Are these OSHA rules applied in your workplace?

Are these OSHA rules applied in your workplace?

OSHA Part 1910.132(d)(1) – “The employer shall assess the workplace to determine
if hazards are present, or are likely to be present, which necessitate the use
of personal protective equipment (PPE). If such hazards are present, or likely
to be present, the employer shall:”

OSHA Part 1910.132(d)(1)(i) – “Select, and have each affected employee use, the
types of PPE that will protect the affected employee from the hazards identified
in the hazard assessment;”

OSHA Part 1910.132(d)(2) – “The employer shall verify that the required
workplace hazard assessment has been performed through a written certification
that identifies the workplace evaluated; the person certifying that the
evaluation has been performed; the date(s) of the hazard assessment; and, which
identifies the document as a certification of hazard assessment.”

OSHA Part 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.”

Joe,
I thought that 1926 and not 1910 applies to construction work.
Don

Don:

True, my question has to do with the workplace and not with construction.
1910.331 through 1910.335 would apply.

I want to start some discussion on the OSHA and 70E requirements related to Arc Flash, etc., and specifically Chapter 1- Safety Related Work Practices in the 2004 Edition of 70E

Joe,
Many employeers are using 70E for guidance in applying the rules that you have cited for the workplace.
The biggest problem in applying 70E is getting a "real world" available fault current. Many utilities give you a "worst case" fault current, which will always let you select equipment that will be in compliance with the NEC, but may lead to the selection of arc flash PPE that is not suitable for the incident energy. This is because the incident energy is related to the total time that the fault exists. If the fault current used in the PPE calculations is higher than what is actually available, then the trip time will be faster and the incident energy less that what is really going to happen.

Also, I forgot that if something is not covered by 1926 for construction work, then the general duty clause makes the rules in 1910 apply to us too.
Don

Don: T

hanks for your well informed comments. Do you think that the "Annex H, Simplified, Two-Category, Flame-Resistant (FR) Clothing System" could be applied as a easy way out of the complicated calculations for some facilities?

Here's the organization of 70E for us to discuss. Chapter 1 is the most important now, and the rest equally important as well.

I also found two files of information that are important:
http://www.nfpa.org/assets/files/PDF/TIA70E-04-1.pdf
http://www.nfpa.org/assets/files/PDF/Errata70E-04-1.pdf

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90.2 Organization.

This standard is divided into the following four chapters and thirteen annexes:

(1) Chapter 1, Safety-Related Work Practices
(2) Chapter 2, Safety-Related Maintenance Requirements
(3) Chapter 3, Safety Requirements for Special Equipment
(4) Chapter 4, Installation Safety Requirements
(5) Annex A, Referenced Publications
(6) Annex B, Informational Publications
(7) Annex C, Limits of Approach
(8) Annex D, Sample Calculation of Flash Protection Boundary
(9) Annex E, Electrical Safety Program
(10) Annex F, Hazard/Risk Evaluation Procedure
(11) Annex G, Sample Lockout/Tagout Procedure
(12) Annex H, Simplified, Two-Category, Flame-Resistant (FR) Clothing System
(13) Annex I, Job Briefing and Planning Checklist

Joe,
I think that you still need a power system study to apply the simplified PPE selection because you must be sure that your system complies with the notes that apply to the table. In many cases the available power in a large industrial installation will exceed what is listed in those notes. For smaller industrial systems and many commercial systems, their may be no problem using the table to select PPE. However, if there would be an incident, and if the PPE was not adequate, I think that the employer could be cited. I guess that my bottom line, is that you must have a good idea of the available current at the point on the system where the work is to be done to use the table.
Don

Don: I understand, with that aside for now, what if the 110.16 rule in the NEC was applied where I would field mark the equipment as indicated.

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...... field marked to warn qualified persons of potential electric arc flash hazards.

Some of that marking is very simple, and is available from manufacturers of equipment with a warning like:

WARNING!
Potential Arc Flash Hazard
Appropriate PPE and Tools Required
when working on this equipment.

We know that the FPN's are not enforceable.

Also, what if 70E Chapter 1 was added to the NEC instead as a new article, or at least in an annex item?

Would that give some useful information to the industry?

I have been told that the cost for PPE for each person, can vary from a few hundred to over a thousand dollars.

What have you implemented in your facility?

Joe,
Generic field marking for arc flash hazards is fine, but I don't like the idea of posting specific incident energy and PPE information on the equipment. There is too much of a chance that the information will be outdated when someone uses it to choose the PPE. I also don't think that safe work rules belong in the NEC. It is an installation code, not a safe work code.
The electricians here have been provided with 1000 volt gloves and 8 cal/cm shirts and pants. Level 2 hoods are also provided for use as needed. A number of Level 4 suits and hoods have been purchased for the rare cases where they would be required. The main rule is that you do not work anything hot except for troubleshooting. The main use of the PPE will be when you verify that the power is off after locking it out. Under the safety rules, you must assume that it is still live until tested with a voltage tester. You are exposed to the live equipment when testing for voltage and PPE is required.
Don

Thanks again Don:

I found a reference to the following NEMA information (been around for a while) in the NECH commentary under "Qualified Person":
http://www.nema.org/stds/hazards-hot.cfm#download

Working on de energized equipment would be the best way whenever possible, and in the commentary for the NEC 110.16 rule a summary is given related to safe work practices in 70E.

I have seen new installation around the country where these warning labels are provided with the panelboards in a brown envelope. They are not usually adhered to the equipment.

I am often asked if this rule is retroactive and naturally I say no -- but recommend that they give some though to the liabilities and the possible fines that may be given by OSHA.

Wow!,
What a discussion is going on here!.
Keep it up guys.
Don,

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Many utilities give you a "worst case" fault current, which will always let you select equipment that will be in compliance with the NEC, but may lead to the selection of arc flash PPE that is not suitable for the incident energy.

Utilities like the one that I work for always give what we call a "maximum-fault-loop current" to the point at which you are working.
However, with working with this sort of stuff all the time, I carry a "Fault-Loop Impedance meter", from getting that value from the meter, you can work out through basic Ohms Law, what the actual Fault current value will be.

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The main rule is that you do not work anything hot except for troubleshooting. The main use of the PPE will be when you verify that the power is off after locking it out. Under the safety rules, you must assume that it is still live until tested with a voltage tester. You are exposed to the live equipment when testing for voltage and PPE is required.

I couldn't disparage anything in that comment.
Half the problem is, when people just disregard the rules and work however they please.
This in itself, needs to be corrected.

It seems that NFPA 70E is not quite matured yet with regard to PPE selection in Table 130.7(C)(9)(a).
It states:
The assumed short-circuit current capacities and fault clearing times for various tasks are listed in the text and notes to Table 130.7(C)(9)(a). For tasks not listed, or for power systems with greater than the assumed short-circuit current capacity or with longer than the assumed fault clearing times, a flash hazard analysis shall be required in accordance with 130.3.

FPN No. 1: Both larger and smaller available short-circuit currents could result in higher available arc-flash energies. If the available short-circuit current increases without a decrease in the opening time of the overcurrent protective device, the arc-flash energy will increase. If the available short-circuit current decreases, resulting in a longer opening time for the overcurrent protective device, arc-flash energies could also increase.

It essentially says that if your fault current or clearing times vary from the tested condition, the table isn't reliable. I would maintain that with variable fault currents available from the utility and OCPD's, you can't use the table.

Thanks Ron, I was aware that you were also interested in 70E and appreciate your comments.

Here's a bit from the front matter in 70E that I would like opinions on too:

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The seventh edition, published in 2004, reflects several significant changes to the document. The major changes emphasize safe work practices. Clarity and usability of the document were also enhanced. The name of the document was changed to NFPA 70E, Standard for Electrical Safety in the Workplace. The entire document was reformatted to comply with the NEC Style Manual, providing a unique designation for each requirement. The existing parts were renamed as chapters and were reorganized with the safety-related work practices relocated to the front of the document to highlight the emphasis, followed by safety-related maintenance requirements, safety requirements for special equipment, and safety-related installation requirements. The chapter on safety-related work practices also was reorganized to emphasize working on live parts as the last alternative work practice. An energized electrical work permit and related requirements were incorporated into the document. Several definitions were modified or added to enhance usability of the document, and Chapter 4 was updated to correlate with the 2002 NEC.

Essential to the proper use of Chapter 4 of this standard is the understanding that it is not intended to be applied as a design, installation, modification, or construction standard for an electrical installation or system. Its content has been intentionally limited in comparison to the content of the NEC in order to apply to an electrical installation or system as part of an
employee’s workplace. This standard is compatible with corresponding provisions of the NEC, but is not intended to, nor can it, be used in lieu of the NEC. It can be debated that all of the requirements of the NEC, when traced through a chain of events, may relate to an electrical hazard, but, for practical purposes, inclusion has not been made of those provisions that, in general, are not directly associated with employee safety. In determining what provisions should be included in Chapter 4, the following guidelines were used:

(1) Its provisions should give protection to the employee from electrical hazards.

(2) Its provisions should be excerpted from the NEC in a manner that maintains their intent as they apply to employee safety. In some cases it has been judged essential to the meaning of the excerpted passages to retain some material not applying to employee safety.

(3) The provisions should be selected in a manner that will reduce the need for frequent
revision, yet avoid technical obsolescence.

(4) Compliance with the provisions should be determined by means of an inspection during
the normal state of employee occupancy without removal of parts requiring shutdown of the electrical installation or by damaging the building structure or finish.

(5) The provisions should not be encumbered with unnecessary details.

(6) The provisions should be written to enhance their understanding by the employer and employee.

(7) The provisions must not add any requirements not found in the NEC, nor must the intent of the NEC be changed if the wording is changed.

Chapter 4 of NFPA 70E was therefore intended to serve a very specific need of OSHA
and is in no way intended to be used as a substitute for the NEC. Omission of any requirements presently in the NEC does not in any way affect the NEC, nor should these omitted requirements be considered as unimportant. They are essential to the NEC and its intended application, that is, its use by those who design, install, and inspect electrical installations.

NFPA 70E, on the other hand, is intended for use by employers, employees, and OSHA.

Please note that Chapter 4 was updated to correlate with the 2002 NEC.

Look here for some useful information concerning this subject:

http://www.ieisa.com/Arcblast.html

[This message has been edited by Joe Tedesco (edited 06-28-2005).]

Around here OSHA is virtually all employer driven. There is not an office within 150 miles and the go teams only respond to serious accidents. When something does happen the fines get piled on and the teams may look next door while they are there but there is no real OSHA inspection program. It will be the employer's risk analysis department and the insurance carrier that drives the day to day monitoring of compliance. This will become a job responsibility (and "condition of employment") for the field supervisor in any company I would want to work for. Safety starts in the field and has to include the dilligence of EVERYONE on the job site. Employees should use the appropriate PPE and challenge anyone who is not using it.
These days, with lawyers driving "risk", it could literally be YOUR job at stake when some 3d party gets hurt and your company gets sued out of existance.

Mike,

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However, with working with this sort of stuff all the time, I carry a "Fault-Loop Impedance meter", from getting that value from the meter, you can work out through basic Ohms Law, what the actual Fault current value will be.

I have never seen or worked with that type of equipment. Can you tell more about how it is used and what it does? Thanks
Don

Don,

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I have never seen or worked with that type of equipment. Can you tell more about how it is used and what it does?

There is a thread here that we had about Fault loop testing.
If you have any more questions regarding this sort of testing, by all means, ask away. [Linked Image]

Mike.

[This message has been edited by Trumpy (edited 06-29-2005).]

Mike,
I looked at the tester information and I don't see how they give me a real world fault current. It appears to me that they use the impedance and the voltage to do a calculation. I don't see how that takes into account the strength of the supply system. It appears that this is more of an infinite bus type of fault current calculation and would not be useful for PPE selection.
Don

Don,

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I don't see how that takes into account the strength of the supply system

Just what do you mean by that Don?.
Exactly what is an infinite bus?, I'm sure I can help. [Linked Image]

Mike,
Systems can only supply so much fault current. It looks like the testers calculate an available fault current based on circuit impedance, voltage and the assumption that the supply system can supply unlimited current (infinite bus).
The calculations for selection the correct PPE require an actual available fault current and not a theoretical maximum. The incident energy produce by the arc often goes up with a lower available fault current. This is because a lower current will often result in a longer time before the OCPD operates and this results in a higher incident energy and will require a higher level of PPE protection.
Don