Live work waiver

[Aleman]

Based on the OP's original post, my question is has anyone there had electrical safety training? By definition a qualified worker has had electrical safety training and should have been able to answer the original question.


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Apologies for the double reply. To be honest I can't remember everything that was in the training. And we haven't had to bother with any paperwork or
official policies on this till now. But thanks for your helpful criticism. Which really wasn't helpful at all.

To the rest of you folks, thanks for the help and suggestions.

 

[wbdvt]

Our panels are up to code per NEC 409 arc flashed rated etc. It's just that we really can't shut stuff off without it getting very expensive.
And the powers that be want some type of safety measures in place and accountability etc.

Once again thanks guys for the help.

Could you explain what is meant by the NEC 409 arc flash rated comment? As far as I know there is no reference to arc flash in NEC 409 only about short circuit ratings but I am willing to be educated on that.

Thanks

 

[Jraef]

Every employer is going to have to address the Live Work Permit on their own, in consultation with their insurance underwriter and their lawyers. The way OSHA works is that if someone gets hurt, they swoop in and want to see what happened. If someone was doing something incorrectly, i.e. not the proper procedure and/or protections, they will want to see who approved it on the Live Work Permit. The people listed on that permit are not only legally responsible for ensuring that all proper training was up to date and all procedures followed, including up to date testing of PPE, etc., they are CRIMINALLY responsible if it didn't take place. So because of that, many lower level managers and supervisors are reluctant to be the final signer of that document and move it up the ladder.

I did some work out at a Lockheed Martin facility a few years ago, the Live Work Permit process was 28 pages long, requiring signatures of people 6 levels up the corporate ladder and if any of them were out of town, you were screwed if you could not power down. So basically, it didn't happen unless the situation was DIRE.

 

[Aleman]

Could you explain what is meant by the NEC 409 arc flash rated comment? As far as I know there is no reference to arc flash in NEC 409 only about short circuit ratings but I am willing to be educated on that.

Thanks

The Arc flash rating is an NFPA70E requirement that establishes the actual flash hazard level of your panel. I'm certainly no expert on this, but some of the guys here really know this stuff. I don't believe the NEC 409 covers the hazard level other than the SCCR rating as you point out. What confuses me are all the standards, NEC, NFPA70E, OSHA, UL508A and which of them are actually required or apply at my location. So my comment was related to the fact that our panels comply with NEC409 and are Arc Flash rated per NFPA70E. And now the company wants some kind of regulation pertaining to live work which isn't a bad thing at all. I just don't want it to be overbearing. See Jraefs post for a real horror story. I wouldn't want to be an electrician at that plant.

 

[wbdvt]

The Arc flash rating is an NFPA70E requirement that establishes the actual flash hazard level of your panel. I'm certainly no expert on this, but some of the guys here really know this stuff. I don't believe the NEC 409 covers the hazard level other than the SCCR rating as you point out. What confuses me are all the standards, NEC, NFPA70E, OSHA, UL508A and which of them are actually required or apply at my location. So my comment was related to the fact that our panels comply with NEC409 and are Arc Flash rated per NFPA70E. And now the company wants some kind of regulation pertaining to live work which isn't a bad thing at all. I just don't want it to be overbearing. See Jraefs post for a real horror story. I wouldn't want to be an electrician at that plant.

It may be a matter of semantics but there is no such thing as arc flash rated per NFPA 70E. NFPA 70E is focused on electric safety in the workplace not on equipment ratings/qualifications. It does require that an arc flash risk assessment shall be performed for a piece of equipment prior to any work being done on that equipment but there is nothing on equipment being arc flash rated. The only reference is to arc resistant switchgear in Article 130.7(C)(15) in the tables to determine Arc Hazard PPE Categories.

 

[zog]

It's just that we really can't shut stuff off without it getting very expensive.
And the powers that be want some type of safety measures in place and accountability etc.

Money is not a factor here, OSHA has fined companies many times for violations involving energized work that was done energized due to a cost factor of shutting down, it's not a valid reason.

 

[kwired]

The Arc flash rating is an NFPA70E requirement that establishes the actual flash hazard level of your panel. I'm certainly no expert on this, but some of the guys here really know this stuff. I don't believe the NEC 409 covers the hazard level other than the SCCR rating as you point out. What confuses me are all the standards, NEC, NFPA70E, OSHA, UL508A and which of them are actually required or apply at my location. So my comment was related to the fact that our panels comply with NEC409 and are Arc Flash rated per NFPA70E. And now the company wants some kind of regulation pertaining to live work which isn't a bad thing at all. I just don't want it to be overbearing. See Jraefs post for a real horror story. I wouldn't want to be an electrician at that plant.

It may be a matter of semantics but there is no such thing as arc flash rated per NFPA 70E. NFPA 70E is focused on electric safety in the workplace not on equipment ratings/qualifications. It does require that an arc flash risk assessment shall be performed for a piece of equipment prior to any work being done on that equipment but there is nothing on equipment being arc flash rated. The only reference is to arc resistant switchgear in Article 130.7(C)(15) in the tables to determine Arc Hazard PPE Categories.

Might be using wrong terminology, but I think he basically means their equipment is field labeled with the incident energy levels and any other required warnings.

 

[mayanees]

Has anyone ever heard of a waiver or form that can be signed by an employee to permit live work for the purpose of troubleshooting, and that is
compliant per existing OSHA NFPA NEC codes? We typically will go into live panels to troubleshoot with proper PPE. But the question of compliance
has come up. Hence the proposal for a waiver or form of some sort. I am vague on all the technicalities of OSHA and thought I'd ask here where a
lot of you people know this stuff very well.

This thread seems to have missed the original question and has gone down the path of the Energized Electrical Work Permit (EEWP) which is an extremely difficult document to work with. Your question specifically addresses troubleshooting, which is exempt from the EEWP process as shown in the 70E excerpt shown below:
130.2(B)(3) Exemptions to Work Permit. An energized electrical work permit shall not be required if a qualified person is provided with and uses appropriate safe work practices and PPE in accordance with Chapter 1 under any of the following conditions:
(1) Testing, troubleshooting, and voltage measuring
(2) Thermography and visual inspections if the restricted approach boundary is not crossed
(3) Access to and egress from an area with energized electrical equipment if no electrical work is performed and the restricted approach boundary is not crossed
(4) General housekeeping and miscellaneous non-electrical tasks if the restricted approach boundary is not crossed

So it is acceptable for you to troubleshoot live circuits without an EEWP provided the PPE requirements for the application are satisfied.

 

[Aleman]

This thread seems to have missed the original question and has gone down the path of the Energized Electrical Work Permit (EEWP) which is an extremely difficult document to work with. Your question specifically addresses troubleshooting, which is exempt from the EEWP process as shown in the 70E excerpt shown below:
130.2(B)(3) Exemptions to Work Permit. An energized electrical work permit shall not be required if a qualified person is provided with and uses appropriate safe work practices and PPE in accordance with Chapter 1 under any of the following conditions:
(1) Testing, troubleshooting, and voltage measuring
(2) Thermography and visual inspections if the restricted approach boundary is not crossed
(3) Access to and egress from an area with energized electrical equipment if no electrical work is performed and the restricted approach boundary is not crossed
(4) General housekeeping and miscellaneous non-electrical tasks if the restricted approach boundary is not crossed

So it is acceptable for you to troubleshoot live circuits without an EEWP provided the PPE requirements for the application are satisfied.

There it is, and thank you mayanees. Yes that is what I'm looking for. The intent is for troubleshooting. We do not actually work on anything hot. Other than meters etc,
the only time I have a tool contact anything hot would be a breaker swap in a panel. Makes me wonder if a fuse replacement is considered to be hot work.

 

[Aleman]

It may be a matter of semantics but there is no such thing as arc flash rated per NFPA 70E. NFPA 70E is focused on electric safety in the workplace not on equipment ratings/qualifications. It does require that an arc flash risk assessment shall be performed for a piece of equipment prior to any work being done on that equipment but there is nothing on equipment being arc flash rated. The only reference is to arc resistant switchgear in Article 130.7(C)(15) in the tables to determine Arc Hazard PPE Categories.

Told you guys I was no expert.
I have been under the impression panels need to be rated these days. But there are different agencies and sets of rules involved and differences depending on
where you are at or who you ask. Seems overly complicated.

 

[mayanees]

There it is, and thank you mayanees. Yes that is what I'm looking for. The intent is for troubleshooting. We do not actually work on anything hot. Other than meters etc,
the only time I have a tool contact anything hot would be a breaker swap in a panel. Makes me wonder if a fuse replacement is considered to be hot work.

... my pleasure Aleman.

And no, but nice try, replacing a fuse is not a part of troubleshooting :roll: and of course that's just my opinion.
Interpretation and the application of 70E is sometimes debatable, but the most important thing is to always meet the PPE requirements of the system you're working on.
I'm 58 years old and grew up when energized interactions were commonplace. Now I'm charged with working in compliance with 70E, and fortunately the standard has somewhat evolved to a better place. I think what's left to change is there needs to be a better definition of 130.2(A) (1):
(A) Energized Work.
(1) Additional Hazards or Increased Risk. Energized work shall be permitted where the employer can demonstrate that de-energizing introduces additional hazards or increased risk.

.. something like: the employer can demonstrate that the task can be completed safely using PPE that meets the requirements of the situation.
Then the EEWP could become a workable document.

But at least now, under normal operations, we can operate a breaker at the face of a panel without PPE and without a 30-foot remote operator.

 

[kwired]

There it is, and thank you mayanees. Yes that is what I'm looking for. The intent is for troubleshooting. We do not actually work on anything hot. Other than meters etc,
the only time I have a tool contact anything hot would be a breaker swap in a panel. Makes me wonder if a fuse replacement is considered to be hot work.

breaker swapping is not troubleshooting. You possibly do some troubleshooting to determine the breaker needs replaced but actually replacing it is not a troubleshooting task.

Replacing a fuse is not hot work if it is on the load side of an open switch such is common with fused "safety switches". If exposed to the line side of the switch it could still be considered a hazard though.

 

[ken44]

Thanks for the replies. We are not trying to get around any safety practices, just trying to be legit. The whole thing is a pain in
the ass but it is what it is. We had a guy who didn't know what he was doing try to troubleshoot an issue. No one was hurt but there
was a small flash. So we are establishing a work permit for live work, and also establishing what and who is a qualified worker. Guess
my post should have been titled 'live work permit' as that is what it will be. Not a waiver.

If anyone has an example of a live work permit I would love to see it.

Can you clarify few things so that we can all learn from this matter?

1. How did a guy who didn't know what he was doing end up in this situation-is he a qualified licensed electrician, if not, how did he end up in this panel and do you know exactly what he did to cause the flash?

2. You said that the panel was compliant, but how old was it and has it been maintained to manufacturers standards?

 

[Aleman]

Can you clarify few things so that we can all learn from this matter?

1. How did a guy who didn't know what he was doing end up in this situation-is he a qualified licensed electrician, if not, how did he end up in this panel and do you know exactly what he did to cause the flash?

2. You said that the panel was compliant, but how old was it and has it been maintained to manufacturers standards?

1. Just a maintenance guy who tried to check voltage and used a crappy meter set to ohms. The thing exploded. The meter's fuse didn't even blow.

2. Probably about 5 years old, and fairly maintained.

I am not an advocate of people working around electricity that don't know what they are doing. Makes for a dangerous situation. Also not a fan of crappy test equipment. Makes for a
potentially dangerous situation. I've seen this in plants before, where there are only a few people that understand electricity and controls but there are times when those people are not
around. And then the poor bastard with the non working machine takes a stab at it. Yes we do need to establish whom is a qualified worker. The reality is that in a lot of plants there
will be pressure to get things running and non qualified personnel may try to troubleshoot an electrical problem. Usually these people will own some sort of cheap meter. Which is exactly
what happened. That said, if the meter was set correctly everything would have been ok. And a better quality meter would have just blown it's fuse.

Also pertaining to your 1st question; I have been working with equipment and controls for many years and it is rare to see a licensed electrician in a equipment tech sort of job. Most of the
licensed guys I have met don't really know controls. So to me, not having a license doesn't necessarily mean someone doesn't know what he or she is doing.

 

[GoldDigger]

The crappy (or just old) meter design is distinguished by use of a fuse and holder combination that cannot interrupt the arc when the fuse blows if the (mis)applied voltage is too high.
Or the fuse only protects the separate high amp terminal.

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[ken44]

1. Just a maintenance guy who tried to check voltage and used a crappy meter set to ohms. The thing exploded. The meter's fuse didn't even blow.

2. Probably about 5 years old, and fairly maintained.

I am not an advocate of people working around electricity that don't know what they are doing. Makes for a dangerous situation. Also not a fan of crappy test equipment. Makes for a
potentially dangerous situation. I've seen this in plants before, where there are only a few people that understand electricity and controls but there are times when those people are not
around. And then the poor bastard with the non working machine takes a stab at it. Yes we do need to establish whom is a qualified worker. The reality is that in a lot of plants there
will be pressure to get things running and non qualified personnel may try to troubleshoot an electrical problem. Usually these people will own some sort of cheap meter. Which is exactly
what happened. That said, if the meter was set correctly everything would have been ok. And a better quality meter would have just blown it's fuse.

Also pertaining to your 1st question; I have been working with equipment and controls for many years and it is rare to see a licensed electrician in a equipment tech sort of job. Most of the
licensed guys I have met don't really know controls. So to me, not having a license doesn't necessarily mean someone doesn't know what he or she is doing.

Thanks Aleman, I appreciate the response and I understand that different environments can bring on all kinds of different issues, I manage over 28 million square foot of space and it varies greatly in purpose and scope and is a continual challenge to keep the workers safe. I have had to implement a policy where certain persons who are designated as techs (jack of all trades) do not perform any electrical work since they do not work under my license due to issues in the past that were similar to your recent matter.