Arc flash responsibilty

[Hassel4]

Here are a few scenarios to help me understand who is responsible for what?
1. I am a property owner of a building in an industrial park. A company leases my property and the lease is setup such that the lessee is responsible for all modifications and maintenance of the electrical distribution system from utility end to outlet. There is a sub station or distribution panel, but they need more. When the lease is up, they restore the facility back to original.
Who is responsible for arc flash requirements?

2. Same setup except, I, the property owner hired a maintenance group to take care of all matters. The lessee has no work, but their employees enter electrical equipment on the floor, panels, MCC, disconnects.

3. Now I am the property owner and bring in an electrical contractor to perform all work. I say the contractor is responsible for training their employees, and providing the proper PPE. I am responsible for arch flash labeling and markings.
:-? hassel4

 

[zog]

Here are a few scenarios to help me understand who is responsible for what?
1. I am a property owner of a building in an industrial park. A company leases my property and the lease is setup such that the lessee is responsible for all modifications and maintenance of the electrical distribution system from utility end to outlet. There is a sub station or distribution panel, but they need more. When the lease is up, they restore the facility back to original.
Who is responsible for arc flash requirements?

2. Same setup except, I, the property owner hired a maintenance group to take care of all matters. The lessee has no work, but their employees enter electrical equipment on the floor, panels, MCC, disconnects.

3. Now I am the property owner and bring in an electrical contractor to perform all work. I say the contractor is responsible for training their employees, and providing the proper PPE. I am responsible for arch flash labeling and markings.
:-? hassel4

These are good questions, I will do my best at answering these, I do a ton of compliance training and used to work with OSHA inspectors quite a bit, but I am not OSHA. That being said, here we go.

1. THe NFPA 70E and OSHA safe work practice requirements are an employer-employee relationship requirement. THe Owner of the equipment is responsible for the labeling. So you need the required warning lables on the equipment and the leasee would be responsible for having safe work practices, PPE, and training in place for thier employees. See article 110.3 of the 2004 NFPA 70E. I must add that this may be one of those things open to interpretation of an OSHA inspector. I would ask OSHA this question at www.OSHA.gov

2. Now you are the employer, so it is all on you.

3. This is an easy one, the 2004 70E added a new section to cover this senario Article 110.4. You are correct in your statement but you must inform the contractor of all hazards on the worksite. Many companies now require proof of 70E compliance for contractors to be on a pre-qualified list. Attached is a sample pre qual form, the 2009 70E will have a similar form in the appendix.