Can some one here answer a loto question . Months ago operators were trained by a osha qualified trainer to teach them the loto of equipment . Now the company has arcflash study with labeling on the circuit breakers and other equipment. If there is a label and ppe is required to be worn when working in theelectrical box, is ppe required when performing a non electrical loto procedure ? The mechanics will work on the machanical parts like a compressor or pump, no electrical work is done except turning breakers off.
Is ppe needed ?
- Thread starter jimbo123
- Start date
- Status
- Location
- Massachusetts
How are the mechanics verifying power if in fact off?
That is part of the LOTO procedure.
- Location
- Massachusetts
If there are exposed to live parts when they are in this MCC they would need PPE
- Location
- Wisconsin
- Occupation
- PE (Retired) - Power Systems
This is a 'design' issue, it is not specifically addressed in NFPA 70E.
This is why every company needs a detailed Electrical Safe Work Practices program.
Most of my customers allow the use of local LOTO for machine servicing (i.e. replace belt, service press) to be done in Cat 0 PPE. If any electrical work is performed (i.e. checking for voltage), then their 70E policies come into play.
I have a few customers that allow street clothes and a few that provide Cat 0 'lab coats'.
This is why every company needs a detailed Electrical Safe Work Practices program.
Most of my customers allow the use of local LOTO for machine servicing (i.e. replace belt, service press) to be done in Cat 0 PPE. If any electrical work is performed (i.e. checking for voltage), then their 70E policies come into play.
I have a few customers that allow street clothes and a few that provide Cat 0 'lab coats'.
I have reread some of my post and see where i made mistakes with explaining the situation.
Here goes, the tables in 70e say to operate a circuit breaker in a 480v mcc it is a hrc 0.
Now after a arc flash analysis is completed and the mcc has a label placed on the bucket or mcc , will operating the circuit breaker with the door closed still be a hrc 0 as listed in table or will a worker have to have ppe to the level of analysis label on mcc ?
No entry is being performed into the mcc or any other exposed electrical parts or any electrical work.
Here goes, the tables in 70e say to operate a circuit breaker in a 480v mcc it is a hrc 0.
Now after a arc flash analysis is completed and the mcc has a label placed on the bucket or mcc , will operating the circuit breaker with the door closed still be a hrc 0 as listed in table or will a worker have to have ppe to the level of analysis label on mcc ?
No entry is being performed into the mcc or any other exposed electrical parts or any electrical work.
weressl
Esteemed Member
That is incorrect. OSHA specifically requires DIRECT verification that the power flow is effectively removed and blocked. Acceptable verifications are the visible 'break' in the conductive parts in all phases, such as parted contacts, that the contacts incidental re-closure is mechanically prevented, removed fuses, or the verified absence of power by measurement when the break is not visible. Secondary control circuit inoperability is specifically denied as an acceptable method of verification, repeatedly stated in letters by OSHA to requests for clarifications. Can be found at the LOTO responses on the OSHA site.
mayanees
Senior Member
- Location
- Westminster, MD
- Occupation
- Electrical Engineer and Master Electrician
My opinion
My opinion
I say this is interacting with the system, and the worker must be suited to the level of the PPE on the label. Once you've done the analysis and determined an incident energy level that necessitates PPE higher than the tables, you can't use the tables.
John M
My opinion
I say this is interacting with the system, and the worker must be suited to the level of the PPE on the label. Once you've done the analysis and determined an incident energy level that necessitates PPE higher than the tables, you can't use the tables.
John M
OSHA is pretty clear on this in their own standard:
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=9805&p_table=STANDARDS
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=23483
With what you are saying, a mechanic who is changing out a band saw blade, which requires LOTO, would need to remove the disconnect cover, or machine cover and take voltage readings to verify? I don't think so. We are talking 1910.147 here, not 1910.133.
Last edited:
weressl
Esteemed Member
The mechanical energy verification FOLLOWS the electrical energy source removal, so first 133 then 147.
You are correct if the employee will be working on electrical portions of the equipment (1910.333(b)(2)(iv)(B)). If however, the employee is not working on the electrical equipment of said machine, he is not required to take voltage readings.
1910.333 deals with preventing electrical shocks and other electrical safety hazards. 1910.147 deals with physical hazards, like ensuring a saw will not start up while conducting maintenance.
We are off-topic to what the OP is asking, but I enjoy the conversation.
puckman
Senior Member
- Location
- ridgewood, n.j.
Let me restate no electrical work will be done , just operating a breaker in a mcc and place a lock and tag on a bucket that will have a level of IE OR PPE on a label , door to bucket will be closed. Does that person operating the circuit breaker with door closed need to be in the level of ppe that is on the label. We are not using tables and believe that we have to dress at what the labels state .
thanks for all the respones with this post.
thanks for all the respones with this post.
Last edited:
weressl
Esteemed Member
My point is that if the mechanical assembly would have a clear break in the mechanical energy transmission train that provides CLEAR break in the mechanical energy path, like a clutch. If that device can be secured in the disengaged position then that would be sufficient. You have to follow the path of energy and verify a visible break, OR lacking visual verification of the energy paths break - as is the case of a circuit breaker - you must test the path to be free of energy, eg. test for voltage. In order to test for voltage, proper PPE for the incident energy exposure must be worn.
weressl
Esteemed Member
The person must wear the PPE.
On a personal note: I disagree with the technical merits of the above, but the majority of professionals agree that this is what must be done to comply with the rules as currently written.
Incidentally a closed door could actually increase the amount of force that the operator would experience as the pressure build up - energy accumulation - would be increased in comparison of an open door where the arc flash energy can start to dissipate through the opening right away. Arc-resistant gears are designed in such fashion where gravity flappers release the arc-flash energy. Standard MCC's usually have no wents and MC Switchgear only has wents for heat removal/ air circulation NOT for relieving arc-flash energy overpressure.
Your question is a bit wide.
PPE is required ALWAYS.
Personal Protective Equipment
That would mean also: glasses, gloves, hard hats.
Sorry strife for the confusion. When there is a label [arc flash] placed on the electrical panel that states a level of ppe to be worn when working in the panel does the same level of ppe apply when the only work is turning a circuit breaker on or off as in loto ? No electrical work just circuit breaker operation.
zog
Senior Member
- Location
- Charlotte, NC
If the label is from the results of an arc flash analysis then yes, it is the hazard at the working distance used for the calculation (Should also be on label) and is independent of the task being done or if doors/covers are removed or installed. Always the same, not task based like the tables.
weressl
Esteemed Member
- Status