OSHA releases letter on requirements for guarding 50 volts or more [US]

In an interpretation letter dated September 4th, 2015, the Occupational Safety and Health Administration (OSHA) clarified the guarding requirements for…

In an interpretation letter dated September 4th, 2015, the Occupational Safety and Health Administration (OSHA) clarified the guarding requirements for 50 volts or more of direct current (DC).

The letter’s two questions

1. Does the electrical guarding requirement at 29 CFR 1910.303(g)(21)(i) apply to voltages below 60 volts DC?
2. If 29 CFR 1910.303(g)(2)(i) applies to live parts operating at 50 volts or more AC or DC, will OSHA treat a failure to guard live parts operating below 60 volts DC as a de minimis violation?

Response to the first question

OSHA stated that guarding requirement in 29 CFR 1910.303(g)(2)(i) does not distinguish between AC or DC voltages and that it therefore applies to live parts operating at 50 volts or more AC or DC.

Response to the second question

OSHA does not accept a failure to guard live parts operating below 60 volts DC as a de minimis violation and that failing to guard live parts operating at any voltage over 50 volts has a direct relationship to employee safety.

OSHA considers all voltages of 50 volts or above to be hazardous to employees regardless of whether the electric current is AC or DC since the current can cause serious injury.

Red-on-line EHS Legalist

Sources:

OSHA Standard Interpretation, Guarding requirements for 50 volts of more DC, September 4, 2015

General electrical standards, 29 CFR 1910.303

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