Ground fault protection on construction extension cords and portable tools

November 4, 1992

Ernest Breaux, Jr.
Bechtel Environmental
[Recipient address omitted]
Dear Mr. Breaux:

This is in response to your August 31 letter requesting an interpretation of an Occupational Safety and Health Administration (OSHA) standard addressing ground fault circuit interrupters on extension cords as well as on portable tools. I apologize for the delay in our response.

Paragraph 1926.404(b)(1) requires an employer to use either ground fault circuit interrupters (GFCI) or an assured equipment grounding conductor program to protect employees on construction sites. The GFCI equipped cord set assembly or the GFCI equipped portable tool assembly must, as a complete unit, be approved as required by 1926.403(a) in accordance with the definition given in 1926.449. If all incorporated GFCI cord sets and/or portable tool assemblies at a construction site are approved and used in a manner such that the entire length of all cords are provided with protection, then the employer would be in compliance with this standard without an assured equipment grounding conductor program. A problem may arise, however, if some but not all cord sets are equipped with GFCI's. In this case, an assured equipment grounding conductor program would be required for all cord sets and equipment connected by cord and plug, as established in paragraph 1926.404(b)(1)(iii). In other words, this would require the testing of all cord sets including those cord sets and portable tools which incorporate their own individual approved GFCI's.

If we can be of any further assistance please contact either myself or Dale R. Cavanaugh of my staff at (202) 219-8136.

Sincerely,
Roy F. Gurnham, Esq., P.E.
Director
Office of Construction and Maritime
Compliance Assistance

[Requester letter reproduced on OSHA page; omitted here.]