The company I work for has just adopted 70E which we're all being tested on. We've gotten a couple of catagory 2 and catagory 4 blast suits with the insulated gloves and sheilds and such.
Originally everyone worked hot without any protection, and now we at least have these suits, so this is a step in the right direction. But the attitude that they've created seems to be something along the lines of "now that we have these suits, we never have to worry about attempting to shut down."
I've heard (mostly on here and other message boards) that OSHA prohibits any work that by defintion doesn't have to be preformed hot (i.e.: anything other than voltage and power testing, etc.) I said this and was told that while I was prohibited from working hot, licensed electricians certainly could.
Both NFPA 70E and CFR 1910 Subsection S seem to say the same thing: "Live parts to which an employee may be exposed shall be deenergized before the employee works on or near them, unless the employer can demonstrate that deenergizing introduces additional or increased hazards or is infeasible due to equipment design or operational limitations."
That doesn't read to me like a prohibition of hot work. That reads to me like a massive loophole to allow hot work. It seems like it just leaves it at the discression of the electrician to decided whether or not shut-down is feasable. If knocking out a lighting circuit puts a group of people in the dark, has that created additional hazards? Is shutdown infeasable because of the lighting circuit layout?
Yes or no, can we or can we not work things hot? This doesn't seem very clear cut at all.
John, It is not really that big of a loophole. The notes to 1910.333(a)(1) say:
Note 1: Examples of increased or additional hazards include interruption of life support equipment, deactivation of emergency alarm systems, shutdown of hazardous location ventilation equipment, or removal of illumination for an area.
Note 2: Examples of work that may be performed on or near energized circuit parts because of infeasibility due to equipment design or operational limitations include testing of electric circuits that can only be performed with the circuit energized and work on circuits that form an integral part of a continuous industrial process in a chemical plant that would otherwise need to be completely shut down in order to permit work on one circuit or piece of equipment.
That letter of interpretation says that unless an additional hazard can be demonstrated to be cause by denergizing, then everything has to be shut down.
That only addresses one of the conditions under which we are apparently allowed to work hot. The other condition is Note 2 which concerns whether or not it is "feasable" to shut down the equipment due to design considerations. This is the part that seems like the loop-hole.
Where do you draw the line between interrupting industrial processes and shutting off a circuit controlling a couple of personal computers? How much inconvenience is tolerable before something becomes "infeasable"?
This may seem argumentative, but I'm trying to get a clear answer because these are the arguments I'm going to get if I use NFPA 70E to suggest that we shouldn't work everything hot simply because we have a flash suit.
Re: Permitted Hot Work#151457 03/17/0707:37 PM03/17/0707:37 PM
My biggest problem with these regulations is that they muddy the waters as to who gets to make the call.
IMO, we, as professionals, are the final authority. Period. WE decide - yes or no.
Throw a new regulation into the mix, and there's all sorts of other folks ... supervisors, managers, engineers, Personnel wonks, chairborne commandos ... who suddenly feel that they get to make your decision for you. "What's the problem? We got you a suit- go ahead and work hot." Or, the opposite: "Joe did it hot yesterday, what's the problem?" Then there's always the Nimrod who wants to write a guy up for not wearing safety glasses while he washes his face...
If the place thinks the line workers are simply chimps with tool belts, then no amount of regulation will fix a management made up of banana-brains.
Re: Permitted Hot Work#151458 03/18/0703:39 PM03/18/0703:39 PM
i started with a new company last year and on my first day i had to read and sign paperwork about an inch thick pertaining to safety rules that everyone is supposed to follow. thing is i soon realized that the job foremen don't enforce these rules at all. if everyone looks the other way it sends a message "don't worry about it". then if you do want to do things the safe way let's face it,it takes you longer to do the same job as the guy who's cutting corners. being new to the company i didn't want to "make waves" so i did everything like everyone else. my ?? is by signing that paperwork are they going to be obligated to pay workman's comp if someone does get hurt cutting corners. (e.g. working off a step ladder that's leaning against the wall because you don't have room to lock the spreaders and we don't have straight ladders on site or not being tied off when working near a leading edge elevated above 6ft.) in my first month i worked a saturday when we were trying to make a deadline and i was sent into a bathroom to fix 277v recess cans that wouldn't come on, (new construction, unoccupied) i asked the subforeman to turn off the curcuit and he said "the boss (foreman) said f#@% it work 'em hot. well, the guy who wired 'em wrong the first time didn't wire 'em hot -or- correctly for that matter. of coarse i did as told and cussed under my breath the whole time. again my ?? is how much legal responsibility does the company have if i would get hurt? how many loopholes do you think their lawyers can find to prtect their pocketbook? any opinions on this would be appreciated.
Re: Permitted Hot Work#151459 03/18/0704:51 PM03/18/0704:51 PM
Hi Mark, for the example you gave of your 277V lighting issue, I pose this question and comment. Isn't working on energized equipment part of the trade? I will always work between grounds, and de-energize when possible. I surley do not feel the need to 'show boat' by working equipment 'hot' when there is no need too. I definitely don't disagree with your beliefs and convictions on the topic..BTW
I also belive that some formen...some.. forget over time how dangerous and unforgiving it is working on energized equipment. They spend to much time in the office and mulling over prints. Maybe the formen you mentioned 'fits the bill'. How long would it have took you to go and flip the breaker for that circuit anyway? Was it feeding something else besides the bathroom? Seems that maybe you could have broken a tap to de-energize without the boss knowing possibly? Just an idea...good luck out there!
Luke Clarke Electrical Planner for TVA.
Re: Permitted Hot Work#151460 03/19/0705:50 PM03/19/0705:50 PM
luke, thanks for the reply. i have worked on plenty of hot circuits myself. in fact when i used to be a licensed journeyman hvac repairman it seems i worked on stuff hot even more often than i do now as a master electrician (troubleshooting problems on a daily basis). so i'm not a stranger to it. and yeah, once i found where the circuit was fed at i did kill it at a splice as you suggested. i was new on the job and had no idea where the breaker was to turn it off (this was a big fed gov't building)- that's why i kindly asked my subforeman to do it. i did get shocked that day re-making that splice (5 12-2 mc's is kind of hard to splice together even when it isn't hot) not bad though, just enough to upset me. i learned a lesson that day, don't take no for an answer. i've been with the company over a year now and have stood my ground more times than not. seems people respect that. i'm a subforeman myself now.
Re: Permitted Hot Work#151461 03/20/0708:03 PM03/20/0708:03 PM
Sorry Mark20, I didn't realize that you were a Master electrician. I'm just a j-man myself. You probably have forgot more than I will ever know, (along with many others on this site) but I am still learning.
Luke Clarke Electrical Planner for TVA.
Re: Permitted Hot Work#151462 03/20/0709:02 PM03/20/0709:02 PM
John, Unfortinately its hard to get a yes or no anwser to questions from OHSA. In my opinion should there be an accident your company will have to justify why things were not shut down. If your employer thinks about it that way it may be eaiser to get a shut down. Also a short circuit may cause longer down time than a short outage or moving to a temporary source. It is also my opinion that that ppe is no substitute for a shut down. Remember your safety is most important to you. If you do not feel comfortable with the task don't do it. I would rather find a new job that valued my safety and judgement. I know thats easy for me to say so take care of yourself out there. Jeff
Re: Permitted Hot Work#151463 03/20/0710:30 PM03/20/0710:30 PM