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1.) Information regarding this can be found at www.osha.gov and by typing "TempCovers™" in the search field. Also, excerpts from the letters found by doing this are on back of this sheet.
Switchboards that have any exposed live parts shall be located in permanently dry locations and accessible only to qualified persons. Panelboards shall be mounted in cabinets, cutout boxes, or enclosures designed for the purpose and shall be dead front. However, panelboards other than the dead front externally-operable type permitted where accessible only to qualified persons. Exposed blades of knife switches shall be dead when open.
(Emphasis added).
The applicable part of the manufacturer recommended procedures states:
2) TempCovers™ are intended to be used only for a period of a work shift that are manned by a qualified and/or licensed persons.
3) Qualified person and/or persons shall be properly trained as per all applicable OSHA Standards and NFPA 70E.
4) The use of proper PPE (Personal Protective Equipment) and he additional use of a barrier is the responsibility of the user/user's employer. Refer to applicable OSHA Standards and NFPA 70E.
(Emphasis added).
The combination of the three instructions/procedures listed above, which includes an instruction to use a barrier in conjunction with the panel, is designed to ensure that the live electrical parts are "accessible only to qualified persons." If a TempCover is used in accordance with these instructions/procedures, the requirements in 29 CFR 1926.405(d) regarding accessibility would be met.
If you need additional information, please contact us by fax at: U.S. Department of Labor, OSHA, Directorate of Constriction, Office of Construction Standards and Guidance, fax# 202-693-1689. You can also contact us by mail at the above office, ,
Room N3468, 200 constitution Avenue, N.W., Washington, D.C., 20210, although there
will be a dely in receiving our correspondence by mail.
Sincerely,
Steven F. Witt, Director
Directorate of Construction
Cumins, Goodman, Fish, Denley & Vickers, P.C.
100 S. College Street
P.O. Box 609
Newberg, Oregon 97132
Re: Whether a TempCovers temporary panel cover, when used
in accordance with manufacturer instructions/procedures,
would comply with the requirement in 29 CFR 1926.405(d)
that access to live electrical parts be limited to qualified persons.
Dear Mr. Goodman:
This is in response to your correspondence submitted June 11, 2007, to the Occupational Safety and Health Administration (OSHA). As you are aware, representatives of your client, TempCovers, Inc., had previously written our office requesting that we determine whether a Temporary Panel Cover ("TempCover") meets OSHA's construction requirements. We issued a response to their inquiries on May 23 2007, in which we stated that use of a TempCover panel cover would not comply with
29 CFR 1926.405(d) because of its ease of removal. In that letter we stated, "Anyone, including unqualified personnel, can readily obtain access to exposed live parts of the panel board."
As you explain in your most recent letter, your client has since developed new manufacturer recommended instructions/procedures for the use of this product.
We have paraphrased your most recent question as follows:
Question: Does the TempCover product, when used in conjunction with maufactureer recommended procedures, comply with the requirements in 29 CFR 1926.405(d) to limit the accessibility of live electrical parts to qualified persons?
Answer:
As we have stated previously, OSHA is generally precluded from approving or endorsing specific products. The variable working conditions at job sites and possible alteration or missapplication of an otherwise safe piece of equipment could easily create a hazardous condition beyond the control of the equipment manufacturer. However, where appropriate, we try to give some guidance to help employers assess whether products are appropriate to use in light of particular OSHA requirements.
REPRODUCTION
Use of Temporary Panelboard ingress barriers in General Industry settings:
The following was stated in the letter dated August 16, 2004 and can be read in its entirety at:
www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id24908
"While the TempCovers are "acceptable" devices for purposes of §1910.303, employers are permitted to use the panelboard barrier only in a manner that conforms with other provisions of 29 CFR Part 1910, Subpart S, and employers are responsible for assuring that the panelboards are being used in accordance with all of the Subpart S provisions."
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