LOTO in industrial facilities

[Kedegraw]

We have operators that are not qualified electricians. Can they as per the NFPA 70E open and close breakers and reset a tripped breaker? if so do we need to document that they can perform the work?

 

[iwire]

Being an electrician does not automatically make someone a qualified person nor does not being an electrician prohibit someone from being a qualified person.

I don't believe that you will find the word 'electrician' in any part of OSHA.

In other words whoever is doing the task has to be a qualified person via specific training for the particular task.


From OSHA http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9976

Qualified person. One who has received training in and has demonstrated skills and knowledge in the construction and operation of electric equipment and installations and the hazards involved.

 

[jim dungar]

We have operators that are not qualified electricians. Can they as per the NFPA 70E open and close breakers and reset a tripped breaker? if so do we need to document that they can perform the work?

You have asked two different questions.
Tripped breakers cannot be reset without making sure the reason for the trip has been rectified.

Any employee may be trained, and therefore be qualified, in specific tasks such as the operation of a LOTO device when voltage does not need to be verified.

 

[zog]

From the FAQ's in the safety section of this forum

According to the NFPA 70E, a ?Qualified Person" is one who is trained and knowledgeable of the construction and operation of the equipment or the specific work method, and be trained to recognize the hazards present with respect to that equipment or work method.

Such persons shall also be familiar with the use of the precautionary techniques, personal protective equipment, insulating and shielding materials, and insulated tools and test equipment. A person can be considered qualified with respect to certain tasks but still be unqualified for others.

An employee that is undergoing on the job training and who, in the course of such training, has demonstrated the ability to perform duties safely at his or her level of training and who is under the direct supervision of a qualified person shall be considered to be a qualified person for the performance of those duties.

In addition, to be permitted to work within the limited approach of exposed energized conductors and circuit parts the person shall be trained in all of the following:
Qualified employees shall be trained and competent in:?The skills and techniques necessary to distinguish exposed live parts from other parts of electric equipment
?The skills and techniques necessary to determine the nominal voltage of exposed live parts
?The minimum approach distances specified in this section corresponding to the voltages to which the qualified employee will be exposed, and,
?The decision making process necessary to determine the degree and extent of the hazard and the personal protective equipment and job planning necessary to perform the task safely
A few notes to add to the 70E definition.?Only the employer can deem an employee qualified after they have had the proper training and have demonstrated profinency using the skills and method learned.
?There is no such thing as NFPA 70E certification, going to a training course does not make an employee qualified.
?The most misunderstood part of the "qualified" term is that it is all emcompassing, you are "qualified" to work on a specific type or piece of equipment.
?Neither a J-card, a masters license, or an engineering degree make you a "qualified person"
?The word "electrician" is not anywhere in the definition of a "qualified person" meaning these rules apply to all employees and you dont have to be an electrician to be "qualified"

 

[don_resqcapt19]

Resetting a tripped breaker is an issue. You are required to investigate why the breaker tripped before you reset it unless you are sure that it tripped from an overload.

 

[pfalcon]

... Tripped breakers cannot be reset without making sure the reason for the trip has been rectified. ...

... You are required to investigate why the breaker tripped before you reset it unless you are sure that it tripped from an overload.

Can you provide the code section for those assertions?

 

[iwire]

Here from OSHA

1910.334(b)(2)

Reclosing circuits after protective device operation. After a circuit is deenergized by a circuit protective device, the circuit may not be manually reenergized until it has been determined that the equipment and circuit can be safely energized. The repetitive manual reclosing of circuit breakers or reenergizing circuits through replaced fuses is prohibited.

Note: When it can be determined from the design of the circuit and the overcurrent devices involved that the automatic operation of a device was caused by an overload rather than a fault condition, no examination of the circuit or connected equipment is needed before the circuit is reenergized.

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9911

 

[pfalcon]

... In addition, to be permitted to work within the limited approach of exposed energized conductors and circuit parts the person shall be trained in all of the following: ...

In a lighting panel where the breakers are switch rated maybe - but if they're not switch rated there should be separately mounted switches outside the panel. Which is what I would endorse anyway.

On a machine tool I doubt you'll find breakers outside the limited approach so ... I really sincerely doubt your company is going to qualify all their operators properly to do the breakers. See Zog's full post.

 

[pfalcon]

Here from OSHA

Reclosing circuits after protective device operation. After a circuit is deenergized by a circuit protective device, the circuit may not be manually reenergized until it has been determined that the equipment and circuit can be safely energized. The repetitive manual reclosing of circuit breakers or reenergizing circuits through replaced fuses is prohibited.

Note: When it can be determined from the design of the circuit and the overcurrent devices involved that the automatic operation of a device was caused by an overload rather than a fault condition, no examination of the circuit or connected equipment is needed before the circuit is reenergized.

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9911

Thanks much. Unfortunately my experience has been that the circuits being reset by operators are just such circuits as to qualify for the note.

 

[don_resqcapt19]

How do they know that the trip was caused by an overload?

 

[zog]

Thanks much. Unfortunately my experience has been that the circuits being reset by operators are just such circuits as to qualify for the note.

Not following your logic, unless you have a trip unit with indication showing what type of fault it tripped on it is pretty hard to know it was an overload.

 

[pfalcon]

Reclosing circuits after protective device operation. After a circuit is deenergized by a circuit protective device, the circuit may not be manually reenergized until it has been determined that the equipment and circuit can be safely energized. The repetitive manual reclosing of circuit breakers or reenergizing circuits through replaced fuses is prohibited.

Note: When it can be determined from the design of the circuit and the overcurrent devices involved that the automatic operation of a device was caused by an overload rather than a fault condition, no examination of the circuit or connected equipment is needed before the circuit is reenergized.

http://www.osha.gov/pls/oshaweb/owad...ARDS&p_id=9911

How do they know that the trip was caused by an overload?

Not following your logic, unless you have a trip unit with indication showing what type of fault it tripped on it is pretty hard to know it was an overload.

As much as I would like to agree with you, your questions are argumentative, legally speaking. Meaning by posing the question you're attempting to make the note to be "of no effect". The presence of the note means that it can be done reasonably with proper design and installation.

For example: Providing the overload is proximate to the motor and upstream OCPD is provided for other fault conditions, the likelihood of of the overload tripping for any other fault condition is negligible.

And please, don't argue negligible. Because after doing a live-dead-live test there's still a negligible chance the dead circuit you plan to work on is actually live. Which if we don't permit overlooking negligible conditions then all circuits are always energized even after lockout.

 

[don_resqcapt19]

If you have a motor starter with a tripped breaker, that to me indicates that there is an issue other than an overload and you need to determine the cause of the trip before reclosing the breaker.

 

[pfalcon]

If you have a motor starter with a tripped breaker, that to me indicates that there is an issue other than an overload and you need to determine the cause of the trip before reclosing the breaker.

OR: It may indicate the machine was designed to trip overloads during jam conditions to prevent equipment damage. Which when combined with upstream OCPD would demonstrate both design and assignable cause.

Please understand Don, our site banned operators and jobsetters from resetting overloads and breakers long ago. Done well before approach boundaries would have reinforced it. And I thoroughly believe that any protective device should pop an investigation before being reset. But OSHA says what OSHA says.

To advance your position to where it would no longer be considered argumentative in court you actually have to provide the criteria for meeting the note. Otherwise the judiciary would be wrong if they failed to discard your opinion. You don't have to agree with the note. You don't have to agree with what it permits. But you're not allowed to rewrite OSHA.

As many people would say about the NEC, if you don't like what OSHA says then get involved and try to change it. That's easier done than it appears. The NFPA70E is considered to supercede a lot of the OSHA electrical regulations according to OSHA letters of interpretation. Find in the 70E where it bans the practice - or get it modified to ban the practice - and you'll have succeeded. OSHA considers the hazards identified in the current (2012) edition of the 70E to be recognized hazards. They're subject to indirect regulation through the general duty clause.