Hot Work off of Scizzor Lift

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jusme123

Senior Member
Location
NY
Occupation
JW
Does anyone know the OSHA standard if working off a lift doing hot work. Looking for copy of actual standard/rules.
277/480v bus plugs done hot, and loads terminated.
 
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WorkSafe

Senior Member
Location
Moore, OK
There is nothing written about this, but I'll have to ask why the work is being done hot, and if the work meets the OSHA exceptions (highly doubt). OSHA considers scissor lifts scaffolds by the way.
 

jusme123

Senior Member
Location
NY
Occupation
JW
There is nothing written about this, but I'll have to ask why the work is being done hot, and if the work meets the OSHA exceptions (highly doubt).

thanks, but we do believe it meets the OSHA standards for hot work
 

WorkSafe

Senior Member
Location
Moore, OK
thanks, but we do believe it meets the OSHA standards for hot work

You do believe you meet the standards? With all do respect, it doesn't sound like your confident in that. You will have to be absolutely certain you meet the exceptions or else it could really bite you in the ass if something were to happen.

Good luck and be safe.
 

jim dungar

Moderator
Staff member
Location
Wisconsin
Occupation
PE (Retired) - Power Systems
Watch out for your arc flash PPE calculations. The 'industry average' of a 2 sec maximum exposure time, is not normally considered valid for 'elevated' work conditions.
 

farmaped

Member
I remember checking into this and couldn't find anything, doesn't mean there isn't relavent information out there, just couldn't find it. We did, however, institute a few additional safety checks, such as decreasing the INST setting on the busway feeder CB during insertion, requiring 1kV megger on bus switch prior to inserting it, and (eventually) adding GF protection for the busway.
The manufacturers I checked with all pretty much said the same thing, that their bus switches were not intended to be inserted while energized, but rather the "plug & play" design was intended to reduce downtime and increase flexibility (in case you were hoping to get some backing from the manufacturer - unlikely).
The NFPA 70E Energized Work Permit may take the bus offline, getting those signatures changes everything!
 

buddhakii

Senior Member
Location
Littleton, CO
All this hot work and required ppe and not permitted stuff has gotten a little out of hand imo. I understand that there needs to be a little oversight and all but if I can't take a recept out of the wall and clip a wire with my side cutters then maybe I am in the wrong trade. If it saves one life right? Well maybe I should just stay indoors and never leave my house because who knows?
 

sii

Senior Member
Location
Nebraska
All this hot work and required ppe and not permitted stuff has gotten a little out of hand imo. I understand that there needs to be a little oversight and all but if I can't take a recept out of the wall and clip a wire with my side cutters then maybe I am in the wrong trade. If it saves one life right? Well maybe I should just stay indoors and never leave my house because who knows?

The OP is not talking about changing out a receptacle hot (not that that should be done either). He's talking about 480 volt hot work on an elevated platform.

There are very limited exceptions such as interruption of life safety means (I'm sure someone can quote the exact wording better than I) that allow you to work hot, I'd be curious what exception he is using.

By your logic I shoud be able to drive 80 mph to work in the morning because I think the 55 speed limit as unreasonable?
 

kwired

Electron manager
Location
NE Nebraska
By your logic I shoud be able to drive 80 mph to work in the morning because I think the 55 speed limit as unreasonable?

And you certainly can, until the policeman catches you doing so. You pay the fine and can do it again if you wish.;)
 

jusme123

Senior Member
Location
NY
Occupation
JW
The OP is not talking about changing out a receptacle hot (not that that should be done either). He's talking about 480 volt hot work on an elevated platform.

There are very limited exceptions such as interruption of life safety means (I'm sure someone can quote the exact wording better than I) that allow you to work hot, I'd be curious what exception he is using.

By your logic I shoud be able to drive 80 mph to work in the morning because I think the 55 speed limit as unreasonable?

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. Live parts that operate at less than 50 volts to ground need not be deenergized if there will be no increased exposure to electrical burns or to explosion due to electric arcs.

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 2: 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.

Note 3: Work on or near deenergized parts is covered by paragraph (b) of this section.
 
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iwire

Moderator
Staff member
Location
Massachusetts
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. Live parts that operate at less than 50 volts to ground need not be deenergized if there will be no increased exposure to electrical burns or to explosion due to electric arcs.

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 2: 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.

Note 3: Work on or near deenergized parts is covered by paragraph (b) of this section.

Those sections allow troubleshooting not new work.

Trust me, if OSHA shows up they will not agree this is allowable work unless there are some very odd circumstances.
 

Fulthrotl

~Autocorrect is My Worst Enema.~
Does anyone know the OSHA standard if working off a lift doing hot work. Looking for copy of actual standard/rules.
277/480v bus plugs done hot, and loads terminated.

ok, you are stabbing new plugs in, so what they serve isn't energized, so interruption of critical process
or life support isn't an issue, with the loads connected.

that leaves the existing loads on the bus. unless there is a critical load on that bus that creates a greater
hazard by being de energized, and you can demonstrate that, this dog isn't gonna hunt.

most sparky's who've been doing this a fair while, have done all manner of things that are not done any
more......

hot stabs,
racking in and out LV and MV breakers,
working all manner of things hot.....
i had to rebuild a 2000 amp asco transfer
switch hot, in a hospital, almost 30 years ago,
and it would qualify for hot work under todays
guidelines.

but, without a compelling reason....
it isn't happening any more, like it or not. if you hot stab,
and something goes south, whoever is the responsible person
on the job just signed up for criminal charges. not a fine,
criminal charges, up to manslaughter, depending on the severity
of the injury.

as late as 1989, i was able to get the crane operator to give me
a ride up on the ball to the top of an 115' facility.

i'm not sure, but i think at this point even admitting i did it 20
years ago may be a misdemeanor.
 

iceworm

Curmudgeon still using printed IEEE Color Books
Location
North of the 65 parallel
Occupation
EE (Field - as little design as possible)
1910.333(a)(1)
... 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. ...
What about this part? Doesn't this give one legal license to do the work hot and osha says it's okay?

i'm not saying it's a good idea - just legal.

ice
 

iwire

Moderator
Staff member
Location
Massachusetts
What about this part? Doesn't this give one legal license to do the work hot and osha says it's okay?

i'm not saying it's a good idea - just legal.

ice


It can in some cases.

But you should not be thinking how you would justify hot work to yourself but how you would justify if you found yourself sitting in front of a lawyer giving a desperation.

You would have to be able to show it was more dangerous to shut things down. That will be tough if someone was hurt doing the hot work.
 

iceworm

Curmudgeon still using printed IEEE Color Books
Location
North of the 65 parallel
Occupation
EE (Field - as little design as possible)
It can in some cases.

But you should not be thinking how you would justify hot work to yourself but how you would justify if you found yourself sitting in front of a lawyer giving a desperation.

You would have to be able to show it was more dangerous to shut things down. That will be tough if someone was hurt doing the hot work.

Interesting - but, nearly off point and useless. What I would do or suggest wouldn't be anything you would have a clue about.

My post concerned the continuous industrial process exemption. I personally don't know what that means. Any process can be shut down - it is just a matter of money. I don't know where one draws the line. Osha doesn't give any clues. So. in your opinion, what would be some examples of those cases?

As it happened, I was asked by "the management" about a particular job that was believed required hot work on a high SSC sytem. And we had techs quite willing to do the job. Being the professional I am, I explained the law exactly as it is written - all of it. I said that yes, the process was continuous, but we could shut it down for 72 hours - it was just a matter of a few hundreds of thousands of dollars. I would need the company to say they thought the process fell under osha 1910.333 exceptions - a written policy statement. That wasn't a decision I would make. I also suggested that if they would give me a few days, I could figure out how to do the job without the shutdown. They did and we (me and the crew together) did. No hot work - other than the Dead Bus Verification. I feel we dodged a bullet on this one. Had we not figured out an alternate method - the company could have easily found a contractor to do it hot. Heck, for that kind of money I would have considered it.

I would not have your post quite so offensive - had it not had the smell of a personal attack.

ice
 

WorkSafe

Senior Member
Location
Moore, OK
I don't think 'iwire' was personally attacking you, but when it comes to electrical safety, he ensures the other person understands the possible consequences, which all employers need to understand. If the employers accepts the risks and consequences for allowing their employees to possibly work unsafely, then so be it.

I don't know what the OP's exact situation was, but if he is not working in a chem plant or a scenario simliar to the OSHA exemption, then your case is pretty moot.
 

Hv&Lv

Senior Member
Location
-
Occupation
Engineer/Technician
Wouldn't the circumstances the OP is working in determine the applicable OSHA part number? If it is new construction, the shouldn't part 1926 be the applicable part? 1910 is general industry standards. Is this maintainance or new construction?

I noticed that 1910.333(A)(1) has been referenced a couple of times. If this is a maintenance project, I can't see where someones safety is worth keeping a plant in operation. What if the power goes out? the plant will be down with an unscheduled outage. UPS's won't operate an entire plant, and generators take a while to come on.

Personally, doing 277/480 hot work with the potential for flash in an elevated scissor lift (mobile scaffold) gives you very little "run"room, especially tapping up something new.
Even in a bucket truck, we aren't allowed to tap up a new service hot on any bank over 225 kVa with the new Arc flash standards. On those less than 225, I need to see where the wires are going, and I ring out any parallel conductors, regardless of what the installer tells me, or I shut the bank down.

I agree with Fulthrotl, most have done things years ago that would lead to immediate termination now. I used to put new transformers online by hand years ago, until I saw a top blow off of one...

If you aren't sure and have to ask if it is the safe way, it may be time to schedule an outage.
 

kwired

Electron manager
Location
NE Nebraska
..but we could shut it down for 72 hours - it was just a matter of a few hundreds of thousands of dollars...

What is the price of a workers life, hopefully it is a number that is undeterminable. Big business sadly may see it as less than cost of 72 hours of down time.
 
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