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.
I have been around, about the same amount of time as you.
My experience is that 70E can be implemented with out the level of 'pain' you consistently describe.
Almost every statement you make is based on how people you have interacted with are implementing codes, not on the codes themselves.
The vast majority (probably >96%)of machine panel locations I have evaluated, over the past 8 years are <1.2 calm/cm². Ny required PPE is definitely more in the area of street clothes than it is moon suit.
Why are you listening to the guys who
sell PPE to tell you how much you need? Do you do the same with insurance?
There is nothing in NFPA70E that says exposed means 'even being able to be reached by a probe'. The 70E definition of exposed actually uses the phrase "inadvertently touched". There is an exception to 130.2 that says if a disconnect switch has been properly used to establish a safe working condition, then the equipment feeding that disconnect does not need to be de-energized. This allows live line side connections,
if a risk assessment has been done and the task is found to be acceptable.
Work permits are about documenting the hazard, and assessing the risk. 70E 130.3(A) says 'specific practices shall be consistent with the nature of the risk'.
It is too bad, too many people skim through standards and then create and enforce unreasonable interpretations. There have not been enough precedent setting cases for the level of paranoia we see concerning implementation of 70E. Almost all of the actual judgements have been for almost blatant disregard of the standard and not for simple mis-application of it.
35 years ago I sold my first plug-on bus duct, even at that time the legal wording of the instructions said to de-energize the bus before installing/removing devices. The sales literature talked about the inherent safety features of 200A and smaller devices (e.g. interlocked to prevent installation when On), but the instructions still said shut it down.
