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, 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
#150551 - 06/26/0510:25 PMRe: Are these OSHA rules applied in your workplace?
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.
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
#150553 - 06/27/0508:48 AMRe: Are these OSHA rules applied in your workplace?
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
#150555 - 06/27/0502:15 PMRe: Are these OSHA rules applied in your workplace?
Wow!, What a discussion is going on here!. Keep it up guys. Don,
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.
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.
Let's face it, these days if you're not young, you're old - Red Green