Bill Ward
Mecklenburg County, NC
As the data-communications specialist for Mecklenburg County`s Telecommunications Div., I was recently approached by the superintendent of the office building in which I work. He asked me if it was necessary to erect plywood barriers that would completely cover the hundreds of telephone termination blocks in the main entry facility and all telecommunications closets (TCs). He said the county`s director of safety told him that in fact he would need to erect such barriers. I said that I would investigate and advised him not to take any immediate action.
Although my voicemail to the safety director went unreturned, I received an e-mail from a park supervisor who asked me to provide covers for all the parks` telephone blocks. She also explained that her safety inspector ordered this action. On the same day, I received a call from one of our wiring contractors, who said that he would be unable to complete a work order because a large sheet of plywood covered all the 66 blocks in the TC. At this point, I had ample evidence that something was amiss and required serious investigation.
I was able to get in touch with the inspector for the parks and recreation department, who was very cooperative and offered a complete explanation. The Occupational Safety and Health Administration (OSHA--Washington, DC) informed Mecklenburg County that we would be subjected to a routine audit this year. To prepare for this audit, several staff members, including the safety director and the parks` safety inspectors, attended a certified osha Inspectors Course at a large university in Georgia. The course instructors informed all participants that, according to osha regulations, any exposed parts carrying 50 or more volts had to be covered. According to the inspector for the parks and recreation department, the instructors said, "This would have a major impact on the [telecommunications] industry." Upon completing the course and returning to work, the staff began implementing what they believed was necessary to protect employees and pass the osha audit.
Incredulous, I began research that produced the following information. The emphasis is mine and not that of any standards-making body.
OSHA Regulations (Standards - 29 CFR) Part 1910.303 (g)(2)(I) states, "Except as (stated) elsewhere...live parts of electrical equipment operating at 50 volts or more shall be guarded against accidental contact by approved cabinets or other (means)."
Immediately following that statement, the regulation lists the other means, which include by location in a room accessible to qualified persons; by permanent, substantial partitions; by location on a suitable balcony; and by elevation of 8 feet or more.
In Part 1910.308 (e)(1), entitled "Communications Systems," the regulations state that the "provisions for communications systems apply to such systems as central-station-connected telephone circuits, radio, and television...equipment, (CATV), and similar central station systems. These installations need not comply with the provisions of 1910.303 through 1910.308(d), except 1910.304(c)(1) [Conductors on poles] and 1910.307(b) [Hazardous and classified locations]."
The instructors of the course based their assumptions on the "50 volts or more" portion of 1910.303. It is true that telephone equipment can produce limited power voltages of 52V or more. However, these signal voltages have no appreciable current capacity and are not dangerous. Furthermore, 1910.308 specifically exempts communications systems such as telephones and televisions.
I contacted the chief electrical inspector with the State of North Carolina OSHA inspectors` office and reviewed this material with him. He emphatically supported my conclusions. Furthermore, he knows of no changes that have any impact on this issue.
Mecklenburg County`s safety inspector said that his ruling to the contrary is based on his knowledge that the 1999 National Electrical Code (NEC) contains changes that will bring about changes to OSHA regulations. I obtained a copy of the 1999 NEC, reviewed it comprehensively for any such changes, and found none. The nec references are as follows:
- Article 90-3, Code Arrangement (paragraph 2): "Chapter 8 covers communications systems and is independent of the other chapters except where they are specifically referenced therein."
- Article 110-27(a), Live Parts Guarded Against Accidental Contact: "Except as elsewhere required or permitted by this code, live parts of electrical equipment operating at 50V or more shall be guarded against accidental contact by approved enclosures or any of the following means." Those means are exactly the ones specified by OSHA.
- Article 110-27(a) of the code, upon which the inspector bases his opinion, is in one of the chapters excluded by Article 90-3.
- Article 800 of Chapter 8 is considered to stand alone. In Section A, Part 800-1, it states, "This article covers telephone, telegraph,...and similar central station systems; and telephones not connected to a central station, but using similar types of equipment..."
Chapter 8 does reference the same exceptions listed in OSHA, notably hazardous locations. The 1999 NEC repeatedly references the TIA/EIA-568A Commercial Building Telecommunications Cabling Standard as the source for recommended standards for communications circuits. This is a welcome reference in the 1999 NEC, in that 568A does not reference or recommend covering telephone or data terminations.
I recognize that the references in both OSHA 1910 and the 1999 nec are difficult to access and pull together, but I emphasize that they make it abundantly clear that communications systems are exempt from any regulations requiring that they be protected or otherwise covered. It is apparent, however, that a well-known university of national prominence is teaching inspectors to initiate actions that could be both costly and a logistical nightmare. Be prepared: OSHA regulations are published in their entirety on the Internet. You also may face this challenge.
Bill Ward, registered communications distribution designer (RCDD), is the data-telecomjmunications specialist for Mecklenburg County, NC. Based in Charlotte, NC, he also is active on BICSI`s Governmental Relations Committee.
