Energized Work Permit

[jacknife76]

Is anyone aware of any (OSHA/NFPA) rules regarding the time limit on keeping records of energized work permits?

If so, please direct me to the documentation or any information you have on the subject.

Thank you.

 

[zog]

That is a great question, I dont think there is a rule on this. I would say 1 year, or to end of the FY after your 300 log is posted. Just my 2 cents.

 

[billsnuff]

Sometimes insurers come into play on these issues. you may want to contact your loss prevention people. also, many companies have established record retention policies. that would be another place to check.

 

[jacknife76]

Thank you for your input. I guess I have been asked if we legally need to keep them. I prefer to, but it appears my records department may not.

I would assume you would want to keep them around, in case OSHA ever comes calling. Its part of (evidence of?) our safety plan.

 

[zog]

I would keep them for a minimum of 1 year, max of 3.

 

[jdsmith]

My plant has a work permit system for cold work, hot work, excavations, critical lifts, confined space, and energized work - all work is permitted! We must keep all work permits on file for one year, so I assume this meets any OSHA and insurance requirements for record keeping.

 

[eric9822]

We keep the all permits on file for a period of one year to prove that we are actually using a permit system. Having a permit system and actually using a permit system are two different things. If you don't retain the permits I am not sure how you can document that you are following the system.

 

[wtucker]

OSHA is enforcing NFPA 70E in spirit, not to the letter. That is, several sections of the OSHA general industry and construction standards address protection against hazards such as arc flash, shock, burns and fire. See http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25540 or http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25557

That second one says, "The General Duty Clause is not used to enforce the provisions of consensus standards, although such standards are sometimes used as evidence of hazard recognition and the availability of feasible means of abatement." But that doesn't mean they won't use it if someone gets hurt.

It's interesting that when OSHA updated the the general industry standards on electrical in 2007, they updated only installation standards, and didn't touch training, work practices, use of equipment or PPE (1910.331 through .335), and said they chose to base the update on the 2000 edition of 70E, not the 2004, which had the big arc flash protection changes. And, they haven't touched the construction industry standards, which are based on the 1979 70E.

My point is, from an OSHA standpoint, don't worry about keeping the Energized Electrical Work Permits, because they're not required by OSHA. It's more important that you USE a permit than that you keep it.