70e policy

[jimbo123]

This is about a company that has a electrical safety policy and had a arc flash survey, Most qualify workers work out of a maintenance department would it be a conflict of interest to have the maintenace director incharge or involved with the electrical policy?
The director has a job to get the work done and not fall behind, In the past i have seen these people give electrical work to a QW with a small amount of electrical experience because he had no one else to do the work.

Any opinuns please on who should be involved with these policys.

 

[petersonra]

I don't really care who is in charge as long as they are not cheating.

The worst electrical safety cheaters I run across tend to be electricians. Can't tell you how many times I have heard "I have been doing this for XX years so it is safe for me". Or "We don't allow anyone but journeymen to do live work because it is too dangerous for apprentices".

 

[cornbread]

IMHO he should be involved, he is the one that should be assuring that 70E is followed.

 

[jimbo123]

Let me expand on this . In the past these guys have said 70e was a bussiness of nfpa and its another way to make money. They have no idea what this is about and feel if you are a mechanic and the company gave you the ppe you can do what every you say you can do with regards to electrical work, especially if the heat is on the Maintence director to get the work done.
This is not about short cuts its about guys being put into a bad situation because saying no drops them down on the go to guy list.
Trying to get a shut down is not the easyest thing to get done. I like to be sure the guy is a safety guy with a little no how with electrical work,
Yes some old timers do not like change and thats not the way they did it back then, one thing they are not the ones signing permits
here. There has to be some type experience that management needs to be involved with this work.

 

[cornbread]

I feel your pain. We had the same issues when we 1st implemented 70E...nothing could be shutdown, it would cost too much money, take too much time. When we started using the energized work permit and having the safety manager and plant manager sign off...noting that they were taking the liability. After explaining the hazards and what could go wrong..it was amasing how they would find opportunities to de-energize equipment. We still do a lot of energized work..but I would say we have the cut the occurances by 2/3. Instead of reacting to situations we are actually planning ahead and looking for window where we can do our jobs in a safe and timely manner. Some of the stronges critics (electricians) have come around and see the benifits of 70E. Its not perfect... but I do believe we have made our work place safer for all involved. I hope your efforts will bring forth the changes we have seen at our site...my only advice it to hang in there..

 

[zog]

I feel your pain. We had the same issues when we 1st implemented 70E...nothing could be shutdown, it would cost too much money, take too much time. When we started using the energized work permit and having the safety manager and plant manager sign off...noting that they were taking the liability. After explaining the hazards and what could go wrong..it was amasing how they would find opportunities to de-energize equipment. We still do a lot of energized work..but I would say we have the cut the occurances by 2/3. Instead of reacting to situations we are actually planning ahead and looking for window where we can do our jobs in a safe and timely manner. Some of the stronges critics (electricians) have come around and see the benifits of 70E. Its not perfect... but I do believe we have made our work place safer for all involved. I hope your efforts will bring forth the changes we have seen at our site...my only advice it to hang in there..

Good to hear, my job for years was to develop and implement 70E into large industrial plants and these issues are common to most places. You need to have management behind the program (I created a special class for management that we delivered prior to developing procedures, buying PPE, or training skilled trades). Both your maintenence manager and safety department need to be involved. The toughest obstacle was always the senior electricians, the ones that have been "Doing it that way for years", tough to change a culture like that but it can be done.

Jimbo, I can vouch for cornbread, these issues he talks about were addressed here in this forum and he had many of the same questions and issues you have. I suspect you both are in a similar environment. Don't give up.

 

[petersonra]

Let me expand on this . In the past these guys have said 70e was a bussiness of nfpa and its another way to make money.

There is a LOT of truth to this statement. IMO, a large percentage of the people involved in the safety industry, including the stds orgs are in it for the money. So what? Should they work for free?

They have no idea what this is about and feel if you are a mechanic and the company gave you the ppe you can do what every you say you can do with regards to electrical work, especially if the heat is on the Maintence director to get the work done.
This is not about short cuts its about guys being put into a bad situation because saying no drops them down on the go to guy list.

It is not about saying no. It is about saying yes AND being in a position to tell people how it can be done safely. The problem tends to be that the training and education and experience level is not to a point where a lot of these guys can figure out how to so it safely. Plus you have a lot of very dubious training consultants out there muddying the waters and deliberately making it more difficult than it needs to be.

Trying to get a shut down is not the easyest thing to get done. I like to be sure the guy is a safety guy with a little no how with electrical work, Yes some old timers do not like change and thats not the way they did it back then, one thing they are not the ones signing permits here. There has to be some type experience that management needs to be involved with this work.

Most people do not like change because experience has shown them that a lot of change is not better, just different and it is inconvenient to them. There is a definite benefit to safe working practices for everyone involved.

The real issue is that NFPA70E was not written in a way that helps people be safe so much as to create a new industry. A lot of it is overkill IMO, and everyone who looks at it knows that, especially at lower HRC levels. There just is not much hazard to speak of from arc flash at levels below HRC2. The std ought to address that in a rational way and allow energized work at those levels.

 

[kwired]

There is a LOT of truth to this statement. IMO, a large percentage of the people involved in the safety industry, including the stds orgs are in it for the money. So what? Should they work for free?




It is not about saying no. It is about saying yes AND being in a position to tell people how it can be done safely. The problem tends to be that the training and education and experience level is not to a point where a lot of these guys can figure out how to so it safely. Plus you have a lot of very dubious training consultants out there muddying the waters and deliberately making it more difficult than it needs to be.




Most people do not like change because experience has shown them that a lot of change is not better, just different and it is inconvenient to them. There is a definite benefit to safe working practices for everyone involved.

The real issue is that NFPA70E was not written in a way that helps people be safe so much as to create a new industry. A lot of it is overkill IMO, and everyone who looks at it knows that, especially at lower HRC levels. There just is not much hazard to speak of from arc flash at levels below HRC2. The std ought to address that in a rational way and allow energized work at those levels.

This is not one of my strong areas but if I understand correctly, using 70E is not an OSHA requirement. But at same time if you follow 70E, you will generally comply with all of OSHA requirements, and therefore 70E is looked upon as the standard to follow. A company can write their own SOP for this, but it is much easier and cost less to just implement 70E, where someone else has done all the research, and continues to make changes as necessary over time.

 

[cornbread]

Osha 269 (me thinks) general duty clause basicaly says employers have to identify and eliminate or mitigate work place hazards. In the electrcial world 70E is a "how to guide" to go about this.

 

[WorkSafe]

Osha 269 (me thinks) general duty clause basicaly says employers have to identify and eliminate or mitigate work place hazards. In the electrcial world 70E is a "how to guide" to go about this.

OSH Act 5(a)1 is the General Duty Clause.

 

[petersonra]

Personally, I think the first training session should have a handout that says this.

No one will work energized unless they have received written direction to do so in the form of an energized work permit signed by one of the following people (list of names not to exceed 2 or 3).

Then the trainer can talk about what constitutes energized work. A lot of old timers just do not consider work like changing out a light bulb, or an electrical outlet, or measuring voltages to be energized work.

Once people get it in their head that working on energized systems is generally no longer allowed, they can start learning the very few cases where it is allowed by written driection of a designated individual.

Forget about arc flash PPE or anything else for the first session. It is about making sure people understand that the crux of the safety issue is not being exposed to electricity.

 

[pfalcon]

This is not one of my strong areas but if I understand correctly, using 70E is not an OSHA requirement. But at same time if you follow 70E, you will generally comply with all of OSHA requirements, and therefore 70E is looked upon as the standard to follow. A company can write their own SOP for this, but it is much easier and cost less to just implement 70E, where someone else has done all the research, and continues to make changes as necessary over time.

Although its not a mandatory standard - its a mandatory standard. Through the general duty clause you must protect against recognized hazards. OSHA will use the 70E as the starting point unless you can produce a different "recognized consensus standard" that they can hold you to. OSHA recognizes that the OSHA standards themselves are out of date. Therefore the current 70E is what they work from by default.

If you roll your own standard - OSHA will compare how it stacks against the 70E.

 

[kwired]

Although its not a mandatory standard - its a mandatory standard. Through the general duty clause you must protect against recognized hazards. OSHA will use the 70E as the starting point unless you can produce a different "recognized consensus standard" that they can hold you to. OSHA recognizes that the OSHA standards themselves are out of date. Therefore the current 70E is what they work from by default.

If you roll your own standard - OSHA will compare how it stacks against the 70E.

Which basically means what I said is true. It is pointless for a company to try to write their own standard, as it will cost too much to do so and you will basically end up with something that may not be the same words or format as 70E, but if you do a thorough enough job will effectively have same requirements. Why pay someone to do something that has already been done for you - plus 70E updates itself as new things are discovered, all you have to do is purchase newer edition instead of continuing to invest in research for keeping current with your own standard.

 

[weressl]

IMO.

NFPA 70E came about because of the rate of incidents due to unqualified workers doing more work and qualified workers violating existing safety policies.

Even if it is/was clear that the incident happened due to workers' negligence, OSHA and the Courts will hold the Company responsible to prevent the occurence.

NFPE 70E de facto allows the Companies to declare less-than qualified workers to be qualified. In essence it dillutes the trade and professionalism. Not only general 'qualified workers' should be allowed to work on energized equipment, but qualification procedures should be specific, measurable and demonstrated. Way too much educational investment on the Company's or the Union's part in employees, who can 'take' the qualification and find higher paying employment somewhere else and then that Company does not need to invest in traning as the employee is allready trained. NFPA 70E result in the employee being shortchanged, again.

 

[WorkSafe]

IMO.

Even if it is/was clear that the incident happened due to workers' negligence, OSHA and the Courts will hold the Company responsible to prevent the occurence.

This is not really how to works. If OSHA does cite the company, the company can contest the violation to the Area Director. The company can then take the contested citation to the Occupational Safety & Health Review Commission (OSHRC) and claim the employee was negligent. They (the Company) would have to prove to the commission that they had properly trained the employee on the tasks at hand, and also enforced their own safety policy, and disciplined employees who failed to follow their rules.

I have seen many citations dismissed because the company could prove the employee was negligent from misconduct.

 

[weressl]

This is not really how to works. If OSHA does cite the company, the company can contest the violation to the Area Director. The company can then take the contested citation to the Occupational Safety & Health Review Commission (OSHRC) and claim the employee was negligent. They (the Company) would have to prove to the commission that they had properly trained the employee on the tasks at hand, and also enforced their own safety policy, and disciplined employees who failed to follow their rules.

I have seen many citations dismissed because the company could prove the employee was negligent from misconduct.

My description of the process was shorthand. Cite some cases of fatality where the Company was held completely harmless due to workers negligence.

 

[WorkSafe]

My description of the process was shorthand. Cite some cases of fatality where the Company was held completely harmless due to workers negligence.

Here's just one:

http://www.oshrc.gov/decisions/html_2010/09-0178.htm

Secretary of Labor v. Paramount Advanced Wireless, Occupational Safety and Health Review Commission, No. 09-0178, 6/21/10

An employer can defend against the Secretary's showing of a violation by establishing the affirmative defense of unpreventable employee misconduct, which requires the employer to prove that: (1) it has established work rules designed to prevent the violation; (2) it has adequately communicated those rules to its employees; (3) it has taken steps to discover violations; and (4) it has effectively enforced the rules when violations have been discovered. E.g., Capform, Inc., 16 BNA OSHC 2040, 2043, 1993-95 CCH OSHD ? 30,589, p. 42,358 (No. 91-1613, 1994); Nooter Constr. Co., 16 BNA OSHC 1572, 1578, 1993-95 CCH OSHD ? 30,345, p. 41,841 (No. 91-237, 1994); accord Brock v. L.E. Myers Co., 818 F.2d 1270, 1276 (6th Cir. 1987), cert. denied, 484 U.S. 989 (1987).

 

[pfalcon]

Which basically means what I said is true. It is pointless for a company to try to write their own standard ... you will basically end up with ... the same words... Why pay someone to do something that has already been done... all you have to do is purchase newer edition...

Exactly

 

[pfalcon]

... NFPA 70E came about because of the rate of incidents due to unqualified workers doing more work and qualified workers violating existing safety policies...

Rates of injuries were declining before the NFPA70E and OSHA were created. I would argue that "unqualified" people were doing more work as you go backwards in time. That OSHA and NFPA70E were just markers of the cultural change that said those old practices should stop. And I expect the 70E will tighten the definition of "qualified" as we go forward.

 

[kwired]

Rates of injuries were declining before the NFPA70E and OSHA were created. I would argue that "unqualified" people were doing more work as you go backwards in time. That OSHA and NFPA70E were just markers of the cultural change that said those old practices should stop. And I expect the 70E will tighten the definition of "qualified" as we go forward.

I have no idea why injuries were declining, but will throw in the likelihood that insurance companies had a little to do with it. Start using safer work practices and creating SOP's and you will have less insurance claims, and will be offered lower premiums, or even denied coverage if you don't use these practices. I run into those kind of things a lot anymore. I have work places that they want you to sign in when working on their site, mostly because insurance wants them to do so.