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#150547 - 06/26/05 08:11 PM Are these OSHA rules applied in your workplace?  
Joe Tedesco  Offline
Member
Joined: Oct 2000
Posts: 2,749
Boston, Massachusetts USA
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 Tedesco, NEC Consultant

Arc Flash PPE Clothing, LOTO & Insulated Tools

#150548 - 06/26/05 08:44 PM Re: Are these OSHA rules applied in your workplace?  
resqcapt19  Offline
Member
Joined: Nov 2000
Posts: 2,148
IL
Joe,
I thought that 1926 and not 1910 applies to construction work.
Don


Don(resqcapt19)

#150549 - 06/26/05 09:00 PM Re: Are these OSHA rules applied in your workplace?  
Joe Tedesco  Offline
Member
Joined: Oct 2000
Posts: 2,749
Boston, Massachusetts USA
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 Tedesco, NEC Consultant

#150550 - 06/26/05 10:06 PM Re: Are these OSHA rules applied in your workplace?  
resqcapt19  Offline
Member
Joined: Nov 2000
Posts: 2,148
IL
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(resqcapt19)

#150551 - 06/26/05 10:25 PM Re: Are these OSHA rules applied in your workplace?  
Joe Tedesco  Offline
Member
Joined: Oct 2000
Posts: 2,749
Boston, Massachusetts USA
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

Quote
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 Tedesco, NEC Consultant

#150552 - 06/27/05 07:09 AM Re: Are these OSHA rules applied in your workplace?  
resqcapt19  Offline
Member
Joined: Nov 2000
Posts: 2,148
IL
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(resqcapt19)

#150553 - 06/27/05 08:48 AM Re: Are these OSHA rules applied in your workplace?  
Joe Tedesco  Offline
Member
Joined: Oct 2000
Posts: 2,749
Boston, Massachusetts USA
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.

Quote
...... 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 Tedesco, NEC Consultant

#150554 - 06/27/05 01:38 PM Re: Are these OSHA rules applied in your workplace?  
resqcapt19  Offline
Member
Joined: Nov 2000
Posts: 2,148
IL
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


Don(resqcapt19)

#150555 - 06/27/05 02:15 PM Re: Are these OSHA rules applied in your workplace?  
Joe Tedesco  Offline
Member
Joined: Oct 2000
Posts: 2,749
Boston, Massachusetts USA
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.


Joe Tedesco, NEC Consultant

#150556 - 06/28/05 02:04 AM Re: Are these OSHA rules applied in your workplace?  
Trumpy  Offline


Member
Joined: Jul 2002
Posts: 8,211
SI,New Zealand
Wow!,
What a discussion is going on here!.
Keep it up guys.
Don,
Quote
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.
Quote
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 grin

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