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OSHA Requirements
(excerpts from OSHA's  website) 

Requirement to use Ground Fault Circuit Interrupters when using extension cords plugged into permanent wiring

Question 1: You ask whether ground fault circuit interrupters (GFCIs) are required if the workers are standing on dry wood, vinyl tile and other flooring that does not have a ground path. You specifically reference an OSHA interpretation dated October 28, 1985, issued by John Miles, dealing with requirements for Ground Fault Circuit Interrupters (GFCIs), and ask if that memo continues to be in effect.

The 1985 memo dealt with 29 CFR 1926.400(h)(2). That provision has since been moved (without substantive change) and is now 1926.404(b)(1)(ii). It provides that:

All 120-volt, single-phase, 15- and 20-ampere receptacle outlets on construction sites, which are not a part of the permanent wiring of the building or structure and which are in use by employees, shall have approved ground-fault circuit interrupters for personnel protection...

The 1985 memo
The 1985 memo dealt with the issue of whether this provision required a GFCI if an extension cord were plugged into a permanent receptacle and powered equipment was, in turn, plugged into the extension cord. The memo stated that it had been OSHA's position that the end of the extension cord was a non-permanent "receptacle" and therefore needed a GFCI. It went on to explain, however, that due to "a recent [Occupational Safety and Health Review Commission] decision, OSHA could only require a GFCI in this circumstance where the exposed employee was in a location with a ready grounding path, such as damp or wet locations, outdoor areas, etc."

Current Policy
The 1985 memo was apparently referencing a decision by an administrative law judge, not the Review Commission; administrative law judge decisions do not have precedential effect. In fact, in 1995, the Review Commission clearly held in Otis Elevator Co., 17 BNA OSHC 1166 (No. 90-2046, 1995)
1 that the receptacle end of an extension cord is a non-permanent receptacle under this standard and that a GFCI is required unless the employer uses an assured grounding conductor program under 1926.404(b)(1)(iii). The application of the standard does not depend on the employee standing on a surface with a ready grounding path. Consequently, this letter rescinds and supersedes the 1985 memo.

Furthermore, it would be inappropriate to apply an across-the-board de minimis policy to these situations; in light of the ever-changing conditions typically encountered on construction sites, it would be unrealistic for us to assume that a ground path across or through the body is absent simply because the workers are standing on the surfaces you mention.

Cover plates are required on 120 volt receptacles.

The equipment grounding requirements for cord and plug connected equipment, contained in Section 250-114 of the 1999 NEC, does not provide an exception that permits the use of a GFCI in lieu of equipment grounding. The GFCI provisions, contained in Section 210-7(d), pertain to the requirements for receptacle replacement and not to the grounding of equipment.

The use of a GFCI-type receptacle or GFCI-type circuit breaker in lieu of an equipment grounding conductor run to the receptacle outlet is permitted by the 1999 NEC, Section 210-7, on branch circuits. However, all of the listed conditions must be met to meet this code exception. Section 210-7(d)(3) contains additional marking and wiring requirements that must be met when GFCI-type receptacle(s) or circuit breaker(s) are used when a grounding means is not available. Strict compliance with these NEC requirements would constitute a de minimis violation of OSHA electrical standard 1910.304(a)(3) as the GFCI-type receptacles would provide additional personnel protection and would not be used in lieu of equipment grounding.

For example, if a GFCI-type receptacle is used, it must be visibly marked "No Equipment Ground," and equipment required to be grounded may not be used in the ungrounded, GFCI-type receptacle. However, many appliances (i.e., lamps; toasters; televisions; double insulated appliances) and tools (i.e., double insulated tools; tools supplied with a low voltage isolating transformer) are not required to be grounded and they may be used in an ungrounded, GFCI-type receptacle. The GFCI feature of these GFCI-type receptacles provides additional electrocution protection in the event of misuse (i.e., a floor buffing machine is powered by a 3-prong plug from a properly marked and wired ungrounded, GFCI-type receptacle).

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at

GFCI a.k.a. Ground Fault Circuit Interrupter

Portable GFCI Outlets - GFCI - Ground Fault Circuit Portable GFCI Outlets
Perfect for indoor and outdoor use. Easiest to install. GFCI
Portable protection on power tools, appliances, outdoor equipment, aquariums, fountains, etc, and is great for the jobsite, workshop or at the marina.  


Permanent GFCI Outlets
15 & 20 Amp, 125 Volt, 60 Hz. Commercial grade with wall plate and screws. GFCI outlets - for all garages, bathrooms and outdoor spaces
Complies with new U.L. / NEC Code Requirements. Buttons Match Body Color.    


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