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#150282 - 01/18/05 11:15 AM Safety related work practices... OSHA... 70E what do I follow?
safetygem Offline
Member

Registered: 01/30/02
Posts: 114
Loc: Ohio, USA
I decided to start this new thread to discuss some of the issues brought up in another thread in this forum: http://electrical-contractor.net/ubb/Forum16/HTML/000180.html

mxslick, you provided some excellent tips in that previous thread.
 Quote:
tips:

1: Always wear PPE when working on anything over 100 volts;
2: NEVER stand directly in front of any breaker/disconnect/fuse pull block when opening or reclosing (and that includes breakers in resi panels!);
3: LOOK AWAY when doing any of the items in #2, so if it arcs you stand lesser chance of eye damage;
4: NEVER pull/install meters without PPE, especially NEVER pull meters to cut power on a faulted system;
5: Most importantly, stay alert and DON'T rush when working live. Despite the pressure to finish/restore power, the extra time it takes to do it safely is a helluva lot less than the time to deal with an injury or equipment damage from rushing.


However, along with captal, I would like to expand on one of your tips and propose the following:
Tip #1. Always use appropriate safe work practices and PPE when you are working on any energized circuit. [ref. NFPA 70E Part II 2-1.1]

All energized circuits present a risk of either direct injuries (electrocution, shock, burns) or indirect injuries (falls). Therefore, you must use appropriate methods to control the hazard.

captal, I agree, everyone should read 70E and develop an electrical safety program. I just wanted to clarify one of your statements...
 Quote:
…wearing gloves above 50 volts is an OSHA requirement. It applies to everyone. OSHA has adopted the new NFPA 70E as a standard and will use it for citing violations.


I assume that you mean that OSHA has adopted 70E-2004. Although I wish it was true, this is unfortunately incorrect.

The current OSHA regulations [29 CFR 1910.301-308] are based on the original version of 70E from 1979, which did not include Part II Safety Related Work Practices. In the early 1990's, OSHA added several sections to its electrical regulations that address a few safety related work practices [1910.331-335], but, they did not incorporate or adopt all of 70E Part II, nor have they included many of the other revisions to 70E that have happened since 1979. Technically, OSHA does not enforce 70E or other "consensus" standards. Compliance officers can use consensus standards as "evidence that a hazard is "recognized" and that there is a feasible means of correcting such a hazard." The OSHA standard that requires the employer to identify electrical hazards and provide PPE is 1910.335(a)(2):
 Quote:
1910.335(a)(1)(i)
Employees working in areas where there are potential electrical hazards shall be provided with, and shall use, electrical protective equipment that is appropriate for the specific parts of the body to be protected and for the work to be performed.


OSHA regularly issues "Letters of Interpretation" and "Directives" that clarify or provide additional insight into their enforcement strategy. One of the more current letters addressing the use of 70E is from 2003 and can be viewed on their website: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=246 17

Neither the OSHA regulations, nor NFPA 70E specify a particular voltage when PPE must be provided and used by employees. Everything depends on an assessment and whether or not other appropriate means exist to protect employees (e.g., denergizing or guarding).

One of the more frustrating things that I find as a safety and health inspector is the level of electrical safety knowledge in the workplace. There are far too many unqualified people performing electrical work and too many people that do not understand the fundamentals of electrical safety.

OSHA has a standard that I use frequently, to ensure that employers understand their obligation to provide training:
 Quote:
1910.332(b)(1)
Employees shall be trained in and familiar with the safety-related work practices required by 1910.331 through 1910.335 that pertain to their respective job assignments.


I explain to employers that this requirement applies to both “qualified” people AND “unqualified” people. Every one needs a fundamental understanding of electrical safety and the hazards present in the workplace.

If everyone was more educated, Joe would have fewer pictures to post in the Violation Photo Forum.

That would be (as Martha Stewart might say) a "good thing."

I hope this wasn't too long winded. It's time for me to get off of my soapbox and let everyone else contribute to the discussion.

Edited to correct UBB Code error.

[This message has been edited by safetygem (edited 01-18-2005).]

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#150283 - 01/19/05 06:16 PM Re: Safety related work practices... OSHA... 70E what do I follow?
capt al Offline
Member

Registered: 06/20/04
Posts: 203
Loc: Norton, Ma USA
safetygem, you are right about 70E 2004 I used the wrong word "adopted" it should have been "recognized". Federal OSHA recognizes NFPA 70E 2004. The last adoption of NFPA 70 was [29 CFR 1926.402(a)] 1984.

[29 CFR 1926.403(i)(2)] Guarding of live parts is where 50 volts or more comes in.

[29 CFR 1926.416(a)]Protection of employees
is where live work will require PPE.

They will use NFPA 70E 2004 to back up their citations as a recognized industry standard. Hopefully they will adopt it.

Thanks for pointing out the use of the wrong word. I'll have to proof read better.

Al

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#150284 - 01/20/05 05:41 AM Re: Safety related work practices... OSHA... 70E what do I follow?
safetygem Offline
Member

Registered: 01/30/02
Posts: 114
Loc: Ohio, USA
Al,
Thanks for replying. As Trumps has indicated, responses seem to be slow in this forum. I hope this doesn't turn into a two man conversation, but, even if that's the case let's hope others are interested in this thread and are "lurking" somewhere in cyberspace.

You brought up some good points again.

Most of your references (OSHA regs.) are from the construction regulations. It's important to remember that for electrical work, many (but not all) of the situations encountered on jobsites require electrical contractors to follow the General Industry regulations (29 CFR 1910).

One of the ways you can determine which set of regulations to follow is by looking at the scope of the standard. In this case the scope of Subpart K (Construction electrical regs.) is found in 1926.402. (bold face added)

 Quote:
1926.402(a)

Covered. Sections 1926.402 through 1926.408 contain installation safety requirements for electrical equipment and installations used to provide electric power and light at the jobsite. These sections apply to installations, both temporary and permanent, used on the jobsite; but these sections do not apply to existing permanent installations that were in place before the construction activity commenced.


As you can see, the Construction electrical regulations actually apply to "power and light" circuits "used on the jobsite." This is a broad way of saying that OSHA is concerned (in this circumstance) about the source of electrical power for fixtures and equipment used by the electrician and other trades that may be working at a given site.

Most (again, but not all) of the work performed by contractors is on existing equipment... or they are installing equipment that will be a permanent part of the structure. So, you must refer to the General Industry standards to determine the requirements in these situations.

Let's make an assumption (for purposes of discussion) that work performed at a given site falls under 1926 Subpart K. 1926.416(a)Protection of Employees does not address PPE. Let's take a look at the text and examine why (bold added):
 Quote:
1926.416(a)(1)

No employer shall permit an employee to work in such proximity to any part of an electric power circuit that the employee could contact the electric power circuit in the course of work, unless the employee is protected against electric shock by deenergizing the circuit and grounding it or by guarding it effectively by insulation or other means.


Guarding by "other means" includes a long list of methods and devices. Section 1926.449, which supplies definitions for all of Subpart K, offers a wide variety of guarding by means other than insulation. OSHA considers guarding to be effective if it successfully removes "the likelihood of approach to a point of danger or contact by persons or objects." Guarding and PPE are two separate issues. Here is the actual description of "guarded" found in the definitions of 1926.449.

 Quote:
Guarded. Covered, shielded, fenced, enclosed, or otherwise protected by means of suitable covers, casings, barriers, rails, screens, mats, or platforms to remove the likelihood of approach to a point of danger or contact by persons or objects.


The 50volt reference you cited is found in both the 1910 and 1926 regulations. And it requires the following...
 Quote:
equipment operating at 50 volts or more shall be guarded against accidental contact...


The generic construction requirement for PPE is actually in 1926.95(a). And... since this standard does not specifically address electrical protective equipment, we must fall back on the General Industry standards.

Why you may ask, (or maybe not ), because the overall scope of the General Industry standards indicates that it applies to "all" places of employment. (bold added)
 Quote:
1910.5(c)(2)
On the other hand, any standard shall apply according to its terms to any employment and place of employment in any industry, even though particular standards are also prescribed for the industry...


Whew... time for me to turn this over again.

Glenn

P.S. There are people that I work with that say I can't introduce myself in less than an hour. When you start talking about a particular topic, I could go on all day. Sorry, if I'm a bit long winded.

Edited to correct UBB code error.

[This message has been edited by safetygem (edited 01-20-2005).]

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