October 12, 1995

Mr. Kirk J. King
Head, Safety Branch Naval
Research Laboratory
Department of the Navy
Washington, D.C. 20375-5320


Dear Mr. King:

This is in response to your August 31, 1994 letter to Mr. Joseph Pipkin in the Directorate of Safety Standards Programs of the Occupational Safety and Health Administration (OSHA). Your letter was forwarded to this OSHA directorate for response. Please accept our apology for the delay in responding. In your letter you requested written interpretation and clarification on the use of flexible cords and cables as temporary wiring for research projects. Your questions and our responses follow.

Question 1: Is temporary wiring (i.e., flexible wiring and extension cords) that is installed by research projects covered under the exemption provided by 29 CFR 1910.305(a)(2)(i)(A) through (C)?

Reply: The reply to your question is "yes", as long as the "research project" can reasonably be considered either experimental or developmental. If that is the case, temporary electrical power and lightning installations, 600 volts, nominal, or less may be used for experimental or developmental work. This is an exception to permanent wiring installations covered by paragraph 1910.305(a). In general, temporary wiring is permitted to be a class less than permanent wiring but must follow most of the rules of permanent installations except as noted in paragraph 1910.305. Flexible wiring and extension cords must be a type identified for hard or extra-hard usage.

Question 2: Specifically, does the clause "not to exceed 90 days" apply to research use of flexible wiring as permanent wiring?

Reply: Use of temporary wiring for a period not to exceed 90 days under paragraph 1910.305(a)(2)(i)(C) is not intended to apply to experimental or developmental work. Temporary wiring may be used during the period of time that experimental or developmental work for a particular research project is being conducted and until it has served the purpose for which installed at which time it must be removed immediately.

Question 3: Does the flexible wiring exemption, that has been granted computer areas with false flooring also apply to research?

Reply: To the extent that computer areas with false flooring are used in experimental or developmental work, the answer to your question is yes pursuant to paragraph 1910.305(g)(1)(i).

Question 4: Are research projects with raised floors required to install conduit wiring when the project exceeds 90 days? Examples of this application would include flexible cords run from electrical panel boxes through holes in the ceiling, walls and floor?

Reply: The reply to your question is "no", there is no 90-day limit as described above. However, temporary wiring must comply with the installation requirements under paragraph 1910.305(a)(2)(iii). Also, under 1910.305(g)(iii) flexible cords and cables may not be run through holes in walls, ceilings or floors unless specifically permitted under paragraph 1910.305(g)(1)(i). Cables entering enclosures containing devices requiring termination must be secured to the box with fittings designed for the purpose.

Question 5: Are electronic technicians allowed to install electrical power or must this work be performed by a licensed electrician?

Reply: A worker, including an employee who is an electronic technician, licensed electrician or otherwise, must be a "qualified person", as defined under paragraph 1910.399, if he or she is to do certain types of electrical installation work as specified in paragraphs 1910.301 through 1910.308. Also, a qualified employee must follow the safety-related work practices under paragraphs 1910.331 through 335 when performing such installation work.

We appreciate your interest in employee safety and health. If we may be of further assistance, please contact the Office of General Industry Compliance Assistance, Mr. Ronald J. Davies, telephone (202)219-8031, extension 110.

Sincerely,



John B. Miles, Jr., Director
Directorate of Compliance Programs




August 31, 1994

U.S. Department of Labor
OSHA/Safety Standards
Attn: Mr. Joseph Pipkin
Room N3609
200 Constitution Avenue, N.W.
Washington, D.C. 20210


Gentlemen:

The Naval Research Laboratory's Safety Branch (Code 1240) is requesting written interpretation and clarification concerning the use of flexible temporary wiring. These concerns are as follows:

1. Is temporary wiring (i.e., flexible wiring and extension cords) that is installed by research projects covered under the exemption provided by 29 CFR 1910.305(a)(2)(i)(A-C)?

2. Specifically, does the clause "not to exceed 90 days" apply to research use of flexible wiring as permanent wiring?

3. Does the flexible wiring exemption, that has been granted computer areas with false flooring also apply to research.

4. Are research projects with raised floors required to installed conduit wiring when the project exceeds 90 days? Examples of this application would include flexible cords run from electrical panel boxes through holes in the ceiling, walls, or floor.

5. Are electronic technicians allowed to install electrical power or must this work be performed by a licensed electrician?

If you have any questions or require additional information, please contact Mr. Albert Pettyjohn on (202)767-2249.

Sincerely,



KIRK J. KING
Head, Safety Branch
By direction of the Commanding Officer