Extension cord indicators and grounding continuity tests

August 9, 1993

MEMORANDUM FOR: LINDA R. ANKU
Regional Administrator

FROM: ROGER CLARK, Director
Directorate of Compliance Programs

SUBJECT: Nationwide Inquiry Concerning a Specific Type of
Extension Cord

This memorandum is in response to your recently transmitted memorandum dated April 13 concerning the use of a specific type of extension cord in meeting our grounding continuity requirements.

We reviewed the enclosed letter which you forwarded to John Fauth Sales Company concerning this issue and found it to be correct. In addition, we made telephone contact with Mr. John D. Fauth and obtained information which confirmed that the LED light embedded in the female end of the "Yellow Jacket" cord set does not meet the intent of our assured equipment grounding conductor program requirements for testing all equipment grounding conductors for continuity. The cord set visual indicator provides an indication that the cord set is energized, but does not indicate whether the cord set has proper grounding continuity or correct wiring.

Any nationally recognized testing laboratory listed, labeled or certified ground continuity tester wired to a cord sets receptacle can be used to comply with the requirements to test the cord (1926.404(b)(1)(iii)(D) and (E)), and to mark the cord as having been tested (1926.404(b)(1)(iii)(G)). This is based on the assumption that all cord connectors used on the site would incorporate the tester or would otherwise be tested in compliance with the ground-fault protection standard. Additionally, this device can be used to test other equipment on the jobsite. However, because it neither identifies other equipment that has been tested nor checks for multiple wiring defects, it cannot be used in lieu of the marking required under 1926.404(b)(1)(iii)(G) for this other equipment. Paragraph (b)(1)(iii)(D)(2) specifically requires each receptacle and plug to be tested individually. Similarly, a ground continuity tester wired to the plug of a cord set or a power cord can be used only to test receptacles and cord sets to which the plug is connected. It does not test the cord set or power cord on which it is installed.

Thank you for providing the Directorate of Compliance Programs with information concerning this issue. If you have any questions or comments please contact Mr. Roy Gurnham or Mr. Dale Cavanaugh of my staff at (202) 219-8136.

[Earlier agency memorandum and company correspondence reproduced on OSHA page; omitted here.]