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.

March 28, 1995

Mr. T. F. Fallon President
Safety Lamp of Houston, Inc.
15550 W. Hardy Road
Houston, TX 77060

Dear Mr. Fallon:

This is in response to your November 4, 1994, letter requesting an interpretation of an Occupational Safety and Health (OSHA) standard addressing portable electric lighting.

We agree with your interpretation that 29 CFR 1926.405(a)(2)(ii)(G) does not apply to the pneumatic 12-volt or 24-volt lights as described in your letter (self-contained units utilizing a turbo-alternator built into the brass housing producing A.C. current).

If we can be of any further assistance, please contact me or Mr. Dale Cavanaugh of my staff at (202) 523-8136.

Sincerely,


Roy F. Gurnham, P.E., J.D. Director
Office of Construction and Maritime Compliance Assistance

Encloser



November 04, 1994

MR. ROY GURNHAM, DIR.
OFFICE OF CONSTRUCTION
U.S. DEPARTMENT OF LABOR OSHA COMPLIANCE
200 CONSTITUTION AVE. N.W.
WASHINGTON, D.C. 20210

DEAR MR. GURNHAM,

I HAVE JUST FINISHED A PHONE CONVERSATION WITH MR. JOE PIPKIN REGARDING PNEUMATIC LAMPS v.s. ELECTRICAL LIGHTING. AND THE CURRENT OSHA SPECIFICATION 405(a)(2)(II)-(G).

SECTION "G" WAS WRITTEN AROUND PORTABLE ELECTRIC LIGHTING UNITS THAT TRAIL AN ELECTRIC POWER CABLE. YOU STATE THAT "PORTABLE ELECTRIC LIGHTING USED IN WET AND/OR CONDUCTIVE LOCATIONS, AS FOR EXAMPLE, DRUMS, TANKS, AND VESSELS, SHALL BE OPERATED AT 12 VOLTS OR LESS." WE ARE TRYING TO CLARIFY THIS SPECIFICATION. IN OUR OPINION THIS SPECIFICATION DOES NOT APPLY TO THE PNEUMATIC 12V or 24V PNEUMATIC LIGHTS AS THEY DO NOT TRAIL AN ELECTRIC POWER CABLE. THE UNITS ARE SELF CONTAINED UTILIZING A TURBO-ALTERNATOR BUILT INTO THE BRASS HOUSING PRODUCING A.C. CURRENT.

THEY HAVE BEEN IN USE SINCE 1930 AND HAVE NEVER CAUSED AN ACCIDENT! (PNEUMATIC v.s. ELECTRIC)

YOURS VERY TRULY,


T.F. FALLON
PRESIDENT