NFPA 70E Lockout Requirments

[Electrobe]

Our plant currently uses none-electrical personnel for many lockouts that do not require electrical work. Example would be a pump change. Here is a very basic procedure for a single point lockout:

-Shutdown equipment
-Open Disconnect at MCC and apply lock to disconnect
-Attempt to start equipment
-Perform work.

Does NFPA 70E require a qualified person to verify absense or voltage for this type of lockout?

Thanks

 

[zog]

Our plant currently uses none-electrical personnel for many lockouts that do not require electrical work. Example would be a pump change. Here is a very basic procedure for a single point lockout:

-Shutdown equipment
-Open Disconnect at MCC and apply lock to disconnect
-Attempt to start equipment
-Perform work.

Does NFPA 70E require a qualified person to verify absense or voltage for this type of lockout?

Thanks

Yes, and the person opening the disconnect needs to be qualified and wearing the proper PPE for arc flash protection.

Welcome to the Forum

 

[Electrobe]

Thanks for the quick reply.

This is going to take a major culture change:grin:

 

[billsnuff]

try this article

try this article

http://www.ecmag.com/index.cfm?fa=article&articleID=7180

 

[eric9822]

Yes, and the person opening the disconnect needs to be qualified and wearing the proper PPE for arc flash protection.

What is the OSHA rule for this? The OP states that no electrical work is taking place. If electrical work were taking place then an absence of voltage check would definately be required. If the lockout is to replace a pump then the isolation of energy needs to be verified but this can be accomplished without exposure to potentially energized equipment and the use of a voltmeter. The common practice for this is to open the disconnect and attempt to start the motor.

 

[cowboyjwc]

The same arc flash potential exists whether you are opening or closing the switch.

And just because you think the switch is open, doesn't mean that there is not still voltage at the pump motor.

 

[zog]

The common practice for this is to open the disconnect and attempt to start the motor.

Common practice dosent make it right. The OSHA LOTO procedures are lengthy but available free at www.osha.gov so I wont type them all out, but it clearly states that just attempting to start the motor is not sufficient for electrical LOTO you need to verify the circuit is deenergized with a meter (Including earing the proper PPE and verifry your meter works before and after the test on a known live source), and in some cases personal protective grounds must be installed that are rated for the available fault current in the system (Typically just for >600V systems)

 

[zog]

This is going to take a major culture change:grin:

Welcome to the NFPA 70E

 

[G0049]

It's not that simple. It depends on whether there is electrical work being done or not. Changing a pump is quite different than changing a pump motor. For the pump itself, the required verification can be the attempt to restart. For the motor, it would not be. Also, pumps are frequently not a single point LOTO. If there is any possibility of backflow from either stored pressure or a parallel pump, then complete isolation of the supply and discharge lines would be required as well. The OSHA requirements are in part 1910.147 at the website linked in post 7.

 

[billsnuff]

What is the OSHA rule for this?

1910.147(c)(1)
Energy control program. The employer shall establish a program consisting of energy control procedures, employee training and periodic inspections to ensure that before any employee performs any servicing or maintenance on a machine or equipment where the unexpected energizing, startup or release of stored energy could occur and cause injury, the machine or equipment shall be isolated from the energy source and rendered inoperative.

NOTE: the OP asked

Does NFPA 70E require a qualified person to verify absense or voltage for this type of lockout?

See the link i posted above re:70E

I can't tell if the OP has a written program describing the steps for the task or not, but without one i believe it is an OSHA violation, even if there is no exposed wiring or elec devices. Further, i believe 70E is in play because it is referenced in 29CFR1910.xxx.

edit spelling

 

[eric9822]

The same arc flash potential exists whether you are opening or closing the switch.

Agreed. The person opening and or closing the switch needs to be qualified for the task and wearing the appropriate PPE.

Common practice dosent make it right..

Agreed. It doesn't necessarily make it wrong either.

The OSHA LOTO procedures are lengthy but available free at www.osha.gov.

I have access to all OSHA regulations and I am fairly familiar wih the LOTO procedures. What I was asking for was the rule that said an electrical verification was required for a non-electrical task. OSHA 29CFR-1910.147(d)6 requires the verification of isolation prior to starting work, it does not state that the only way to accomplish that is through a voltage verification. For the purposes of a pump change the verification is to confirm that the motor will not turn and a bump start should confirm that.

attempting to start the motor is not sufficient for electrical LOTO you need to verify the circuit is deenergized with a meter (Including earing the proper PPE and verifry your meter works before and after the test on a known live source), and in some cases personal protective grounds must be installed that are rated for the available fault current in the system (Typically just for >600V systems).

Agreed, this is not adequate for electrical work and in some cases grounds need to be installed. This was not however what the OP was asking.

 

[billsnuff]

OSHA 29CFR-1910.147(d)6 requires the verification of isolation prior to starting work, it does not state that the only way to accomplish that is through a voltage verification. For the purposes of a pump change the verification is to confirm that the motor will not turn and a bump start should confirm that.

Agreed, if you have complied with 1910.147(c) and have done a risk analysis and have a written program.

 

[Electrobe]

I can't tell if the OP has a written program describing the steps for the task or not, but without one i believe it is an OSHA violation, even if there is no exposed wiring or elec devices. Further, i believe 70E is in play because it is referenced in 29CFR1910.xxx.

We have a written program describing these steps but verification of voltage is only done when a qualified electrican is going to work on the electrical componets (ie motor terminals or other). Basically just wanted to know if it was always necessary to verify absence of voltage when an electrical disconnect is used for lockout.

Thanks for all the comments!

 

[petersonra]

Does NFPA 70E require a qualified person to verify absense or voltage for this type of lockout?

However, the definition of qualified is left to the employer.

For zog: do you think that the following product would allow you to test for the absence of voltage without requiring the use of PPE?

http://www.graceport.com/prod_voltage.cfm

or

http://www.graceport.com/prod_checkvolt.cfm

 

[Electrobe]

do you think that the following product would allow you to test for the absence of voltage without requiring the use of PPE?

I would think these would be ok as long as they were confirmed to go from the on-to-off state while the equipment is being shut off. OFF may mean the unit has failed.

 

[Electrobe]

The OSHA LOTO procedures are lengthy but available free at www.osha.gov so I wont type them all out, but it clearly states that just attempting to start the motor is not sufficient for electrical LOTO you need to verify the circuit is deenergized with a meter

I could not find where this is stated because there was too much data to digest.

I guess by definition "zero energy state" means no energy to the equipment and if one-phase of a 3-phase system is still live, the equipment is not at "zero energy state". The attempt to start would not catch this in my example.

Also in my example, if during the pump change it was determined that the motor bearing was bad and the motor needed to be replaced this could lead to a bad situation. LOTO of equipment should mean that any work can be performed on the equipment because it has been verified.

 

[billsnuff]

I use the grace indicator, but the literature states that it does not relieve you from a 'live-dead-live' test. but it will tell you if the power is off for non-electrical tasks.

 

[billsnuff]

also, with grace eng products, one must be careful in deciding where to connect, line side vs load side. if connected to load side of a disco in a cabinet, voltage (480 3ph) would still be present in the cabinet and necessitate the appropriate PPE for the entire task if performed in the cabinet, based on the approach limits.

 

[G0049]

LOTO of equipment should mean that any work can be performed on the equipment because it has been verified.

That might sound good, but it really doesn't work that way. The employer can have several different LOTO procedures for the same piece of equipment, depending on the task to be perfomed, the hazards presented by that task and the skill level of the person doing the task. They might have a very simple procedure for the oiler who lubes the pump, a more complicated procedure for a mechanic who could change or repack the pump, and the full blown procedure for the electrician who would change the motor. While the full blown procedure would protect the oiler, it would be so involved and time comsuming that it wouldn't be done. A great procedure that isn't followed, is not as safe as a simpler one that was.

 

[Fulthrotl]

Welcome to the NFPA 70E

and we haven't even approached the 2008 code requirements for
opening all sources of power on multiwire branch circuits, or in the
event that is not possible, pulling separate neutrals, making it no
longer a mulitwire branch circuit.

as the iPhone commercial says..... "this changes EVERYTHING"

sigh. perhaps a cold frothy beverage would help my perception of
all of this stuff.....