Electrical Safety Consultants Inc

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Electrical Safety

Q: When will we see the revision to Federal OSHA 1910.269 and OSHA 1926 Subpart V?

A: Federal OSHA recently published an updated Federal Register which shows the OSHA 1910.269 and OSHA 1926 Subpart V regulations scheduled for publication in February 1, 2011. I know David Wallis, Federal OSHA Director of Electrical Standards, is working on the last bit of the new regulations. The reason for the delay is the uncertainty of what NESC Subcommittee 8 "Work Rules" plans on doing with the MAD tables for the 2012 NESC. The 2009 IEEE 516 made some significant changes to MAD and more changes are expected in the next revision of 516, leaving OSHA unsure what to publish for MAD in the new regulations.

Lift Truck Line grounding coverup

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 2007 NESC or NFPA 70E?

A: As an electric utility company your facilities from the generator to the customer's service point is covered by the 2007 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. 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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