November 2, 2015

Manuel Rosas
President
PinPoint Safety
1122 Industrial Drive, Suite 113
Matthews, NC 28105

Dear Mr. Rosas:

Thank you for your letters of January 10, 2011 and March 23, 2015 to the Occupational Safety and Health Administration (OSHA)’s Directorate of Construction. We apologize for the delay in our response. You have a specific question regarding our October 3, 2002, letter to Mr. John Tanese and the electrical standard, 29 CFR 1926.405(j)(1)(i). This letter constitutes OSHA’s interpretation of only the requirements discussed and may not be applicable to any question not delineated in your original correspondence.

Scenario
You have requested additional clarification of OSHA’s interpretation letter to Mr. Tanese regarding the protection of painters from electrical hazards posed by uncovered electrical receptacles. In that letter, OSHA stated that it was a violation of 29 CFR 1926.405(j)(1)(i) to permit employees to work in areas where the covers of energized outlet and switch receptacles have been removed during painting operations.

In your letter, you agree that exposing workers to uncovered receptacles presents a shock hazard, but note that removal of those covers is necessary to apply a quality paint finish. You ask whether wrapping all the live electrical parts of the receptacles with electrical rope is a permissible alternative to leaving the covers in place.

Question: Is the practice of wrapping conductive metal parts of switches and outlets with electrical tape instead of retaining in place the covers to those switches and outlets compliant with the 29 CFR 1926.405(j)(1)(i) requirement that “fixtures, lampholders, lamps, rosettes, and receptacles shall have no live parts normally exposed to employee contact?”

Answer: No. Although the application of electrical tape to conductive parts, as described above, will likely reduce worker exposure to the shock hazards of uncovered receptacles, it is not an acceptable alternative to retaining receptacle covers in place or turning off power. Workers preparing walls for painting could still inadvertently place sharp metal tools into a receptacle and receive a shock if the tool pierces electrical tape covering the conductive parts of the uncovered receptacle. In any case, the general electrical requirements of 29 CFR 1926.403(b)(2) require certified electrical equipment to “be installed and used in accordance with instructions included in the listing, labeling, or certification.” OSHA is unaware of any manufacturer of certified switches or outlets that instructs the use of electrical tape as an acceptable alternative to receptacle covers. In short, whenever a receptacle cover is removed, the receptacle must be de-energized to permit work in the area.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. 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 http://www.osha.gov. If you have any further questions, please feel free to contact the Directorate of Construction at (202) 693-2020.

Sincerely,

James G. Maddux, Director
Directorate of Construction