How to comprehend the paragraph architecture of OSHA standards in 1910 Subpart S

placebo_master

Starting to get Involved
#1
I've been assigned to read OSHA 1910 Subpart S (Electrical) to determine if a product we're designing is consistent with the applicable regulations in that subpart. This being my first time reading these regulations in the context of product development, I want to be sure that I understand the architecture of how OSHA presents its regulations.

My question is specifically regarding 1910.305. The first paragraph claims the following:

1910.305(a)
Wiring methods. The provisions of this section do not apply to conductors that are an integral part of factory-assembled equipment.

What I'm wondering is if the claim made in this paragraph applies to any of the subsequent lower-case paragraphs. For example, does the claim in 1910.305(a) also apply to 1910.305(g), or is paragraph (g) independent of paragraph (a):

1910.305(g)
Flexible cords and cables
 
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John C. Abnet

Teacher, sensei, kennari
Leader
Super Moderator
#2
What I'm wondering is if the claim made in this paragraph applies to any of the subsequent lower-case paragraphs
Good day;
Each individual lower case "paragraph" has sub listed requirements (e.g. 1, ii., etc...) that are specific to that paragraph. The subsequent paragraphs are then autonomous of each other unless referring back.

In the example you stated, there is no reference in "g" to previous paragraph "a", therefore, each stands alone/autonomous.

Hope this helps.

Be well.
 

Randy

Super Moderator
#3
It's a safety regulation and not a manufacturing requirement or guide. You need to go to UL, ANSI, ASTM or some place other than OSHA
 

placebo_master

Starting to get Involved
#4
It's a safety regulation and not a manufacturing requirement or guide. You need to go to UL, ANSI, ASTM or some place other than OSHA
We maintain a library of manufacturing standards that we incorporate into our best design practices. And I hear your point about OSHA being a safety regulation and I know with confidence that the bulk of the regulations don't apply to design practices. For context, this exercise was motivated by a requirement given to us by our client that effectively stated "all electrical equipment shall be compliant to relevant OSHA regulations."

So I framed the activity this way (and I'm curious to hear your thoughts/critiques so I can learn for future projects): how can we make a design that enables our client to comply with the OSHA regulations dictated in 1910 Subpart S? Most of the regulations in that subpart weren't in the scope of our work, but there were a handful of regulations that I thought did apply to us. For example, this "chunk" felt applicable to the design:

1636036440613.png

I know that in our business context 1910.303(e)(2) is also required by MIL-STD-810 (can't cite the specific section off memory but there's definitely a labelling durability requirement). Similarly, I'm assuming there's a standardized labelling requirement that's consistent with 1910.303(e)(1)— I assume that because, though I'm new to aerospace, I know one exists for the domain of medical devices. The point is that other standards we adhere to overlap with the OSHA regulations in this example, but we still want to demonstrate to our client that we considered their compliance needs in our design.
 

placebo_master

Starting to get Involved
#6
Good day @placebo_master ;
May in inquire as to what type of industry(ies) your organization is in?

Be well.
I work for a consulting firm, and the majority of our business is focused on design and testing of medical and aerospace devices. The project I'm assigned to now is developing a piece of aerospace equipment that will be used in the field by technicians.
 

John C. Abnet

Teacher, sensei, kennari
Leader
Super Moderator
#7
Understood....thank you.

Not sure if your organization utilizes/is familiar, but in one organization (automotive manufacturing) I worked with we created PFMEA (Process Failure Mode and Effect Analysis) documents specific to plant/infrastructure.

Examples: Handrails.; Stairs; Mezzanines, etc...
We would then assess risk and also identify what governance (statutory/regulatory) applied. Yours could be as easy as a simple matrix.

In the example I provided, it then became easy for the maintenance team to simply refer to the PFMEA and the feature in question. If they were installing/modifying/relocating a stairway, they could simply see if that feature was identified in the PFMEA, and then quickly see what governance applied AND if we had any of our own protocol/controls that needed to be adhered to.

Hope this helps.

Be well.
 
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