OSHA and Other Hot Work Prohibitations

[short circuit faulted]

Good Morning,
Bidding job at hospital - basically a remove the beating electrical heart of the building and replace - four 1600A bus duct risers going up 12 floors - engineers proposed method is to relocate bus plugs from one duct to another remove existing duct and replace then relocate existing loads to new duct, repeating the process to move the duct - also entails replacing switchboards and installing new pad mounts to feed - replace 5000 receptacles - rework lighting to life saftey branches all in 365 days -

But I digress, the electrical engineer has stated "Hot Work" will be required for this project - all bidder stated thier policies did not allow hot work - now EE is stating in addenda regardles of policy hot work will be performed - I need some ammo to fire back with - can anyone help?

 

[iwire]

Start here

1910.333(a)(1)

"Deenergized parts." Live parts to which an employee may be exposed shall be deenergized before the employee works on or near them, unless the employer can demonstrate that deenergizing introduces additional or increased hazards or is infeasible due to equipment design or operational limitations. Live parts that operate at less than 50 volts to ground need not be deenergized if there will be no increased exposure to electrical burns or to explosion due to electric arcs.


Note 1: Examples of increased or additional hazards include interruption of life support equipment, deactivation of emergency alarm systems, shutdown of hazardous location ventilation equipment, or removal of illumination for an area.


Note 2: Examples of work that may be performed on or near energized circuit parts because of infeasibility due to equipment design or operational limitations include testing of electric circuits that can only be performed with the circuit energized and work on circuits that form an integral part of a continuous industrial process in a chemical plant that would otherwise need to be completely shut down in order to permit work on one circuit or piece of equipment.


Note 3: Work on or near deenergized parts is covered by paragraph (b) of this section.

But some parts of a hospital likely could fall under Note 2.

However, if the reason a circuit can not be shut off is life threating to others it seems foolish to try to perform work on that same circuit, accidents can happen and the circuit could drop out.

Also I do not think any of the buss duct manufacturers recommend hot installs of bus duct switches.

 

[weressl]

Start here
Also I do not think any of the buss duct manufacturers recommend hot installs of bus duct switches.

Hmmmm,............. and I thought that the whole idea behind bus duct is the modularoity and that you can change the configuration w/o shutting down the whole distribution system. :-?

Or did just NFPA 70E made all those things, including MCC's obsolete?:smile:

 

[iwire]

Hmmmm,............. and I thought that the whole idea behind bus duct is the modularoity and that you can change the configuration w/o shutting down the whole distribution system. :-?

I am not really sure, you may well be right, but how much different is it from installing an I-Line breaker hot and that is prohibited (Or at least not condoned by Square D)

 

[weressl]

I am not really sure, you may well be right, but how much different is it from installing an I-Line breaker hot and that is prohibited (Or at least not condoned by Square D)

Then what IS the benefit of plug in devices versus bolt on, if not the potential to plug it in energized? The plug in connection costs more, have a higher potential for failure, etc.

 

[short circuit faulted]

IMHO - There are very limited instances where hot work may be required - however the very nature of the work presents the possiblity of great damages to equipment and personnel than the "supposed reason" for working it hot. Switchgear with faulted section takes a lot longer to replace than making a wiring connection with power off.

 

[brother]

you also, might want to add that in some 'cases/attitudes' like this, there WILL be a shutdown of power, wheather planned or unplanned(accidents). This can be very dangerous.

Even in a hospital, you can 'plan' KEY WORD' PLANN' to be sure that those life threating/life safety loads can be refed during this project. It may cost a little more, but its still safer and less expensive than dealing with attorneys!!

 

[jim dungar]

Then what IS the benefit of plug in devices versus bolt on, if not the potential to plug it in energized? The plug in connection costs more, have a higher potential for failure, etc.

Plug-in devices are intended to reduce not eliminate downtime.

De-energize equipment - remove plug on device from box - install using tested connection - re-energize equipment.

De-energize equipment - remove bolt-on device from box - locate hardware (hopefully it is all there) - torque multiple bus connections - re-energize equipment.

 

[cschmid]

Good Morning,
Bidding job at hospital - basically a remove the beating electrical heart of the building and replace - four 1600A bus duct risers going up 12 floors - engineers proposed method is to relocate bus plugs from one duct to another remove existing duct and replace then relocate existing loads to new duct, repeating the process to move the duct - also entails replacing switchboards and installing new pad mounts to feed - replace 5000 receptacles - rework lighting to life saftey branches all in 365 days -

But I digress, the electrical engineer has stated "Hot Work" will be required for this project - all bidder stated their policies did not allow hot work - now EE is stating in addenda regardles of policy hot work will be performed - I need some ammo to fire back with - can anyone help?

WOW where to start because you are just bidding the job..The requirements are to do this hot so that must be part of the Job..so must the cost of a law firm because this job is associated with a lawsuit or two maybe even three..the liability insurance just went through the roof so plan on an increased cost there..you will not collect final payment until lawsuits are settled..that will tie up your bonding for an extended period of time..plus the decrease in production and an increase in overtime..

You will need to isolate what jobs can be done hot and what jobs can not be done hot..plus you will need to have every aspect verified before work can start..this will require some serious capital to even start this project so risk verses reward better be high..

I would require the EE firm to give direction on all hot work including the procedures expected to be followed before the bid was submitted and I would have my attorney check the procedures for liability reasons..this one is management nightmare..

 

[zog]

Well the reality is you should do all that cschmid (SKOL VIKINGS by the way) mentioned, and bid accordingly, then some other guy desperate for work will come in and not have any problems doing this hot, wont have the proper training or procedures to do it, and submit a bid at about 30% of yours.

Hate to say it, but it is the truth and until "those guys" learn (the hard way), get busted by OSHA, or retire, the safety culture of our trade will have a hard time changing to the point where the "good guys" doing the right thing to protect themselves and employees will lose out on jobs because of it.

In my experience hospitals are among the worst, I actually had a safety director at a hospital ask me to lie to thier staff saying thier PPE and procedures were sufficient for the work they were doing (Using the tables when they were not even close to being within the limitations of the tables). The safety director said "Worst case, if something happens, we have a burn unit on site" , I was floored and told them to find someone else to lie for them and hung up the phone.

 

[weressl]

Plug-in devices are intended to reduce not eliminate downtime.

De-energize equipment - remove plug on device from box - install using tested connection - re-energize equipment.

De-energize equipment - remove bolt-on device from box - locate hardware (hopefully it is all there) - torque multiple bus connections - re-energize equipment.

That is NOT the original intent of the plug-in design. They WERE intended to allow the Owner to install and remove under power.

There would be no potential cost justification for the extra cost of drawout otherwise.

 

[jim dungar]

That is NOT the original intent of the plug-in design. They WERE intended to allow the Owner to install and remove under power.

There would be no potential cost justification for the extra cost of drawout otherwise.

Drawout and plug-in/on are two different types of construction. An 800A drawout switchgear breaker and an 800A I-Line breaker are definitely built with different installation methods in mind.

 

[weressl]

Drawout and plug-in/on are two different types of construction. An 800A drawout switchgear breaker and an 800A I-Line breaker are definitely built with different installation methods in mind.

That is statement without addressing the core issue. Both were designed, produced and marketed to be interchangeable under energized condition.

How about MCC's?

 

[short circuit faulted]

Thank You

Thank You

Thanks you most especially IWIRE & CSCHMID for your timely and pertinet reponses. This is a three horse race for the project and the project is a estimator and project manager NIGHTMARE. Logistically there is no parking available for construction personnel no area within the hospital to stage anything other than material for that days work, lay down area is limited and about half a mile from the work area. Couple an engineer firm with the arrogance to say your saftey policies are not valid and who apparently believes 12 stories of hospital can be reworked electrially in 365 days and you have the recipe for whoever picks the wrong multipler to put on the finished quote as having literally bought high profile exposure and the associsated liablities. I'm supposing this engineer has never seen the results of an arc flash to personnel or equipment - It only takes once to have a memory that lasts a lifetime. Personally I'm figuring a 1.30 adder on top of honest labor estimate for the dead time for both people and materials getting on site and the thumb in rear time spent waiting for approval on the scheduled shutdowns - Had they pre-purchased the equipment then they might have an outside chance for meeting schedule. I've done this for 25 years and unfortunately I see it getting worse instead of better, with the dwidling pipeline of new folks getting into trade and drawings that could be used for purposes other than electrical installation stamped with the new electrical engineering creed; "Contractor responsible for verifing all existing conditions prior to bid - No change orders shall be considered involving existing conditions." - Sadly I remember drawings you could take off the complete job by the electrical engineers notes.

 

[iwire]

Both were designed, produced and marketed to be interchangeable under energized condition.

From Square D

HAZARD OF ELECTRIC SHOCK, EXPLOSION, OR ARC FLASH
• Apply appropriate personal protective equipment (PPE) and follow safe electrical
work practices. See NFPA 70E.
• This Plug-in unit must be installed and serviced only by qualified electrical
personnel.
• Do not install the circuit breaker type Plug-in unit onto the busway without a circuit
breaker installed.
• Use only Square D brand circuit breakers in this Plug-in unit.
• The circuit breaker catalog prefix must match the Plug-in unit prefix.
• Do not install, operate, or remove the Plug-in unit with the cover open or removed.
• Turn off power to the busway before installing or removing the Plug-in unit.
• Turn off power to the busway before working on the line side of the Plug-in unit.
• Turn off the Plug-in unit before opening or working inside the enclosure.
• Always use a properly rated voltage sensing device at all load side connections to
confirm the Plug-in unit is off.
Failure to follow these instructions will result in death or serious injury.

Square D? PowerBus

 

[weressl]

Thanks you most especially IWIRE & CSCHMID for your timely and pertinet reponses. This is a three horse race for the project and the project is a estimator and project manager NIGHTMARE. Logistically there is no parking available for construction personnel no area within the hospital to stage anything other than material for that days work, lay down area is limited and about half a mile from the work area. Couple an engineer firm with the arrogance to say your saftey policies are not valid and who apparently believes 12 stories of hospital can be reworked electrially in 365 days and you have the recipe for whoever picks the wrong multipler to put on the finished quote as having literally bought high profile exposure and the associsated liablities. I'm supposing this engineer has never seen the results of an arc flash to personnel or equipment - It only takes once to have a memory that lasts a lifetime. Personally I'm figuring a 1.30 adder on top of honest labor estimate for the dead time for both people and materials getting on site and the thumb in rear time spent waiting for approval on the scheduled shutdowns - Had they pre-purchased the equipment then they might have an outside chance for meeting schedule. I've done this for 25 years and unfortunately I see it getting worse instead of better, with the dwidling pipeline of new folks getting into trade and drawings that could be used for purposes other than electrical installation stamped with the new electrical engineering creed; "Contractor responsible for verifing all existing conditions prior to bid - No change orders shall be considered involving existing conditions." - Sadly I remember drawings you could take off the complete job by the electrical engineers notes.

Hear ya and feel sorry for the trade. Unfortunately engineering firms became money machines hogtied by lawyers. So they hire engineers who can push out the paper and create documents that are engineering and design documents, but not construction drawings.

 

[iwire]

From GE Spectra series

WARNING: HAZARD OF ELECTRICAL SHOCK OR BURN! The plug must be turned OFF before installing on or removing from the busway. Failure to do so may cause serious injury or death! It is a good safety practice to de-energize the busway before inserting or removing bus plugs. In the United States, it is necessary to comply with all Federal and local safety procedures, including NFPA 70E 2-1.3 directing the use of appropriate PPE (Personal Protective Equipment) such as face shield, insu?lating gloves, and flame-resistant clothing. In Canada, be sure to comply with the appropriate requirements of the Canadian Electrical Code. Only properly trained personnel may install bus plugs on or remove them from energized busway. In addition, all bus plug installation instructions must be followed completely.

Sounds like they are calling it 'live work' so you better have a good reason to present to OSHA for having to do it live.

 

[weressl]

From Square D



Square D? PowerBus

Yes Bob, that is what it says NOW.

The users just have not caught up with the fact that they are paying for something they can never legally use.

 

[weressl]

From GE Spectra series

Only properly trained personnel may install bus plugs on or remove them from energized busway.

Rest my case.....:smile:

I also want to point out that on MCC buckets have an avaliable feature -shutters- that will cover the energized vertical buss after the bucket is withdrawn from the cubicle. This also clearly points to the fact that MCC's and all sort of plug in type units were designed for energized insertion and removal and that the new 70E makes the entire industry of such devices useless.

 

[iwire]

Yes Bob, that is what it says NOW.

I agree, times change.

Now I think that if you as an engineer direct someone to do it live you are on shaky ground. Hot work is not allowed by OSHA with or without PPE except for a very few reasons. Don't bother showing how you can stretch those reasons to fit what you want, if someone gets hurt those reasons will look ridiculous.

The users just have not caught up with the fact that they are paying for something they can never legally use.

Bus duct or I-Lines still will reduce downtime even with shutting them down to do the actual install. :smile: