Osha Nfpa70e Requirements Neta 2011

7/30/2019 Osha Nfpa70e Requirements Neta 2011

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Does NFPA 70E

Really Require Anything New?

Palmer HickmanDirector of Code and Safety Training and Curriculum Development

National Joint Apprenticeship and Training Committee for the Electrical Industry


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Agenda

A case study from NIOSHs Fatality Assessment

and Control Evaluation (FACE) program

A look at a number of OSHAs provisions

A look at a number of NFPA 70E provisions

Final thoughts


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Electrical Project Supervisor Dies

On May 16, 1992, a 46-year-old electrical

project supervisor died when he contacted an

energized conductor inside a control panel.

The victim had worked for this employer for 5

years and 3 months as a project supervisor,

and had approximately 27 years of electrical

experience.


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The employer was an industrial electrical

contracting company that had been in

operation for 10 years.

The company and victim had been working at

the packaging plant for 6 months before the

incident; this was the company's first fatality.


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adapted from http://www.cdc.gov/niosh/face/In-house/full9220.html

The company's written safety program,

administered by the president/CEO and the

project supervisors, included disciplinaryprocedures specifying that three reprimands

would result in termination.

The county coroner reported the cause ofdeath as cardiac arrest due to electrical shock.


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What Was the Task?

The company had been contracted to install

two control cabinets, conduit, wiring, and two

solid-state compressor motor starters for two

400-horsepower air compressors.

On the day of the incident, the victim and

three co-workers arrived at the plant at 7 a.m.


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What Was the Task?

They were scheduled to install the last starter

and to complete the wiring from the

compressor motor to the starter in the control

panel, and from the starter control panel to

the main distribution panel.

Once installation was completed, they were to

check the operation of the unit.


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What Transpired?

The helper turned the switch to the "on"

position, energizing the components inside

the starter control panel.

The victim pushed the starter "start" button,

and the starter indicator light activated, but

the compressor motor did not start.


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What Transpired?

When the compressor motor did not engage,

the victim concluded that a problem existed

inside the starter control panel.

The victim directed the electrician to retrieve

a voltmeter so that he could check the

continuity of the wiring inside the starter

control panel.


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What Transpired?

In the interim, the victim opened the startercontrol panel door without de-energizing theunit and reached inside to trace the wiring

and check the integrity of the electrical leads. In doing so, he contacted the 480-volt primary

lead for the motor starter with his left hand.

Current passed through the victim's left handand body and exited through his feet to theground.


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What Transpired?

The victim yelled, and the helper immediately

turned the main distribution switch to the

"off" position as the victim collapsed to the

floor.

A plant maintenance supervisor walking by

the area saw the event and called the

emergency medical service (EMS).


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What Transpired?

The helper checked the victim and

immediately administered cardiopulmonary

resuscitation (CPR).

The EMS arrived in 10 to 15 minutes,

continued CPR, and transported the victim to

the local hospital where he was pronounced

dead 1 hour and 20 minutes after the incidentoccurred.


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RECOMMENDATIONS/DISCUSSION:

Recommendation #1: Employers should stress

and reinforce the importance of following

established safe work procedures, with

particular emphasis on de-energizing

electrical systems before any work is

performed.


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RECOMMENDATIONS/DISCUSSION:

Recommendation #2: Employers should

routinely conduct scheduled and unscheduled

worksite safety inspections.

Recommendation #3: Employers should

encourage workers to actively participate in

workplace safety.


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What Does OSHA Require?

OSH ActSection 5. Duties

(a) Each employer --

(1) shall furnish to each of his employeesemployment and a place of employmentwhich are free from recognized hazards that

are causing or are likely to cause death orserious physical harm to his employees;


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1926.21(b)(2)

The employer shall instruct each employee inthe recognition and avoidance of unsafe

conditions and the regulations applicable tohis work environment to control or eliminateany hazards or other exposure to illness orinjury


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Protective equipment, including personal protectiveequipment for eyes, face, head, and extremities,protective clothing, respiratory devices, andprotective shields and barriers, shall be provided,

used, and maintained in a sanitary and reliablecondition wherever it is necessary by reason ofhazards of processes or environment, chemicalhazards, radiological hazards, or mechanical irritantsencountered in a manner capable of causing injury

or impairment in the function of any part of thebody through absorption, inhalation or physicalcontact.[1910.132(a)]


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The employer shall verify that the required

workplace hazard assessment has been

performed through a written certification that

identifies the workplace evaluated; the personcertifying that the evaluation has been

performed; the date(s) of the hazard

assessment; and, which identifies thedocument as a certification of hazard

assessment.


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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 deenergizingintroduces additional or increased hazards or

is infeasible due to equipment design or

operational limitations.[1910.333(a)(1)]


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If the exposed live parts are not deenergized

(i.e., for reasons of increased or additional

hazards or infeasibility), other safety-related

work practices shall be used...

The work practices that are used shall be

suitable for the conditions under which the

work is to be performed and for the voltagelevel of the exposed electric conductors or

circuit parts. [1910.333(a)(2)]


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While any employee is exposed to contact

with parts of fixed electric equipment or

circuits which have been deenergized, the

circuits energizing the parts shall be lockedout or tagged or both

[1910.333(b)(2)]


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Use of Protective Equipment

When working near exposed energized

conductors or circuit parts, each employee

shall use insulated tools or handling

equipment if the tools or handling equipment

might make contact with such conductors or

parts.


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Use of Protective Equipment

Protective shields, protective barriers, or

insulating materials shall be used to protect

each employee from shock, burns, or other

electrically related injuries while that

employee is working near exposed energized

parts which might be accidentally contactedor where dangerous electric heating or arcing

might occur.


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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 courseof work, unless the employee is protected

against electric shock by deenergizing the

circuit and grounding it or by guarding iteffectively by insulation or other means.

[1926.416(a)(1)]


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What Does NFPA 70E Require?

from 110.8(B)(1)

Appropriate safety-related work practices

shall be determined before any person

approaches exposed live parts within the

Limited Approach Boundary by using both

shock hazard analysis andflash hazard

analysis.


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A shock hazard analysis shall determine:

the voltage to which personnel will be

exposed,

boundary requirements, and

the personal protective equipment necessary

in order to minimize the possibility of

electrical shock to personnel.


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130.1(A)(1)

Energized Electrical Work Permit

if live parts are not placed in an electrically

safe work condition the work to be

performed shall be considered energized

electrical work andmust [generally] be

performed by written permit only


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from 110.6(A) and (B)

Employees shall be trained:

to understand the specific hazards associated with

electrical energy in safety-related work practices and procedural

requirements

to identify and understand the relationship

between hazards and injury. The degree of training provided shall be determined

by the risk to the employee.


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from 110.6(A) and (B)

Employees shall be trained:

to understand the specific hazards associated with

electrical energy in safety-related work practices and procedural

requirements

to identify and understand the relationship

between hazards and injury. The degree of training provided shall be determined

by the risk to the employee.


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130.7(D)(1)

employees must use insulated tools and/orhandling equipmentwhen working inside the

limited approach boundary

130.7(D)(1)(f)

. Protective shields, protective barriers, or

insulating materials shall be used to protecteach employee from shock, burns, or otherelectrically related injuries


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OSHA is the Shall

Is 70E the How?


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OSHA Letter of Interpretation

adapted fromhttp://osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=

25973 1926.95(a); 1926.416(a); 1926.416(a)(1); 1926

Subpart K

February 29, 2008


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OSHA requirements are set by statute, standards andregulations

Interpretation letters explain these requirements and howthey apply to particular circumstances, but they cannot create

additional employer obligations The letter constitutes OSHA's interpretation of the

requirements discussed

Enforcement guidance may be affected by changes to OSHArules

From time to time guidance is updated in response to newinformation.


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Question (1)

Employees will be using an insulated device toverify that an electrical circuit that has been

"turned off, locked, and tagged" is de-energized.

Are these employees required to use PPEunder OSHA's construction standard1926.416(a)(1) and/or NFPA 70E?


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Answer: Section 1926.416(a)(1) provides:

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 powercircuit in the course of work, unless the employee is

protected against electric shock by de-energizing the

circuit and grounding it or by guarding it effectively

by insulation or other means


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In this scenario, the employees are exposed to the

hazard of electric shock since a determination that

the circuit has been de-energized has not yet

occurred. These employees must be protected against electric

shock "by guarding [the part] by insulation or other

means."

When so guarded, PPE would not be required to

protect against the electric shock hazard, [BUT]


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An additional hazard that may be associated

with the work described in your scenario is

that ofarc 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 tooccur


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However, 29 CFR 1926.95(a) provides that:

Protective equipmentshall be provided, used, and

maintained in a sanitary and reliable conditionwherever it is necessary

------------------------------------

Industry consensus standards can be evidence that

there is a hazard for which that PPE is "necessary."


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While the NFPA 70E consensus standard has notbeen adopted as an OSHA standard, it is relevant asevidence that arc flash is a recognized hazard and

that PPE is necessary to protect against that hazard NFPA 70E Article 130 sets out alternative

approaches for protecting against arc flash

Use an arc flash analysis to determine the FlashProtection Boundary and PPE to be used withinthat boundary


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NFPA 70E's Hazard/Risk Category Classifications assigns a"Hazard/Risk Category" of "1" or higher for "Work onenergized parts, including voltage testing

Under Table 130.7(C)(10), that categorization triggersvarious PPE provisions, includingflame-resistant clothingand other protective equipment

Thus, NFPA 70E is evidence that the industry recognizes thehazard of arc flash, that this hazard is present when testing

voltage, and that, when present, it is necessary for PPE tobe used to protect the employee from it


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Because the arc flash hazard varies with site-specific

factors, we [OSHA] cannot determine from the

information provided the extent of the arc flash

hazard in the scenario or the appropriate PPE

One way of ensuring that an employee is

adequately protected is to use the NFPA 70E for

assessing the factors in a specific situation anddetermining what protection to use


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Question 2: Is flame-resistant clothing required for

employees working on electrical installations

covered by Subpart S?

Question 3: How is OSHA enforcing 1910.132 and

Subpart S with regard to the latest edition of NFPA

70E requirements?

Question 4: Does OSHA issue Section 5(a)(1)General Duty Clause violations to companies who

do not follow the new NFPA 70E requirements?


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Question 2 Reply

Where there is no 1910.335(a)(2)(ii) safeguardthat would fully protect against the hazards, anemployer is still obligated under the OccupationalSafety and Health Act of 1970 to take reasonable

steps that will protect the employee to the degreepossible

OSHA recommends that employers consultconsensus standards such as NFPA 70E-2004 toidentify safety measures that can be used to comply

with or supplement the requirements of OSHA'sstandards for preventing or protecting against arc-flash hazards


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Question 2 Reply

Other NFPA 70E, Article 130 provisions, such

as the justification for work through the use of

an energized electrical work authorization

permit, and the completion of a job briefingwith employees before they start each job,

additionally decrease the likelihood that

exposure to electrical hazards would occur.


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Question 3 Reply

OSHA has not conducted a rulemaking to adopt therequirements of the latest edition of NFPA 70E and, therefore,does not "enforce" those requirements. However, industryconsensus standards, such as NFPA 70E, can be used by OSHAand employers as guides in making hazard analyses andselecting control measures.

With regards to enforcing 1910.132 and the Subpart Sstandards, the PPE requirements contained in Subpart Swould prevail over the general requirements contained in

1910.132 where both standards would apply to the samecondition, practice, control method, etc. See 1910.5(c)(1).


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Question 4 Reply

A violation of the General Duty Clause, Section 5(a)(1) of theAct, exists if an employer has failed to furnish a workplacethat is free from recognized hazards causing or likely to causedeath or serious physical injury.

The General Duty Clause is not used to enforce the provisions

of consensus standards, although such standards aresometimes used as evidence of hazard recognition and theavailability of feasible means of abatement.

In addition, the General Duty Clause usually should not beused if there is a standard that applies to the particular

condition, practice, means, operation, or process involved.See 1910.5(f).


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Final Thoughts

How many of us have received an electrical

shock or know someone who has been

involved in an arc flash event?

Would the NIOSH recommendations, if put

into practice before the work commenced,

have saved the life of the 46-year-old?

Does OSHA have rules in place?

Does NFPA 70E require more that OSHA?


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Documents

Osha Nfpa70e Requirements Neta 2011