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Standard Interpretations
06/24/2002 - Guidance on "Approval" Requirments for Flexible Corrugated Plastic Covers in the General Industry.

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• Standard Number: 1910.305(b)(2); 1910.147(c)(5); 1910.303(g)(2)(ii); 1910.399


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.


June 24, 2002

MEMORANDUM TO: KENNETH W. GERECKE,
Assistant Regional Administrator, Region III

FROM: RICHARD E. FAIRFAX, Director
[Directorate of Enforcement Programs]

SUBJECT: Guidance on "Approval" Requirements for Flexible Corrugated Plastic Covers in the General Industry


This memo is a revision to and supersedes the June 28, 2000 memo requesting Guidance on "Approval" Requirements for Flexible Corrugated Plastic Covers and Generic Circuit Breaker Panel Switch Lockouts. A member of your staff, John McFee, provided additional information and clarification (via telephone) regarding the actual use of the flexible corrugated plastic covers.

Mr. McFee stated that these plastic covers are temporary and primarily used in General Industry by qualified persons to prevent personnel from accidentally contacting energized parts of a panelboard that are mounted inside a cabinet and accessible only from the front. Additionally, we later determined that these plastic covers are also used extensively in the construction industry.

We met with the Directorate of Construction to discuss the extent of use in the construction industry. As a result, a joint memorandum was agreed upon and signed by the Director of the [Directorate of Enforcement Programs], Richard E. Fairfax, and the Director of Construction, Russell B. Swanson. A copy of that memorandum is attached for your review.

I hope you find this information useful. If you have any questions, please feel free to contact [the Office of General Industry Enforcement] at (202) 693-1850.

[Corrected 6/2/2005]


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