I now work at a facility that builds systems we sell to customers. The system uses DIN rail mounted components and the modular terminal blocks are the spring loaded type instead of screw terminals. I was talking with the safety officer and he was telling me that the safety consultant was just in the building and had commented that these terminal blocks were considered as having exposed surfaces. They were called exposed because an individual could push a pice of conductive material into a hole and make contact with energized components.

My reply was that we now have to remove every convience outlet because someone could do the same thing! Plus totally enclose every power supply with a perforated cover or any device that wasn't IP68.

Is this safety consultant blowing smoke or do we really have to protect idiots at all costs?

Larry:
Hence the mandate for the TR receptacles! Iguess we are headed for a flood of new "idiot defense" equipment.

Your systems should fall into the qualified persons catagory, so maybe a warning label on the enclosure would suffice?

Are we going to look at a future of TR items?

I guess I can't use the argument that if a person has a current driver's license, they might be smart enough to not stick conductive materials into electrical bits.

I can see accidental contact protection, but now we have to protect against deliberate actions too?

A person is compentent enough to get a job, drive to the place of employment, pass background and security checks, and be smart enough to work in a manufacturing environment, we still think they are dumb enough to stick a paperclip into electrical works?

Idiocracy, here we come.

I recently got stuck in a truck with an oil exec and, having nothing to talk about, I brought up the topic of safety. Their policy is that zero risk is the standard for their company

I did work for another oil company that had a "gloves on at all times, NO EXCUSES" policy. He though that was stupid. I think the rule is that their policies are smart and everyone else's policy is stupid.

So, I asked what he thought about the speed limit being increased from 55 to 65 mph, at the known risk of a 50% increase in traffic deaths. It was a very quiet trip after that because he was driving 65 in a 55 zone. I guess he thought the risk was worthwhile to reduce the time he had to spend with me.

If we really thought, as a society, that zero risk is the standard, that would end bungee jumping, football, swimming, boating, eating with a knife, cooking... It's impossible to regulate reasonable, so the rules get longer.

You cannot fix stupid, or regulate in to extinction! Every time a new fool proof device is invented a new improved fool will figure a way to defeat it. The answer is for people to be responsible for their own actions, YOU stuck the paper clip into the receptacle, YOU got electrocuted, I fail to see why I have to spend more money to install things to protect YOU, when I am smart enough not to do that.

Welcome back to the Middle Ages, my dear serf!

I've become convinced that 90% of the enthusiasm for "safety" is but a charade to impose authority and take away freedom.

Look at the basic premise: YOU are not smart enough to know what is safe, but some complete stranger in an office 1000 miles away is!

Most anything can be twisted into a 'safety' issue, giving despots a blank check to -at a minimum- practice 'seagull management' (swoop down, crap on everything, fly off).

Look at it this way: If the cops came to your door and said they wanted to check for drug ... wouldn't the response 'let's see the warrant' be reasonable and expected? Yet, some guy shows up at the front gate and says "I'm from OSHA and want to inspect," what's your response? Do you ask him for a warrant?

Imagine if, at the grocery store, you had to 'pass inspection' before they let you check out? It's only to protect your health, after all.

Even here at these forums, look at how many of us are so willing to write laws to impose on others. More is better, if it only saves one life, etc.

Don't let facts get in the way, either. A few examples:

1) Despite hysterical fears screamed in the press, returning to speed limits above 55mph did NOT lead to increased highway carnage- even for places with new limits in excess of 85mph;

2) The entire 'gun debate' is fraught with assertions that have long been debunked. "More Guns, Less Crime," which debunks these assertions, is written by a man who taught alongside our President at the U of C. Yet, the same tired lies keep getting trotted out, to justify further controls in the name of 'safety;' and,

3) Look to "Amish Country" for some insights to the 'misery loves company' principle. Over-regulated folks assert "it's not fair- we need to apply the rules to the Amish, too!" Note that folks don't say "The Amish are right- we need to trim back our government." This, despite plenty of testimony that Amish buildings don't fall apart (or burn down) any more than "permitted" buildings. This is even more impressive, as those folks still heat, cook, and light using open flames!

OSHA needs to be eliminated.

I have two takes on safety regulation:

When I started in the trade, I was sent to the top of a 10 foot ladder to remove 2 ft x 4 ft fluorescent lights from a 16 foot ceiling in the middle of a warehouse. I don't just think my employer put me in a dangerous situation, I was really scared. At 17 years of age I didn't know how to stand up for myself. Under-regulation is bad.

I had a co-worker who hurt his back at home then came to work and claimed that he was injured lifting a fire extinguisher from the bracket. We went to every fire extinguisher in the plant and lowered them by 6 inches because action must be taken to prevent all injuries. Then there was a rule about the height of fire extinguishers. Over-regulation isn't a solution.

There are several ways to put a value on our lives. Here is one: Princeton University

I have seen safety people with no clue specifying things.

A large printer in the computer room has to have an eyewash station according to the new safety manager but the photo copier on the other side of the wall in the office area that uses the same toner does not.

all the toners come in a sealed leak proof plastic cartridge and there has never been any incidents of exposure to loose toner.

The operators found that the eyewash station requires the raised floor to be opened so a pail can be put under it when they do the quarterly refreshing of the water. Just what they need splashing water onto cables and outlets in a computer room.

The computer operators also have to use cut resistant gloves and safety goggles to open boxes of paper according to this safety guy. He wanted to get rid of the utility knife they use but he couldn't figure how to get the boxes open without one.

Have you ever tried putting shrink numbers on a #18 wire while wearing leather gloves? No wonder we can't compete with China.
http://www.youtube.com/watch?v=xxT-f-hb8Sg

Has anyone ever been in front of OSHA or had OSHA come to their job site? I was inspecting a large job with 5-7 story buildings. On one building the roofers were just throwing garbage off the roof and they hoped it landed in the dumpsters. Another day, an iron worker slipped off an I-beam and hit the deck below. (About an 8-10'drop) However the deck wasn't secured yet, so it opened up and he dropped to the floor below. ( Another 10') He survived but he got hurt pretty good.

OSHA stopped by that job site more than once. It was almost funny, every time an OSHA guy stopped by, all the workers would run into the woods.

Gee, Harold ... what ever happened to folks saying 'not me' and voting with their feet? Have we become a society of women and mice?

It's not safe. That's the individuals call, and his right. Not long ago, a contractor quit a government job near Reno, as he was not convinced the bridge he was to build was safe. Walking away from a multi-million dollar job.

Oddly enough, there is NO agency - not OSHA, not the building department, no one - with the brief to pass judgement on structural designs. Can't hide behind the inspector.

Sorry, but I've seen plenty of folks simply walk away when they felt the situation was unsafe. I've seen it get to the point of one contractor threatening to pull his crew if a hazard was not addressed. I've seen such crews leave.

On the 'other' side of the coin, I've seen endless silliness come out of 'safety' offices. These clown have gone so far as to attempt to specify the shape of toilet seats!

Now, some folks in my town want the trash man picking through the trash and making notes, so the city can look for 'illegal' construction activity. That ought to be fun, especially in light of the very lax permit requirements here.

Too true. I LIVE IN the heart of Amish Country and I can testify to that firsthand. If you followed them throughout their day, you could probably nail some safety or code violation every 10 minutes, all day long.

The one thing that OSHA and so many other safety organizations are blind to is the "happy medium". Some safety is better than no safety; moderate safety is better than extreme safety. Let the stupidity get killed off, don't let it breed!

It isn't about safety, really. It's about saving money.

Where I am, we have a workers' compensation board that decides who gets paid for their injury and how much they get paid.

I knew a fellow who hurt his back and had an operation. Afterwards, the only work he could find was guarding a small town police cell at night. The injury got worse until he couldn't drive to work or stay sitting or standing for very long. So, he started collecting full compensation.

The compensation board sent him to a doctor and the doctor recommended against another operation because there was a 50% chance he would never walk after.

The compensation board said they were willing to take that chance.

They liked the odds that there was a 50% chance that they could cut him off. If they lost the bet, they were already paying him, anyway.

I know they have an appeal procedure. Those appeals were handled entirely by another comp board employee. I knew one of them and she was quite unsympathetic to the plight of workers.

I once went in front of an OSHA inspector. Not because I did something wrong, but because one of my customers did. This nursing home had a handyman (1st mistake) who thought he could fix anything. So he tried his hand at fixing a 3 phase reversing switch in the kitchen (2nd mistake)He wired it wrong and someone got hurt. OSHA came in and fined the owner for I think $4,000. This was back in the '80's. The owner was fine for just 2 violations, I forget the first but the second was that there was no GFI protection for the counter top "outlets". This before it was required. Plus the device was a rain tight reversing 3 phase switch. So I had to go on behalf of the owner to testify that GFI protection was not required as per NEC at the time.

The documentation I was given to justify the safety statements is OSHA 1910.333 printout where it talks about employees coming in contact with energized circuit parts "indirectly through some other conductive object." Specifically 1910.333(a)(2)

The paragraph then refers to specific work practices in paragraph (c).


1910.333(c)

"Working on or near exposed energized parts."

1910.333(c)(1)

"Application." This paragraph applies to work performed on exposed live parts (involving either direct contact or by means of tools or materials) or near enough to them for employees to be exposed to any hazard they present.



Does this section refer to working with control equipment that you can't reach energized parts without using a tool?

It "seems" to me that someone is taking a sentence out of context and using it to justify something else. Am I all wet or do you folks see it the same way?

I take it as a tool contacting energized parts. Now, using screw terminals seems to present the same condition, right??

Or, are they looking fr covers over all terminals?

I'm confused.

As it was explained to me, if an indivdual could use a conductive item and is able to make contact with energized parts, that means that there is hazard present. Such as a paper clip, a metal knife blade, keys, etc. Therefore we must pursue avenues to minimize or eliminate the "hazard". As I understand, this means de-energizing the system or require tools to gain access to the energized parts.

While I concede someone has to work at it to harm themselves, where do we draw the line? If my interpretation of this is correct, then ALL unused outlets must be de-energized. That will certainly cause problems for anyone who needs to find the correct breaker to turn on a de-energized outlet to plug in a vacuum cleaner, trouble light, or battery charger for their computer. How about circuits where some of the outlets are used and the rest of them empty?

My philosophy is that people have to have some basic sense. If they are that much of a hazard that we have to protect them from themselves, then they should not be allowed to be in the work area, be allowed to use fire, or drive a motorized vehicle. Typically if a person is not trained to not stick objects into electrical bits, we hire a sitter to keep them out of trouble.

Larry:
Re-reading this from the begining, I have to ask this,

Are the components that create the issue within an enclosure? If so, then would not only 'qualified' people have access to the interior of the enclosure?

A compliant few warning label on the enclosure may be a solution.

Larry's bringing up an issue that would fit right in, if we had an 'industrial' forum. Follow this train of thought first:
1) Open a control panel or starter, there are lots of things that can shock you;
2) So, industry started making things with arc shields, dividers, etc.;
3)Then industry -in part with the arrival of IEC stuff here - went another step and started making thing 'finger safe.' So, for example, you could test or change a fuse without ever being able to actually touch anything live.

Completely independent of this:
1) The NFPA has been hawking their 'maintenance' and 'safety' standards for years (probably hoping to repeat the success they had with the NEC);
2) OSHA begins to rely on "70E" as defining the standard practices. Trouble is, 70E is completely ignorant as regards all the design and standards work already done (by parties other than the NFPA); and,
3) The NFPA doubles down on this power grab by adding a section to the NEC about control panels, and calls for their listing.

70E wants full moon suit and testing to ensure power is off. 70E does not recognize any design element that will allow a test probe yet exclude a finger. 70E wants arc-flash calcs and documented selective co-ordination at ever step, from the PoCo drop to the last outlet. 70E completely disregards the safety of control circuits, since the same cabinet has 'power circuits' in it as well.

End result? You are supposed to treat the latest, safest stuff the same way as you would treat stuff that was little more than spring clips and rusty nails, mounted in the open on a 2x4.

It's like the tax code: if they want to gig you, they will- and there's not a damn thing you can do about it.

We are building / designing / testing a machine. The machine uses what I think are touch safe terminals. All energized parts >60V are insulated or behind suitable insulators. I am standing there, inside a roped off area, more than 40 inches between the rope barrier and the open energized control panel. The safety consultant was concerned that the panel should be shut whenever the machine is energized. We have been running the machine for debug purposes with the panels left open. People inside the roped off area are aware of potential hazards and are properly trained.

Larry:

IMHO, the safety consultant may be trying to justify his time/fee.

Qualified people working on a machine under testing/debug require access.

The print plant i worked in, had a safety guy who would measure the barrier to equipment clearance (space) and bust chops for an inch or two! The production manager 'relocated' the safety guy down to shipping area!

I used to try to maintain 44" clear on my side of the barrier. We used 5' high welding screens and had enough of them to block a 52' RotoPress.

When I went in front of OSHA to defend my customer, the gentleman from OSHA told me that in general, electricians are one of the more safety orientated groups out there. The worst groups were excavators and siding people. Now this was back in the late'80's that I did this, so I don't know if anything has changed since then. Also I was told that the OSHA inspectors hit you with huge fines because the inspector gets a chunk of that fine.

This is so blatantly wrong it is hilarious, and leads me to the conclusion that you should not be taken seriously.

NFPA70E simply says to wear the appropriate PPE for whatever task you are performing.
NFPA70E clearly requires you to perform a Risk Analysis as part of determining the appropriate PPE.
The main point of NFPA70E is for an employer to produce a Safe Work Practices program for their employees.

Do people mis-quote and mis-apply MFPA70E - absolutely they do. Do bullies (e.g ignorant OSHA inspectors) abuse their power - again absolutely.

Should we get rid of any standard that is misued by some one?

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.

On one larger job the poco sparked up a rather large service for us, {8' switchgear, all Eframe breakers} and called me to turn it all on

So i doned my entire arc suit to go and meet them, when i arrived the poco rep (a man of some serious tenure) said "I've never seen an electrician in one of those!"

~S~

i really have a thing about salesfolks , they're usually biased, and leave out a lot of pertinent info because of it

~S~