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Testing and inspection of construction ground fault circuit interrupters

Summary A construction company asked about testing ground fault circuit interrupters at jobsites. OSHA said 1926.404(b)(1) did not itself require GFCI testing, while another rule required frequent and regular equipment inspections. It said monthly testing and prompt replacement, shown through logs or procedures, could affect whether a defective device warranted a serious citation.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1992-02-04
Date issued
February 4, 1992
Status
Active
Status last verified October 10, 2026

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About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

February 4, 1992

MEMORANDUM FOR: BYRON R. CHADWICK
REGIONAL ADMINISTRATOR

THROUGH: LEO CAREY, DIRECTOR
OFFICE OF FIELD PROGRAMS

FROM: PATRICIA K. CLARK, DIRECTOR
DIRECTORATE OF COMPLIANCE PROGRAMS

SUBJECT: Magna Electrical Construction Co., Inc. Letter
Requesting Ground Fault Circuit Interrupter Information

This is in response to your November 18 memorandum forwarding the Magna Electrical Construction Company's request for information on OSHA requirements for testing ground fault circuit interrupters (GFCIs) at construction sites. I apologize for the delay in responding to your inquiry.

Section 1926.404(b)(1) does not require GFCIs to be tested. However, 1926.20(b)(2) does require the frequent and regular inspections of equipment. The instructions included with the devices indicate that they should be tested monthly. If an employer can demonstrate, for example, by means of logs or procedures, that he or she tests GFCIs monthly and promptly replaces those found defective, then a serious citation may not be appropriate for defective GFCIs found upon inspection, provided the faulty devices are replaced promptly.

In regard to Magna's remaining two questions concerning the proper procedures for testing GFCIs, I have attached the Electrical/Electronic Technical Note 91-1 which outlines the acceptable test procedure.

[Attached technical note not reproduced on OSHA's page.]

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