Answer Library / Machines & Electrical

Does every construction site need GFCIs, or is an assured equipment grounding conductor program enough?

Quick answer

One or the other, always. The employer must use either ground-fault circuit interrupters or an assured equipment grounding conductor program to protect employees on construction sites (29 CFR 1926.404(b)(1)(i)). The GFCI route covers all 120-volt, single-phase, 15- and 20-ampere receptacles that are not part of the permanent wiring and are in use by employees (1926.404(b)(1)(ii)). The program route requires a written program, daily visual inspections, and documented continuity tests at set intervals (1926.404(b)(1)(iii)).

Temporary power is where construction electrocutions happen, and this paragraph is the answer the standard gives. It offers a choice, and either choice has to be done completely.

The choice. The employer shall use either ground-fault circuit interrupters or an assured equipment grounding conductor program to protect employees on construction sites, in addition to any other equipment grounding requirements (29 CFR 1926.404(b)(1)(i)).

Option one: GFCIs. All 120-volt, single-phase, 15- and 20-ampere receptacle outlets on construction sites that are not part of the permanent wiring of the building and are in use by employees must have approved ground-fault circuit interrupters for personnel protection; receptacles on small portable generators with insulated conductors are excepted (29 CFR 1926.404(b)(1)(ii)). This is the route most sites take because it requires no paperwork, only hardware.

Option two: the assured equipment grounding conductor program. The program must cover all cord sets, non-permanent receptacles, and cord-and-plug equipment available for use (29 CFR 1926.404(b)(1)(iii)). A written description must be available at the jobsite (29 CFR 1926.404(b)(1)(iii)(A)), and the required continuity and terminal tests must be performed before first use, before equipment is returned to service after repair, after any incident that could have caused damage, and at intervals not exceeding 3 months — 6 months for cord sets and receptacles that are fixed and not exposed to damage (29 CFR 1926.404(b)(1)(iii)(E)).

In practice, the program route is heavier than it looks: the quarterly test cycle has to be documented and the colored tape has to mean something. A site that has a few GFCI pigtails and a vague recollection of a program has neither option in place.

29 CFR 1926.404(b)(1)(i)29 CFR 1926.404(b)(1)(ii)29 CFR 1926.404(b)(1)(iii)29 CFR 1926.404(b)(1)(iii)(A)29 CFR 1926.404(b)(1)(iii)(E)
Source: An analysis from the construction electrical standard, 29 CFR 1926 Subpart K (1926.404). Primary reference: read it on osha.gov →

Federal rule shown. If the workplace is in one of the 29 State Plan states and territories, the state standard governs and may differ — see Known Limitations.

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