JBD, I appreciate your opinion. Alas, I have been around this bush many times, and my comments stand. Frequent readers of this forum are well aware of my opposition to both OSHA and 70E.
Open any industrial control panel, and there is both low-voltage control wiring and the full-voltage power circuit. Thus, the operator who opens the cabinet, for any reason, is required to don PPE until after all accessible live parts are proven to be dead.
"PPE" depends upon the arc-flash rating, or defaults to the 'worst case' table in 70E. Most any company selling PPE will gladly demonstrate how 70E requires you to buy lots of stuff from them, even is all you have are 240 circuits of 100 amps or less.
"Exposed" live parts are anything that can be reached, even if only with a probe. 70E makes no allowance at all for insulated tools or protected probes, or that the live parts are not associated with your task.
The 70E rules apply whatever the reason for opening the panel - even if it is opened for something as mundane as changing a VFD setting. Heaven forbid you're thinking of doing something like checking the fuses!
Heck, the 70E requirements apply when you're racking in a breaker or snapping a disconnect on to a bus duct - Full PPE until proven dead - despite the fact the equipment was originally designed to let you perform your task with nearly zero chance of your contacting a 'live' part.
