Electrical
AEGCP field guide for temporary power on construction sites
Run a written assured equipment grounding conductor program when GFCI nuisance trips on long temp feeders and big tools make the GFCI path unworkable.
Direct answer
An assured equipment grounding conductor program (AEGCP) is one of two ways OSHA lets you protect workers on temporary 120 V construction receptacle circuits, the other being GFCI protection. Under 29 CFR 1926.404(b)(1), the AEGCP is a written program, run by a competent person, that tests every cord set, temporary receptacle, and cord-and-plug tool for ground continuity and correct termination.
Key takeaways
- OSHA 29 CFR 1926.404(b)(1) requires either GFCI protection or a written AEGCP on temporary 120V receptacles; running neither is a violation.
- An AEGCP requires two tests: ground-conductor continuity (catches open ground) and correct terminal attachment (catches a miswire continuity alone passes).
- Test before first use, before return after repair, after any suspected-damage incident, and at intervals not exceeding 3 months.
- Fixed cord sets and receptacles not exposed to damage may be tested at intervals not exceeding 6 months.
- A plug-in GFCI or three-light tester does NOT satisfy the continuity test; use a low-resistance ohmmeter or continuity tester.
The AEGCP, and the choice OSHA actually gives you
An assured equipment grounding conductor program (AEGCP) is a written program that tests the ground path on every cord set, temporary receptacle, and cord-and-plug tool on a construction site, on a schedule, and keeps a record of what passed. It is the second of two options OSHA allows for protecting workers on temporary power, and it is the one crews choose when ground-fault circuit interrupters cause more trouble than they prevent.
OSHA gives you a binary choice for 120 V, single-phase, 15 and 20 A receptacle outlets that are not part of the permanent wiring. You either put GFCI protection on those outlets, or you run an AEGCP. One or the other. There is no third door where you do neither, and that is the part crews get wrong when a job has no GFCIs and no written program either.
The reason the AEGCP exists is that GFCIs nuisance-trip. On a long temporary feeder, a welder, a concrete saw, or a big pump, the leakage current and inrush can trip a GFCI that is working exactly as designed, and a tripped tool on a deadline is how people start defeating protection. The AEGCP is the path that keeps the ground path verified without the trips, as long as somebody actually runs it.
What does the OSHA rule actually require?
The controlling rule is 29 CFR 1926.404(b)(1), the construction standard for ground-fault protection on temporary wiring. It opens by saying the employer shall use either GFCI protection or an assured equipment grounding conductor program to protect employees, and it spells both out in the subparagraphs that follow.
The GFCI option lives at 1926.404(b)(1)(ii). It applies to all 120 V, single-phase, 15 and 20 A receptacle outlets that are not part of the permanent wiring of the building or structure and are in use by employees. Those outlets get approved GFCIs for personnel protection. The AEGCP option lives at 1926.404(b)(1)(iii), and it is the alternative for employers who do not take the GFCI route.
Read that structure carefully, because the obligation is not optional. The rule does not say protect workers if convenient. It says use one method or the other, full stop. As with all federal OSHA standards, some states run their own OSHA-approved plans that can be at least as strict, so confirm the version your jurisdiction enforces, but the two-path framework is the baseline everywhere.
What has to be in the written program?
The rule names three things the program must have, and an inspector checks for all three. First, a written description of the program, including the specific procedures the employer adopted, available at the jobsite for inspection and copying. Second, one or more competent persons designated to implement it. Third, the required tests, performed and recorded on the schedule the rule sets.
The written description is the part most jobs treat as a formality and then cannot produce. It is not a generic binder downloaded once and forgotten. It has to describe your procedures: who tests, what gets tested, what tester is used, what the pass criteria are, how items are marked, and how failed items are pulled. The standard expects the written program physically available at the jobsite, not in a home-office server nobody on site can reach.
If the paper does not exist, the program does not exist as far as OSHA is concerned, even if a guy is faithfully testing cords every quarter. No written description and no records is the same as no program, and on a site with no GFCIs that is a live exposure, not a paperwork ding.
What are the two required tests?
The AEGCP requires two tests, and they check two different failure modes. The first is a continuity test: all equipment grounding conductors shall be tested for continuity and shall be electrically continuous. The second is a termination test: each receptacle and attachment cap or plug shall be tested for correct attachment of the equipment grounding conductor, and that conductor shall be connected to its proper terminal.
Continuity catches the open ground. A broken strand inside a cord, a backed-out crimp in a plug, a corroded pin, any of it leaves the ground conductor electrically open even though the cord still powers the tool. The tool runs fine and looks fine. Then a fault energizes the frame, the ground has no path back to trip the breaker, and the next person to touch it is the fault path.
The termination test catches the miswire. A plug or receptacle wired with the ground landed on the neutral terminal, or the hot and ground swapped, passes a simple continuity check end to end but is wired wrong in a way that is more dangerous than an open ground. Both tests apply to all cord sets, all receptacles that are not part of the permanent wiring, and all cord-and-plug-connected equipment required to be grounded.
| Test | What it confirms | What a failure means |
|---|---|---|
| Continuity of the equipment grounding conductor | The ground path is electrically continuous end to end | Open ground, broken strand, bad crimp, corroded pin |
| Correct attachment to proper terminal | The ground lands on the ground terminal, not neutral or hot | Miswired plug or receptacle, swapped conductors |
How often do you have to test?
The rule sets four triggers for testing, and the calendar interval is the one people remember and the others are the ones that catch them. Test before first use. Test before equipment is returned to service following any repairs. Test before equipment is used after any incident that can reasonably be suspected to have caused damage, the classic example being a cord set run over by a lift or a truck. And test at intervals not to exceed 3 months.
There is one exception to the 3-month interval. Cord sets and receptacles that are fixed and not exposed to damage are tested at intervals not exceeding 6 months. The word doing the work there is fixed and not exposed. A receptacle bolted in a temp panel inside a locked room is a different risk than a quad on a cart that gets dragged through mud every shift, and the rule treats them differently. Anything that moves, gets stepped on, or lives in the weather is on the 3-month clock.
The incident trigger is the one that keeps you honest day to day. A cord that gets run over goes out of service and gets retested before it goes back, color or no color. The quarterly cycle does not buy you a pass on a cord that took visible damage yesterday.
| Trigger | Interval |
|---|---|
| Before first use | Every item, before it goes into service |
| Before return to service after repair | Each repaired item |
| After any incident suspected of causing damage | That item, before reuse |
| Periodic, movable or exposed items | Not to exceed 3 months |
| Periodic, fixed and not exposed to damage | Not to exceed 6 months |
The color-code marking system
The color code is how a crew sees at a glance that a cord or tool is current without pulling the test record. After an item passes, the tester wraps a band of colored tape near the plug, and the color says which test period it passed in. Walk the site, see this quarter's color, and you know that cord was tested. See last quarter's color or no color, and it is due or unverified.
OSHA does not mandate which colors you use. The standard requires the tests and the record. The color tape is an accepted, common industry method for tracking and showing currency, not a separate legal requirement, so the colors are the employer's choice as long as the written program defines them. What matters is that the scheme is written down and everyone on site reads it the same way.
A common rotation runs by season so nobody has to memorize a table: white for winter, green for spring, red for summer, orange for fall, then it repeats. Whatever you pick, put the legend in the written program and post it at the test station. The failure mode here is two crews on the same site using different colors, or a color carried over from a previous job, so a band that means tested to one person means expired to another.
| Period | Common color (example only) |
|---|---|
| 1st quarter, winter | White |
| 2nd quarter, spring | Green |
| 3rd quarter, summer | Red |
| 4th quarter, fall | Orange |
How do you run the continuity test?
Continuity is a resistance check on the ground conductor from one end to the other. For a cord set, you read from the ground pin of the male plug to the ground hole of the female end, with the cord disconnected and dead. A low-resistance ohmmeter or a continuity tester reads near zero ohms on a good conductor. An open or a high reading means the ground is broken somewhere in the cord or a termination.
Flex the cord while you read it, especially at the strain reliefs right behind both plugs. That is where the strands fatigue and break, and a cord that reads continuous lying still can read open the moment you bend it where it actually flexes in service. A static reading misses the intermittent open that bites someone holding the tool.
For a tool, you read from the ground pin of the plug to a bare metal point on the frame or housing, again near zero ohms. For a temporary receptacle that is not part of the permanent wiring, you verify the ground path back to its source. Whatever the item, the question is the same: is the ground electrically continuous, and does it stay continuous when the thing moves the way it moves on the job.
A plug-in GFCI tester does not test continuity
This is the trap, and OSHA has addressed it directly: a plug-in GFCI tester or receptacle tester is not a substitute for the continuity test the AEGCP requires. Those three-light testers and GFCI trip-button testers tell you a receptacle is roughly wired and that a GFCI trips. They do not measure the resistance of the ground conductor, and they do not prove the ground is continuous all the way back.
The continuity test needs an instrument that actually reads the ground path: a low-resistance ohmmeter or a dedicated continuity tester. Run the AEGCP on a three-light tester and you have documented nothing the rule asks for, even though the paperwork looks done.
There is a deeper point here. The AEGCP is the path you took because you did not want to rely on GFCIs, so using a GFCI tester to run it is circular. Test the conductor with a conductor tester.
The correct-termination test
The termination test confirms the equipment grounding conductor lands on its proper terminal at receptacles and at attachment caps and plugs. It is the check that the device is wired right, not just that the ground wire is whole. A continuity test alone will pass a plug where the ground and neutral are swapped, because the ground pin still connects to something continuous. That something is the wrong conductor.
On a plug or a receptacle you confirm the ground conductor is on the ground terminal, the grounded conductor on the neutral terminal, and the ungrounded conductor on the hot. A miswired ground on the neutral terminal is the dangerous one. Under a fault it can put the neutral current on the equipment frame or leave the frame energized, and it will not read as an open ground on a simple end-to-end check.
The new guys assemble pigtails and replacement plugs fast and land the green wire by feel. Confirm the landing on every assembled or repaired end before it goes back in service. The termination test is cheap. The reversed ground it catches is the kind of error that hides until somebody is the path to ground.
The competent person role
The rule requires the employer to designate one or more competent persons to implement the program. Competent person is a defined term in the OSHA construction standards, at 1926.32(f): someone capable of identifying existing and predictable hazards in the work and who has authorization to take prompt corrective measures to eliminate them. The authority half is the half jobs forget.
On the AEGCP that means the competent person can pull a cord out of service on the spot and make it stick, not file a request and hope. They own the testing, the marking, the records, and the call on what is too damaged to repair. If the person doing the testing cannot tag a failed tool out and have it stay tagged out, they are a tester, not a competent person, and the program has a hole in it.
On a large build you usually name more than one, by area or by shift, so coverage does not collapse when the named person is off site. Put their names in the written program and keep it current as crews turn over. An inspector can ask who the competent person is, and the right answer is a name, not a shrug.
GFCI vs AEGCP: when does each make sense?
GFCI protection wins on most jobs and it is the default for a reason. It is automatic, it does not depend on anyone remembering to test, and it protects against faults the AEGCP never sees, because a GFCI trips on the leakage current of an actual fault while the AEGCP only proves the ground path was intact the last time someone checked. For ordinary 120 V hand tools and site receptacles, GFCI is simpler and safer to administer.
The AEGCP earns its place where GFCIs trip on loads that are not faults. Long temporary feeders build up enough capacitive leakage to trip a GFCI with nothing wrong. Welders, large pumps, concrete saws, and motor loads with real inrush trip GFCIs on starting current. On a data center build the temp power runs are long, the tools are big, and the schedule is unforgiving, which is exactly the mix where a poorly chosen GFCI plan turns into defeated devices and bypassed protection.
The honest read is that a lot of large sites run both: GFCI on the general-use 120 V receptacles where it works, and a written AEGCP covering the high-draw and long-feeder equipment where GFCI nuisance trips would otherwise get the protection defeated. What you cannot do is run neither. Picking the AEGCP because GFCIs are inconvenient and then not actually running the program is worse than the trips you were avoiding.
| Situation | Better fit |
|---|---|
| General-use 120 V hand tools and site quads | GFCI |
| Long temporary feeders with capacitive leakage | AEGCP |
| Welders, large pumps, motor inrush loads | AEGCP |
| No one available to run and record a program | GFCI |
| Need protection against an actual ground fault | GFCI (AEGCP only verifies the path) |
Cord sets and the daily visual check
The quarterly test is the floor, not the whole job. Cords get damaged between tests, and the damage is usually visible before it is electrical. A current color band on a cord does not mean the cord is safe today. It means it passed three months ago. The daily look is what covers the gap.
Before use, the person grabbing the cord checks it: cuts and abrasion through the jacket, exposed conductors, cracked or melted insulation, pulled-out strain reliefs, bent or missing ground pins, painted-over or taped-over plugs hiding a repair, and the heat-and-pull damage at the male end where cords get yanked out by the cord instead of the plug. Any of that pulls the cord, full stop, regardless of color.
Two specifics worth calling out. A missing ground pin is not a damaged cord to be retested later, it is an immediately-out item, because the ground is gone by inspection. And a cord that got run over goes out under the incident trigger even if the jacket looks fine, because the strands inside can be broken where you cannot see them. Test it before it goes back, do not assume.
Tagging and removing failed items from service
A failed item has to leave service in a way that survives the next person who wants to use it. That means a physical tag and physical removal, not a note in a logbook. The fastest way to undo a good program is to find a bad cord, set it aside, and watch someone pick it up an hour later because nothing on the cord said stop.
Tag the failed item, cut or remove the plug if the call is to scrap it, and get it out of the active bins and gang boxes. If it is repairable, it goes to repair and does not come back until it is fixed and retested, which is the before-return-to-service trigger, not the next quarterly cycle. The competent person makes the repair-or-scrap call and has the authority to enforce it.
Removing a failed item from service is the whole point of testing. Finding the open ground and leaving the cord in the pile is worse than not testing, because now there is a record that the problem was found and the tool stayed in play. That is the documentation working against you.
The record an inspector asks for
The record is what proves the program ran. The rule requires that tests be recorded, and that the record identify each receptacle, cord set, and cord-and-plug-connected equipment that passed, and indicate the last date it was tested or the interval for which it was tested. That record, plus the written program, is exactly what an OSHA inspector asks to see on a site with no GFCIs.
What an inspector is checking is simple and brutal. Is there a written program on site. Is a competent person named. Is there a test record. Does the record match what is actually in service, meaning the cords and tools in the boxes carry current color and appear in the record. A site running an AEGCP with no paper trail is treated as a site with no protection method at all, because the alternative method, GFCI, is not there either.
Keep the record where the work is. The written program and the test record both have to be available at the jobsite for inspection and copying. A clean record in an office two states away does not help the foreman standing in front of a compliance officer.
Temporary power on a data center build
Large data center and industrial builds are where the AEGCP earns its keep, because the temporary power system is itself a major installation. Temp feeders run hundreds of feet across a slab the size of several football fields, spider boxes and temp panels feed hundreds of tools across multiple trades, and the loads include welders, core drills, and large pumps that trip GFCIs on inrush. The scale is what makes a tracked, recorded program the workable path.
The temporary installation also lives under the NEC. NFPA 70 Article 590 covers temporary installations, including how temporary feeders, panels, and receptacles are built and protected, and it carries its own GFCI provisions for temporary wiring. Article 250 governs grounding and bonding for the system as a whole. The AEGCP under OSHA is the personnel-protection program layered on top of an installation that has to be built to the NEC in the first place. They are not the same requirement and meeting one does not meet the other.
On a job this size the program is a logistics problem as much as a safety one. You are tracking thousands of cord ends across trades you do not employ, on a schedule that does not pause for testing. That is why the marking system and a clean record matter more here than anywhere: a foreman has to clear a tool by color in seconds, and the competent person has to find the one cord that is overdue among thousands.
What to document
The record has to tie each item to a test, a date, a result, and a tester, so a reviewer can confirm the program ran and so an overdue item can be found. Identify the item uniquely, because a record that says cord passed without saying which cord proves nothing. Capture the type, the test date, who tested it, the result, and the color period it was marked with.
Keep the written program in the same place, with the competent person named, the test procedure described, the tester listed, the pass criteria stated, and the color legend defined. The two together, the program and the running record, are the document set. One without the other does not satisfy the rule.
| Field to record | Why it matters |
|---|---|
| Item ID (unique tag or number) | Ties the test to a specific cord, receptacle, or tool |
| Type (cord set, receptacle, tool) | Sets which tests and which interval apply |
| Test date | Proves currency against the 3 or 6 month interval |
| Tester (name) | Ties the result to the competent person or designee |
| Result (pass or removed) | Pass goes back in service, fail comes out |
| Color period applied | Lets the field verify currency at a glance |
| Trigger (periodic, repair, incident, first use) | Shows why the test was run |
Common mistakes
- Running no GFCIs and no written AEGCP either, treating the program as optional when it is one of two required paths.
- No written program on site, or a generic binder that does not describe your actual procedures, names, and color legend.
- No test record, or a record that does not identify each item and its last test date.
- Using a three-light or GFCI plug-in tester to satisfy the continuity test, which it does not measure.
- Leaving a failed or expired-color item in the active bins instead of tagging it and pulling it.
- Carrying a color scheme over from a previous job, or two crews on one site using different colors.
- Skipping the incident retest on a cord that was run over because the jacket still looks intact.
- Naming a tester who has no authority to pull a tool out of service and make it stick.
Field checklist
Want this checklist to run itself on every job — with photo proof and a signed record crews can hand the customer? That's FieldOS.
Standards and references
The controlling rule is OSHA 29 CFR 1926.404(b)(1), which sets the two-path requirement, GFCI protection at (b)(1)(ii) or an AEGCP at (b)(1)(iii), and spells out the program contents, the two tests, the test triggers and intervals, and the recordkeeping. The competent-person definition the program relies on is at 1926.32(f). Confirm whether your jurisdiction is under federal OSHA or a state plan, since state plans can be at least as strict.
The temporary electrical installation itself is built to the NEC, NFPA 70. Article 590 covers temporary installations, including temporary feeders, panels, lighting, and receptacles, and it carries GFCI and grounding provisions for temporary wiring that exist independently of the OSHA program. Article 250 governs grounding and bonding for the system. NECA temporary power practices give installation guidance that fills in how the temp system is actually built and maintained.
The color-code marking system is common industry practice for showing test currency, not an OSHA-specified color set, so the colors are the employer's choice as long as the written program defines them. Manufacturer instructions and the equipment listing govern the tools and cords themselves. Cite the rule that controls the point: OSHA for the personnel-protection program, the NEC for how the temporary installation is built, and the adopted edition and local amendments control where they apply.
Units, terms, and abbreviations
The program goes by a few names and acronyms across specs, written programs, and toolbox talks, so the same idea reads differently from one document to the next.
An assured equipment grounding conductor program is abbreviated AEGCP and is sometimes called an assured grounding program or a non-permanent electrical inspection program. The equipment grounding conductor is the EGC. Ground-fault circuit interrupter protection is GFCI, sometimes written GFI on older equipment. Continuity is read in ohms, near zero on a sound ground conductor, with a low-resistance ohmmeter or a continuity tester. Test intervals are expressed in months: 3 months for movable or exposed items, 6 months for fixed items not exposed to damage.
- AEGCP
- Assured equipment grounding conductor program, the written OSHA program that tests and records the ground path on temporary power equipment
- EGC
- Equipment grounding conductor, the ground path that carries fault current back to trip the breaker
- GFCI / GFI
- Ground-fault circuit interrupter, the alternative protection method that trips on fault leakage current
- Competent person
- Per OSHA 1926.32(f), someone able to identify hazards and authorized to take prompt corrective action, including removing items from service
- Continuity
- An electrically continuous path, confirmed as near-zero ohms end to end with a low-resistance ohmmeter or continuity tester
- Cord set
- An extension cord or flexible cord assembly with attachment plug and connector, a primary item the program tests
FAQ
What is an assured equipment grounding conductor program (AEGCP)?
An AEGCP is a written OSHA program for temporary power that tests every cord set, temporary receptacle, and cord-and-plug tool for ground continuity and correct termination, on a set schedule, and records the results. Under 29 CFR 1926.404(b)(1) it is one of two ways to protect workers, the other being GFCI protection.
GFCI or AEGCP: which should I use on temporary power?
GFCI is the simpler default and protects against actual ground faults automatically. Choose an AEGCP where GFCIs nuisance-trip, on long temporary feeders, welders, and high-inrush tools. Many large sites run both: GFCI on general-use receptacles, a written AEGCP on the high-draw equipment. You must run one method or the other, never neither.
How often do I have to test under an AEGCP?
Test before first use, before returning equipment to service after repair, after any incident reasonably suspected of causing damage such as a cord run over, and at intervals not exceeding 3 months. Cord sets and receptacles that are fixed and not exposed to damage are tested at intervals not exceeding 6 months.
What are the two tests an AEGCP requires?
First, a continuity test: every equipment grounding conductor must be electrically continuous end to end. Second, a termination test: each receptacle and plug must have the ground conductor connected to its proper terminal. Continuity catches an open ground; the termination test catches a miswire that continuity alone would pass. Both apply to all temporary cords, receptacles, and tools.
What colors do I use to mark tested cords?
OSHA does not mandate specific colors. The standard requires the tests and the record; colored tape is a common industry method for showing currency. Pick a scheme, define it in your written program, and post it. A common seasonal rotation is white for winter, green for spring, red for summer, orange for fall.
What do I do if a cord fails the test?
Tag it and remove it from service immediately so no one picks it up again. Scrap it or send it to repair; a repaired cord is retested before it returns, under the before-return-to-service trigger, not at the next quarterly cycle. The competent person makes the repair-or-scrap call and has authority to enforce removal.
Can a plug-in GFCI tester satisfy the continuity test?
No. A three-light receptacle tester or plug-in GFCI tester does not measure the resistance of the ground conductor, so it cannot prove continuity, and OSHA has stated a GFCI is not a substitute for the continuity test. Use a low-resistance ohmmeter or a dedicated continuity tester to read the ground path.
Who has to run the AEGCP?
The employer designates one or more competent persons to implement the program. Per OSHA 1926.32(f), a competent person can identify the hazards and is authorized to take prompt corrective action, which here means pulling a failed tool out of service and making it stick. A tester without that authority does not satisfy the role.
What does an OSHA inspector ask for on an AEGCP site?
The written program available on site, a named competent person, and the test record identifying each cord set, receptacle, and cord-and-plug tool that passed with its last test date. The inspector checks that the record matches what is actually in service. No paper trail is treated as no protection method, since GFCIs are absent too.
Does an AEGCP replace the NEC requirements for temporary power?
No. The AEGCP is an OSHA personnel-protection program under 1926.404(b)(1). The temporary installation itself is built to the NEC, NFPA 70 Article 590 for temporary installations and Article 250 for grounding and bonding. Meeting one does not meet the other; the temp system must be built to code and the program run on top of it.
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Codes cited in this guide
This guide is written and reviewed against the published standards below. Always confirm the current adopted edition with the authority having jurisdiction.