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Personal Protective Equipment : Changes & Electrical Contractors Presented By: Jerry Rivera Director of Safety, NECA Objectives OSHA Act NFPA 70E OSHA Letters of Interpretation Compliance Guide Questions Occupational Safety and Health Act OSHA Act 1970 – – – To assure safe and healthful working conditions authorizing enforcement of the standards developed under the Act Providing research, information, education OSHA General Duty Clause Section 5: Duties – (a) Each Employer – – Shall furnish to each of his employees employment and a place of employment free from recognized hazards Shall comply with occupational safety and health standards OSHA General Duty Clause Section 5: Duties – (b) Each employee shall comply with: – – occupational safety and health standards regulations and orders issued pursuant to this Act which are applicable to his own actions and conduct 29 CFR 1910 Subpart I 1910.132(a) – Protective equipment: eyes, face, head, and extremities protective clothing, respiratory devices, and protective shields 29 CFR 1910 Subpart I 1910.132(d) – Hazard assessment and equipment selection. 1910.132(d)(1) – The employer shall assess the workplace to determine if hazards are present, or are likely to be present 29 CFR 1910 Subpart I 1910.132(d)(1)(i) – Select, and have each affected employee use, the types of PPE that will protect the affected employee 1910.132(d)(1)(ii) – Communicate selection decisions to each affected employee. 29 CFR 1910 Subpart I 1910.132(f)(1) The employer shall provide training to each employee to know at least the following: – – – – – – When What How to properly don on and off Limitations Proper care Demonstrate understanding 29 CFR 1926 Subpart E 1926.95(a) – Protective equipment: eyes, face, head, and extremities protective clothing, respiratory devices, and protective shields 29 CFR 1926 Subpart E 1926.95(b) – – Employee-owned equipment employer shall be responsible to assure its adequacy, including proper maintenance, and sanitation of such equipment. 1926.95(c) – All personal protective equipment shall be of safe design and construction for the work to be performed. 29 CFR 1926 Subpart E 1926.95(d) – Payment for Protective Equipment 1926.95(d)(1) – Includes personal protective equipment (PPE), used to comply with this part, shall be provided by the employer at no cost to employees 29 CFR 1926 Subpart E 1926.95(d)(4) – The employer is not required to pay for: Everyday clothing, street shoes, and normal work boots 1926.95(d)(5) – – The employer must pay for replacement PPE Except when the employee has lost or intentionally damaged the PPE 29 CFR 1926 Subpart E 1926.95(d)(7) – – Became effective on February 13, 2008 Must implement the PPE payment requirements no later than May 15, 2008 Employer Payment For PPE Final Rule Establishes a uniform requirement for employers payment of PPE required This rule does not set forth new requirements Merely requires employers to pay for the PPE that is used in complying with OSHA regulations Industry Standards Some of the Construction Industry standards were adopted under the Construction Safety Act. Subsequently adopted under OSHA Standards pursuant to Section 6(a). Industry Standards NFPA 70E January 1976 Formal appointment of electrical standard committee (NFPA 70E) Formed to assist OSHA Electrical safety standards could be promulgated under Section 6(b) OSHA Act Standard Interpretations 02/29/2008 – – Question: Whether employees who are verifying that an electrical system is deenergized or are turning off breakers are required to use personal protective equipment Answer: Industry consensus standards can be evidence that there is a hazard for which that PPE is necessary NFPA 70E 90.2 Scope – This standard addresses electrical safety requirements for employee workplaces that are necessary for the practical safeguarding of employees during activities such as the installation, operation, maintenance, and demolition of electric conductors, electric equipment, signaling and communications conductors and equipment, and raceways. Article 110 110.2 Purpose – Intended to provide the employee safety relative to electrical hazard in the workplace Article 110 110.3 Responsibilities – Shall be implemented by employees – The employers shall provide the safety related work practices and shall train the employees who shall then implement them. NFPA 70E 110.5 Relationship (A) Host employer responsibilities (B) Contact Employer Responsibilities Hazard communication Host employer must require employees to abide by safety related rules Advise host employer of any unique unanticipated or measure to correct NFPA 70E 110.6 Training Requirements (A) Safety Training Qualified person, unqualified person (B) Types of training Metering equipment (E) Emergency procedures First aid and CPR (D) Employee Training Documented NFPA 70E 110.7 Electrical Safety Programs (D) Electrical Safety Controls (F) Hazard/Risk Evaluation Procedures Limited Approach Boundaries before work starts (G) Job Briefing General Repetitive task Routine Work NFPA 70E (H) Electrical Safety Audits – Shall be audited – Frequency established by employer – Changes Review OSHA Regulation Acknowledge Changes Industry Standards Before Addressing PPE Electrical Hazards Types of Electrical Hazards Shock Arc Flash Arc Blast – – – Bureau of Labor Statistic reports 3,378 died from electrical injuries in workplace (19922002). Electrocutions are the forth leading cause of work related death. Numbers do not favor the Electrical Industry. Personal Protective Equipment Hazards Assessments Employee Exposure Training Personal Protective Equipment Selection Payment Industry Standards Written – Performance language – Technical Confusing – NECA Voice Electrical Industry Code Making Panels (NEC) Including NFPA 70E NECA Publications NECA – Arc Flash/Shock Analysis – Flash Protection Boundaries – Hazard Risk categories Arc Flash Energy Levels Required within the Flash Protection Boundary Based on Flash Hazard Analysis as well as other hazards Clothing as PPE? – – * non-melting * Flame-Resistant (FR) Arc Flash Energy Levels Calculate Incident Energy Level (cal/cm2) Select the Hazard / Risk Category using Table 130.7(C)(11) Verify calculations of Hazard/Risk Category using Table 130.7(C)(9)(a) NECA Publications Eliminates the guessing game Practical Easy to Use NECA’s PPE Selector Personal Protective Equipment (head-toe) Insulated Tools Clothing as PPE? – * non-melting – * Flame-Resistant NECA’s PPE Selector Based on tasks Hazardous Risk Categories Personal Protective Equipment Selection NECA Publications Head to Toe Insulated Tools Metering Equipment – – Fluke Others NECA LOTO Guide Identify electrically safe work condition Procedures necessary for implementing a Lockout/Tagout Differences between a simple and complex Lockout/Tagout NECA LOTO Guide LOTO PREPARATION Review Company Written LOTO Plan Identify energy sources including stored energy identify procedures to release stored energy Means for verifying disconnection Identify workers affected or exposed Ensure employees are trained NECA LOTO Guide a) How energy controlled b) Ensures exposed understand hazards c) Method for accounting NECA Publications User friendly Lots of visuals Road map for compliance NECA Publications Nancy Sipe, Customer Service Representative – – Order Desk 301-215-4504 [email protected] OSHA Reminder Most Frequent Citations – Electrical lockout/tagout – Electrical wiring methods, components and equipment – Electrical system design Largest Fines – – Electrical (classified) locations Electrical lockout/tagout Do you have exposure? Employees coming in contact with energized electrical conductors or circuit parts with the hands, feet, or other body parts, with tools, probes, or with test equipment What is PPE? Question: Do employers have to pay for lineman belts and hooks when used to comply with an OSHA standard? Response: Yes. Lineman belts and hooks provide protection to employees from falls while climbing and/or performing work. This equipment is PPE and employers must pay for it when the equipment is used to comply with an OSHA standard. OSHA Citations Compliance OSHA- Shall requirements (law) NFPA 70E – Provides guidance in meeting the OSHA regulations NECA Publications – Offer practical guidance for contractors and installers Questions to Consider Personal Protective Equipment Programs – – – – – – Exposure Hazard Assessment Level of Protection Personal Protective Equipments Required Training Payment Method Any Questions? Contact: Jerry Rivera Director of Safety, NECA [email protected] 301-215-4546