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#147546 - 12/07/02 01:20 PM OSHA's view on working live and your responsibility (liability) as a contractor.
OSHA Professor Offline
Member

Registered: 12/06/02
Posts: 50
Loc: Chicago
Lot's of people are confused as to what OSHA requires or how OSHA interprets regulations. Want to know what OSHA says?
Who decides when and how to work live? OSHA (actually the courts/legal system) has decided that question! Is the electrician responsible or the contractor? Does interrupting production qualify to wok live in OSHA eyes? What constitutes working live?
Could you be cited by OSHA? Under what circumstances?
OSHA senior electrical professor at OSHA's National Training Institute answers these questions and more in a short article which can be viewed at: http://www.oshazone.com/forums/showthread.php?s=4a66b9a20dbf2de6e5dac39af09d8ba7&threadid=7

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Arc Flash PPE Clothing, LOTO & Insulated Tools
#147547 - 12/07/02 01:40 PM Re: OSHA's view on working live and your responsibility (liability) as a contractor.
Scotts Offline
Member

Registered: 01/17/02
Posts: 224
Loc: Ventura, CA, USA
I have not looked at the link, but I must add that first of all you need to check if you are in a state with it's own OSHA program. These states are required to have laws as effective as the OSHA standard. However they can be stricter. For instance Cal/OSHA does not have Lockout/Tagout, they have Lockout/Blockout. It is much different from the fed OSHA standard. You cannot just tagout a machine, also the cord under the control of one person does not apply in California.
Scott

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#147548 - 12/07/02 02:16 PM Re: OSHA's view on working live and your responsibility (liability) as a contractor.
sparky Offline
Member

Registered: 10/18/00
Posts: 5545
A good 'no bull' thread OSHA Professor, i like that.

For many here, you may be our only opportunity to converse with 'da man', so please stick around

~sparky

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#147549 - 12/07/02 02:33 PM Re: OSHA's view on working live and your responsibility (liability) as a contractor.
OSHA Professor Offline
Member

Registered: 12/06/02
Posts: 50
Loc: Chicago
Scott, you're absolutely right about state plan OSHA programs. As you pointed out they have to be at least as effective as Fed OSHA. The bottom line is that the hazards need to be controlled. Everyone needs to check to see if their State has more specific requirements above and beyond Fed OSHA. Like we teach, OSHA Standards are MINIMUM Standards for safety!

Sparky, Thanks for the vote of support. Like I tell all my students which include OSHA investigators, State plan investigators, State plan consultation inspectors, Other federal agencies, private sector and lots more-----I tell it like it is - no BS here. You may not like what you hear but its fact. Don't shoot the messenger.
For a Federal employee I'm not always perfectly politically correct but after all I'm in the business of saving lives not running for political office. I have an extremely demanding schedule traveling training (60 to 80% of the time on the road) and helping our OSHA investigators with particularly complex fatality or catastrophy investigations but I'll stick around and check in when I can, I think that my e-mail is also available for people to write me directly as well.
Anyway Thank you.
OSHA Professor "Grizzy"

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#147550 - 12/07/02 02:54 PM Re: OSHA's view on working live and your responsibility (liability) as a contractor.
Joe Tedesco Offline
Member

Registered: 10/07/00
Posts: 3325
Loc: Boston, Massachusetts USA
http://electrical-contractor.net/ubb/Forum4/HTML/000182.html

WARNING!! ELECTRICAL BURN IMAGES HERE!!



[This message has been edited by Joe Tedesco (edited 12-08-2002).]
_________________________
Joe Tedesco, NEC Consultant

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#147551 - 12/07/02 03:54 PM Re: OSHA's view on working live and your responsibility (liability) as a contractor.
Scotts Offline
Member

Registered: 01/17/02
Posts: 224
Loc: Ventura, CA, USA
True enough. Your article is too the point. As the safety guy at work I always stress that we (the company) can do all that we can but you (the employee) have to think safety at all times. After all we will be dinged with an incident, however you will be the one hurt. No one should go home hurt from work, maybe tired from working so hard, but not hurt.

Everytime I tell them that my goal is to go an entire year without an accident they usually laugh and say it cannot be done. I then tell them that it can and if anyone is planning on getting hurt at work to come talk to me.

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#147552 - 12/07/02 05:54 PM Re: OSHA's view on working live and your responsibility (liability) as a contractor.
sparky66wv Offline
Member

Registered: 11/17/00
Posts: 2339
Loc: West Virginia
Welcome to ECN, OSHA Professor!

We look forward to your input and hope to have some questions answered. We hope you'll have the time!

You won't be treated like "the enemy" or an outsider, most of us here are interested in safety and are very glad an "OSHA Rep" has come aboard.

Hope you like us!

_________________________
-Virgil
Residential/Commercial Inspector
5 Star Inspections
Member IAEI

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#147553 - 12/07/02 05:54 PM Re: OSHA's view on working live and your responsibility (liability) as a contractor.
OSHA Professor Offline
Member

Registered: 12/06/02
Posts: 50
Loc: Chicago
Joe,

Let me begin with your post script. Do you have me confused with oshaman ? I’m OSHA Professor. You and I have never had any discussion regarding same. Perhaps the book you are referring to is “An Illustrated Guide to Electrical Safety” Fourth Edition, published by ASSE and edited by Thomas M. Kovacic.

You’re question “How does the revised 2002 NEC definition of "Qualified Person" sit with OSHA? “ I’m not sure with what you mean by “sit with OSHA” . Let me say that OSHA has no opinion whatsoever regarding the definition change in the 2002 NEC. Does this change, in any way impact OSHA or affect our enforcement in any way? No! I’ve seen all the endless discussions regarding this change on some board back when the 2002 NEC was published and I won’t go into all those pros and cons which you are aware.

From an OSHA perspective it is of no consequence for numerous reasons which I will elaborate on. First of all as a professional who trains electrical inspectors you are aware that AHJ’s can’t cite definitions. OSHA can’t cite definitions. We use them to clarify the requirements of standards (regulations). OSHA already defines qualified person in 1910.399 and it’s the same as NFPA 70-1999 (1999 NEC). Our definition has been there since we promulgated the electrical safety related work practices standard and even earlier in our construction standards. Legally we can’t go to a consensus organizations definition if we already defined the term. As a side note we can’t use a consensus organizations standard such as the NEC (using our 5 (a) (1) general duty clause if we (OSHA) already has a specific standard which addresses the hazard. OSHA always has to use / cite the most vertical (specific) standard. This is despite the fact the NEC may be more restrictive.

Now having said all that, does OSHA think training is important ? Absolutely ! So much so that OSHA has specific standards (have had for years) that require training. You are familiar with the OSHA web site at www.osha.gov Check out 1926.21 (b) (2) in the construction standards. This requires all employees to be trained to recognize and avoid hazards they are likely to encounter on a construction site (I’m paraphrasing it off the top of my head), 1910.332 is training under the electrical safety related work practice standard in the OSHA general industry standards. This also requires training for both qualified as well as unqualified electrical workers. These specific training requirements for qualified workers goes well beyond the current definition for qualified in the 2002 NEC.
Again, OSHA must use the most vertical standards even when using consensus organization standards. The NEC is not the place we would use to reference electrical work practices, because it isn’t a work practice standard it is more appropriately characterized or categorized as an installation specification standard.

There are four primary types or categories of electrical standards for safety. The first category deals with how do we install electrical equipment, devices, etc so its safe or more specifically the premises wiring system introduces no hazards? We go to the NEC and OSHA installation specification standards 1910.301 - .308 for that information. However is it possible to install a device or equipment according to these installation specification standards and still have an unsafe or hazardous condition ? Yes if someone made the equipment or device in their garage. Enter the second category of standards. Standards that insure that any product is manufactured to do it’s intended function safely such as U.L. standards or product listing. OSHA has an NRTL (Nationally Recognized Testing Laboratory) program and requires all electrical equipment in the workplace to be listed or labeled by an OSHA NRTL. OSHA NRTL’s include U.L., FM, CSA, ETL and others. OSHA Standards 1910.303(a) & .303 (b) (1) i & 1926.401(a)& (b,).
Since it’s possible to install safely and have a listed piece of equipment and still introduce hazards such as brewing gasoline through an electric coffee maker or misuse relocatable power taps (LOL) enter the third category of standards. Installation and use OSHA 1910.303(b)(2), 1926.403(b)(2), NEC Article 110.3 These all state that listed and labeled equipment shall be used in accordance with any instructions included in the listing and labeling.
Finally the last category is for when we work on or near electrical installations and equipment, the electrical safety related work practices standards, OSHA 1910.331-.335 and NFPA 70 E. These are the two standards that OSHA would use for qualified worker training requirements and actual work practices including some PPE requirements.

I do recognize that there is some overlap in these standards categories such as Article 110.2 , 110.3b and some other overlap. Remember, I’m categorizing generally.

The final point I’d like to make is that the NFPA 70 E “Standard for Electrical Safety Requirements for Employee Workplaces” contains both safe work practices in it’s part II, and also contains installation specification standards from the NEC in it’s part I. This has been a valuable tool for OSHA because in the past, lawyers have submitted the argument that since the NEC has it’s roots in 1897 hazards considerations which are primarily for property protection it is not directly nor was it intended when adopted to address people protection. Since NFPA 70 E has taken all the installation specification standards that pertain to people protection and included them in 70 E Part I, it solves lots of enforcement issues. Lastly since OSHA construction standards in the 1926 have very little for electrical safety related work practices (found in 1926.416) OSHA has the option to use NFPA 70 E on any electrically related construction activities. Such as qualified person either testing or racking in or out breakers on a 120/240v panel which is a hazard addressed in 70 E. I wonder how many qualified persons de-energize the panel to do that or are wearing insulated gloves, FR clothing, face shield and have insulated (not wrapped with electrical tape but real insulated) tools.

Try not to ask such a lengthy or detailed question next time Joe. Thanks to everyone for allowing me this forum. Thus endith the OSHA lesson.

OSHA Professor - Grizzy

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#147554 - 12/07/02 06:25 PM Re: OSHA's view on working live and your responsibility (liability) as a contractor.
sparky66wv Offline
Member

Registered: 11/17/00
Posts: 2339
Loc: West Virginia
After reading the linked article:

Wow...

My helper Jimmy will be trained far differently than I was!!!!

Yikes... (Pardon my ignorance) I'm one of those that owns a hardhat, perscription safety glasses, steel-toed boots and steel-toed mud boots, and that's about it. I've got "rubber gloves" that aren't listed for anything, but I only use them in thngs like ground fault conditions while troubleshooting.

Otherwise, I have no other PPE and only a few cheap 1000V screwdrivers.

I guess I have to get 1000V torque wrenches and a 1000V torque screwdriver too?!?!? Do they even make one?!?!


*slowly breathe in... slowly breathe out...*



[This message has been edited by sparky66wv (edited 12-07-2002).]
_________________________
-Virgil
Residential/Commercial Inspector
5 Star Inspections
Member IAEI

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#147555 - 12/07/02 08:35 PM Re: OSHA's view on working live and your responsibility (liability) as a contractor.
OSHA Professor Offline
Member

Registered: 12/06/02
Posts: 50
Loc: Chicago
sparky66wv,

Don't panic buddy ! It's OK.
Your PPE and insulated tools are important. There are suppliers of insulated hand tools out there. Search the net for insulated hand tools. I'm a little partial to cementex insulated hand tools because they have a double layer of insulation consisting of two different colors. When the inner color begins to show through and becomes visible it's time to replace the tool. There are socket wrenches and all kinds of tools available. There is also a line of tools which are insulating and meet the ASTM (American Society of Testing Materials) standard for insulated tools. Just when you thought you were getting a handle on all these standards some new ones show up. The composite tools except for the screwdriver tip for example the rest of the shaft is a nonmetallic composite material. No insulation to wear out. They are super light in weight. About 1/4 the weight of other tools. Imagine carrying a tool belt around that only 1/4 of the weight of your present load. I've actually had electricians in class tell me they don't like those tools at all because they say when they strike the tool with a hammer the tool breaks. I generally tell them that I don't like fluke meters for the same reason. As soon as you hit them with a hammer they break. Certainly a sign of a poor product (LOL). Just be sure that any insulated / insulating tools you acquire meet the ASTM - 1505 standard. BTW all hand tools are rated for 1000 volts. Not like gloves where you can get them at different voltages.
Gloves as well as other insulating PPE or "cover up" can be purchased in 6 different voltage classes from 500 volts (the newest ASTM category) through 40Kv. Don't get way more than you need for your work because the discomfort of wearing extra heavy gloves will limit dexterity and discourage you from wearing them when needed. Also they have to be worn with the leather protectors. If you think, like I do that the class 00 (500 volt gloves) are a little on the flimsy side for 480 work certainly don't go beyond the next class (0) 1Kv glove. BTW gloves can be purchased with a two color construction different inner color than the outer color. That's an option that makes it easier to inspect for damage / wear etc. All the OSHA requirements for insulated PPE are at: http://osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9787&p_text_version=FALSE

They have to be "proof tested every 6 months to insure that they will still withstand the voltage they are rated for. There are companies that do this testing for anywhere between about $5 and $20 per pair of gloves and certify that they were tested to the ASTM standards. The glove is then either stamped with the test date on the cuff or the date due for testing (6 months). What is the last test date on your gloves?

Your life rests in the integrity of your gloves so don't loan them, don't abuse them.

They have to be daily inspected before use which includes an air inflation test to be sure there are no pin holes etc. Also the daily inspection must include examining for : (excerpts of the OSHA Standard)
1910.137(b)(2)(ii)
Insulating equipment shall be inspected for damage before each day's use and immediately following any incident that can reasonably be suspected of having caused damage. Insulating gloves shall be given an air test, along with the inspection.

1910.137(b)(2)(iii)
Insulating equipment with any of the following defects may not be used:

1910.137(b)(2)(iii)(A)
A hole, tear, puncture, or cut;

1910.137(b)(2)(iii)(B)
Ozone cutting or ozone checking (the cutting action produced by ozone on rubber under mechanical stress into a series of interlacing cracks);

1910.137(b)(2)(iii)(C)
An embedded foreign object;

1910.137(b)(2)(iii)(D)
Any of the following texture changes: swelling, softening, hardening, or becoming sticky or inelastic.

1910.137(b)(2)(iii)(E)
Any other defect that damages the insulating properties.
..1910.137(b)(2)(iv)
1910.137(b)(2)(iv)
Insulating equipment found to have other defects that might affect its insulating properties shall be removed from service and returned for testing under paragraphs (b)(2)(viii) and (b)(2)(ix) of this section.

1910.137(b)(2)(v)
Insulating equipment shall be cleaned as needed to remove foreign substances.

1910.137(b)(2)(vi)
Insulating equipment shall be stored in such a location and in such a manner as to protect it from light, temperature extremes, excessive humidity, ozone, and other injurious substances and conditions.

It looks like a lot of regulations but its pretty basic. Proof test twice a year and do the daily (when you use the gloves) inflation test and visually inspect for the defects listed in the standard.
As an OSHA investigator, I don't recall having interviewed an electrician yet who is aware of these requirements. As an OSHA Professor / trainer I'm trying to change that.

If you take a deep breath it should be because you are glad that your gloves and tools have protected you so long without having received the TLC that they need.

OSHA Professor - Grizzy

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