esp policy?

[puckman]

The company i work for has a " energized electrical work policy " and they use part of osha and 70e as a guide for qualified workers to work from.
Their LOTO policy they said is under Osha not 70e. They also want us to work from the tables in 70e and use the Limit of approach boundries except the 70e tables in their policy is from nfpa 2004 issue. Also our electric service is to large for defaulting to tables.
Can a company devise a workers safety policy using both 70e and osha rules and be in complience with the law? Is osha LOTO differrent than 70e LOTO ? We usually do a multi worker LOTO.

My boss try to get them to do an analysis but they didn't get it.

 

[zog]

The company i work for has a " energized electrical work policy " and they use part of osha and 70e as a guide for qualified workers to work from.
Their LOTO policy they said is under Osha not 70e. They also want us to work from the tables in 70e and use the Limit of approach boundries except the 70e tables in their policy is from nfpa 2004 issue. Also our electric service is to large for defaulting to tables.
Can a company devise a workers safety policy using both 70e and osha rules and be in complience with the law? Is osha LOTO differrent than 70e LOTO ? We usually do a multi worker LOTO.

My boss try to get them to do an analysis but they didn't get it.

The OSHA electrical standard is a legeally enforcable interpretation of the NFPA 70E. The 1st 70E was in 1979, in 1981 OSHA released the "Final Rule" electrical standard based on that 70E. SO they are basically the same thing but the OSHA standard lags the last 70E revision by a few years. OSHA is releasing a revised electrical standard this year based on the 2004 70E, they are over due on th release so I hope they are chaging it to reflect the 2009 70E.

But for LOTO, it would be tough to find anything different betwen the two.

Now OSHA also has a General Duty Clause that requires employers to follow current industry standards for employee safety, they define those as the "industry standards" that section of OSHA is based on, so they can enforce the latest standards (In this case the 2009 70E) via that clause. The delay in industry standard changes and OSHA revisions is the reason the general duty clause exists.

 

[jim dungar]

But for LOTO, it would be tough to find anything different betwen the two.

The OSHA rule for LOTO does not always require verification with a voltage tester, like 70E does. For many general situations (i.e. changing a belt) OSHA allows a simple 'try to start the machine' test for LOTO. Many companies try to use this general OSHA method instead of the more severe requirements for verification of actual 'de-energization' before performing electrical work.

 

[RETRAINDAILY]

The bigger companies Ive worked make the electrician or any one opening a panel to follow 70e with full PPE Intel verification with a company meter that is on a fully stocked cart.
Then operators that enter equipment,sanitation,or mechanics follow loto try (OSHA standard)

 

[puckman]

Does anyone know if Osha requires analysis on the electrical service before defaulting to the tables like 70e requires?
Again thanks to everyone for all the information given here .

 

[RETRAINDAILY]

does OHSA require us to follow NFPA 70E?
I have been in allot of Factories that have OSHA inspectors and they don't follow it.
Some want you to follow it to a tee I'm thinking it is more a insurance thing.

 

[WorkSafe]

does OHSA require us to follow NFPA 70E?
I have been in allot of Factories that have OSHA inspectors and they don't follow it.
Some want you to follow it to a tee I'm thinking it is more a insurance thing.

NFPA 70E is not a "OSHA standard." It is a concensus standard that meets the intent of OSHA Subpart S (1910) and K for 1928 and could site the employer for not following it under the General Duty Clause.

I have never heard of a employer being in compliance with 70E and not with OSHA.

 

[jim dungar]

I have never heard of a employer being in compliance with 70E and not with OSHA.

Excellent concise point.

Yes, it possible to create your own safety program without basing it on NFPA70E. But, do you want to run the risk that it is not defensible to OSHA or to a 'court of law'.

 

[RETRAINDAILY]

I have never heard of a employer being in compliance with 70E and not with OSHA.

Try this again

Factors that that follow 70E to tee, follow OHSA to a tee
(someone yelling at you if you take you safety glasses off to wipe the sweat out of your eyes.)
And then there are factory's that follow OSHA standards but not 70e.
More are all the time. but few have been asset.

 

[zog]

The OSHA rule for LOTO does not always require verification with a voltage tester, like 70E does. For many general situations (i.e. changing a belt) OSHA allows a simple 'try to start the machine' test for LOTO. Many companies try to use this general OSHA method instead of the more severe requirements for verification of actual 'de-energization' before performing electrical work.

Not sure where you get that from:

1910.333 (b)(2)(iv)(B) A qualified person shall use test equipment to test the circuit elements and
electrical parts of equipment to which employees will be exposed and shall verify
that the circuit elements and equipment parts are deenergized. The test shall also
determine if any energized condition exists as a result of inadvertently induced
voltage or unrelated voltage backfeed even though specific parts of the circuit
have been deenergized and presumed to be safe. If the circuit to be tested is
over 600 volts, nominal, the test equipment shall be checked for proper operation
immediately after this test.

1910.269 says the same thing.

 

[pfalcon]

NFPA 70E is not a "OSHA standard." It is a concensus standard that meets the intent of OSHA Subpart S (1910) and K for 1928 and could site the employer for not following it under the General Duty Clause.

I have never heard of a employer being in compliance with 70E and not with OSHA.

70E is typically more restrictive since OSHA has essentially lifted their requirements from the 70E. There are minor differences including that OSHA is typically one or two code cycles behind the 70E; Not everything was lifted; Some other things were added.

Bottom line is what WorkSafe said above that I emphasized.

Too bad OSHA doesn't have a better review process. The whole section could be written as "Comply to NFPA70E 2004 edition with the following amendments." Save paper - save confusion.

 

[jim dungar]

Not sure where you get that from:

General LOTO can be found in 1910.147, which is not as proscriptive as the sections you quoted.

This section includes an acceptable procedure.
"Appendix A to ?1910.147?Typical Minimal Lockout Procedure

(7) Ensure that the equipment is disconnected from the energy source(s) by first checking that no personnel are exposed, then verify the isolation of the equipment by operating the push button or other normal operating control(s) or by testing to make certain the equipment will not operate."

 

[rbalex]

In the latest (third) Final Standard , Part V. Summary and Explanation of the Final Standard, Section A, Issues, FedOSHA gives their rationale for deliberately avoiding extracting material from the latest version(s) of 70E. (They never actually "adopted" any Edition) It's a very long, laborious read.

IMO, what it essentially boiled down to is FedOSHA's (non-voting) representatives, the current and former Director of Electrical Enforcement Operations, had a great deal more influence on the development of the 2000-70E Edition, than subsequent Editions. But they can enforce the later Editions through the General Duty clause.

 

[zog]

IMO, what it essentially boiled down to is FedOSHA's (non-voting) representatives, the current and former Director of Electrical Enforcement Operations, had a great deal more influence on the development of the 2000-70E Edition, than subsequent Editions. But they can enforce the later Editions through the General Duty clause.

The current director was formerly the 70E chairman. So expect some revisions soon.

 

[rbalex]

The current director was formerly the 70E chairman. ...

Are you sure? Ray Jones was the immediate past 70E Chair (2004 & 2009), Steven Roll was his predecessor (2000). David Wallis is the current FedOSHA EE Director.

In any case, the NFPA TC Chairs, are certainly influential, but they don't have veto power.

 

[zog]

Are you sure? Ray Jones was the immediate past 70E Chair (2004 & 2009), Steven Roll was his predecessor (2000). David Wallis is the current FedOSHA EE Director.

In any case, the NFPA TC Chairs, are certainly influential, but they don't have veto power.

My bad, I was talking about Ken M, guess he is Director for region 1 only.

 

[zog]

General LOTO can be found in 1910.147, which is not as proscriptive as the sections you quoted.

This section includes an acceptable procedure.
"Appendix A to ?1910.147?Typical Minimal Lockout Procedure

(7) Ensure that the equipment is disconnected from the energy source(s) by first checking that no personnel are exposed, then verify the isolation of the equipment by operating the push button or other normal operating control(s) or by testing to make certain the equipment will not operate."

Ok, but for electrical LOTO you should use the Electrical OSHA standards right?

 

[jim dungar]

Ok, but for electrical LOTO you should use the Electrical OSHA standards right?

Absolutely.

But not every LOTO situation is for working on electrical circuits.

I am dealing with a facility that thinks they need a 70E qualified person to verify electrical de-energization as part of every LOTO switch operation, even if the purpose is to only change the belt on a motor.

The fact is, there are many facilities that do not train the employees on the specifics and differences of electrical work, which means they are not qualified in the eyes of 70E.

 

[pfalcon]

Ok, but for electrical LOTO you should use the Electrical OSHA standards right?

OSHA is absolutely required.
NFPA is absolutely recommended because they may ding you throught the general duty clause.