Does OSHA or NEC Mandate hot gloves?

[oregonshooter]

Excluding NFPA 70E (not madatory and my boss wants to cherry pick from it only) I can't find anything that says Electricians are required to wear hot gloves when testing/working on voltages above 50v in OSHA 1910 or NEC.

The reason I ask is my plant has never required it and they are kinda starting to worry about 70E and have taken the step to buy 12cal coveralls and will be adding FR gloves but I'm hoping to hit two birds with one stone and convince them to issue 1000V Salsbury hot gloves.

We have one set in the shop of 15 electricians and they have never been tested since they bought them in 2002 and yes, I did point out this violates 1910.137(b)(2)(xii) .

I've been searching for the past 6 hours and got nothing. Did I miss something and is working (testing voltage/current) in 480vac panels bare handed common in the industrial settings? This is a wood products plant.

 

[iwire]

If you are allowed to work hot ....

1910.333(c)(2)

"Work on energized equipment." Only qualified persons may work on electric circuit parts or equipment that have not been deenergized under the procedures of paragraph (b) of this section. Such persons shall be capable of working safely on energized circuits and shall be familiar with the proper use of special precautionary techniques, personal protective equipment, insulating and shielding materials, and insulated tools.

 

[pfalcon]

SEC. 5. Duties
(a) Each employer --
(1) shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees;

1910.9(a)
Personal protective equipment. Standards in this part requiring the employer to provide personal protective equipment (PPE), including respirators and other types of PPE, because of hazards to employees impose a separate compliance duty with respect to each employee covered by the requirement. The employer must provide PPE to each employee required to use the PPE, and each failure to provide PPE to an employee may be considered a separate violation.

1910.335(a)(1)(i)
Employees working in areas where there are potential electrical hazards shall be provided with, and shall use, electrical protective equipment that is appropriate for the specific parts of the body to be protected and for the work to be performed.

So, yes, OSH Act of 1970 does mandate gloves for hot work.

 

[oregonshooter]

Thanks guys, I did find those.

The second part of my question is more important I think as from what I've seen with OSHA at the plant is that as long as the employer has a plan or policy it does not have to meet any standards that OSHA might recommend but will cost them should someone get hurt for not following accepted industry practice.

So how common is using VP gloves on < 480vac?

Is it "hot work" to change out starters in buckets that have their main bucket breaker off with the bucket still in the stabs? They call that a dead circuit here and are OK with taking off the FR gloves. See what I mean about "cherry picking?"

70E would have you doing it in a 40cal space suit. I mean I'm all for common sense on the issue and 70E does tend to go to the far right extreme on some common applications. Are we that far in the backwoods to the industry (not using VP gloves & at class 2 level all day) or probably the norm?

 

[don_resqcapt19]

...Is it "hot work" to change out starters in buckets that have their main bucket breaker off with the bucket still in the stabs? They call that a dead circuit here and are OK with taking off the FR gloves. See what I mean about "cherry picking?" ...

Removing and installing buckects in a MCC with live bus is, in my opinion, one of the more dangerous types of live work. You never know what will happen at the bus stabs as you can't see them.

 

[oregonshooter]

I agree on the buckets. I've seen bad things happen on a mis aligned 4160 bucket. :blink:

1910.9(a)
Personal protective equipment. Standards in this part requiring the employer to provide personal protective equipment (PPE), including respirators and other types of PPE, because of hazards to employees impose a separate compliance duty with respect to each employee covered by the requirement. The employer must provide PPE to each employee required to use the PPE, and each failure to provide PPE to an employee may be considered a separate violation.

Does this read that a community hot glove set is OK or that each person should have his own set?

 

[zog]

1910.335 (a)(2) "Energized parts." If the exposed live parts are not deenergized (i.e., for reasons of increased or additional hazards or infeasibility), other safety-related work practices shall be used to protect employees who may be exposed to the electrical hazards involved. Such work practices shall protect employees against contact with energized circuit parts directly with any part of their body or indirectly through some other conductive object. The work practices that are used shall be suitable for the conditions under which the work is to be performed and for the voltage level of the exposed electric conductors or circuit parts. Specific work practice requirements are detailed in paragraph (c) of this section.

 

[zog]

Thanks guys, I did find those.

The second part of my question is more important I think as from what I've seen with OSHA at the plant is that as long as the employer has a plan or policy it does not have to meet any standards that OSHA might recommend but will cost them should someone get hurt for not following accepted industry practice.

Nonesense, I see OSHA fines everyday for not following the OSHA standard rules, which are minimum requirements.

So how common is using VP gloves on < 480vac?

Very common in a facility, not so common for a electrician wiring a house.

Is it "hot work" to change out starters in buckets that have their main bucket breaker off with the bucket still in the stabs? They call that a dead circuit here and are OK with taking off the FR gloves. See what I mean about "cherry picking?"

I agree with the others, pulling MCC buckets is one of the most dangerous thing you can do, 70E committe agrees with that by making this a HRC 4 task in thier risk based tables.

70E would have you doing it in a 40cal space suit. I mean I'm all for common sense on the issue and 70E does tend to go to the far right extreme on some common applications. Are we that far in the backwoods to the industry (not using VP gloves & at class 2 level all day) or probably the norm?

Again, very dangerous task, pulling buckets and racking breakers are by far the most common causes of arc flash injuries/deaths. If you are wearing HRC 2 all day your safety department is just plain lazy. And forget about the FR gloves, minimal protection, misapplied by workers 99% of the time, hard to work in, and a waste of money.

 

[zog]

I agree on the buckets. I've seen bad things happen on a mis aligned 4160 bucket. :blink:
?

Typically thee is a much larger arc flash hazard on a 480V MCC bucket than there is on a 4160V starter.

 

[zog]

Excluding NFPA 70E (not madatory and my boss wants to cherry pick from it only).

Not mandatory? OSHA fines companies every day for not following 70E. It seems very obvious to me that your plant has not has the required OSHA and 70E training and no one should be doing any energized work at all at your facility until some very serious issues are addressed.

 

[S'mise]

I agree on the buckets. I've seen bad things happen on a mis aligned 4160 bucket. :blink:

Does this read that a community hot glove set is OK or that each person should have his own set?

Rules aside, I would not trust anyone else's gloves.
Tell you penny pinching boss to get everyone their own pair.

 

[oregonshooter]

zog,
You make all good points and I agree 100% but the reality of it is that OSHA here doesn't do their job as far as electrical hazards are concerned and the "we have always done it this way" attitude prevails. They are better than they were 15 years ago when I started, but like many places they "talk it" but don't "walk it" on a lot of stuff.

70E only is a factor if OSHA fines under Sec. 5 General Duty if I understand it correctly and enforcement is not done here, so that's what my boss is thinking "not mandatory" means. :thumbsdown:

The company sent him to a seminar on 70E and he has shown me the books they have but the position is that we will do what we want until told we can't by OSHA. He doesn't want to make people work in VR gloves because they do suck and take getting use to but the older I get the more I'd like to see things done right around here and my future job so I'm studying up on it even if I can't change the current employers mind.

The 70E concern came after an arc-flash on a 480vac breaker was reset (3) times with a direct short by a new electrician. It was undersized for INT amps so they changed them out and started thinking about arc-flash in general.

Very common in a facility, not so common for a electrician wiring a house.

That's what I thought. Too bad actually. I would think the potential is much greater for AF in a plant with 100's of 480vac 3ph applications.

I'm going to continue looking up what I can and present it to the boss. I have little hope of it making a difference as it's not a matter of ignorance on his part as it is him and the company being lazy and cheap.

So far I have the following. If anyone has something to add I'd appreciate it.

08-11-2011 JLL
Electrical Work and PPE

“HOT WORK” IS TO BE THE EXCEPTION NOT COMMON PRACTICE IN THE WORK PLACE ACCORDING TO OSHA. HOT WORK = 50VAC OR GREATER NOT LOCKED OUT
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.

UNLESS IT IS LOCKED OUT, IT’S CONSIDERED “ENERGIZED” (EVEN IS POWER IS OFF) AND REQUIRES VOLTAGE RATED PPE
1910.333(c)(2)
"Work on energized equipment." Only qualified persons may work on electric circuit parts or equipment that have not been deenergized under the procedures of paragraph (b) of this section. Such persons shall be capable of working safely on energized circuits and shall be familiar with the proper use of special precautionary techniques, personal protective equipment, insulating and shielding materials, and insulated tools.

1910.333(b)(1)
Conductors and parts of electric equipment that have been deenergized but have not been locked out or tagged in accordance with paragraph (b) of this section shall be treated as energized parts, and paragraph (c) of this section applies to work on or near them.




PPE MUST BE PROVIDED TO THE INDIVIDUAL AND MAINTAINED/TESTED IN ACCORDANCE TO NEC OR RELEVANT STANDARDS, INCLUDING NFPA 70E BY THE EMPLOYER OR BE IN VIOLATION OF OSHA’S “GENERAL DUTY” CLAUSE.
OSH Act “General Duty Clause” - SEC. 5. Duties
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=2743&p_table=OSHACT


1970 SEC. 5. Duties
(a) Each employer --
(1) shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees;

1910.9(a)
Personal protective equipment. Standards in this part requiring the employer to provide personal protective equipment (PPE), including respirators and other types of PPE, because of hazards to employees impose a separate compliance duty with respect to each employee covered by the requirement. The employer must provide PPE to each employee required to use the PPE, and each failure to provide PPE to an employee may be considered a separate violation.


1910.335(a)(1)(i)
Employees working in areas where there are potential electrical hazards shall be provided with, and shall use, electrical protective equipment that is appropriate for the specific parts of the body to be protected and for the work to be performed.


Hot Gloves
1910.137(a)(2)(i)
Equipment shall be capable of withstanding the a-c proof-test voltage specified in Table I-2 or the d-c proof-test voltage specified in Table I-3.
1910.137(b)(2)(xii)
The employer shall certify that equipment has been tested in accordance with the requirements of paragraphs (b)(2)(viii), (b)(2)(ix), and (b)(2)(xi) of this section. The certification shall identify the equipment that passed the test and the date it was tested.
Note: Marking of equipment and entering the results of the tests and the dates of testing onto logs are two acceptable means of meeting this requirement.
Table I-6. - Rubber Insulating Equipment Test Intervals
___________________________________________________________________
Rubber insulating gloves | Before first issue and every 6 months thereafter(1).
___________________________|_______________________________________
Footnote(1) If the insulating equipment has been electrically
tested but not issued for service, it may not be placed into service
unless it has been electrically tested within the previous 12 months.

 

[zog]

zog,
You make all good points and I agree 100% but the reality of it is that OSHA here doesn't do their job as far as electrical hazards are concerned and the "we have always done it this way" attitude prevails. They are better than they were 15 years ago when I started, but like many places they "talk it" but don't "walk it" on a lot of stuff.

70E only is a factor if OSHA fines under Sec. 5 General Duty if I understand it correctly and enforcement is not done here, so that's what my boss is thinking "not mandatory" means. :thumbsdown:

It is not OSHA's job, it is the employers job to have a safe workplace. It is not about the fines, it is about sending empoyees home afer work, not to the burn unit (a.k.a. Hell on earth)

The company sent him to a seminar on 70E and he has shown me the books they have but the position is that we will do what we want until told we can't by OSHA. He doesn't want to make people work in VR gloves because they do suck and take getting use to but the older I get the more I'd like to see things done right around here and my future job so I'm studying up on it even if I can't change the current employers mind.

Hot work should be very rare, in 99% of cases working live is a violation of OSHA (See iwires quote)

The 70E concern came after an arc-flash on a 480vac breaker was reset (3) times with a direct short by a new electrician. It was undersized for INT amps so they changed them out and started thinking about arc-flash in general.

Resetting into a fault like that is a OSHA violation too, common one to be cited.

That's what I thought. Too bad actually. I would think the potential is much greater for AF in a plant with 100's of 480vac 3ph applications.

I'm going to continue looking up what I can and present it to the boss. I have little hope of it making a difference as it's not a matter of ignorance on his part as it is him and the company being lazy and cheap.
t.

Don't give up, we can give you all the ammo you need, have you read the FAQ's in this section of the forum?

 

[oregonshooter]

I have read the FAQs and about 20 old threads on PPE. (does the software close them automatically because of age?)

I've fought this company on safety for the past 10 years and was on both plant safety committees and the confined space team but gave up after years of being blown off and no commitment on the companies part to do the right thing. I'll never understand why a company will pay thousands of dollars to be trained as a "trainer" and then not listen to a thing you learned on their dime? :slaphead:

Like you said, it's not about being forced to do it... it's about developing a safe working atmosphere a "culture of safety" was a popular term they threw around a few years ago.

I'm only interested in this stuff because I see it as the future and will be trying to find a job that will be using it when I quit in 6 months to a year. My only goal right now is to sponge up everything I can on NEC/NFPA and take my Sup. test and find a better place to work.

Doing an install according to NEC is usually by accident here. I'm sure there are many places like it in the industry but It's my only experience so it's hard to know how backwards the place you work at is unless you move around and times have changed significantly in the past 15 years I would assume, but having a sample rate of (1) I would not know that.

I came from the mines where we followed MSHA and NEC pretty close. We worked mostly 4160-13.8KV and 1600DC trolley so safety was a big concern, but most guys I work with have never seen anything over 480vac and never seen arc-flash.

I'll continue to learn and appreciate all the input from the members here. Thanks again!

 

[pfalcon]

Sadly, you aren't going to find the answers you're looking for in any of the codes. This is because you're looking for political answers not standards, but don't yet realize it.

So:

OSHA is a watchdog organization. They have no responsibility for anything but do have authority to punish.
OSHA will presume full compliance to the 70E unless you have a different, written policy.
If there are gaps in your policy then OSHA will presume the 70E fills them.

OSHA or its state equivalent may never, ever show up at your site. They may never, ever pay attention to your company. Therefore as your supervision seems to presume, compliance for the sake of OSHA appears to be a waste of time. It isn't for two special reasons.

1) We all like to go home in one piece. There are few things more devasting to a person than to be a safety victim. The devastation ripples outward from there. You can be emotionally crippled just knowing that your accepted practices helped promote the accident. An accident is life changing for more than just the victim though he gets the worst.

2) With or without an accident, OSHA might just come to call. Efforts to comply tend to permit negotiation on the size of the fines or even a delay to enforcement. If OSHA comes in then your supervision will probably be amazed that the inspectors are not taken in by all their rainbow statements. They've been there, done that, and are selling the T-shirts not buying them. Businesses that have blatantly ignored OSHA have been bankrupted and supervision/owners jailed. Even if they don't go that far you may find it convenient to give them an office as they're parked in your shop. Nothing ruins company profits like having an OSHA inspector placing your shop on his inspection route.

Apparently your supervision is all about the money (reason 2) though we can hope for better (reason 1) somewhere in their psyche. They may even have Supervisor Puffery Syndrome That's where so many people have been so afraid to contradict them that they begin to think no one ever will. OSHA will. They're not intimidated by SPS. And many bureaucrats, which many OSHA inspectors are, take a special pride in poking SPS. It could be a very bad time for your supervision.

Good luck.

 

[zog]

Oregon has a state OSHA program and you may find some more ammo there
www.orosha.org

Here is one for your glove testing.
http://www.orosha.org/interps/2008/rubber.pdf

This is a list of violations and fines for not using electrical gloves
http://www.osha.gov/pls/oshaweb/sea...t=electrical gloves&p_status=CURRENT&p_title=

A good interpretation letter about glove use on LV
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=22605

 

[oregonshooter]

pfalcon,
Yeah, I know the drill. It's been the same for 15 years with safety in general at this place. To be fair, it's not all my sup's fault. He is doing what the company wants... saving money.

OSHA inspected the plant last month, no results yet. They have never talked to the maint. department and seem to worry only about ergo and minor obvious issues. I know with MSHA it was not uncommon to get a mechanical engineer doing our sub-station & pump install evaluations and they had a simple check list and no knowledge of how they should be outside of that list. I suspect the same is often true with the OSHA inspectors. Hard to believe this company was SHARS certified a few years ago and no VP was in effect then either.

zog,
That is some excellent linkage, thank you!

PS> One good thing is that my on shift co-worker is becoming aware. He's a 1st year Journeyman and watching all the arc-flash video and reading the "code corner" clipboard I have on my locker with the stuff I find made him think twice about working in a hot panel and re-energizing a motor that had tripped on OC and brought the two upstream BKRs with them.

That's my goal and it seems to be starting to work. Make people (including myself) aware of the hazards they work with and they will want to work safer.

I was in a ph2ph 4160 arc-flash in my first year apprenticeship that engulf me in a fire ball (no injury) and have a higher degree of respect for the hazards than most I work with for it. I don't get shocked like many I work with mainly because that experience made me realize no piece of machinery or time savings is worth my life. What doesn't kill you make you stronger.

 

[GonzaloGomez]

Oregon Electrical Safety Orders

Oregon Electrical Safety Orders

Oregon OSHA Regulation 1910.335:

http://www.orosha.org/pdf/rules/division_2/div_2.pdf#page=1809

states that:
"(i) Employees working in areas where there are potential electrical hazards shall be
provided with, and shall use, electrical protective equipment that is appropriate for
the specific parts of the body to be protected and for the work to be performed."

The regulation requires appropriate PPE be used. NFPA 70E is the only document that I know that gives guidance on appropriate PPE for a situation.

Here in California, the Cal-OSHA Electrical Safety Orders specifically require insulating gloves for energized work over 250 volts to ground or between ungrounded conductors.