Feds vs. State vs. Feds

[Part 77]

We are at an interesting juncture at the power plant I work at.
Our corporation adopted a Lockout/Tagout (LOTO) program 2 years ago that requires each employee to LOTO equipment they are working on. This replaced the long time standard of a Tagout only used in the utility industry for years. We are also bound to follow OSHA which now reguires LOTO to be used. The third wrinkle in the mix is Washington Administrative Code (WAC) "Safety for Electrical Workers" standards.
Recently an electrician was sent to work on the stepup transformer (20KV-500KV) which sends power to a local BPA substation and the grid. He requested to put a personal lock on the switches in the BPA substation which isolate the transformer from the grid before starting his task. He was not allowed to place a lock by the BPA sub operator as "...that's not how we do it. We don't allow you to enter the yard and place a lock".
Naturally this caused quite a discussion on how to comply with the rules, policies and regs that contradict what BPA allows. A call was made to WA State Dept. of Labor and Industries, who sent inspectors to the plant to investigate. No decisions have been made.
Anyone "been there, done that"? If so, what was the consensus?

 

[brother]

We are at an interesting juncture at the power plant I work at.
Our corporation adopted a Lockout/Tagout (LOTO) program 2 years ago that requires each employee to LOTO equipment they are working on. This replaced the long time standard of a Tagout only used in the utility industry for years. We are also bound to follow OSHA which now reguires LOTO to be used. The third wrinkle in the mix is Washington Administrative Code (WAC) "Safety for Electrical Workers" standards.
Recently an electrician was sent to work on the stepup transformer (20KV-500KV) which sends power to a local BPA substation and the grid. He requested to put a personal lock on the switches in the BPA substation which isolate the transformer from the grid before starting his task. He was not allowed to place a lock by the BPA sub operator as "...that's not how we do it. We don't allow you to enter the yard and place a lock".
Naturally this caused quite a discussion on how to comply with the rules, policies and regs that contradict what BPA allows. A call was made to WA State Dept. of Labor and Industries, who sent inspectors to the plant to investigate. No decisions have been made.
Anyone "been there, done that"? If so, what was the consensus?

Im just curious as to there is not another 'disconnect' between the BPA station and the this transformer other than the one at the BPA??. That just seems odd to me (depending on how long the run is), then again Ive never done work on BPA stuff. That being said, as the way the 'law' is written' I say BPA has to let the guy put his lock on it, just because "that's not how we do it. We don't allow you to enter the yard and place a lock" doent excuse them from not following the law. Let us know the outcome.

 

[weressl]

We are at an interesting juncture at the power plant I work at.
Our corporation adopted a Lockout/Tagout (LOTO) program 2 years ago that requires each employee to LOTO equipment they are working on. This replaced the long time standard of a Tagout only used in the utility industry for years. We are also bound to follow OSHA which now reguires LOTO to be used. The third wrinkle in the mix is Washington Administrative Code (WAC) "Safety for Electrical Workers" standards.
Recently an electrician was sent to work on the stepup transformer (20KV-500KV) which sends power to a local BPA substation and the grid. He requested to put a personal lock on the switches in the BPA substation which isolate the transformer from the grid before starting his task. He was not allowed to place a lock by the BPA sub operator as "...that's not how we do it. We don't allow you to enter the yard and place a lock".
Naturally this caused quite a discussion on how to comply with the rules, policies and regs that contradict what BPA allows. A call was made to WA State Dept. of Labor and Industries, who sent inspectors to the plant to investigate. No decisions have been made.
Anyone "been there, done that"? If so, what was the consensus?

State law can only override the Federal Law if it is stricter than the Federal requirement.

It seems to me that the Owner of the transformer is responsible to place an ACCESSIBLE isolating means on both sides of the transformer, so that is what is may be alcking in the installation itself. The OSHA LOTO is in force for a loooong time, it is not recent. Lacking this the Management of the two separate entities should negoitiate how to accomplish the safe work while maintaining each Companies legal entitiy without overlapping obligations.

 

[eric9822]

We have a two large utility controlled substation yards at our site and we typically are not allowed to enter them. We do however enter them with Utility personnel when we need to apply our locks to the utility owned equipment. You may want to check with the guys supervisor(s) and confirm what the utilities policy is about applying LOTO to their equipment. The guy may be operating under the assumption that you are never allowed in their yard. I can't imagine a utility having a policy in place that prevents you from applying a lock as required by OSHA.

 

[Part 77]

I was offline this weekend.

brother,
This installation was built in 1970-71. There are 2 units producing power. Since then, a co-gen plant was built and parralels one of the units that feed the BPA yard. Isolation and switching equipment was put in for the co-gen plant and allows us to LOTO that 500KV circuit on our property. The circuit in question is original and was a straight shot from the step-ups on that unit to the BPA yard a mile or so away, with no isolation equipment on our property.
weressl,
When the dust settles, I suspect State law will overide BPA.
eric,
The local BPA yard operator has never had this come up till now and may think he's in the right. Time will tell. This will literally become a "Federal" case and the insurance Companies, lawyers and bureaucrats will have to come to a consensus.