cord is a flexible cord that is No. 12 or larger.

Additionally, 1926.403(a) requires all electrical conductors used by employers on a construction site to be "approved." Section 1926.449 defines "approved" as:

Acceptable to the authority enforcing this subpart. The authority enforcing this subpart is the Assistant Secretary of Labor for the Occupational Safety and Health. The definition of "acceptable" indicates what is acceptable to the Assistant Secretary of Labor, and therefore approved within the meaning of this subpart.
Section 1926.449 defines "acceptable" as:

An installation or equipment is acceptable to the Assistant Secretary of Labor, and approved within the meaning of this subpart K:
(a) If it is accepted, or certified, or listed, or labeled, or otherwise determined to be safe by a qualified testing laboratory capable of determining the suitability of materials and equipment for installation and use in accordance with this standard; or
(b) With respect to an installation or equipment of a kind which no qualified testing laboratory accepts, certifies, lists, labels, or determines to be safe, if it is inspected or tested by another Federal agency, or by a State, municipal, or other local authority responsible for enforcing occupational safety provisions of the National Electrical Code, and found in compliance with those provisions; or
(c) With respect to custom-made equipment or related installations which are designed, fabricated for, and intended for use by a particular customer, if it is determined to be safe for its intended use by its manufacturer on the basis of test data which the employer keeps and makes available for inspection to the Assistant Secretary and his authorized representatives.
Assuming the extension cord you are repairing was initially "acceptable," ?1926.403(a) precludes you from using a repaired cord if the cord is significantly altered as a result of the repair. For example, you are precluded from using a repaired cord if the repair changes the cord's original flexibility.1 As you may be aware, the State of Minnesota operates its own occupational safety and health program under a plan approved by Federal OSHA. Under this plan, the Minnesota Department of Labor promulgates and enforces occupational safety and health standards under authority of State law, and posts them on its website at http://www.dli.mn.gov/mnosha.asp. Although some of Minnesota's standards are different, both its standards and interpretations must be at least as effective as Federal OSHA's. For information on Minnesota's Electrical standard and its enforcement, we suggest that you contact:

James Krueger, Compliance Director
443 Lafayette Road North
St. Paul, Minnesota 55155-4307
PH: (651) 284-5050
TOLL FREE: (877) 470-6742
FAX: (651) 284-5741
Sincerely,



Bill Parsons, Acting Director
Directorate of Construction
 
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W

wtucker

Senior Member
Location
Connecticut
jimbo123 said:
Does anyone have an idea if a company called Osha and asked if their electrical panels should have electrical labels or 70e type labels on them what their response would be? Something more then an identifier of equipment.
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Why don't you try it? Seriously. They're not going to take down your name or anything like that. Call OSHA's area office (the number should be in the phone book), and ask to speak with a compliance officer who knows about the electrical standards.
 
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