Extension cords during construction work

April 15, 1992

Mr. Robert L. Echols
Belco Electric, Inc.
[Recipient address omitted]
Dear Mr. Echols:

This is in response to your January 31 letter requesting an interpretation of the application of Occupational Safety and Health Administration (OSHA) construction standards and whether temporary wiring requirements apply to cord sets connected to permanent wiring.

In regard to what constitutes a construction site or when OSHA construction standards apply, please be advised that part 1926 applies to all "construction work" which is defined in 29 CFR 1910.12(b) as "work for construction, alteration and/or repair, including painting and decorating." Therefore, OSHA construction standards would apply to the electrical installation referred to in your letter if construction, alteration or repair work is being performed. Whether or not the permanent wiring has been installed is not relevant to the applicability of the standard. The key factor is whether the activity being performed is construction work.

In regard to whether an extension cord, used to supply power between permanent wiring and a hand tool, is temporary wiring, please be advised that OSHA considers extension cords as temporary extensions of branch circuits and therefore GFCI's or an assured equipment grounding conductor program is normally required (1926.404(b)(1)).

However, if the area in which work is being performed is completed to the extent that the building finish has been applied and if employees are not exposed to contact with large grounded objects (such as metal ducts and structural steel and concrete, including flooring), the severe ground-fault hazards addressed by the standard would not be present. The Agency's policy is to treat this condition as de minimis (1926.404(b)(1)) in such areas, whether or not the electric power to tools in use is supplied by extension cord sets. This is based on the permanent nature of the electrical installations and the condition and maintenance of electrical tools and equipment used in general industry, as contrasted with the temporary wiring, which is frequently moved, and the rough use, abuse, and the relatively poorer condition and maintenance of electrical tools and equipment found on construction sites.

If we can be of any further assistance, please contact Mr. Roy F. Gurnham or Mr. Dale R. Cavanaugh of my staff in the Office of Construction and Maritime Compliance Assistance at (202) 523-8136.

Sincerely,
Patricia K. Clark, Director
Directorate of Compliance Programs