NFPA 70E - Justification for live work

[sttopr1]

NPPA 70E, Article 130.1, FPN #2 among other things says that if circuits are part of a "continuous process", work on these circuits while energized would be justified. What is the definition of a continuous process? Would a utility company's headquarters where switching of substation circuits takes place and where the data storage and networking for the entire company is located be considered a contiuous process? How about any large company where the data storage and networking for the entire company is located? What if UPS or back up generators are capable of feeding such equipment, would this eliminate the justification for working on circuits while energized? Example, if I have an Sqaure D I-line switchboard and one breaker in the panel feeds a data room, which may or may not have backup power, and I need to install an additional breaker. Consider that the data room may feed a local office network, a worldwide network, or possibly an ATC operation. I would prefer to de-energize everything, but we all know this is not always possible. The lack of this definition has raised several questions between myself and several customers, many who say if it is not a life or death situation (life support etc,) de-energize. Any input?

 

[eric9822]

See this OSHA letter of interpretation.

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25559

 

[don_resqcapt19]

I would prefer to de-energize everything, but we all know this is not always possible.

Sure it is. It may not be convenient, but it is always physically possible to de-energize. Think about this...if you really think it can't be de-ergergized under controlled conditions, what will happen when there is a fault that takes it down because you were working it hot?

 

[zog]

Well said Don.

Think of it this way, if someone gets hurt you will need to explain to OSHA why you did not shut it down, will your reason be good enough?

 

[stormywyo]

Out here in the mining industry, lots of the electrical troubleshooting has to be done while energized. It is impossible to find lots of the electrical problems with the equipment de-energized..

 

[raider1]

Out here in the mining industry, lots of the electrical troubleshooting has to be done while energized. It is impossible to find lots of the electrical problems with the equipment de-energized..

Troubleshooting and voltage testing fall under "infeasibility" in NFPA 70E section 130.1(A)(2). Take a look at FPN No 2 to that section.

Chris

 

[stormywyo]

Thanks--I will look at it, I am currently separated from my book--Me home--it office

 

[RHJohnson]

It always hard for me to understand when someone say's you can always shut it down, not to work hot.
I am comfortable working things energized, I did it for years, on an almost daily basis, as did other electricians I worked with. We were all well trained in one very important aspect - we were working - give the job all your attention. We did not talk about beer night, girl friends, wives, our kids, or anything else. Doing so would get you banished.
300 men depended on us to keep things running so they could do their job, and not be sent home.
In an underground mine, if you have a problem and would need to shut off the power you would need to hoist all the men out of the mine. That is MSHA law. If the main hoist is even down because of a problem for more than an hour you are required to report it to MSHA, and begin hoisting the crew out using emergency escape routes.
Talk all you want about what would happen if you made a mistake. We worked knowing we could not make a mistake.

 

[iwire]

It always hard for me to understand when someone say's you can always shut it down, not to work hot.

You have trouble understanding the truth?

I am comfortable working things energized, I did it for years, on an almost daily basis,

Great good for you.

But why risk your life to save someone some money?

The only reason is wanting to feel like a tough guy, a hero, brave etc.

In an underground mine, if you have a problem and would need to shut off the power you would need to hoist all the men out of the mine. That is MSHA law.

Then get them out of the mine.

Talk all you want about what would happen if you made a mistake. We worked knowing we could not make a mistake.

That statement makes no sense at all.

You are a human, you are more then capable of making a mistake no matter how good you think you are.

 

[iwire]

Back to the OP these OSHA interpretations might help.

Standard Interpretations referencing 1910.333(a)(1)

 

[iwire]

Troubleshooting and voltage testing fall under "infeasibility" in NFPA 70E section 130.1(A)(2). Take a look at FPN No 2 to that section.

Yes but don't forget that you can only troubleshoot, you can not make the repairs and while it is hot you must have all your required PPE on.

 

[nakulak]

90.2 B 2

mining is not covered under NEC

does osha apply to mining ?, I though that msha applied (I have absolutely no familiarity with msha)

 

[rbalex]

MSHA is to mines, as the Coast Guard is to marine operations, as DOT is to land transportation, as most military standards are military facilities. In most cases they still cross reference FedOSHA personnel safety standards where the "mission" of the federal commission or department is not affected.

When I sat on the 70E committee, the ultimate consideration was whether additional hazards were introduced from a disorderly system shutdown. Economic consequences just weren’t an immediate part of the equation. Both the current and previous past Director of the FedOSHA mechanical and electrical department were in attendance.

We did recognize that some older facilities would have compliance problems, but continuous process issues were basically personnel or possibly permanent equipment damage from a disorderly shutdown. I pointed out that I can design several types of electrical industrial distribution systems where most genuine continuous processes can be maintained without an overall system shutdown. In most cases they are more vulnerable from utility failures. Of course, I didn’t claim the design would necessarily be economically attractive – simply that it can be done.

One thing that is often missed is that safety and reliability usually go hand in hand. For example, double-ended, secondary selective systems cost about double that of a common radial system. But it can usually be worked on safely without a process shutdown. It is also statistically on the order of 3 magnitudes (2000-3500 times) more reliable with respect to premises electrical distribution systems for continuous operations assuming it is properly designed, installed and maintained. My basic background is refineries and other continuous petro-chemical/chemical process facilities.

 

[stormywyo]

90.2 B 2

mining is not covered under NEC

does osha apply to mining ?, I though that msha applied (I have absolutely no familiarity with msha)

Some mining equipment is not covered by the NEC. Whatever remains, in Wyoming, is covered by the NEC. More mines are training their employees in the NEC because 30CFR has a lot of short comings. The way NFPA 70E comes under MSHA is by adoption of this standard by the mine operator. MSHA enforces company safety policies. Most of the local mine operators are training their employees in NFPA 70E and providing them with the appropriate PPE. They, for the most part, have completed their hazard assessment...

 

[cschmid]

so how does NAPA 70E relate to a correctional progamed institution..not a prision but a hospital for the mentally ill..

 

[dbuckley]

where the data storage and networking for the entire company is located be considered a contiuous process? How about any large company where the data storage and networking for the entire company is located? What if UPS or back up generators are capable of feeding such equipment, would this eliminate the justification for working on circuits while energized? Example, if I have an Sqaure D I-line switchboard and one breaker in the panel feeds a data room, which may or may not have backup power, and I need to install an additional breaker. Consider that the data room may feed a local office network, a worldwide network, or possibly an ATC operation.

The problems relating to data centres have been solved for eons, and its just a cost balance. How much is the company willing to have scheduled downtime versus equipping the facility with non-stop power? There is no third way, which is to work hot.

Even adding MCBs can be safe, with the right panel, such as the MG (Schneider) "isobar" widely used in the Eurovolt universe - no exposed live bits in the panel. So you can open the panel, hammer out a knockout, shove in the wires, add a breaker, wire it up, megger test and enliven and close the front, all without disturbing the operation of a panel, and all without getting belted or blinded.

 

[WDeanN]

so how does NAPA 70E relate to a correctional progamed institution..not a prision but a hospital for the mentally ill..

That one's easy...
That's were most of the authors reside!

 

[cornbread]

Working in a chemical plant we have situations where powering down does create an additional hazard. Leaving chemcials in the pipes / tanks with out control can be dicey at best. One may argue that the system should be purged of chemicals, but in many cases the design of system does not allow this. We are asking in every case, "can the the power be shut off" and we have succeded in de-energizing equipment that in the past would have been worked hot. However we still run in to those occasions where hot work is required.

 

[rbalex]

As I noted in my initial response, the 70E committee did recognize some older facilities may have such problems [130.1(A)(2)]. That was the primary reason for the justification document added in Appendix J. The document itself is not actually part of NFPA 70E; however, it reflects the elements listed in Subsection 130.1(B) which are required. Subsection 130.1(B)(11) requires live work to be approved by someone with the legal responsibility to assure worker safety. Said person cannot plead ignorance of the dangers involved.

 

[wtucker]

Well said Don.

Think of it this way, if someone gets hurt you will need to explain to OSHA why you did not shut it down, will your reason be good enough?

Think of it THIS way: if your partner/employee gets DEAD, you will need to explain to his WIFE and KIDS why you did not shut it down, will your reason be good enough?