June 8, 2001In a letter issued earlier this year, which carbon-copied Federal OSHA Region IX office, the Department of Industrial Relations, Division of Occupational Safety & Health in San Francisco, stated that it considers unknown sewer environments to be hazardous classified locations subject to Class I, Division 1 electrical classification.
The U.S. Department of Labor in 29 CFR 1910.307(b) requires the use of approved electrical equipment in such environments. The letter delineates that equipment, wiring methods and installations of equipment in classified locations shall be one or more of the following: (a) intrinsically safe, (b) approved for the classified location, or © of a type and design which provides protection from hazards arising from the combustibility and flammability of vapors, liquids, gases, dusts or fibers.
The Division is requiring all electrical equipment used in sewer inspections to be approved for any use and, where applicable, to be approved for hazardous location and wet location applications. It emphasized that it enforces the Title 8, California Code of Regulations standards at places of employment in California, including municipalities. According to the letter, municipal employers are subject to the same financial and criminal penalties for violations as are private sector employers. In addition, employers creating a hazard may be cited at multi-employer work sites.
Additional questions about this important California safety measure may be directed to Larry McCune, Principal Engineer, Telephone: 415-703-5163.