Here's how a local Denver area OSHA inspector explained it to me... OSHA considers worker safety to be the responsibility of the company employing them. Electrical safety for both the facility and it's infrastructure and the equipment connecting into it's electrical system is the responsibility of the work-place.
Subpart S-Electrical ref. 1910.302(a) scope: states that this section covers electrical installations and utilization equipment. ref. 1910.399 definition for utilization equipment: equipment which utilizes electric energy for mechanical, chemical, heating, lighting, or similar useful purpose. Comment: Most any equipment that plugs into a 110V outlet has useful purpose. ref. 1910.303 (a) The conductors and "equipment" required or permitted by this subpart shall be "acceptable" if "approved". ref. 1910.399: "Equipment" is defined as, material, fittings, devices, appliances, fixtures, apparatus, and the like, used as a part of, or "in connection" with an electrical installation. Comment: Anything that plugs into a standard 110V outlet is in connection with an electrical installation. ref. 1910.399: "Approved" is defined as Acceptable to OSHA. ref. 1910.399: "Accepted" is defined as accepted, certified or listed by a nationally recognized testing laboratory (NRTL). In the case of purchased equipment which is not preapproved by a NRTL, said equipment may be inspected or tested on site by a NRTL, or federal, state municipal or local safety authority. In the case of equipment manufactured on site for on site uses, said equipment may deemed safe if tested or inspected by methods indicated in the previous statement or by the manufacturer. If the latter method is to be used testing must be per national safety standards and test inspection information must be kept on file, on site and made available to OSHA inspectors if called upon to do so. Although they have the authority to do so, OSHA does not routinely inspect business for compliance. They do not have the time, money or personnel to do so. OSHA will check a business for safety concern/s if there is a complaint from an employee within the organization. In the latter case the extent of the investigation is usually limited to the review of the complaint, but OSHA as always has the option to look as far as they choose into safety aspects of the business. If there is a serious injury or death as a result of a safety related concern OSHA may then look into all aspects of safety within the business. This includes not only the physical aspects of safety (which would include electrical safety hazards such as unsafe equipment), but records (e.g. training, injury, illness, etc.)as well. Gail Birdsall Compliance Engineer Hach Co. -----Original Message----- From: geor...@lexmark.com [mailto:geor...@lexmark.com] Sent: Tuesday, August 17, 1999 7:11 AM To: emc-p...@majordomo.ieee.org Subject: Re: U.S. National Product Safety "Laws" This discussion is opening more issues than it is closing. No one can merely "skim" through 29 CFR 1900 or the NEC and find what they are looking for, so I may have missed what I was looking for given the time that I had. Like Doug, I cannot find a single definitive statement, or combination thereof, that would require an "appliance", in this case a PC or peripheral, to meet any requirement other earth gounding and/or double insulation. Likewise with the NEC. Section 645 addresses ITE. A good deal is said about the "installation" for ITE, but little about the actual ITE equipment itself. Items that ARE mentioned include that all exposed noncurrent-carrying metal parts of an ITE "system" must be grounded or double insulated (645-15), and that a marking of rated voltages etc. must be affixed (645-16). So here is the challenge. Can anyone "prove" that 29 CFR 1900 or the NEC specifically requires ITE to meet more than some grounding/marking requirements, or be required to be approved by an NRTL. Proof is citing clearly stated sections obviously applicable to typical ITE products. Sorry, but vague references to something "I once saw....." are not allowed. Like many product safety professionals, I received much verbal input on the "known" requirements when I took this position. It is becoming more obvious that some "facts" passed down through generations of PSEs may not be entirely accurate. They are definitely not clear, or this discussion would not be taking place. BTW, I would like the phone number of any lawyer capable of providing "definitive" answers. ---------------------- Forwarded by George Alspaugh/Lex/Lexmark on 08/17/99 08:47 AM --------------------------- roger.viles%wwgsolutions....@interlock.lexmark.com on 08/17/99 05:03:28 AM Please respond to roger.viles%wwgsolutions....@interlock.lexmark.com To: dmckean%corp.auspex....@interlock.lexmark.com cc: emc-pstc%majordomo.ieee....@interlock.lexmark.com Subject: Re: U.S. National Product Safety "Laws" Doug, I agree entirely! Yesterday I sent the below mail to a fellow emc-pstc groupie: "I have struggled through the OSHA webpages before, including SubPart S: SubPart Title: Electrical - Design Safety Standards for Electrical Systems where it does clearly say: "Approval. The conductors and equipment required or permitted by this subpart shall be acceptable only if approved." Under definitions, approved refers to acceptable which is defined as: "(i) If it is accepted, or certified, or listed, or labeled, or otherwise determined to be safe by a nationally recognized testing laboratory" So it is quite clear that conductors and equipment for electrical systems must be listed or similar. However nowhere does it make clear what is covered under "equipment". Is a PC covered? Probably yes. Is a palmtop with mains adaptor covered? Maybe. Is a pocket calculator covered? Surely not." So I too would like a definitive answer! (Well, if the answer is definitive, it probably comes from a lawyer, so I might not like it!). Regards, Roger Viles WWG Doug McKean <dmck...@corp.auspex.com> on 17/08/99 04:48:09 Please respond to Doug McKean <dmck...@corp.auspex.com> To: emc-p...@majordomo.ieee.org cc: (bcc: Roger Viles/PLY/Global) Subject: Re: U.S. National Product Safety "Laws" Dear Fellow Professionals, Let me be the devil's advocate for the moment. I normally do not like to pick apart standards, but this one has been kicking around my mind for years. I will refer all to the following websites so we're all on the same playing field. http://www.osha-slc.gov/OshStd_toc/OSHA_Std_toc.html http://www.osha-slc.gov/OshStd_toc/OSHA_Std_toc_1910_SUBPART_S.html Would you please note that in 29 CFR 1910.301 "Introduction", that the "practical safeguarding of employees in their workplaces" has four parts to it: "... a) Electrical systems. b) Safety-realted work practices. c) Safety-related maintenance requirements. d) Safety requirements for special equipment. ..." Of the four major divisions for safeguarding employees, please note the first one - "Electrical Systems". As stated in 29 CFR - 1910.399 "Definitions", a "system" is defined as "Utilization system. A utilization system is a system which provides electric power and light for employee workplaces, and includes the premises wiring system and utilization equipment." Had the standard used the word "equipment", then as such 29 CFR - 1910.399 "Definitions" would have used the following definition "Utilization equipment. Utilization equipment means equipment which utilizes electric energy for mechanical, chemical, heating, lighting, or similar useful purpose." Therefore, people, I submit that since 29 CFR 1910 directs it's attention to "systems", it is strictly concerned with that which provides electrical power or lighting and does NOT concern itself with "equipment", i.e. that utiliizes said power. Comments? Regards, Doug McKean --------- This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: "unsubscribe emc-pstc" (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators). --------- This message is coming from the emc-pstc discussion list. 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