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Exposed Energized Conductor or Circuit Part - OSHA vs NFPA70E

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    Exposed Energized Conductor or Circuit Part - OSHA vs NFPA70E

    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 [LIST][*]Exposed. . . . Not isolated or guarded. [/LIST]

    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:

    [LIST][*]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). [/LIST]



    NFPA 70E's definition of Exposed is[LIST][*] 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. [/LIST]

    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".

    #2
    1910.399

    Try these definitions for OSHA - 1910.399: https://www.osha.gov/pls/oshaweb/owa...ARDS&p_id=9976


    Originally posted by Jimland58 View Post
    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 [LIST][*]Exposed. . . . Not isolated or guarded.[/LIST]

    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:

    [LIST][*]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).[/LIST]



    NFPA 70E's definition of Exposed is[LIST][*] 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.[/LIST]

    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".

    Comment


      #3
      Originally posted by OSHA_70E_Questions View Post
      Try these definitions for OSHA - 1910.399: https://www.osha.gov/pls/oshaweb/owa...ARDS&p_id=9976

      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/stand...ons/2010-02-03

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

      Comment


        #4
        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."
        Last edited by wtucker; 05-03-18, 04:59 PM.

        Comment


          #5
          Originally posted by wtucker View Post
          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.
          I live for today, I'm just a day behind.

          Comment


            #6
            IMHO, any outdoor, insulated conductor carrying power is considered exposed.

            Comment


              #7
              Originally posted by Sahib View Post
              IMHO, any outdoor, insulated conductor carrying power is considered exposed.
              What about outdoors but within raceway, cable sheath or box/cabinet?
              I live for today, I'm just a day behind.

              Comment


                #8
                Originally posted by kwired View Post
                What about outdoors but within raceway, cable sheath or box/cabinet?
                In such cases, won't the definition of 'isolated/guarded' apply?

                Comment


                  #9
                  Originally posted by Sahib View Post
                  In such cases, won't the definition of 'isolated/guarded' apply?
                  I guess. Wouldn't it apply to open bare conductors in a substation with a fence around it, for anyone outside the fence anyway?
                  I live for today, I'm just a day behind.

                  Comment


                    #10
                    Originally posted by kwired View Post
                    I guess. Wouldn't it apply to open bare conductors in a substation with a fence around it, for anyone outside the fence anyway?
                    AHJ call?

                    Comment


                      #11
                      Originally posted by Sahib View Post
                      AHJ call?
                      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 live for today, I'm just a day behind.

                      Comment


                        #12
                        Originally posted by kwired View Post
                        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.

                        Comment


                          #13
                          Originally posted by Sahib View Post
                          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.
                          I live for today, I'm just a day behind.

                          Comment


                            #14
                            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).

                            Comment


                              #15
                              Originally posted by Sahib View Post
                              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
                              I live for today, I'm just a day behind.

                              Comment

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