Art,

You absolutely win the prize for the first truly definitive answer to my
challenge!  Obviously Mr. Blocher had the same trouble interpreting the
meaning of "utilization equipment".  Note how simple it was for OSHA to
clearly state that desktop computuers (PCs) are included.  It is a shame
that the wording in the CFR is so much more obtuse.  Now all we need is
about 10,000 more such letters to cover pencil sharpeners, plotters,
staplers, etc.

The horse was not dead, but I think your note finished it off.

BTW, your prize is a nomination for the Product Safety Hall of Fame, to
be established at the beginning of the third millenium.

Regards, George


Hello George,

While I'm reluctant to flog a dead horse, somewhere along this discussion
thread, someone was looking for a "definitive statement" regarding the
subject at hand.  After searching OSHA's Interpretation Letters I found
the following letter relating OSHA's requirements and (desktop) computers.

Regards, Art Michael
Editor - Int'l Product Safety News

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   OSHA Banner Image Map
   OSHA Standards Interpretation and Compliance Letters
   02/18/1992 - Electrical standards as it applies to desktop computers.
     _________________________________________________________________

   OSHA Standard Interpretation and Compliance Letters - Table of
   Contents OSHA Standard Interpretation and Compliance Letters - Table
   of Contents
     _________________________________________________________________

     * Record Type: Interpretation
     * Standard Number: 1910.303;1910.399
     * Subject: Electrical standards as it applies to desktop computers.
     * Information Date:02/18/1992

     _________________________________________________________________

   February 18, 1992

   William K. Blocher President
   BBC Computers Inc.
   7 Columbia Circle
   Merrimack, New Hampshire 03054

   Dear Mr. Blocher:

   Thank you for your letter of January 23, requesting clarification on
   the applicability of 29 CFR 1910 Subpart S, Electrical standards, to
   desktop computers.

   Desktop computers are "appliances" otherwise described as "utilization
   equipment" when used by employees in the workplace. By 29 CFR
   1910.303(a) "equipment" required or permitted by 29 CFR 1910 Subpart S
   shall be "accepted" only if "approved". "Approved" means acceptable to
   the authority, that is, the Assistant Secretary of Labor for
   Occupational Safety and Health, enforcing 29 CFR 1910 Subpart S. The
   definition of "acceptable" includes three different methods to
   determine acceptable equipment, and these methods are specified at
   1910.399. A copy of the 1910.399 definitions, specified by quotation
   marks in this letter, is enclosed for your use.

   We appreciate your interest in occupational safety and health. If we
   can be of further assistance, please do not hesitate to contact us.

   Sincerely,



   Patricia K. Clark, Director
   Directorate of Compliance Programs

   Enclosure
     _________________________________________________________________

   OSHA Standard Interpretation and Compliance Letters - Table of
   Contents OSHA Standard Interpretation and Compliance Letters - Table
   of Contents tracking image
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