Transcript Slide 1

Initiating ESWP
Electrical Safe Work Practices
(aka Arc Flash/Blast NFPA 70 E)
Patrick Ostrenga
Retired OSHA Compliance
Assistance Specialist
1
NRTL
Or what does OSHA accept
2
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
3
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.
4
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
5
So what does OSHA cite
6
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
7
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.
8
1910.399 Definitions
Acceptable.
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
A definition is not citable by OSHA but the
standard that uses that definition is!
9
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
10
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
11
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.
12
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.
13
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 considerations:1910.303(b)(1)(i) Suitability
for installation and use in conformity with the provisions
of this subpart;
Note 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.
14
This is what I used to train OSHA
employees in how to issue citations
A potential avd 1910.303(b)(1)(i)
• 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
15
What’s new
• New PPE directive
• What is PPE?
– Personal protective equipment
• LINK
• http://www.osha.gov/OshDoc/Directive_pdf
/CPL_02-01-050.pdf
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17
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.
18
Question
•
When an employer decides to use flameresistant 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?
19
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). …
20
• 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
21
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.
22
ELECTRICAL HAZARD 1
• Shock
•
•
•
•
•
Electricity has poor warning properties
Do you see that something is energized?
Can you smell that it’s energized?
Can you hear that it’s energized?
BUT You can FEEL it’s energized!
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There are other hazards in addition
to shock
• You can be injured or killed by electricity
without touching it.
25
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.
26
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.
27
ELECTRICAL HAZARD 2
• ARC Flash
•
•
•
•
•
Can be calculated before
Thermal effect
Protection is based on a 1.2 cal/cm2
PPE can protect from the flash but…
ES Work Practices can reduce probability
of an occurrence But not a guarantee
28
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.
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The site after
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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!).
32
33
Effects of the Incident
• Both men were
seriously burned and
were transported by
Helicopter and
Ambulance to the
Burn Center.
34
OSHA’s 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
35
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
36
Scenario
• Troubleshoot a transfer switch.
• 13.2 KV in panel
• Working on the 120 volt switch
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Result
• 3 seriously injured
• 9 OSHA citations
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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.
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• How
• Accurate
is it?
• When was
it
updated?
42
This is a
snapshot
of a one
line
Do your
“qualified”
people
know how
to read it?
43
ARC
Warning
Label ?
Hazard level
or PPE
It is a 4160
Lighting
arrestor
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45
The victim thought the arrestor
was on the load side not the line
side
Does this meet the definition of
qualified?
46
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.
47
OSHA and NFPA 70E
48
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
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The Electrical Safe Work Practice
Standards have not changed.
• OSHA IS THE SHALL &
• NFPA 70E IS THE HOW
OSHA recommends that employers consult
consensus standards such as NFPA 70E-2004
to identify safety measures that can be used to
comply with or supplement the requirements
of OSHA's standards for preventing or
protecting against arc-flash hazards.
Interpretation of November 14, 2006
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§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 safetyrelated work practices shall be consistent with the nature
and extent of the associated electrical hazards.”
51
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.”
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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
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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.”
54
You can work energized when;
1. Deenergizing introduces additional or
increased hazards
2. It is infeasible
1. This means the testing of electric circuits that
can only be performed with the circuit
energized
2. and work on circuits that form an integral part
of a continuous industrial process
55
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_docum
ent?p_table=INTERPRETATIONS&p_id=25559
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To qualify an exception to deenergization 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.
57
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.
58
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
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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
60
To verify de-energization
• When one is to verify de-energization you must
garb up in the appropriate PPE, because a deenergized system need to be verified. Deenergized 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_document?p_table=INTERPRETATIONS&p_id=25973
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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.
62
Electrical Safety
• Special Training is required for work on
electrical equipment
• Only Authorized QUALIFIED !!!!!
Employees may conduct electrical work
Special Training
• Training for Authorized Employees
MUST cover:
–
–
–
–
–
Safe Work Practices
Isolation of Electrical Sources
Test Equipment
Tools & PPE
Other aspects
Hazards
• Electrical Hazards Include
– Electrical Shock
– Electrical Explosions Arc Blast
– Electrical Burns Arc Flash
• These can result in severe injury or death
Safe Work Practices
• Before starting work…
– De-energize, Lock, Tag and Test all circuits of 50
volts or less
– Deenergize all Power Sources
– Disconnect from all electric energy sources
Control circuit devices such as…
– push buttons
– selector switches
– interlocks
…may not be used as the sole means for
de-energizing circuits or equipment.
Lock & Tag…
• Lock & Tag all Sources
– Place Lock & Tag on each disconnecting
means used to de-energize circuits
– Attach Lock so as to prevent operating the
disconnecting means
– Place Tag with Each Lock
If a Lock cannot be applied…
• A tag used without a lock must be supplemented
by at least one additional safety measure that
provides a level of safety equal to that of a lock.
• Examples:
– Removal of an isolating circuit element such as
a fuse
– Blocking of a controlling switch
– Opening of an extra disconnecting device.
Release Stored Energy…
• Stored electric energy must be released
before starting work.
– Discharge all Capacitors &
– Short-Circuit & Ground all high capacitance
elements
Is it “Dead”?…MILAB
• Verify System is De-energized
– Operate the equipment
controls to check that
equipment cannot be
restarted.
– Use test equipment to test each component of
circuits & electrical parts for voltage & current
– Garb up in the ATPV rated clothing
•
What do we do if we have to work
energized?
• First determine if one really cannot turn it
off. (inconvenience is not a VALID
reason)
• Then do a hazard evaluation.
– Find out who is exposed
– Verifying that a circuit is de-energized is an
exposure that may need protection.
71
You mean using a meter requires PPE?
• Yes, NFPA 70E (a nationally recognized
standard) notes in Table 130.7(C)(9) that the
following task requires the use of PPE ranging
from Hazard Risk Category 1 to Category 4 or
from (1.2 to 40 Cal cm2)
• “Work on energized electrical conductors and
circuit parts, including voltage testing”
72
Do we have to do an arc flash
evaluation?
• You must protect your employees from a hazard. To
determine the level of protection you must find out
what they are exposed to.
• Your path to compliance is either the tables in NFPA
70E or an electrical site evaluation or an equivalent.
• Plain Language; Either you follow the tables if
you are able to or a do an electrical site
engineering study
73
130.5 Arc Flash Hazard Analysis.
• An arc flash hazard analysis shall determine the Arc Flash
Protection Boundary and the personal protective equipment
that people within the Arc Flash Protection Boundary shall
use. The arc flash analysis shall be updated when a major
modification or renovation takes place. It shall be reviewed
periodically, not to exceed five years to account for changes in
the electrical distribution system that could affect the results of
the arc flash analysis. The arc flash analysis shall take into
consideration the design of the overcurrent protective device
and its opening time including its condition of maintenance.
74
You have to do a hazard assessment
for the PPE, in this case it is a Flash
Hazard Analysis
• You have two choices in NFPA 70 E
• Do an analysis of the entire system
• Follow the tables and read the limitations
(Most do not read the or understand the footnotes
which in the new 2012 code are in the tables because
most sites ignored them)
75
So how do we find out what level of
protection our people need.
• You must find out what you have in the facility for
OCPD (what‘s that?)
• Over Current Protective Devices
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Check your tester…
• Check test equipment (Volt-Ohm Meter) on a
known live source of same rating to ensure it
works before and after checking the circuit on
which you will be working
• Is your tester appropriate
• Class III or IV?
• Cheap testers are not a good thing.
Re-energizing Equipment…
– Conduct tests and visual inspections to ensure
all tools, electrical jumpers, shorts, grounds,
and other such devices have been removed
– Warn others to stay clear of circuits and
equipment.
– Each lock and tag must be removed by the
person who applied it
– Visually check that all employees are clear of
the circuits and equipment.
Energized….
• Working with Energized Parts
Persons working on energized equipment must be
familiar with the proper use of special
precautionary techniques, personal protective
equipment, insulating and shielding materials,
and insulated tools.
Working on energized circuits
• When working on energized circuits
–
–
–
–
–
Isolate the area from all traffic
Post signs & barricades
Use an attendant if necessary
Use insulated tool, mats and sheeting
Use electrical rubber sheeting to cover nearby
exposed circuits
Conductive Materials
• Conductive materials and equipment must
be handled so as to prevent them from
contacting exposed energized conductors or
circuit parts
Conductive Apparel
• Remove all conductive articles of jewelry
and clothing, such a watch bands, bracelets,
rings, key chains, necklaces, metalized
aprons, cloth with conductive thread, or
metal headgear.
Turning off breakers
• What do we need
• link
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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.
84
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
85
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.
86
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.
87
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.
88
• An Arc is an unplanned EVENT
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.
89
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.
90
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
91
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?
92
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 deenergized 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
93
• 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…
94
• 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.
95
SO if it
is being
verified
that it is
off,
wear
the PPE
when
testing
96
Of the arc flash incidents on the
OSHA Database
• ABOUT half occurred when testing.
97
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.
98
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?
99
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
100
So there is a hazard
• What do you do?
– A. De-energize and Lockout
– Don’t forget to test to make sure it’s not live.
But we can’t turn
it off.
But we can’t turn
it off.
But we can’t turn
it off.
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If you can’t 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!
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What policy is the best policy ???
OSHA IS THE SHALL
&
NFPA 70E IS THE HOW
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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.
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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
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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
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Next Steps for Compliance are ???
•Glove Up
•Tool Up
•Dress Up
•Work Safe
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Gloves…
are your first line of defense
• Insulated Rubber Gloves, ASTM Spec.
• Leather Protectors, ASTM Spec.
• Tested / Certified, OSHA 1910.137
“Electrical Protective Devices”
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Gloves… most common
Class 0
Class 2
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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.
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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.
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Rubber Insulating Equipment Test Intervals
• Type of equipment
• Rubber insulating line
hose|
• Rubber insulating covers
• When to test
• Upon indication that
insulating value is suspect.
• Same as above
• Before first issue and every…
• Rubber insulating blankets • 12 months thereafter(1)
• Rubber insulating gloves
• 6 months thereafter(1)
• Rubber insulating sleeves • 12 months thereafter(1)
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
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Insulated
Hand
Tools
Testing in accordance
with ASTM F1505-01
10,000 VAC Dielectric Test
(steel shot bath)
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If you don’t see this
symbol . . .
It’s NOT truly insulated
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• 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
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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.
• Source
– DIRECTIVE NUMBER: CPL 02-01-050
EFFECTIVE DATE: February 10, 2011
– SUBJECT: 29 CFR Part 1910, Subpart I, Enforcement
Guidance for Personal Protective Equipment in General
Industry
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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
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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
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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
120
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 That’s good, well let’s get
started and go out to do the walk around
inspection of your facility.
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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
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CSHO to Maint Electrician
• CSHO How old is this place and 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 breakers?
• Sparky yes, We replace them when they fail.
• (this tells us that there is no OCPD maintenance
program)
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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, I’ve 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.
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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 can’t
• When can’t 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 manager had a fit.
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Any other times that you can’t 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.
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CSHO to Maint Electrician
• Could I look in your tool box?
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128
Electricians’ Tools
Electrical Tape as
Insulation
Gouge –
Weld Mark
129
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 don’t have any live work procedures. And
when you do test you are exposed to a shock, flash
and blast hazard.
• Sparky Yea, but I am careful.
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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.
131
OR
• You have the example of a VPP company
that did their homework, and protected their
people.
132
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.
133
What does a new hood look like?
134
• 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.
135
136
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
137
The employee was protected
• You can see in next slide how the hood
looked after being exposed to the arc flash
but what you can’t 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
138
139
Remember what the “before” looked
like?
140
or
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142
143
144
145
146
147
148
Both of these were during testing
• What is better?
A
Replacing protective clothing or
B. Getting skin grafts?
149
!!!!WARNING!!!!
• The following slides are very
graphic.
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155
BNSF Arc Flash Incident
• Background
– 480V breaker
– On 03/04/2009 at 08:40 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.
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163
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.
164
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.
165
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.
166
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 employer’s work, and that might not
be recognized by the contract employer or its employees;
and
• (b) Information about the employer’s installation that the
contract employer needs to make the assessments required
by Chapter 1.
• (2) The host employer shall report observed contractemployer-related violations of this section to the contract
employer.
167
(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 employer’s
work,
(b) Any unanticipated hazards found during the contract
employer’s 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.
168
2012 NFPA70 E code
169
110.1 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 standard, that
are related to the contract employer’s work, and that might
not be recognized by the contract employer or its
employees
• b. Information about the employer’s 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 standard to the contract
170
employer.
(B) Contract Employer Responsibilities.
(1) The contract employer 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 safetyrelated work rules required by the host
171
employer.
(B) Contract Employer Responsibilities
Continued.
(3) The contract employer shall advise the host
employer of:
a. Any unique hazards presented by the contract
employer’s work,
b. Any unanticipated hazards found during the
contract employer’s 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
172
Who got the system up and running
before you went to work on it today
173
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175
What is the
interrupting
capability of
a grade 8
bolt?
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•Contact info
Patrick Ostrenga
Retired OSHA Compliance
Assistance Specialist
414-530.9305
[email protected]
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