Exposed Energized Conductor or Circuit Part - OSHA vs NFPA70E

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QUESTION: For a insulated energized (over 50v) cable, is OSHA saying that the cable is an Exposed Energized conductor but NFPA 70E is saying that is NOT an Exposed Energized conductor?

OSHA's 1910.269 definition of Exposed is
  • Exposed. . . . Not isolated or guarded.

OSHA's 1910.269 definition of Isolated is
o Isolated. Not readily accessible to persons unless special means for access are used.

OSHA's 1910.269 definition of Guarded is
o Guarded. Covered, fenced, enclosed, or otherwise protected, by means of suitable covers or casings, barrier rails or screens, mats, or platforms, designed to minimize the possibility, under normal conditions, of dangerous approach or inadvertent contact by persons or objects.

One of the interpretations I saw from OSHA stated:


  • 1910.269(l)(2) Interpretation: An employee who is "exposed to contact" with an energized part under this definition is still "exposed to contact" with the energized part even if insulation covers the part, the employee or both. See §1910.269(x) (defining "exposed" as not isolated or guarded; merely covering a conductor or an employee with insulation does not provide guarding or isolation).



NFPA 70E's definition of Exposed is
  • Capable of being inadvertently touched or approached nearer than a safe distance by a person. It is applied to electrical conductors or circuit parts that are not guarded, isolated or insulated.

So ..... it seems to me that OSHA says exposed is "not isolated or guarded" and NFPA 70E says exposed is "not guarded, isolated or insulated".
 
Location
Boston
1910.399

1910.399

Try these definitions for OSHA - 1910.399: https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9976


QUESTION: For a insulated energized (over 50v) cable, is OSHA saying that the cable is an Exposed Energized conductor but NFPA 70E is saying that is NOT an Exposed Energized conductor?

OSHA's 1910.269 definition of Exposed is
  • Exposed. . . . Not isolated or guarded.

OSHA's 1910.269 definition of Isolated is
o Isolated. Not readily accessible to persons unless special means for access are used.

OSHA's 1910.269 definition of Guarded is
o Guarded. Covered, fenced, enclosed, or otherwise protected, by means of suitable covers or casings, barrier rails or screens, mats, or platforms, designed to minimize the possibility, under normal conditions, of dangerous approach or inadvertent contact by persons or objects.

One of the interpretations I saw from OSHA stated:


  • 1910.269(l)(2) Interpretation: An employee who is "exposed to contact" with an energized part under this definition is still "exposed to contact" with the energized part even if insulation covers the part, the employee or both. See §1910.269(x) (defining "exposed" as not isolated or guarded; merely covering a conductor or an employee with insulation does not provide guarding or isolation).



NFPA 70E's definition of Exposed is
  • Capable of being inadvertently touched or approached nearer than a safe distance by a person. It is applied to electrical conductors or circuit parts that are not guarded, isolated or insulated.

So ..... it seems to me that OSHA says exposed is "not isolated or guarded" and NFPA 70E says exposed is "not guarded, isolated or insulated".
 


Thanks! I guess OSHA has some work to do on making the definitions consistent.

However, I'm still confused by their letter of interpretation when it comes to insulation. Here's a direct link to the letter: https://www.osha.gov/laws-regs/standardinterpretations/2010-02-03

Look at Scenario/Response #1. Appears to say that even if it's insulated it is still exposed???
 

wtucker

Senior Member
Location
Connecticut
Whoa! You guys are looking at two different sections of the OSHA standards, two different worlds!

.269 covers power generation, transmission and distribution. They probably don't mention insulation because those voltages often have a weather cover, not insulation.

.399 is part of Subpart S--basically the work of an inside wireman.

You can't take definitions from one and apply them to the other.

And 70E does NOT cover, according to Art. 90(B)(4), "installations under the exclusive control of an electric utility."
 
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kwired

Electron manager
Location
NE Nebraska
Whoa! You guys are looking at two different sections of the OSHA standards, two different worlds!

.269 covers power generation, transmission and distribution. They probably don't mention insulation because those voltages often have a weather cover, not insulation.

.399 is part of Subpart S--basically the work of an inside wireman.

You can't take definitions from one and apply them to the other.

And 70E does NOT cover, according to Art. 90(B)(4), "installations under the exclusive control of an electric utility."
That is from NPFA 70, I don't think it is in 70E.
 

Sahib

Senior Member
Location
India
You realize topic is about safe work practices and how to determine when a certain condition exists and not so much about install procedures?
I realise, but there might be safe work practices in install procedures also.
 

kwired

Electron manager
Location
NE Nebraska
I realise, but there might be safe work practices in install procedures also.
AHJ is typical term for whoever approves installation. They don't ordinarily get involved in work practice safety procedures, they are checking code compliance on the installation.

Safety procedures are a little more driven by company policy - with outside influence by insurance companies, OSHA, etc. to encourage using an already recognized publication such as 70E as your safety policy for tasks involving electrical hazards.
 

Sahib

Senior Member
Location
India
Kwired:

Perhaps our interaction clarified OP: An open, insulated, energized, outdoor conductor is exposed (per OSHA) and an open, insulated, energized, indoor conductor is not exposed (per NFPA 70E).:)
 

kwired

Electron manager
Location
NE Nebraska
Kwired:

Perhaps our interaction clarified OP: An open, insulated, energized, outdoor conductor is exposed (per OSHA) and an open, insulated, energized, indoor conductor is not exposed (per NFPA 70E).:)
I give up. OSHA (kind of) wants us to follow 70E, yet they contradict it with what you just mentioned:blink:
 

Sahib

Senior Member
Location
India
The safety lesson here is, do not touch an open, energized, outdoor conductor, even though it is insulated, because it is exposed per OSHA.
 
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