Ground Maintenance Program

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normanam

Member
Consultant trying to site me for not having a formal maintenance schedule for our grounding system (internal audit). Here's exactly what he states. I cannot find anywhere that requires this. Industrial facility mostly 480Y installation. Officially stating it comes from 1901.304 (g)

Here is the quote


Essentially OSHA took a circuitous route to get to this requirement:
? First OSHA required either GFCI or assured grounding on construction sites for temporary wiring per 29 CFR Part 1926.
? Then the Industry standard in 1910.304 (b) required a similar program for similar wiring in industry in "construction like" settings. Unfortunately while many industries are past the point of being able to, by regulation, use temporary wiring, in fact temporary wiring is still used in many plants (and not for construction only). Thus the extension of 1910.304 (b) to any temporary type wiring (flexible cord/cables) - even those used past six months and not technically temporary at all.
? Then 1910.304 (g) required that all building wiring (system, circuits, equipment) be grounded. Various means are provided in this regulation and NEC to assure that this grounding is in fact functional over time. Consequently the phrase "assured grounding" is meant to relate that a facility must prove that grounding in fact is functional; keeping in mind that various grounding schemes are available for use and may, therefore, need various "proving" requirements.

OSHA in general practice ALWAYS puts the responsibility on the user of equipment to determine either through manufacturer's information or through user knowledge (testing, inspections) that equipment is being used as specified by whomever designed the equipment.

So essentially, you can call the inspections needed for other than temporary wiring something else - besides an "assured grounding program"; however the requirement is still in play - the facility must have a means to prove compliance and usually an overall assured grounding program (by any other name) is how that requirement is met.
 

pfalcon

Senior Member
Location
Indiana
First of all, make him reference the afflicting paragraph. 1910.304(b) is a really large reference. He is refering to 1910.304(b)(3)(ii). Here's a link to explanatory material from OSHA.

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=FEDERAL_REGISTER&p_id=21193

OSHA said:
It should also be noted that not all maintenance, remodeling, or repair work is construction-like.

So no, the section 1910.304(b)(3)(ii) does not create a circuitous route to backdoor grounding requirements. Your consultant needs to separate his opinions from code; not be vague and blend them into it.

He should be saying that in his opinion that following an incident that OSHA may demand proof of maintenance. In his opinion a written program would pacify OSHA that you are doing due diligence.
 

normanam

Member
Not having dealt with this in the past, are other people doing testing on their grounding and bonding systems using a formalized program? 70E (205.5) says they shall be maintained, but I don't recall any requirement for a formal program.

I am currently thinking about using a 3 point test every 3 years at the substation to make sure our earth connection stays well maintained. I would then have each piece of equipment visually inspected during any PM activities, with an electrical test maybe every 5-10 years. Any thoughts? Each piece of equipment was installed with a separate EGC as well as continuous conduit system, so I personally feel it overkill to test annually a system that was built with such redundancy, but also do not want to be breaking any applicable codes.
 

cowboyjwc

Moderator
Staff member
Location
Simi Valley, CA
My question would be, are you just checking to make sure that it's still grounded or are you trying to maintain a certain amount of ohms?

Depending on when you test it, (after a rain, after a drought, cooler weather, warmer weather) it will affect the readings, if your trying to maintain a certain resistance.
 
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