Either GFCIs or an AEGCP
29 CFR 1926.404(b)(1)(i) requires the employer to protect employees from ground faults using either ground-fault circuit interrupters (GFCIs) or an assured equipment grounding conductor program (AEGCP). One is required. Neither is not an option.
Trap: requiring both. The rule makes them alternatives. The AEGCP has not been dropped; it remains one of the two permitted methods.
Which outlets need GFCIs
Under 1926.404(b)(1)(ii), GFCI protection covers all 120 V, single-phase, 15 and 20 A receptacle outlets on construction sites that are not part of the permanent wiring of the building and are in use by employees.
Traps:
- Outlets that are part of the permanent wiring are exactly what the rule excludes.
- The rule does not reach every receptacle of any voltage and amperage.
- There is no distance-from-water condition in this rule; 6 ft is the fall protection trigger.
The generator exemption
1926.404(b)(1)(ii) exempts receptacles on a portable or vehicle-mounted generator only when every condition is met:
- two-wire, single-phase
- rated not more than 5 kW
- the generator's circuit conductors are insulated from its frame and all other grounded surfaces
Trap: "any generator of 5 kW or less" drops the wiring and insulation conditions. A vehicle mount does not remove the 5 kW limit, and a three-wire 10 kW generator bonded to its frame fails all three conditions.
Running an AEGCP
1926.404(b)(1)(iii) requires a written description available at the jobsite, one or more designated competent persons to run it, and:
- A visual inspection before each day's use of cord sets, plugs, receptacles and cord-and-plug equipment.
- Tests before first use, after repairs, after suspected damage, and at least every 3 months ((iii)(E)).
- Fixed cord sets and receptacles not exposed to damage may go up to 6 months between tests.
Trap: confusing the daily visual inspection with the test. Equipment exposed to damage is tested at least every 3 months; 6 months is only for fixed equipment not exposed to damage, and once a year is not in the rule.