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Defining a refinery's hazardous electrical location

Summary An OSHA region asked where a refinery's Class I, Division II hazardous electrical location ended. OSHA said the National Electrical Code supplied performance criteria but no fixed distance, so inspectors had to assess the site conditions case by case. OSHA archives the memo.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1979-12-03
Date issued
December 3, 1979
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 10, 2026

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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

December 3, 1979

MEMORANDUM FOR: CURTIS A. FOSTER
REGIONAL ADMINISTRATOR

THRU: ROGER CLARK
Field Coordinator

FROM: GROVER C. WRENN
Director, Federal Compliance and State Programs

SUBJECT: National Electrical Code Interpretation

As you indicated in your July 27, 1979 memorandum, the National Electrical Code provides the requirements for a Class I, Division II area, but gives no specific criteria as far as distance is concerned, as to where a Class I, Division II area stops. Article 500-4(b) of the National Electrical Code provides the necessary criteria for properly evaluating a Class I, Division II location. It is not practical or possible for this office to replace the performance requirements with specification type (dimensional) requirements in regard to the distance that should be used on the ground level of a refinery in calculating where a Class I, Division II, area stops and where the nonclassified area begins. The complex variables involved in both cases does not permit the approach you have suggested. Compliance officers will have to use professional judgment and the performance standards to assess hazardous location requirements on a case by case basis.

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