Initiating ESWP Electrical Safe Work Practices (aka Arc Flash/Blast NFPA 70 E)

1. Initiating ESWPElectrical Safe Work Practices (aka Arc Flash/Blast NFPA 70 E) Patrick Ostrenga Retired OSHA Compliance Assistance Specialist

2. NRTL Or what does OSHA accept

3. 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

4. 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.

5. 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

6. So what does OSHA cite

7. 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

8. 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.

9. 1910.399 DefinitionsAcceptable. 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 3A definition is not citable by OSHA but the standard that uses that definition is!

10. 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

11. 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

12. 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.

13. 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.

14. 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.

15. A potential avd 1910.303(b)(1)(i) This is what I used to train OSHA employees in how to issue citations • 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

16. 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

18. 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.

19. 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?

20. 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). …

21. 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 wear conductive shoes

22. 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.

23. 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!

25. There are other hazards in addition to shock • You can be injured or killed by electricity without touching it.

26. 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.

27. 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.

28. ELECTRICAL HAZARD 2 • ARC Flash • Can be calculated before • Thermal effect • Protection is based on a 1.2 cal/cm2 • PPE can protect from the flash but… • ES Work Practices can reduce probability of an occurrence But not a guarantee

29. 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.

31. The site after

32. 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!).

34. Effects of the Incident • Both men were seriously burned and were transported by Helicopter and Ambulance to the Burn Center.

35. 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

36. 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

37. Scenario • Troubleshoot a transfer switch. • 13.2 KV in panel • Working on the 120 volt switch

39. Result • 3 seriously injured • 9 OSHA citations

41. 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.

42. How • Accurate is it? • When was it updated?

43. This is a snapshot of a one line Do your “qualified” people know how to read it?

44. ARC Warning Label ? Hazard level or PPE It is a 4160 Lighting arrestor

46. The victim thought the arrestor was on the load side not the line sideDoes this meet the definition of qualified?

47. 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.

48. OSHA and NFPA 70E

49. 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

50. The Electrical Safe Work Practice Standards have not changed. • OSHA IS THESHALL & • NFPA 70EIS THEHOW OSHA recommends that employers consult consensus standards such as NFPA 70E-2004 to identify safety measures that can be used to comply with or supplement the requirements of OSHA's standards for preventing or protecting against arc-flash hazards. Interpretation of November 14, 2006