Transcript WITC New Richmond-No..

Electrical Safety
Electrical Hazards
Arc Blast
Arc Flash
WITC April 2011
NRTL
Or what does OSHA accept
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
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.
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
So what do we cite
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
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.
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
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
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
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.
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.
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.
This is what I use 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
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
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.
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?
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). …
• 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
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.
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
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.
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?
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?
Pick One
A Kill the main and reset while deenergized
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 don’t need that hot clothing.
D The preferred ?
Result
• 1 Dead
• 2 Injured
• OSHA citations
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
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
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.
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.
You need to Co-ordinate your
system
• Amperage
• Interrupting time
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”
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.
Remember Maintenance
is an Issue
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;
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)
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
Electrical Safety
Electrical Hazards
Arc Blast
Arc Flash
Initiating ESWP
Electrical Safe Work Practices
(aka Arc Flash/Blast NFPA 70 E)
Patrick Ostrenga
Compliance Assistance Specialist
Milwaukee Area Office / Region V
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 employer’s 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 OSHA’s website at www.osha.gov.
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.
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!
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.
What do we focus on?
Rank the following.
•Task
•Safety Hazard
•Distractions
There are other hazards in addition
to shock
• You can be injured or killed by electricity
without touching it.
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.
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.
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.
The site after
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!).
Effects of the Incident
• Both men were
seriously burned and
were transported by
Helicopter and
Ambulance to the
Burn Center.
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
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
Scenario
• Troubleshoot a transfer switch.
• 13.2 KV in panel
• Working on the 120 volt switch
Result
• 3 seriously injured
• 9 OSHA citations
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.
• How
• Accurate
is it?
• When
was it
updated?
This is a
snapshot
of a one
line
Do your
“qualified”
people
know how
to read it?
ARC
Warning
Label ?
Hazard level
or PPE
It is a 4160
Lighting
arrestor
The victim thought the arrestor
was on the load side not the
line side
Does this meet the definition
of qualified?
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.
OSHA and NFPA 70E
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
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
§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.”
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.”
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
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.”
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
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
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.
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.
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 deenergize 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
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
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
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.
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.
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
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.
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.
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
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.
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.
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
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?
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
• 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…
• 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.
SO if it
is
being
verified
that it
is off,
wear
the
PPE
when
testing
Of the arc flash incidents on the
OSHA Database
• ABOUT half occurred when testing.
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 reenergized 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.
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.
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?
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
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.
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!
What policy is the best policy
???
OSHA IS THE SHALL
&
NFPA 70E IS THE HOW
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.
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
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
Recent events
• Miller Coors
Next Steps for Compliance are
???
•Glove Up
•Tool Up
•Dress Up
•Work Safe
Gloves…
are your first line of defense
• Insulated Rubber Gloves, ASTM Spec.
• Leather Protectors, ASTM Spec.
• Tested / Certified, OSHA 1910.137
“Electrical Protective Devices”
Gloves… most common
Class 0
Class 2
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.
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.
Rubber Insulating Equipment Test Intervals
• Type of equipment
• Rubber insulating line
hose|
• Rubber insulating
covers
• Rubber insulating
blankets
• Rubber insulating
gloves
• Rubber insulating
sleeves
• 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)
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
Insulated
Hand
Tools
Testing in accordance
with ASTM F1505-01
10,000 VAC Dielectric Test
(steel shot bath)
If you don’t see this
symbol . . .
It’s NOT truly insulated
• 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
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.
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
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
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
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.
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
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.
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.
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 supt
had a fit.
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
CSHO to Maint Electrician
• Could I look in your tool box?
Electricians’ Tools
Electrical Tape as
Insulation
Gouge –
Weld Mark
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.
• Sparky Yea, but I am careful.
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.
OR
• You have the example of a VPP company
that did their homework, and protected
their people.
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.
What does a new hood look like?
• 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 doubleended.
• 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
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
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
Both of these were during
testing
• What is better?
A
Replacing protective clothing or
B. Getting skin grafts?
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.
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.
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.
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.
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.
(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
Who got the system up and running
before you went to work on it today
What is the
interrupting
capability of
a grade 8
bolt?
•www.osha.gov
Patrick Ostrenga
Compliance Assistance Specialist
OSHA
Milwaukee, WI
414-297-3315
[email protected]