Have you ever heard that it’s not legal to replace the plug on the end of an electrical cord because replacement plugs aren’t molded to the cord like the original plugs? So have we. In fact, we’ve been asked this question recently by a few clients, so we have decided to write a blog just to clear it up.
For those of you who don’t have the time or patience to read all of the detail, the short answer without any explanation is… it IS legal to use a replacement plug as long as the plug is UL listed and the repair is made in accordance with the manufacturer’s instructions. For those of you who crave the details or need to see the proof, let’s dive into OSHA’s standards in order to get the answer.
Our first stop will be 1926.404(b)(1)(iii)(C), which is shown below. This standard confirms that the repair of electrical components (including plugs) is allowed!
- “Each cord set, attachment cap, plug and receptacle of cord sets, and any equipment connected by cord and plug, except cord sets and receptacles which are fixed and not exposed to damage, shall be visually inspected before each day’s use for external defects, such as deformed or missing pins or insulation damage, and for indications of possible internal damage. Equipment found damaged or defective shall not be used until repaired.”
Even though this clearly states that plugs can be repaired, it does not list the requirements for the replacement parts, which is really what we want to know. Right? However, if we read 1926.403(a) we will see that “All electrical conductors and equipment shall be approved“. So, therefore, if replacement plugs are “approved” then they are allowed. Right? Are you following? So how do we know if a replacement plug is “approved”? Well… let’s keep drilling down. OSHA’s definition of “Approved” is found under 1926.449 and it reads:
- “Approved. Acceptable to the authority enforcing this Subpart. The authority enforcing this Subpart is the Assistant Secretary of Labor for Occupational Safety and Health…”
In other words, approved means anything that is “acceptable” to OSHA. Yes, we do realize this seems ambiguous, but bear with us. Let’s check OSHA’s definition of “acceptable” in 1926.449. It states…
- “Acceptable. An installation or equipment is acceptable to the Assistant Secretary of Labor, and approved within the meaning of this Subpart K… (a) If it is accepted, or certified, or listed, or labeled, or otherwise determined to be safe by a qualified testing laboratory capable of determining the suitability of materials and equipment for installation and use in accordance with this standard…”
So this would imply that any electrical component (including replacement plugs) that are labeled by a qualified testing laboratory (such as Underwriter’s Laboratories) would be accepted and approved by OSHA for repairs. The one other thing to consider is that any repair not made in accordance with a manufacturer’s instructions would not be considered as acceptable, so make sure to follow the instructions.
We hope this brings you some clarity to this issue, but in case you want more information, click here to visit a Letter of Interpretation from 2014 that addresses this exact issue.
