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Electrical Safety

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Title: Electrical Safety


1
Electrical Safety
  • Electrical Hazards
  • Arc Blast
  • Arc Flash
  • WITC April 2011

2
NRTL
  • Or what does OSHA accept

3
Does OSHA accept the "CE" mark or accept
equipment certified by foreign testing
organizations?
  • The CE mark is unrelated to the requirements for
    product safety in the US. It is a generic mark
    used in the European Union (EU) to indicate that
    a manufacturer has declared that the product
    meets requirements in the EU for product safety.
    In the US, under OSHA's NRTL requirements, the
    product must have the specific mark of one of the
    NRTLs recognized to test and certify these types
    of products

4
What is the CE
  • Many products seeking entry into the European
    Union must comply with the European Directives
    and bear the CE Marking. The CE Marking is the
    manufacturers self-declaration, showing
    compliance with all applicable directives.

5
How does OSHA enforce the requirements for NRTL
approval?
  • OSHA primarily enforces the requirements for NRTL
    approval by
  • 1) recognizing NRTLs to assure itself that
    qualified organizations test and certify the
    safety of products used in the workplace,
  • 2) auditing each NRTL annually to verify that it
    sustains the quality of its operation and
    continues to meet requirements for recognition,
    and
  • 3) performing workplace inspections during which
    OSHA compliance officers (CSHOs) review specific
    products to check whether they contain the
    certification mark of an NRTL.
  • OSHA may cite an employer and impose penalties if
    the officer finds improperly certified products
    for which OSHA requires certification

6
So what do we cite
7
1910.302(b) Extent of application
--1910.302(b)(1) Requirements applicable to all
installations.
  • The following requirements apply to all
    electrical installations and utilization
    equipment, regardless of when they were designed
    or installed 1910.303(b) -- Examination,
    installation, and use of equipment

8
1910.303(a) Approval.
  • The conductors and equipment required or
    permitted by this subpart shall be acceptable
    only if approved, as defined in Sec. 1910.399.

9
1910.399 DefinitionsAcceptable. An installation
or equipment is acceptable to the Assistant
Secretary of Labor, and approved within the
meaning of this Subpart S if it meets 1, 2, or
3
10
Acceptable and approved if 1
  • (1) If it is accepted, or certified, or listed,
    or labeled, or otherwise determined to be safe by
    a nationally recognized testing laboratory
    recognized pursuant to 1910.7 or

11
Acceptable and approved if 2
  • (2) With respect to an installation or equipment
    of a kind that no nationally recognized testing
    laboratory accepts, certifies, lists, labels, or
    determines to be safe, if it is inspected or
    tested by another Federal agency, or by a State,
    municipal, or other local authority responsible
    for enforcing occupational safety provisions of
    the National Electrical Code, and found in
    compliance with the provisions of the National
    Electrical Code as applied in this subpart or

12
Acceptable and approved if 3
  • (3) With respect to custom-made equipment or
    related installations that are designed,
    fabricated for, and intended for use by a
    particular customer, if it is determined to be
    safe for its intended use by its manufacturer on
    the basis of test data which the employer keeps
    and makes available for inspection to the
    Assistant Secretary and his authorized
    representatives.

13
So it must have an approval
  • Accepted. An installation is "accepted" if it has
    been inspected and found by a nationally
    recognized testing laboratory to conform to
    specified plans or to procedures of applicable
    codes.

14
So what does OSHA do
  • 1910.303(b) Examination, installation, and use of
    equipment --1910.303(b)(1) Examination. Electric
    equipment shall be free from recognized hazards
    that are likely to cause death or serious
    physical harm to employees. Safety of equipment
    shall be determined using the following
    considerations1910.303(b)(1)(i) Suitability for
    installation and use in conformity with the
    provisions of this subpartNote to paragraph
    (b)(1)(i) of this section Suitability of
    equipment for an identified purpose may be
    evidenced by listing or labeling for that
    identified purpose.

15
A potential avd 1910.303(b)(1)(i)
This is what I use to train OSHA employees in how
to issue citations
  • The XXXX equipment was in use without being
    accepted, or certified, or listed, or labeled, or
    otherwise determined to be safe by a nationally
    recognized testing laboratory recognized pursuant
    to 1910.7

16
Whats new
  • New PPE directive
  • What is PPE?
  • Personal protective equipment
  • LINK
  • http//www.osha.gov/OshDoc/Directive_pdf/CPL_02-01
    -050.pdf

17
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18
Are tools PPE
  • NOTE Insulated protected tools and testing
    equipment are not considered to be personal
    protective equipment when working in proximity to
    exposed electrical parts. These tools are
    designed to make contact with exposed energized
    conductors or circuit parts.

19
Question
  • When an employer decides to use flame-resistant
    clothing (FRC) to protect employees from any type
    of fire exposure hazard (e.g., flash fire or arc
    flash) is the employer required to pay for the
    FRC?

20
Yes
  • The employer is required to provide, ensure use,
    and maintain protective clothing in a sanitary
    and reliable condition whenever it is necessary
    by reason of hazards, capable of causing injury
    in any part of the body, as addressed in 29 CFR
    1910.132(a). Where employees are exposed to
    electrical hazards (e.g., substations or
    electrical panels that present the potential for
    arc flash) refer to Safeguards for personnel
    protection. - 29 CFR 1910.335 and 29 CFR
    1910.132(a) for PPE. Where there are flash fire
    hazards in General Industry occupations e.g., in
    the oil and gas industry and in
    petroleum-chemical plants, the employer is
    required to pay for FRC as indicated in 29 CFR
    1910.132(h)(1).

21
  • Electrically conductive shoes provide protection
    against the buildup of static electricity.
    Employees working in actual or potentially
    explosive and hazardous locations must wear
    conductive shoes to reduce the risk of static
    electricity buildup on the body that could
    produce a spark and cause an explosion or fire.
    Foot powder should not be used with protective
    conductive footwear because foot powder provides
    insulation and reduces the conductive ability of
    the shoes. Silk, wool, and nylon socks can
    produce static electricity and should not be worn
    with conductive footwear. Conductive shoes must
    be removed when the task requiring their use is
    completed.
  • NOTE Employees exposed to electrical hazards
    must never wear conductive shoes

22
Wisconsin
  • Comm 16.004 Authority. (1) DEPARTMENT AUTHORITY.
  • The department shall have the authority and
    responsibility for interpreting this chapter and
    the National Electrical Code, and granting
    special permission as specified in this chapter.
    A formal interpretation of this chapter shall
    remain in effect until rescinded or changed or
    until the edition of the National Electrical Code
    is changed in s. Comm 16.014.

23
Comm 16.010 Inspection and maintenance.
  • All electrical installations and equipment shall
    be cleaned and inspected at intervals as
    experience has shown to be necessary.
  • Any equipment or electrical installation known to
    be defective so as to endanger life or property
    shall be promptly repaired, permanently
    disconnected, or isolated until repairs can be
    made.
  • Construction, repairs, additions and changes to
    electrical equipment and conductors shall be made
    by qualified persons only.
  • History Cr. Register, October, 1990, No. 418,
    eff. 11-1-90 CR

24
WI largely adopts the NEC
  • The National Electrical Code, NEC-2008, subject
    to the changes, additions or omissions specified
    in subch. III, is hereby incorporated by
    reference into this chapter
  • Comm 16.015 Changes, additions or omissions to
    NEC. Changes, additions or omissions to the
    National Electrical Code (NEC) are specified in
    this subchapter and are rules of the department
    and not requirements of the NEC.

25
Qualified
  • One who has skills and knowledge related to the
    construction and operation of the electrical
    equipment and installations and has received
    safety training to recognize and avoid the
    hazards involved.
  • So where do you put your desk?

26
So all of you are Qualified???
  • Answer the questions to the following scenarios
  • 2 pieces of switch gear have failed a few years
    ago and are not in the mix, the third will not
    reset using the remote reset device.
  • What do you do?

27
Pick One
  • A Kill the main and reset while de-energized
  • B Do it live and reset with Arc flash clothing
    including a 40 call hood and suit with gloves
  • C Get out there and do it with two others to
    watch. I dont need that hot clothing.
  • D The preferred ?

28
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29
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30
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31
Result
  • 1 Dead
  • 2 Injured
  • OSHA citations

32
The codes are there to protect.
  • We have
  • Comm 16
  • NEC
  • OSHA
  • NFPA 70 E
  • The first 2 tend to deal with installations. OSHA
    also has installation requirements but OSHA along
    with NFPA 70 E also looks at Safe Work Practices
    for the Electricians

33
Interrupting rating
  • NEC 110.9 Equipment intended to interrupt current
    at Fault levels shall have an interrupting rating
    sufficient for the nominal circuit voltage and
    the current that is available at the line
    terminals of the equipment.
  • Adopted by WI without change

34
OSHA
  • 1910.303(b)(4) Interrupting rating. Equipment
    intended to interrupt current at fault levels
    shall have an interrupting rating sufficient for
    the nominal circuit voltage and the current that
    is available at the line terminals of the
    equipment. Equipment intended to interrupt
    current at other than fault levels shall have an
    interrupting rating at nominal circuit voltage
    sufficient for the current that must be
    interrupted.

35
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36
OSHA 1910.303(b)(5)
  • Circuit impedance and other characteristics. The
    overcurrent protective devices, the total
    impedance, the component short-circuit current
    ratings, and other characteristics of the circuit
    to be protected shall be selected and coordinated
    to permit the circuit protective devices used to
    clear a fault to do so without the occurrence of
    extensive damage to the electrical components of
    the circuit. This fault shall be assumed to be
    either between two or more of the circuit
    conductors, or between any circuit conductor and
    the grounding conductor or enclosing metal
    raceway.

37
You need to Co-ordinate your system
  • Amperage
  • Interrupting time

38
Selective Co-ordination
  • The term selective coordination refers to the
    selection and setting of protective devices in an
    electric power system in such a manner as to
    cause the smallest possible portion of the system
    to be de-energized due to an abnormal condition.
    The most commonly encountered abnormal condition
    is an overcurrent condition, defined by the NEC
    as any current in excess of the rated current of
    equipment, or the ampacity of a conductor

39
Drawback
  • The fact that time is used to coordinate the
    operation of protective devices in series has an
    important, and unfortunate, drawback
  • The closer to the source of power, the slower the
    protective device must be to coordinate with
    downstream devices.
  • This means that for faults close to the source of
    power, fault clearing will be slower than it
    could be if coordination were not a
    consideration.
  • This has important implications for equipment
    damage and arc-flash hazards, both of which must
    be taken in to consideration in an over-all
    system design.

40
Remember Maintenance is an Issue
41
OSHA 1910.304(f)(2)(ii)
  • Each protective device shall be capable of
    detecting and interrupting all values of current
    that can occur at its location in excess of its
    trip setting or melting point

42
Testing and Maintenance
  • Variable settings
  • Get it running (bolts copper pipe etc)
  • Replacements, do you always consult the One line
    or do you replace with what is there?
  • Bean Counter or value non-engineering.
  • You have to have the capablity to interrupt the
    power. (65 KA or 25KA)

43
CB Testing Maintenance General Considerations
  • Circuit breakers require
  • Testing and maintenance
  • Verify proper calibration and operation
  • Testing performed with the circuit breaker
    removed from the enclosure
  • Required for all circuit breakers and may require
    special equipment
  • Operation at least once per year
  • Testing and maintenance are required to ensure
    proper protection by circuit breaker systems.
  • Molded case and insulated case circuit breakers
    cannot be repaired must replace

44
Electrical Safety
  • Electrical Hazards
  • Arc Blast
  • Arc Flash

45
Initiating ESWPElectrical Safe Work Practices
(aka Arc Flash/Blast NFPA 70 E)
  • Patrick Ostrenga
  • Compliance Assistance Specialist
  • Milwaukee Area Office / Region V

46
Official Disclaimer
  • This information has been developed by an OSHA
    Compliance Assistance Specialist and is intended
    to assist employers, workers, and others as they
    strive to improve workplace health and safety.
    While we attempt to thoroughly address specific
    topics for electrical issues it is not possible
    to include discussion of everything necessary to
    ensure a healthy and safe working environment in
    a presentation of this nature. Thus, this
    information must be understood as a tool for
    addressing workplace hazards, rather than an
    exhaustive statement of an employers legal
    obligations, which are defined by statute,
    regulations, and standards. Likewise, to the
    extent that this information references practices
    or procedures that may enhance health or safety,
    but which are not required by a statute,
    regulation, or standard, it cannot, and does not,
    create additional legal obligations. Finally,
    over time, OSHA may modify rules and
    interpretations in light of new technology,
    information, or circumstances to keep apprised
    of such developments, or to review information on
    a wide range of occupational safety and health
    topics, you can visit OSHAs website at
    www.osha.gov.

47
Nature of Electrical Accidents
  • Electrical accidents, when initially studied,
    often appear to be caused by circumstances that
    are varied and peculiar to the particular
    incidents involved.
  • However, further consideration usually reveals
    the underlying cause to be a combination of three
    possible factors
  • work involving unsafe equipment installations
  • workplaces made unsafe by the environment
  • unsafe work performance (unsafe acts).
  • The first two factors are sometimes considered
    together and simply referred to as unsafe
    conditions.

48
ELECTRICAL HAZARD 1
  • Shock
  • Electricity has poor warning properties
  • Do you see that something is energized?
  • Can you smell that its energized?
  • Can you hear that its energized?
  • BUT You can FEEL its energized!

49
The sad numbers


  • The Bureau of Labor Statistics (BLS) data
    indicates 2,726 nonfatal electrical shocks
    involved days away from work a year, between 1992
    and 2001, in private industry.
  • The Occupational Safety and Health
    Administration (OSHA), estimates there are
    approximately 350 electrical-related fatalities a
    year, which roughly equals one fatality per day.
  • In addition, statistics from the National
    Institute for Occupational Safety and Health
    (NIOSH) show electrocution is the third- leading
    cause of death at work among 16 and 17-year-old
    workers, accounting for 12 percent of all
    workplace deaths.

50
What do we focus on?Rank the following.
  • Task
  • Safety Hazard
  • Distractions

51
There are other hazards in addition to shock
  • You can be injured or killed by electricity
    without touching it.

52
ARC FLASH
  • According to the National Fire Protection
    Association (NFPA), Arc-flash is an electric
    current that passes through air when insulation
    or isolation between electrified conductors is no
    longer sufficient to withstand the applied
    voltage. The flash is immediate, but the result
    of these incidents can cause severe injury
    including burns. Each year more than 2,000 people
    are treated in burn centers with severe arc flash
    injuries.

53
These also take a toll
  • A study by Capelli-Schellpfeffer, Inc. reports
    that between 5 and 10 arc-flash incidents causing
    serious injuries that require treatment in a burn
    center occur each day. Of these, 1 or 2 result in
    death.
  • A CDC/NIOSH study puts the total number of
    arc-flash injuries from 1992 through 2001 at
    17,101.

54
An event
  • Install a new 30 amp 3 phase 480 volt circuit
    breaker and hardware, to feed a newly installed
    sub-panel.
  • Decision work energized, since turning it off
    would to take too much time.

55
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56
The site after
57
The arc occurred
  • High Amperage Current arcing through air. This
    is initiated by contact between two energized
    points (generating intense heat, light, sound and
    pressure!).

58
Effects of the Incident
  • Both men were seriously burned and were
    transported by Helicopter and Ambulance to the
    Burn Center.

59
OSHAs Enforcement
  • Electrical Contractor Received
  • 5 Serious Citations
  • Assessment, PPE Training
  • 2 Willful Citations
  • Live Parts, PPE
  • General Contractor Received
  • 3 Serious Citations
  • Live Parts, PPE Training

60
ELECTRICAL HAZARD 3
  • ARC BLAST
  • Can NOT be easily calculated before
  • EXPLOSIVE with
  • Shock Wave
  • Shrapnel
  • molten
  • solid
  • Protection is IFFY
  • ES Work Practices can reduce probability
  • But not a guarantee

61
Scenario
  • Troubleshoot a transfer switch.
  • 13.2 KV in panel
  • Working on the 120 volt switch

62
Result
  • 3 seriously injured
  • 9 OSHA citations

63
1910.399 Definitions
  • The definition of a qualified Person has
    changed from One familiar with the construction
    and operation of the equipment and the hazards
    involved.
  • To One who has received training in and has
    demonstrated skills and knowledge in the
    construction and operation of electric equipment
    and installations and the hazards involved.

64
  • How
  • Accurate is it?
  • When was it updated?

65
This is a snapshot of a one line Do your
qualifiedpeople know how to read it?
66
ARC Warning Label ? Hazard level or PPE It is a
4160 Lighting arrestor
67
(No Transcript)
68
The victim thought the arrestor was on the load
side not the line sideDoes this meet the
definition of qualified?
69
Effects of Electrical Current
  • 0.5 - 3 mA - Tingling sensations
  • 3 - 10 mA - Muscle contractions and pain
  • 10 - 40 mA - Let-go threshold
  • 30 - 75 mA - Respiratory paralysis
  • 100 - 200 mA - Ventricular fibrillation
  • 200 - 500 mA - Heart clamps tight
  • 1500 mA - Tissue and Organs start to burn
  • You are twice as likely to be shocked rather than
    arced
  • Wear your gloves and test them.

70
OSHA and NFPA 70E
71
OSHA and 70E
  • OSHA tells us the WHAT
  • Uses broad, regulatory, non-prescriptive language
  • Performance standard you decide how
  • 70E tells us the HOW
  • Specific
  • Work practices
  • PPE selection
  • Hazard/Risk Analysis Methodology
  • Recommended forms

72
The Electrical Safe Work Practice Standards have
not changed.
  • OSHA IS THE SHALL
  • NFPA 70E IS THE HOW
  • Industry consensus standards, such as NFPA 70E,
    can be used by employers as guides to making the
    assessments and equipment selections required by
    the standard. Similarly, in OSHA enforcement
    actions, they can be used as evidence of whether
    the employer acted reasonably
  • Interpretation of 07/25/2003

73
1910.333 Selection and use of work practices --
electrical
  • (a) General. Safety-related work practices shall
    be employed to prevent electric shock or other
    injuries resulting from either direct or indirect
    electrical contacts, when work is performed near
    or on equipment or circuits which are or may be
    energized. The specific safety-related work
    practices shall be consistent with the nature and
    extent of the associated electrical hazards.

74
1910.333(a)(1) Deenergized parts.
  • Live parts to which an employee may be exposed
    shall be deenergized before the employee works on
    or near them, unless the employer can demonstrate
    that deenergizing introduces additional or
    increased hazards or is infeasible due to
    equipment design or operational limitations.

75
1910.333 (a)(1)Note 1
  • Examples of increased or additional hazards
    include interruption of life support equipment,
    deactivation of emergency alarm systems, shutdown
    of hazardous location ventilation equipment, or
    removal of illumination for an area.
  • NOTE The NFPA 70E code has removed the
    illumination exemption from its reasons

76
1910.333 (a)(1) Note 2 Infeasibility
  • Examples of work that may be performed on or
    near energized circuit parts because of
    infeasibility due to equipment design or
    operational limitations include testing of
    electric circuits that can only be performed with
    the circuit energized and work on circuits that
    form an integral part of a continuous industrial
    process in a chemical plant that would otherwise
    need to be completely shut down in order to
    permit work on one circuit or piece of
    equipment.

77
You can work energized when
  1. Deenergizing introduces additional or increased
    hazards
  2. It is infeasible
  3. This means the testing of electric circuits that
    can only be performed with the circuit energized
  4. and work on circuits that form an integral part
    of a continuous industrial process

78
What is a Continuous Process?
  • The term "continuous industrial process" was
    derived from its use in the National Electrical
    Code (NEC). In the NEC "continuous industrial
    process" is used in the context of situations
    where the orderly shut down of integrated
    processes and equipment would introduce
    additional or increased hazards.

Source 12/19/2006 interpretation click on link
below http//www.osha.gov/pls/oshaweb/owadisp.show
_document?p_tableINTERPRETATIONSp_id25559
79
To qualify an exception to de-energization one
must
  • Therefore, to qualify for the exception found in
    Note 2 of 1910.333(a)(1), the employer must, on
    a case-by-case basis, determine if the orderly
    shutdown of the related equipment (including the
    panel) and processes would introduce additional
    or increased hazards. If so, then the employer
    may perform the work using the electrical safe
    work practices found in 1910.331-1910.335,
    including, but not limited to, insulated tools,
    shields, barrier, and personal protective
    equipment.

80
Most working while energized is done out of
compliance with OSHA ESWP
  • If the orderly shutdown of the related equipment
    and processes would not introduce additional or
    increased hazards, but merely alter or interrupt
    production, then the de-energization of the
    equipment would be considered feasible, and the
    exception found in Note 2 of 1910.333(a)(1)
    would not apply.

81
So what is required if one is to work energized?
  • IT is a last resort to be used only if it is a
    greater hazard to de-energize or infeasible. You
    must have
  • Qualified worker(s)
  • PPE as required (Based on NFPA 70E tables or a
    study)
  • Shock protection (gloves, tools, restricted
    conductive aspects e.g. metal conductive
    articles)
  • Arc Flash protection (clothing, face shield
    hearing protection and more)
  • A Work Practice
  • Proper Tools i.e. Rated for the voltage

82
But testing is allowed (with protection)
  • NFPA 70E's Table 130.7(C)(9)(a), Hazard/Risk
    Category Classifications, referenced above, lists
    the task, "Work on energized parts, including
    voltage testing" and assigns it a "Hazard/Risk
    Category" of "1" or higher. Under Table
    130.7(C)(10), that categorization triggers
    various PPE provisions, including non-melting
    clothing, flame-resistant clothing, and other
    protective equipment.Thus, NFPA 70E is evidence
    that the industry recognizes the hazard of arc
    flash, that this hazard is present when testing
    voltage, and that, when present, it is necessary
    for PPE to be used to protect the employee from
    it

83
To verify de-energization
  • When one is to verify de-energization you must
    garb up in the appropriate PPE, because a
    de-energized system need to be verified.
    De-energized means all sources of potential
    hazards in the panel.
  • NFPA 70E is evidence that the industry
    recognizes the hazard of arc flash, that this
    hazard is present when testing voltage, and that,
    when present, it is necessary for PPE to be used
    to protect the employee from it.

http//www.osha.gov/pls/oshaweb/owadisp.show_docum
ent?p_tableINTERPRETATIONSp_id25973
84
1910.333(b)(2)(iv)(B)
  • A qualified person shall use test equipment to
    test the circuit elements and electrical parts of
    equipment to which employees will be exposed and
    shall verify that the circuit elements and
    equipment parts are deenergized. The test shall
    also determine if any energized condition exists
    as a result of inadvertently induced voltage or
    unrelated voltage backfeed even though specific
    parts of the circuit have been deenergized and
    presumed to be safe.

85
The job meets the exemption and I can work
energized
  • If the exposed live parts are not deenergized
  • Then safety-related work practices (which are
    usually poorly documented in the real world)
    shall be used to protect employees who may be
    exposed to the electrical hazards involved.

86
You must have a work practice.
  • Such work practices shall protect employees
    against contact with energized circuit parts
    directly with any part of their body or
    indirectly through some other conductive object.
    The work practices that are used shall be
    suitable for the conditions under which the work
    is to be performed and for the voltage level of
    the exposed electric conductors or circuit parts.
    Specific work practice requirements are detailed
    in paragraph (c) of this section

87
A Work Practice Requires
  • Only qualified persons may work on electric
    circuit parts or equipment that have not been
    deenergized under the procedures of paragraph (b)
    of this section. Such persons shall be capable of
    working safely on energized circuits and shall be
    familiar with the proper use of special
    precautionary techniques, personal protective
    equipment, insulating and shielding materials,
    and insulated tools.

88
1910.333(c)(8)
  • "Conductive apparel." Conductive articles of
    jewelry and clothing (such a watch bands,
    bracelets, rings, key chains, necklaces,
    metalized aprons, cloth with conductive thread,
    or metal headgear) may not be worn if they might
    contact exposed energized parts. However, such
    articles may be worn if they are rendered
    nonconductive by covering, wrapping, or other
    insulating means.

89
Remember in Definitions
  • The definition of a qualified Person has
    changed from One familiar with the construction
    and operation of the equipment and the hazards
    involved.
  • To One who has received training in and has
    demonstrated skills and knowledge in the
    construction and operation of electric equipment
    and installations and the hazards involved.
  • An Arc is an unplanned EVENT

90
Construction PPE
  • 1926.95(a) "Application." Protective equipment,
    including personal protective equipment for eyes,
    face, head, and extremities, protective clothing,
    respiratory devices, and protective shields and
    barriers, shall be provided, used, and maintained
    in a sanitary and reliable condition wherever it
    is necessary by reason of hazards of processes or
    environment, chemical hazards, radiological
    hazards, or mechanical irritants encountered in a
    manner capable of causing injury or impairment in
    the function of any part of the body through
    absorption, inhalation or physical contact.

91
1926.416(a) Protection of employees -
  • 1926.416(a)(1) No employer shall permit an
    employee to work in such proximity to any part of
    an electric power circuit that the employee could
    contact the electric power circuit in the course
    of work, unless the employee is protected against
    electric shock by deenergizing the circuit and
    grounding it or by guarding it effectively by
    insulation or other means.

92
To Clarify
  • A recent letter asks in effect the following
  • Whether employees who are verifying that an
    electrical system is de-energized or are turning
    off circuit breakers are required to use personal
    protective equipment.

Link to interpretation
93
The question
  • Question (1) Scenario Employees will be using
    an insulated device to verify that an electrical
    circuit that has been "turned off, locked, and
    tagged" is de-energized. Are these employees
    required to use Personal Protective Equipment
    (PPE) under OSHA's construction standard
    1926.416(a)(1) and/or NFPA 70E?

94
The response
  • the employees are exposed to the hazard of
    electric shock since, at the time they are doing
    the work, a determination that the circuit has
    been de-energized has not yet occurred.
    Therefore, under this provision, these employees
    must be protected against electric shock "by
    guarding the part by insulation or other
    means." When so guarded, under this provision,
    PPE would not be required to protect against the
    electric shock hazard.
  • HOWEVER

95
  • An additional hazard that may be associated with
    the work described in your scenario is that of
    arc flash. While Subpart K requirements have the
    effect of reducing the likelihood of an arc
    flash, Subpart K does not address the hazard that
    an arc flash poses to employees if it were to
    occur.
  • However, 29 CFR 1926.95(a) provides that
    Protective equipment, including personal
    protective equipment for eyes, face, head, and
    the extremities, protective clothing, respiratory
    devices, and protective shields and barriers,
    shall be provided, used, and maintained in a
    sanitary and reliable condition wherever it is
    necessary by reason of hazards

96
  • Industry consensus standards can be evidence that
    there is a hazard for which that PPE is
    "necessary." While the NFPA 70E consensus
    standard has not been adopted as an OSHA
    standard, it is relevant as evidence that arc
    flash is a recognized hazard and that PPE is
    necessary to protect against that hazard.

97
SO if it is being verified that it is off, wear
the PPE when testing
98
Of the arc flash incidents on the OSHA Database
  • ABOUT half occurred when testing.

99
Example
  • After servicing a water pump, employee 1 was
    unable to restart the pump and contacted his
    supervisor.
  • The supervisor met employee 1 at the pump's
    electrical control panel.
  • Employee 1 had thrown the electrical disconnect
    and opened the panel cover.
  • He checked inside the panel and saw no obvious
    faults such as blown fuses and decided to check
    the voltage with a voltmeter.
  • With the panel cover still open, employee 1
    re-energized the circuitry. With the supervisor
    holding the voltmeter, employee 1 took the leads
    and attempted to check the voltage when the arc
    flash occurred.
  • Employee 1 was not wearing gloves and received
    2nd and 3rd degree burns to his hands.

100
How do we start to comply?
  • Wear the right PPE
  • TURN IT OFF
  • TEST TO MAKE SURE IT IS OFF
  • But we have to work energized
  • Is it a greater hazard or infeasible or
    inconvenient? If not truly a greater hazard
    infeasible then you are in violation.

101
What is a recognized hazard?
  • NFPA 70E ( Is this a nationally recognized
    Consensus Standard which recognizes Arc Blast and
    Arc Flash?)
  • Does and Arc Blast or flash have the potential to
    cause serious harm?
  • Are there the basic requirements for a general
    duty clause violation?

102
We have come a long way
  • 158. Electricians often test circuits for the
    presence of voltage by touching the conductors
    with the fingers. This method is safe where the
    voltage does not exceed 250 and is often very
    convenient for locating a blown-out fuse or for
    ascertaining whether or not a circuit is alive.
    Some men can endure the electric shock that
    results without discomfort whereas others
    cannot
  • 159. The presence of low voltage can be
    determined by testing. The method is feasible
    only where the pressure is but a few volts and
    hence is used only in bell and signal work. Where
    the voltage is very low, the bared ends of the
    conductors constituting the two sides of the
    circuit are held a short distance apart on the
    tongue. If voltage is present a peculiar mildly
    burning sensation results, which will never be
    forgotten after one has experienced it.
  • American Electricians Handbook 1942

103
So there is a hazard
  • What do you do?
  • A. De-energize and Lockout
  • Dont forget to test to make sure its not live.

But we cant turn it off.
But we cant turn it off.
But we cant turn it off.
104
If you cant feasibly (????????) de-energize
  • 1. Evaluate what the hazards are and get an
    energized electrical work permit
  • 2. Select the right person to do the job
  • a.Trained in the process, and this means any
    helper assigned to assist must be qualified.
  • b. Give that person the PPE required based upon
    calculations or the table in 70E but read the
    footnotes.
  • 3. Use tools that are appropriate also
  • DO NOT INTRODUCE A HAZARD INTO A HAZARDOUS AREA!

105
What policy is the best policy ???
  • OSHA IS THE SHALL
  • NFPA 70E IS THE HOW

106
Energized Work Permit 1
  • Description and location of the work to be
    performed.
  • Justification why it is to be done live.
  • Greater Hazard
  • Infeasible
  • Not wanting to pay weekend or shift differential
    is not a valid reason.

107
Energized Work Permit 2
  • A description of the safe work practices to be
    used
  • Results of the shock hazard analysis
  • Shock Protection Boundary
  • Flash Hazard Analysis
  • Flash Protection Boundary

108
Energized Work Permit 3
  • The personnel protective Equipment needed
  • Means used to restrict the Access of unqualified
    people to the area
  • Evidence of a job briefing
  • Energized work approval by
  • Authorizing management or
  • Safety Officer or
  • Owner
  • WITH THEIR SIGNATURE

109
Recent events
  • Miller Coors

110
Next Steps for Compliance are ???
  • Glove Up
  • Tool Up
  • Dress Up
  • Work Safe

111
Gloves are your first line of defense
  • Insulated Rubber Gloves, ASTM Spec.
  • Leather Protectors, ASTM Spec.
  • Tested / Certified, OSHA 1910.137 Electrical
    Protective Devices

112
Gloves most common
Class 0
Class 2
113
1910.137(b)(2)(x)(D)
  • Rubber insulating gloves and sleeves with minor
    physical defects, such as small cuts, tears, or
    punctures, may be repaired by the application of
    a compatible patch. Also, rubber insulating
    gloves and sleeves with minor surface blemishes
    may be repaired with a compatible liquid
    compound. The patched area shall have electrical
    and physical properties equal to those of the
    surrounding material. Repairs to gloves are
    permitted only in the area between the wrist and
    the reinforced edge of the opening.

114
1910.137(b)(2)(xii)
  • The employer shall certify that equipment has
    been tested in accordance with the requirements
    of paragraphs (b)(2)(viii), (b)(2)(ix), and
    (b)(2)(xi) of this section. The certification
    shall identify the equipment that passed the test
    and the date it was tested.

115
Rubber Insulating Equipment Test Intervals
  • When to test
  • Upon indication that insulating value is suspect.
  • Same as above
  • Before first issue and every
  • 12 months thereafter(1)
  • 6 months thereafter(1)
  • 12 months thereafter(1)
  • Type of equipment
  • Rubber insulating line hose
  • Rubber insulating covers
  • Rubber insulating blankets
  • Rubber insulating gloves
  • Rubber insulating sleeves

Footnote(1) If the insulating equipment has been
electrically tested but not issued for service,
it may not be placed into service unless it has
been electrically tested within the previous 12
months
116
Insulated Hand Tools
Testing in accordance with ASTM F1505-01
10,000 VAC Dielectric Test (steel shot bath)
117
If you dont see this symbol . . . Its NOT truly
insulated
118
  • Voltage rated tools
  • shall be rated for the voltage on which they are
    used
  • shall be double insulated
  • built to ATSM F1505 standards(double triangle
    marking)
  • many tool are available in composite construction
  • rated at 1000 volts, tested to 10,000 volts
  • 3M 33 wrapped tool is not an insulated tool
  • tool must be inspected before each use

119
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120
Flash Hazard Analysis
  • 2-1.3.3. Flash Hazard Analysis Flash hazard
    analysis shall be done before a person approaches
    any exposed electrical conductor or circuit part
    that has not been placed in an electrically safe
    work condition
  • Whether based on industry tables or using
    analytical engineering techniques, a flash hazard
    analysis is a safety related (and required by the
    NFPA 70 E) must do for commercial, industrial,
    and utility electrical power systems.

121
How do we select the process
  • Get a copy of 70 E and look at the standard
  • Create a Decent one-line diagram of the
    electrical.
  • Find out who is exposed and use the tables as a
    start.
  • Train, get the PPE and Tools
  • Re-evaluate
  • Plan to re-engineer and add arc reducing fusing
    or breakers to reduce the arc potential
  • Enforce the rules

122
Identify the nearest disconnect
  • Most one lines do not identify the nearest
    disconnect unless it is an OCPD (over current
    protective device) So a simple switch will not be
    identified in the analysis.
  • Put the identity of the nearest upsteam
    disconnect on the label

123
You will go back to your jobsite
  • Safety director to maintenance electrician
  • I just learned about arc flash and blast, it
    scared the out of me.
  • Do you work energized?
  • Electrician to Safety director
  • I always turn it off
  • Thank You is the SD response

124
Now we have an OSHA inspection
  • CSHO to safety director
  • What do you have for an ESWP program?
  • SD to CSHO we never work energized we lock it out
    all the time.
  • CSHO to SD Thats good, well lets get started
    and go out to do the walk around inspection of
    your facility.

125
CSHO to Maint Electrician
  • What kind of testing devices do you have?
  • Sparky to CSHO , I have an ammeter, phase
    tester, a VOM from , a solenoid tester, an
    electrical field tester, and a few others.
  • What do you have to for PPE?
  • Sparky to CSHO, Safety glasses and a hard hat
    with muffs
  • CSHO HMMMMMMMMMM

126
CSHO to Maint Electrician
  • CSHO How old is this place
  • CSHO What kind of a system do you have to
    maintain?
  • Sparky to CSHO This place is 40 years old and we
    have added a lot of new equipment. The only new
    stuff is the buss bar on the new line.
  • CSHO, do you have any of those old 70s breakers?
  • Sparky yes, We replace them when they fail.

127
CSHO to Maint Electrician
  • Do you have a one line diagram?
  • Sparky, somewhere I think
  • So when you have to trouble shoot a problem in
    this old plant what do you use.
  • Sparky, Ive been in this plant for 29 years.
  • Any new guys like you?
  • Sparky, yea Curly and Mo retired so they hired
    Larry We are training him.

128
CSHO to Maint Electrician
  • What is your up time goal
  • Sparky, 90
  • So when you troubleshoot and find the problem,
    you always turn the power off?
  • Sparky, Welllllllllll. Sometimes we cant
  • When cant you?
  • Sparky, The new line has one main disconnect,
    that kills the program if you turn it off. We
    did it once and the production supt had a fit.

129
Any other times that you cant turn it off?
  • Sparky, No
  • You mean you know where every thing is fed from?
  • Sparky, Welllllllllll, most of the time
  • What about your new guy Larry
  • Sparky, Oh he is just learning
  • So he guesses

130
CSHO to Maint Electrician
  • Could I look in your tool box?

131
Electricians Tools
Gouge Weld Mark
Electrical Tape as Insulation
132
CSHO to Maint Electrician
  • So you do work energized,
  • Your tools are not rated,
  • You have no idea of the calorie levels to which
    you are exposed,
  • You have no arc PPE and you work hot swapping
    buss plugs from a ladder.
  • You dont have any live work procedures.
  • Sparky Yea, but I am careful.

133
CSHO to Safety Director
  • You were made aware of Arc Flash and Blast at the
    ________
  • You have ignored all of the hazards
  • You will be receiving correspondence from us in
    the future. Now let us discuss some abatement
    dates.

134
OR
  • You have the example of a VPP company that did
    their homework, and protected their people.

135
WOOD RIVER
Tuesday, Wood River experienced a significant
electrical arc flash incident in one of the
substations.  there were ___injuries and it
looks as though they will have the substation
back in service in the next 3 or 4 days.
136
What does a new hood look like?
137
  • One of the two feeders to their substations had
    been replaced during a turnaround. 
  • Both main feeders had been energized but not yet
    tied together or double-ended. 
  • Prior to connecting the new energized feeder to
    the substation, phase testing was being performed
    in order to validate that all three phases on
    both feeders were aligned in the appropriate
    position. 
  • This is mandated by procedure because closing the
    tie when the feeders are out of phase would
    result in a major fault. 

138
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139
The arc
  • They speculate that the initiating event occurred
    when the metal edge on one of the voltage meter
    probes touched the edge of the grounded steel
    shutter. 
  • The arc occurred and

140
The employee was protected
  • You can see in next slide how the hood looked
    after being exposed to the arc flash but what you
    cant see is that the inside of the hood looks
    like new.  A few years ago they upgraded their
    electrical safe work practices and their
    electrical PPE to state of the art gear

141
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142
Both of these were during testing
  • What is better?
  • A Replacing protective clothing or
  • B. Getting skin grafts?

143
BNSF Arc Flash Incident
  • Background
  • 480V breaker
  • On 03/04/2009 at 0840 hours an electrical
    flashover was reported while  the contractor was
    trying to find information regarding 480 V
    breakers.  This resulted in injuring three
    contractor employees one with first degree burn
    and two with 2nd degree burns.  All the victims
    were transported to clinic for first aid
    treatment and then transported to Care Hospital
    for further examination and treatment.

144
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145
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146
NFPA 70E
  • 110.4 Multiemployer Relationship.
  • (A) Safe Work Practices. On multiemployer
    worksites (in all industry sectors), more than
    one employer may be responsible for hazardous
    conditions that violate safe work practices.

147
OSHA Multi-employer Worksite Policy
  • On multi-employer worksites (in all industry
    sectors), more than one employer may be citable
    for a hazardous condition that violates an OSHA
    standard.

148
NFPA 2004 70 E 110.4 on Multiemployer
Relationship.
  • (B) Outside Personnel (Contractors, etc.).
    Whenever outside servicing personnel are to be
    engaged in activities covered by the scope and
    application of this standard, the on-site
    employer and the outside employer(s) shall inform
    each other of existing hazards, personal
    protective equipment/clothing requirements, safe
    work practice procedures, and emergency/evacuation
    procedures applicable to the work to be
    performed. This coordination shall include a
    meeting and documentation.

149
NFPA 2009 70 E on Multiemployer Relationship
  • 110.5 Relationships With Contractors (Outside
    service personnel, etc.)
  • (A) Host Employer Responsibilities.
  • (1) The host employer shall inform contract
    employers of
  • (a) Known hazards that are covered by this
    section, that are related to the contract
    employers work, and that might not be recognized
    by the contract employer or its employees and
  • (b) Information about the employers installation
    that the contract employer needs to make the
    assessments required by Chapter 1.
  • (2) The host employer shall report observed
    contract-employer-related violations of this
    section to the contract employer.

150
(B) Contract Employer Responsibilities.
  • 1) The contract employee shall ensure that each
    of his or her employees is instructed in the
    hazards communicated to the contract employer by
    the host employer. This instruction is in
    addition to the basic training required by this
    standard.
  • (2) The contract employer shall ensure that each
    of his or her employees follows the work
    practices required by this standard and
    safety-related work rules required by the host
    employer.
  • (3) The contract employer shall advise the host
    employer of
  • (a) Any unique hazards presented by the contract
    employers work,
  • (b) Any unanticipated hazards found during the
    contract employers work that the host employer
    did not mention, and
  • (c) The measures the contractor took to correct
    any violations reported by the host employer
    under paragraph (A)(2) of this section and to
    prevent such violation from recurring in the
    future.

151
Who got the system up and running before you went
to work on it today
152
What is the interrupting capability of a grade 8
bolt?
153
  • www.osha.gov

Patrick Ostrenga Compliance Assistance Specialist
OSHA Milwaukee, WI 414-297-3315 ostrenga.patrick_at_
dol.gov
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