Standard Interpretations - Table of Contents
• Standard Number: 1910.307(c)

October 12, 1993

Ms. Angela Wynn
Contract Specialist
General Services Administration
Federal Supply Service
Washington, DC 20406

Dear Ms. Wynn:

This is in response to your telefax of September 7, 1993, addressed to Mr. Roy Resnick of my staff, consisting of correspondence from a representative of Underwriters Laboratories Inc. to Tennant, a manufacturer of battery power operated cleaning equipment, dated July 29, 1993, (Exhibit 1.A.), and a letter from Tennant to you, dated July 30, 1993 (Exhibit 1.B.), and further telephone conversations with him concerning additional developments associated with your letter of May 28, 1993. As requested in your conversations with Mr. Resnick, we will again attempt to clarify the situation as it involves requirements for third-party certification of certain equipment by the Occupational Safety and Health Administration (OSHA).

To iterate, OSHA has determined that battery power operated cleaning (sweeper/scrubber) equipment is not regulated under the OSHA General Industry standard for powered industrial trucks, section 1910.178. The pertinent requirements are resident in Subpart S - Electrical, of our General Industry Standards (Exhibit 2, pertinent sections, pp 1-8). Where this equipment will be used in a classified locale, section 1910.307 - Hazardous (Classified) Locations, would apply.

Specifically, two of the three provisions under section 1910.307(c) - Electrical Installations, (pp 1 and 2), are applicable. Battery power operated cleaning equipment must comply with either section 1910.307(c)(1) - Intrinsically safe, or 1910.307(c)(2) - Approved for the hazardous (classified) location, both of which require that the specific hazardous (classified) location be identified. By referring to section 1910.399 - Definitions Applicable to T