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Q: When did Federal OSHA revise OSHA 1910.269 and OSHA 1926 Subpart V?

A: On April 11, 2014, Federal OSHA published the updated OSHA 1910.269 and OSHA 1926 Subpart V.

Lift Truck Line grounding coverup

Q: I am being told by some in the electric utility industry that my harness must be "arc-rated."

A: A quote from David Wallis, ESCI Director of Standards and Work Rules, and the author of 29 CFR OSHA 1910.259(l)(8):

"FR Body Protection which includes FR clothing and proper PPE is for the protection of the body. A harness does not provide arc flash protection for the body."

OSHA requires the harness to meet the ASTM F887-04 or later standard. For a harness to be compliant with ASTM F887 the manufacturer must expose the harness to a 40 cal arc flash, then immediately drop test it. If the harness passes, it is compliant with ASTM F887.

David recently answered a similar question with the following:

Q: 30 of the Q&A on the electric power standard (osha.gov/dsg/power_generation) states that harnesses and shock-absorbing lanyards meeting ASTM F887-04, or later versions of that standard through ASTM F887-13, be deemed to comply with the provisions requiring personal fall arrest equipment used by employees who are exposed to hazards from flames or electric arcs to be capable of passing a drop test after exposure to an electric arc with a heat energy of 40 ± 5 cal/cm2.

A: OSHA estimated that nearly all fall protection equipment in use in electric power industries in 2014 met ASTM F887-04 or later and that employers would not need to replace any fall protection equipment because of the new arc-related testing requirements. (The fall protection costs assumed in the economic analysis resulted from the purchase of work positioning equipment that would arrest an employee's fall.) Note that there is no such thing as fall protection equipment with an arc rating. OSHA relied on the definition of "arc rating" in ASTM F1506-02ae1, which read: "the maximum incident energy (E1) resistance demonstrated by a material prior to breakopen or at the onset of a second-degree burn."

To my knowledge, no fall protection equipment has been tested to achieve an arc rating meeting this definition by the test method in ASTM F1959. (Nor will this equipment meet ASTM F1506, which OSHA relies on for arc ratings.) In addition, the purpose of assigning an arc rating for a material is to determine that material's ability to protect an individual from the heat energy from an electric arc. Neither harnesses nor lanyards will provide such protection. Consequently, any "arc rating" provided by the manufacturer of such equipment would not be valid. The purpose of the arc-related requirements in §§1910.269(g)(2)(ii) and 1926.954(b)(1)(ii) is to ensure that the fall protection equipment will arrest a fall after exposure to an electric arc. It is not to protect an employee wearing the fall protection equipment from the heat energy from an electric arc.

Q: Two qualified workers cover-up all three phases of a 12.5 kV overhead pole including covering all three phases with rated plastic cover-up, the arms and pole with rated cover and even the common neutral. Both workers then return to the ground and one worker leaves the worksite. Can one qualified worker by them self go back up, enter MAD and install a cutout on the arm with everything completely covered with rated cover-up?

A: No, per OSHA 1910.269(L)(1), one qualified worker cannot enter MAD and do any work by them self, even with all the exposed conductors and equipment covered with rated cover-up. It requires two workers, one to perform the work and the second to be a safety watch for the first to perform any work within the MAD of a 12.5 kV line.

Q: A follow-up question to the one above. Can one qualified worker wearing rated gloves and sleeves enter MAD and install a cutout on the arm with everything completely covered with rated cover-up?

A: No, it does not matter if the worker is wearing rated gloves and sleeves and all exposed lines and equipment are covered with rated cover-up, it will take two workers to perform any work within MAD.

Q: There are a number of unanswered questions related to when rated FR clothing is required when performing particular tasks at our electric utility. Are meter readers who only read meters required to wear rated FR clothing? How about an engineer who is a qualified worker to enter a substation to perform engineering assessments and will not be operating any equipment?

A: The 2007 NESC 410.A requires the employer to perform a hazard assessment to determine if an arc flash could occur while performing various tasks. And, a hazard assessment would find no arc hazard potential for a meter reader simply reading meters. Also, a hazard assessment would find no arc hazard potential for an engineer who enters a substation to conduct simple engineering assessments. Neither the meter reader nor engineer in these two identified tasks would be required to wear rated FR clothing.

Q: I represent an electric utility company which owns generation, transmission, substations and a distribution system. Which FR clothing standard must my company follow; the 2017 NESC or the 2018 NFPA 70E?

A: As an electric utility company your facilities from the generator to the customer's service point is covered by the 2017 NESC and the FR clothing requirements of NESC 410.A. NFPA 70E has no jurisdiction from the generator to the customer service point. Where NFPA 70E has jurisdiction is on the customer's side of the service point. This also includes any electric utility facility which is not an integral part of the generation, transmission and distribution system. Your company's corporate office building, the engineering and operations service center buildings, the storeroom and other similar facilities are under NFPA 70E. Some utilities can, and do, apply the 2018 edition of NFPA 70E in generating plants to comply with OSHA's arc-flash protection requirements in §1910.269(l)(8). Also remember, if you send one of your qualified electrical workers trained under OSHA 1910.269 into the customer's home or facility, you are in the land of NFPA 70E and the National Electric Code (NEC) not the NESC.

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