DIVISION
MEMORANDUM
MIOSHA
General Industry Safety and Health Division
Michigan Occupational Safety and Health Administration
Department of Licensing and Regulatory Affairs
DOCUMENT IDENTIFIER:
DATE:
GISHD-MEMO-COM-14-1
February 4, 2014
SUBJECT: Part 39, Design Safety Standards for Electrical Systems, and Part 40,
Electrical Safety-Related Work Practices – Classification and Severity of Citations
I.
Purpose:
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Scope:
III.
References:
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Distribution:
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VI.
Contact:
Originator:
To establish consistent classification and severity of citations for
violations involving exposed live parts under either Parts 39 or 40.
This instruction applies to General Industry Safety and Health
Division (GISHD) staff.
A. General Industry Safety Standard Part 39. /R408.13901 et seq.,
Design Safety Standards for Electrical Systems.
B. General Industry Safety Standard Part 40./R408.14001 et seq.,
Electrical Safety-Related Work Practices.
MIOSHA Staff; OSHA Lansing Area Office; General; S-drive
Accessible; MIOSHA Weekly; and Internet Accessible.
Elaine Clapp, Safety and Health Manager
/Adrian Z. Rocskay/____________
Adrian Z. Rocskay, Division Director
General Industry Safety and Health Division
When citing a violation of any rule in Part 39, Design Safety Standards for Electrical Systems, or
Part 40, Electrical-Safety Related Work Practices, if there are exposed live parts to which there is
potential employee contact, all violations will be classified as Serious. The severity will be
classified as high if electrical shock is listed as a hazard or an employee has the potential for
contact with an exposed live part. Severity does not affect the assessment of probability, which
may be lesser or greater depending on each situation. If an employee injury has occurred, the
probability will be classified as greater. The probability can be classified as greater even if there
has been no employee injury (for example, the employee is in close proximity to exposed live
parts on a regular basis).
When there are no exposed live parts and there is no potential employee exposure to electrical
shock, violations of Parts 39 and 40 will normally be classified as other-than-serious.
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