Replacing or repairing a 15A cord caps

[The Smashing Electrons]

I once heard that repair or replacement of 15A cord caps (male or female) can only be done with molded/cord (one piece) assembly according to OSHA is this true? Has any one else heard this?

Here is the fuel for the fire below;

April 4, 2010

Letter # 20070926-7973

Re: Whether extension cords may be repaired and returned to use.

Question: Where an extension cord being used in construction has been damaged near the plug end, is it permissible to replace the plug with an approved cord cap made for that type of cord, provided the repair is done by a qualified electrician?

Answer: Extension cords used in construction may be repaired, so long as the repair returns the cord to the "approved" state required by §1926.403(a).

This section states, "All electrical conductors and equipment shall be approved."

The repair of cords and cord sets is permitted under 1926.404(b)(1)(iii)(C):

Each cord set, attachment cap, plug and receptacle of cord sets, and any equipment connected by cord and plug, except cord sets and receptacles which are fixed and not exposed to damage, shall be visually inspected before each day's use for external defects, such as deformed or missing pins or insulation damage, and for indications for possible internal damage. Equipment found damaged or defective shall not be used until repaired. (Emphasis added.)​

Repairs of extension cords are therefore permitted under §1926.404(b)(1)(iii)(C). However, in order to remain compliant with §1926.403(a), the repairs must return the equipment to the state in which it was initially approved.

Similar repairs are discussed in our May 19, 2003 letter to Barry Cole:

To satisfy the requirements of the OSHA standards, a repair would have to restore the tool to its "approved" condition in accordance with §1926.403(a). Tools ... are approved as complete factory-produced entities. The approval is for the tool as a whole - its design, capacity, materials and construction. This provision precludes the use of an approved tool if its characteristics are materially altered.​

If you need additional information, please contact us by fax at: U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Guidance, fax # 202-693-1689. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail.

Sincerely,

 

[iwire]

A screw on cord cap does not return a cord with molded on ends to original condition.

We don't mess around with this, the fines are too high to risk against the cost of a new cord.

 

[mpoulton]

It doesn't have to be returned to original condition (with molded plugs), just to an "approved" state. Replacement cord caps are "approved" specifically for that use. They are required to be "heavy duty" grade devices, since "heavy duty" cord sets are required. We did this routinely at a very large commercial contractor I worked for. We even kept cord caps in the job trailer to replace damaged ones for subs who brought them in - but had zero tolerance for use of damaged cords on the site. Note that any OTHER damage to the cord, like a cut in the jacket, renders it unfixable.

 

[JFletcher]

Here's a recent thread on the topic that may be of help:

http://forums.mikeholt.com/showthread.php?t=177191

 

[iwire]

It doesn't have to be returned to original condition (with molded plugs), just to an "approved" state. Replacement cord caps are "approved" specifically for that use.

I disagree, it says 'as approved' not 'use approved parts.

 

[dmxtothemax]

A screw on cord cap does not return a cord with molded on ends to original condition.

We don't mess around with this, the fines are too high to risk against the cost of a new cord.

What is the difference ?

What is special about a moulded on plug,
That a new replacement would not meet ?

 

[iwire]

What is the difference ?

What is special about a moulded on plug,
That a new replacement would not meet ?

To me personally nothing other than it is not the same state it was when it was originally approved.

The real issue is what a non-electrician OSHA inspector thinks, will they use common sense or will they go by the letter of the regulation?

With a first offense fine of up to 7K and repeat offenses within seven years up to 70K I don't see it as worth the risk.

A new cord for $60 or a new cord cap for $10 plus $25 in labor.

How much are you saving vs how much you are risking?

 

[don_resqcapt19]

When you look at the definition of "approved" in OSHA you will find that it is different from the one in the NEC. With OSHA approved = listed. So a repair would never be approved as the completed work is not listed.

 

[GoldDigger]

When you look at the definition of "approved" in OSHA you will find that it is different from the one in the NEC. With OSHA approved = listed. So a repair would never be approved as the completed work is not listed.

Even if you equate "approved" with "listed", it does not require the the repaired cord to be be listed. It requires it to be in the same condition as it was at the time it was listed. Still not an easy thing to match, though.

 

[mpoulton]

When you look at the definition of "approved" in OSHA you will find that it is different from the one in the NEC. With OSHA approved = listed. So a repair would never be approved as the completed work is not listed.

I don't agree with that conclusion from a legal perspective. Listed or recognized cord caps are "approved" by UL specifically for the purpose of replacing plugs on cord sets. They have no other use, and they are approved for that use. Use of listed/recognized parts in the listed/recognized manner produces an "approved" result. If you and iwire were correct in your analysis, listed cord caps would have no legal use at all, and the OSHA letter explaining how to perform allowable repairs to damaged cord sets would be moot because there would be no way of actually performing such a repair. The plain text of the OSHA regulations, together with that opinion letter from OSHA, authorizes the replacement of cord ends. This is also the common-sense logical outcome, which doesn't hold much weight legally but is often a good backup argument.



With that said, I have to include the disclaimer that this is not a formal legal opinion that anyone is entitled to rely on.

 

[don_resqcapt19]

I don't agree with that conclusion from a legal perspective. Listed or recognized cord caps are "approved" by UL specifically for the purpose of replacing plugs on cord sets. They have no other use, and they are approved for that use. Use of listed/recognized parts in the listed/recognized manner produces an "approved" result. If you and iwire were correct in your analysis, listed cord caps would have no legal use at all, and the OSHA letter explaining how to perform allowable repairs to damaged cord sets would be moot because there would be no way of actually performing such a repair. The plain text of the OSHA regulations, together with that opinion letter from OSHA, authorizes the replacement of cord ends. This is also the common-sense logical outcome, which doesn't hold much weight legally but is often a good backup argument.



With that said, I have to include the disclaimer that this is not a formal legal opinion that anyone is entitled to rely on.

My understanding of the OSHA requirement is that the complete tool must still be approved after the repair. Installing a listed cord cap is safe, but I can see an OSHA citation. Like Bob, said just not worth risk.

 

[Johnnybob]

I once heard that repair or replacement of 15A cord caps (male or female) can only be done with molded/cord (one piece) assembly according to OSHA is this true? Has any one else heard this?

Here is the fuel for the fire below;

April 4, 2010

Letter # 20070926-7973

Re: Whether extension cords may be repaired and returned to use.

Question: Where an extension cord being used in construction has been damaged near the plug end, is it permissible to replace the plug with an approved cord cap made for that type of cord, provided the repair is done by a qualified electrician?

Answer: Extension cords used in construction may be repaired, so long as the repair returns the cord to the "approved" state required by §1926.403(a).

This section states, "All electrical conductors and equipment shall be approved."

The repair of cords and cord sets is permitted under 1926.404(b)(1)(iii)(C):

Each cord set, attachment cap, plug and receptacle of cord sets, and any equipment connected by cord and plug, except cord sets and receptacles which are fixed and not exposed to damage, shall be visually inspected before each day's use for external defects, such as deformed or missing pins or insulation damage, and for indications for possible internal damage. Equipment found damaged or defective shall not be used until repaired. (Emphasis added.)​

Repairs of extension cords are therefore permitted under §1926.404(b)(1)(iii)(C). However, in order to remain compliant with §1926.403(a), the repairs must return the equipment to the state in which it was initially approved.

Similar repairs are discussed in our May 19, 2003 letter to Barry Cole:

To satisfy the requirements of the OSHA standards, a repair would have to restore the tool to its "approved" condition in accordance with §1926.403(a). Tools ... are approved as complete factory-produced entities. The approval is for the tool as a whole - its design, capacity, materials and construction. This provision precludes the use of an approved tool if its characteristics are materially altered.​

If you need additional information, please contact us by fax at: U.S. Department of Labor, OSHA, Directorate of Construction, Office of Construction Standards and Guidance, fax # 202-693-1689. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, N.W., Washington, D.C. 20210, although there will be a delay in our receiving correspondence by mail.

Sincerely,

So I would first wonder, can you legally use a 15A cord in a commercial/industrial environment? I was under the impression they had to be rated at least 20A! I know all receptacles and switches I install have to be 20A rated.

 

[iwire]

So I would first wonder, can you legally use a 15A cord in a commercial/industrial environment? I was under the impression they had to be rated at least 20A! I know all receptacles and switches I install have to be 20A rated.

The NEC allows 15 amp devices in commercial or industrial locations.

Any rule prohibiting that would be a local code or job specification.

 

[mpoulton]

So I would first wonder, can you legally use a 15A cord in a commercial/industrial environment? I was under the impression they had to be rated at least 20A! I know all receptacles and switches I install have to be 20A rated.

Yes, a 15A rated cord set is fine. Almost all cord sets use a 15A plug. When is the last time you saw an extension cord with a 20A plug on it, except for a special purpose?

 

[just the cowboy]

What would a cord cap be used for?

What would a cord cap be used for?

What would a cord cap be used for if not for repair? I cut extension cords up in a heartbeat with a bad end because they are worn most of the time and are a use item. But as said power tools that is a differant story. But I always wondered what use is a cord cap if it needed to be an approved use. I can put a 480 volt 30 amp plug cap on a pump but not a 130volt 15 amp plug cap on a drill????

Cowboy

 

[iwire]

What would a cord cap be used for if not for repair?

The repair of things not subject to an OSHA inspector.

I cut extension cords up in a heartbeat with a bad end because they are worn most of the time and are a use item.

For my own use for sure, on one of the job sites I work on no way.