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 https://www.osha.gov.
June 18, 1987
Ms. Judy Wells
R1 CR 650
Pleasant Lake, Indiana 46779
Dear Ms. Wells:
This is in response to your letter of May 11 to President Ronald W. Reagan inquiring about the possible non-grounding of your wheelchair to eliminate static electricity while you, yourself, are grounded. Your letter was forwarded to the [Directorate of Science, Technology and Medicine] of the Occupational Safety and Health Administration (OSHA) for response.
Static electricity is generated when objects of dissimilar substances move relative to each other. If one of the objects is nonconductive, such as the rubber wheels on your wheelchair, the electric charge may accumulate and produce sparks. To prevent the generation of the static charges or to drain off charges generated on an object, a conductive path must be insured. While you are grounded through ground straps, all components of your wheelchair may or may not be grounded.
As you know, many devices are available for employee grounding including boot and shoe straps, wrist straps, smocks, aprons, floor mats, table tops, and seat covers. While there are no grounding devices designed specifically for wheelchairs, it would not be a major problem to use a combination of the above devices to achieve grounding. It is imperative, however, that all elements of the wheelchair-employee system be grounded. Such a task should be a relatively easy one to accomplish.
Please contact this office if further information is required.
Sincerely,
Edward J. Baier, Director
[Directorate of Science, Technology and Medicine]
[Corrected 10/22/2004]