Does operation of a lighting circuit breaker require PPE?

[ericlemmon1]

An office building where I work has several flush panelboards equipped with SWD-rated 20A circuit breakers that control the ceiling light fixtures. There are no separate toggle switches. The senior management has issued an edict that operation of any lighting circuit breaker must be performed by a person wearing HRC Level 0 PPE, which is defined as: Natural-fiber long-sleeved shirt, pants, hard hat, safety glasses, and leather safety shoes. Since this is an administrative facility, the lighting breakers are normally turned on and off by guards, custodians, and office workers. I find no reference in NFPA 70E, 2012 edition, that exempts common 120/208V lighting panels from the PPE requirement. My plan is to have toggle switches installed, but in the meantime my only recourse is to leave all lights on 24/7. Have I missed something?

 

[WorkSafe]

Are the breakers SWD rated?

Disregard. Just read your question again.

My opinion, this would be up to management, but if something were to happen, OSHA could probably ding them for not wearing HRC gear.

 

[petersonra]

as absurd as this sounds, it may well be a correct interpretation of 70E.

considering how many millions or billions of times lights have been turned on and off by circuit breakers by people with no training and no PPE with a total of zero injuries over the past century, one would think that someone would get a clue, but apparently not.

there well may be as much risk in operating a light switch as a CB. how do you mitigate that risk?

 

[jim dungar]

there well may be as much risk in operating a light switch as a CB. how do you mitigate that risk?

Do not confuse hazard with risk.

The arc flash incident energy level and the shock voltage are both hazards. The risk is the probability that the hazard will occur.

NFPA70E clearly requires every employer to conduct a risk analysis as part of their electrical safe work practice program. Most do not do this and instead jump to extreme, and sometimes foolish, procedures. As far as NFPA70E is concerned there is no difference between operating a CB or a light switch, appropriate PPE is required for both tasks.

A risk analysis can take into account all of the event history and probability of occurrence our industry has accumulated over the years.

 

[zog]

An office building where I work has several flush panelboards equipped with SWD-rated 20A circuit breakers that control the ceiling light fixtures. There are no separate toggle switches. The senior management has issued an edict that operation of any lighting circuit breaker must be performed by a person wearing HRC Level 0 PPE, which is defined as: Natural-fiber long-sleeved shirt, pants, hard hat, safety glasses, and leather safety shoes. Since this is an administrative facility, the lighting breakers are normally turned on and off by guards, custodians, and office workers. I find no reference in NFPA 70E, 2012 edition, that exempts common 120/208V lighting panels from the PPE requirement. My plan is to have toggle switches installed, but in the meantime my only recourse is to leave all lights on 24/7. Have I missed something?

Sounds like the tables were used to determine the HRC 0 (Which rumor has is going away in 2015), which is not the same as "no hazard". If you do an actual arc flash analysis and prove there is no hazard then you can say no PPE is required. Then again, if you do the study and find out there is a hazard it might be higher and require HRC 1 or 2 PPE. (Doubtful but possible) at which point you cannot go back to the HRC 0 requirement from the tables.

 

[Jraef]

...I find no reference in NFPA 70E, 2012 edition, that exempts common 120/208V lighting panels from the PPE requirement. My plan is to have toggle switches installed, but in the meantime my only recourse is to leave all lights on 24/7. Have I missed something?

As a gross over simplifaction, what they were trying to do was get people to do an arc flash analysis and develop a program of safe practices. So they made it that if you do not do one, you use the tables and the tables make ilife difficult because they leave no room for exceptions since they are a default set of practices based on the worst possible case given for any task.

So bottom line, your senior management decided that rather than spend a little money for someone to actually assess the situation for what it really is and providing task appropriate training, they would rather implement idiotic rules that burden the people below them.

 

[zog]

So bottom line, your senior management decided that rather than spend a little money for someone to actually assess the situation for what it really is and providing task appropriate training, they would rather implement idiotic rules that burden the people below them.

Heh, well said.

 

[PetrosA]

So bottom line, your senior management decided that rather than spend a little money for someone to actually assess the situation for what it really is and providing task appropriate training, they would rather implement idiotic rules that burden the people below them.

Out of curiosity, how much would it cost to get a study like this done as well as training and certification for a decent number of employees? Let's say a building has three panels used for switching warehouse lighting or such and two more panels that control corridor and exterior lights, and they want to avoid (for whatever reason...) having switches installed. I can imagine that for many people in charge of situations like this, it's kind of like telling them they need to certify all the mops, brooms and janitorial staff in the building to comply with new airborne particulate regulations - there would be some strange reactions to that. No one had ever given a thought to the safety or effectiveness of the mops and brooms or the janitor for the last 5 decades... so it's either hire a cleaning service to ensure a qualified broom and mop handler will be available when needed or buy Tyvek suits and respirators for your current cleaning staff and make them wear the gear to conduct basic janitorial duties.

 

[mayanees]

Out of curiosity, how much would it cost to get a study like this done as well as training and certification for a decent number of employees? Let's say a building has three panels used for switching warehouse lighting or such and two more panels that control corridor and exterior lights, and they want to avoid (for whatever reason...) having switches installed. .

I suggest the cost would be $5-10k.
The Power Study needs to model the system back to the Utility source, and that includes their contribution and ocpd information. Much of the cost comes from the collection of system data.
There are additional benefits that come from the Study, like coordination with the Utility device. But the Study could also reveal that devices aren't rated for the available fault current, in which case additional cost could be incurred.
The system also needs to be maintained in order for the arc flash labels to applicable. That cost.... maybe as low as $1500.
John M

 

[SalixKetuur]

Z462-08

Z462-08

In Canada, according to the Z462-08 "Workplace Electrical Saftey" standards, published by the Canadian Standards Association, operation of a circuit breaker or fused switch with covers on for equipment operating at 240V or less does not require insulating gloves and places the hazard/risk category at 0.

 

[zbang]

Maybe it's a tail-wagging-the-dog thing, but why would operating switching-duty breakers need an AF energy evaluation while operating a set of toggle switches, supplied by those breakers, in a box mounted directly the panel, not need the same evaluation? (Because one is a "breaker" and the other is a "switch"? That's not a sensible distinction.) Is it simply that a wall switch is meant to be operated without PPE? What about the switching-duty breaker? There must be some nuances that I've missed.

 

[GoldDigger]

Maybe it's a tail-wagging-the-dog thing, but why would operating switching-duty breakers need an AF energy evaluation while operating a set of toggle switches, supplied by those breakers, in a box mounted directly the panel, not need the same evaluation? (Because one is a "breaker" and the other is a "switch"? That's not a sensible distinction.) Is it simply that a wall switch is meant to be operated without PPE? What about the switching-duty breaker? There must be some nuances that I've missed.

One important distinction is that the switch is supplied with power through a branch circuit breaker which limits the energy available, while the breaker itself is supplied with power through the bus of a subpanel or main panel which has a much greater amount of fault energy available.
If each breaker which controlled a particular lighting load were fed from another upstream breaker of the same amperage, it would not be the same problem.

 

[GOZ]

Not sure if it's been suggested yet. Would installing Occupancy Sensors be an option for your situation?

 

[ken44]

I removed this post as it somehow ended up on the wrong thread.

 

[ericlemmon1]

Not sure if it's been suggested yet. Would installing Occupancy Sensors be an option for your situation?

Not really. In the particular case I reported, all eight ceiling troffer strings are controlled only by eight SWD-rated 20A circuit breakers. This is a large room filled with cubicles for the engineers, and it would be quite distracting if the lights started going off randomly when nobody happened to pass by the panel. The long-term solution is to install toggle switches for the lighting circuits.

 

[GOZ]

Not really. In the particular case I reported, all eight ceiling troffer strings are controlled only by eight SWD-rated 20A circuit breakers. This is a large room filled with cubicles for the engineers, and it would be quite distracting if the lights started going off randomly when nobody happened to pass by the panel. The long-term solution is to install toggle switches for the lighting circuits.

Actually i was referring to ceiling mounted sensors. I have had good luck with installing these in cubical areas in the past. Or perhaps programmable timer switchs under the panelboard. Just a suggestion.

 

[wbdvt]

Hmmm, I wonder if "senior management" puts on the appropriate PPE, that they have deemed necessary in the workplace, when a branch circuit breaker trips in their house and they have to reset it? Kind of makes you think about the absurdity of it all.

 

[spark master]

As far as NFPA70E is concerned there is no difference between operating a CB or a light switch, appropriate PPE is required for both tasks.

Please explain this statement in detail. I am faced with the same situation. Building has switched rated 20amp breakers, that are used every day. I was going to install 1900 box's next to the panel, and build a row of 20 amp light switches. I told the customer, this would negate the need for PPE. However, you are saying it doesn't matter??? Even if I move the switch mechanism out of the panel ???

 

[jim dungar]

Please explain this statement in detail. I am faced with the same situation. Building has switched rated 20amp breakers, that are used every day. I was going to install 1900 box's next to the panel, and build a row of 20 amp light switches. I told the customer, this would negate the need for PPE. However, you are saying it doesn't matter??? Even if I move the switch mechanism out of the panel ???

Why would operating the breakers need PPE?
What level of PPE is required?
What are the results of your risk analysis?

How is operating a switch different than operating a breaker?
Where did you find information, in NFPA70E, about an exception for switches.

 

[spark master]

Why would operating the breakers need PPE?
What level of PPE is required?
What are the results of your risk analysis?

How is operating a switch different than operating a breaker?
Where did you find information, in NFPA70E, about an exception for switches.

Answers like these is why I don't visit this forum too much. There is not one study I have seen, where they did a risk analysis on a men's room light switch. In fact, I am going to hang a pair of safety glasses on the light switch in every bathroom in the building, and require every employee to don their moon suit before going potty.