PPE for Residential and light commercial HVACR work

[iwire]

This is pretty stupid on your part.

The arc flash study and so full PPE is required for any equipment at 50V or greater.

However,

Arc flash studies and so full PPE are not required in homes that are single-family residences.

That means we do not have to label panels in dwelling units with the arc flash info.

We are still required to wear the appropriate level of PPE.

That can be very simple PPE or very heavy PPE dependent on the fault current.

 

[Sahib]

We are still required to wear the appropriate level of PPE.

Without conducting an arc flash study, no way to wear the appropriate level of PPE.

Very simple PPE or very heavy PPE dependent on the fault current.

Do you have some fetish that is satisfied by acting the fool?:?
Just shut up already.

 

[don_resqcapt19]

This is pretty stupid on your part.

The arc flash study and so full PPE is required for any equipment at 50V or greater.

However,

Arc flash studies and so full PPE are not required in homes that are single-family residences.

I don't recall any exceptions in 70E that say you don't need PPE when working on energized equipment in a dwelling unit. Can you cite the section for me?

 

[iwire]

Without conducting an arc flash study, no way to wear the appropriate level of PPE.

You are not listening.

We are not required to do an arc flash study so that we can post the arc flash info on a dwelling unit panel.

We are required to wear the appropriate PPE and that will take some amount of analysis to determine.

 

[Sahib]

You are not listening.We are not required to do an arc flash study so that we can post the arc flash info on a dwelling unit panel.We are required to wear the appropriate PPE and that will take some amount of analysis to determine.

You are not understanding. Without complete arc flash study it is not possible to wear appropriate PPE. You are invited to disprove it.

 

[iwire]

You are not understanding. Without complete arc flash study it is not possible to wear appropriate PPE. You are invited to disprove it.

I cannot disprove a fact and have no intention of trying.

However just because one standard does not require an arc flash study does not mean compliance with other standards and rules will not require some form of analysis which might be tables or an full blown arc flash study.

The fact remains unless the the equipment is dead I cannot be exposed to it without some level of PPE. Furthermore I have to wear PPE while testing to make sure it is dead. This applies to almost all electrical installations in the US.

 

[don_resqcapt19]

You are not understanding. Without complete arc flash study it is not possible to wear appropriate PPE. You are invited to disprove it.

There is nothing to disprove...the rules require PPE for work on energized electrical equipment. You are correct that a posting of the incident energy or other arc flash hazard information is not required at a dwelling unit electrical equipment, but that has nothing to do with the requirement to use PPE for energized work. You may be able to use the tables in 70E to select the PPE without doing a full arc flash study, but you have to make sure that your system is one that you are permitted to use the table information for. If the tables do not apply, you will have to do a study to select the correct PPE to work on the energized equipment.

Note that even if you have the utility open the circuit on the line side of the dwelling unit service, you still need PPE based on the incident energy that would be available if the power was still on. You need this to do the verification testing to prove that the power is off.

 

[user 100]

I don't recall any exceptions in 70E that say you don't need PPE when working on energized equipment in a dwelling unit. Can you cite the section for me?

There aren't any that I am aware of. Sahib, just b/c most residential people don't wear ppe doesn't mean it isn't ever required.

You are not listening.

He is not.

You are not understanding. Without complete arc flash study it is not possible to wear appropriate PPE. You are invited to disprove it.

Answered expertly here

V V V V V

There is nothing to disprove...the rules require PPE for work on energized electrical equipment. You are correct that a posting of the incident energy or other arc flash hazard information is not required at a dwelling unit electrical equipment, but that has nothing to do with the requirement to use PPE for energized work. You may be able to use the tables in 70E to select the PPE without doing a full arc flash study, but you have to make sure that your system is one that you are permitted to use the table information for. If the tables do not apply, you will have to do a study to select the correct PPE to work on the energized equipment.

Note that even if you have the utility open the circuit on the line side of the dwelling unit service, you still need PPE based on the incident energy that would be available if the power was still on. You need this to do the verification testing to prove that the power is off.

 

[jim dungar]

Without conducting an arc flash study, no way to wear the appropriate level of PPE.

An arc flash study using IEEE1584 is not explicitly required by any national code.
OSHA requires the employer to determine what the appropriate PPE is. I think there may be more than (8) industry acceptable methods that can be used.
NFPA70E requires that an arc flash Risk Analysis be performed. This analysis may be performed without a study, and there is definitely no need to calculate an exact incident energy value .

There is no way to get around the issue of shock protection PPE, but, again no study is required.

 

[Sahib]

NFPA70E requires that an arc flash Risk Analysis be performed. This analysis may be performed without a study, and there is definitely no need to calculate an exact incident energy value.

Single family residences is one place where no arc flash study is required. Other such places may be mentioned here.

 

[electrofelon]

Single family residences is one place where no arc flash study is required. Other such places may be mentioned here.

That is a broad and vague statement that may or may not be true. First, it depends on what you mean by "arc flash study", maybe there is some confusion over that term. For example, here, people would not consider calculating available fault current an arc flash study. A "study" would often involve calculating incident energy. Then it depends on what you mean by "required". The NEC does not require an "arc flash study", but it does require calculating and labeling of Available fault current. There are other standards and requirements that a company or worker may have to comply with that would require a full blown analysis of incident energy.

We can keep beating this horse to death. 99.9% of people (and I am one of them) work hot and dont were any PPE beyond safety glasses for resi work and dont thing twice about it. Can an employee work hot in the US? Technically, just about never.

 

[jim dungar]

Single family residences is one place where no arc flash study is required.

No NFPA70E does not require that AF labels be installed in single family homes. Employees are required to comply with their company's safe work practices including PPE.

The language is very specific, there is a difference between an analysis and a study.

 

[Sahib]

This should be true:

An arc flash accident is a very rare event in a residence.

Because majority of you are doing regularly this without being killed by any arc flash:

99.9% of people (and I am one of them) work hot and dont were any PPE beyond safety glasses for resi work and dont thing twice about it.

 

[jim dungar]

Because majority of you are doing regularly this without being killed by any arc flash:

There is no statistical proof that AF is a lethal hazard at 120/240V single-phase. There is no shortage of documentation establishing that the predominant lethal hazard is Electrical Shock.

 

[dresource]

The town I work in, like most I'm sure, is full of properties where either electrical equipment was installed improperly to being with, or where property owners have done their own work and modifications. I would love to have a qualified electrician perform an inspection on every job site, but that will never happen.

I need enough knowledge to know when to stop work immediately. Property owners might not appreciate that. However, it is for their own safety.

The sad part is that not too many appreciate their own safety until it's too late!

 

[Jraef]

Here is the part being missed. If you work FOR someone, your EMPLOYER IS REQUIRED to have an electrical safety program in place. It must be reviewed periodically, and all employees who are exposed to electrical work are required to be periodically certified (not sure of the term here) to have read and comprehend that policy. Part of that program must include the use of whatever it takes to maintain a safe working environment, generally interpreted as either no live work, or the use of personal protective equipment (PPE). The level of PPE for tasks is to be included in that document. You as an employee must use whatever level of PPE your employer tells you to use. That is YOUR responsibility, but nothing says you can't over protect either. If you are doing residential work and your employer says you must use PPE2 no matter what, you must comply. If the employer says it is up to you to determine what PPE is required for a task, then they must have equipped you with the necessary training and tools to determine that.

All of this is federal workers safety LAW, as laid out in the Federal Register. For the EMPLOYER, failure to do this is punishable by civil fines and criminal charges for any and all managers and supervisors. NFPA 70E is not a law, however it is a "highly suggested" means of complying with that law. There are no 70E police looking over your shoulder to see what PPE you are wearing. There are no requirements providing for "jack booted thugs" to randomly break down the employers door to come in and look for compliance either. But the power that OSHA has is to INVESTIGATE ACCIDENTS or reported violations and punish those not in compliance with the federal statutes.

So IF something bad happens (electrically) and OSHA comes in, the first thing they will want to see from an employer is the electrical safety program documents. Don't have it? Plan on getting a lawyer, and you might want to get your affairs in order because you might be taking an extended unplanned vacation with minimal accommodations. Have one but your employees didn't sign on to it? Same thing. Have one, the employees signed it but ignored the requirements? Now the onus is on a supervisor who allowed it. Nobody allowed it by the employees did it anyway? Now it's on them which would not be criminal under the OSHA statutes, but depending on how bad it was and if anyone else was hurt, may fall under "willful negligence". Bottom line though, if nothing bad happens, nobody knows if you are out of compliance. It's a risk some people are willing to take, either for money or convenience. But all stakeholders should make themselves aware of all of the risks. Every time I bring this up to "management" types, you can see them shiver in their shoes at the mention of criminal charges. Most of them claim to have had no idea, but when they bring it up to their lawyers, they get the truth and jump all over putting out a program.

So taking this a step further: this law also cannot be "subrogated" meaning an employer cannot get around the requirements for having an electrical safety program by just hiring a contractor and making it their responsibility. So in a "commercial" setting, that implies the customer is an employer, which makes them subject to the federal worker safety statutes, regardless of whether they contracted it out or not. This is not to say that a commercial enterprise that never does electrical work must have this useless policy, it just means that when they contract with someone, they are responsible for ensuring THAT contractor has a policy that meets the OSHA standard. So that means any contractor doing commercial electrical work MUST have an electrical safety program in place, even if you are a one-man-show. Does every small commercial enterprise know this and make a point of ensuring that anyone they hire meets this criteria? No, but they should, and it might be buried in the insurance documents they signed for their business. Do some know but choose to ignore? Absolutely, but again, at their own personal risk, including that of criminal prosecution. This by the way is a great argument for someone trying to compete against an unlicensed contractor or handyman doing commercial work.

Then finally residential. If you are doing electrical work as an employee of a company, the company must have a program and you must follow it, including their PPE requirements. If you are a one-man-show and you ONLY do residential work, technically you can get away with not having a program. The homeowner is not an "employer", he is hiring you as an independent contractor. You are also not an employer if you have no employees. That's the ONLY way it works that "you don't need PPE for residential work". In reality if you love your family and want to protect them from the devastation of not having you to provide for them, you SHOULD be concerned with your PPE.

Recap: you ALWAYS need PPE if you are an employee. You ALWAYS need PPE if doing commercial or industrial work even if you work on your own. You ALWAYS should use appropriate PPE when doing residential work as an independent contractor, but if you chose not to, that's your own risk.

 

[K8MHZ]

Sahib,

I appreciate your concern for our safety here in the US, but I think your efforts should be aimed at the activities in India.

 

[David Goodman]

Here is the part being missed. If you work FOR someone, your EMPLOYER IS REQUIRED to have an electrical safety program in place. It must be reviewed periodically, and all employees who are exposed to electrical work are required to be periodically certified (not sure of the term here) to have read and comprehend that policy. Part of that program must include the use of whatever it takes to maintain a safe working environment, generally interpreted as either no live work, or the use of personal protective equipment (PPE). The level of PPE for tasks is to be included in that document. You as an employee must use whatever level of PPE your employer tells you to use. That is YOUR responsibility, but nothing says you can't over protect either. If you are doing residential work and your employer says you must use PPE2 no matter what, you must comply. If the employer says it is up to you to determine what PPE is required for a task, then they must have equipped you with the necessary training and tools to determine that.

All of this is federal workers safety LAW, as laid out in the Federal Register. For the EMPLOYER, failure to do this is punishable by civil fines and criminal charges for any and all managers and supervisors. NFPA 70E is not a law, however it is a "highly suggested" means of complying with that law. There are no 70E police looking over your shoulder to see what PPE you are wearing. There are no requirements providing for "jack booted thugs" to randomly break down the employers door to come in and look for compliance either. But the power that OSHA has is to INVESTIGATE ACCIDENTS or reported violations and punish those not in compliance with the federal statutes.

So IF something bad happens (electrically) and OSHA comes in, the first thing they will want to see from an employer is the electrical safety program documents. Don't have it? Plan on getting a lawyer, and you might want to get your affairs in order because you might be taking an extended unplanned vacation with minimal accommodations. Have one but your employees didn't sign on to it? Same thing. Have one, the employees signed it but ignored the requirements? Now the onus is on a supervisor who allowed it. Nobody allowed it by the employees did it anyway? Now it's on them which would not be criminal under the OSHA statutes, but depending on how bad it was and if anyone else was hurt, may fall under "willful negligence". Bottom line though, if nothing bad happens, nobody knows if you are out of compliance. It's a risk some people are willing to take, either for money or convenience. But all stakeholders should make themselves aware of all of the risks. Every time I bring this up to "management" types, you can see them shiver in their shoes at the mention of criminal charges. Most of them claim to have had no idea, but when they bring it up to their lawyers, they get the truth and jump all over putting out a program.

So taking this a step further: this law also cannot be "subrogated" meaning an employer cannot get around the requirements for having an electrical safety program by just hiring a contractor and making it their responsibility. So in a "commercial" setting, that implies the customer is an employer, which makes them subject to the federal worker safety statutes, regardless of whether they contracted it out or not. This is not to say that a commercial enterprise that never does electrical work must have this useless policy, it just means that when they contract with someone, they are responsible for ensuring THAT contractor has a policy that meets the OSHA standard. So that means any contractor doing commercial electrical work MUST have an electrical safety program in place, even if you are a one-man-show. Does every small commercial enterprise know this and make a point of ensuring that anyone they hire meets this criteria? No, but they should, and it might be buried in the insurance documents they signed for their business. Do some know but choose to ignore? Absolutely, but again, at their own personal risk, including that of criminal prosecution. This by the way is a great argument for someone trying to compete against an unlicensed contractor or handyman doing commercial work.

Then finally residential. If you are doing electrical work as an employee of a company, the company must have a program and you must follow it, including their PPE requirements. If you are a one-man-show and you ONLY do residential work, technically you can get away with not having a program. The homeowner is not an "employer", he is hiring you as an independent contractor. You are also not an employer if you have no employees. That's the ONLY way it works that "you don't need PPE for residential work". In reality if you love your family and want to protect them from the devastation of not having you to provide for them, you SHOULD be concerned with your PPE.

Recap: you ALWAYS need PPE if you are an employee. You ALWAYS need PPE if doing commercial or industrial work even if you work on your own. You ALWAYS should use appropriate PPE when doing residential work as an independent contractor, but if you chose not to, that's your own risk.

Thank you for taking the time to write this down. It is appreciated.

 

[kwired]

Here is the part being missed. If you work FOR someone, your EMPLOYER IS REQUIRED to have an electrical safety program in place. It must be reviewed periodically, and all employees who are exposed to electrical work are required to be periodically certified (not sure of the term here) to have read and comprehend that policy. Part of that program must include the use of whatever it takes to maintain a safe working environment, generally interpreted as either no live work, or the use of personal protective equipment (PPE). The level of PPE for tasks is to be included in that document. You as an employee must use whatever level of PPE your employer tells you to use. That is YOUR responsibility, but nothing says you can't over protect either. If you are doing residential work and your employer says you must use PPE2 no matter what, you must comply. If the employer says it is up to you to determine what PPE is required for a task, then they must have equipped you with the necessary training and tools to determine that.

All of this is federal workers safety LAW, as laid out in the Federal Register. For the EMPLOYER, failure to do this is punishable by civil fines and criminal charges for any and all managers and supervisors. NFPA 70E is not a law, however it is a "highly suggested" means of complying with that law. There are no 70E police looking over your shoulder to see what PPE you are wearing. There are no requirements providing for "jack booted thugs" to randomly break down the employers door to come in and look for compliance either. But the power that OSHA has is to INVESTIGATE ACCIDENTS or reported violations and punish those not in compliance with the federal statutes.

So IF something bad happens (electrically) and OSHA comes in, the first thing they will want to see from an employer is the electrical safety program documents. Don't have it? Plan on getting a lawyer, and you might want to get your affairs in order because you might be taking an extended unplanned vacation with minimal accommodations. Have one but your employees didn't sign on to it? Same thing. Have one, the employees signed it but ignored the requirements? Now the onus is on a supervisor who allowed it. Nobody allowed it by the employees did it anyway? Now it's on them which would not be criminal under the OSHA statutes, but depending on how bad it was and if anyone else was hurt, may fall under "willful negligence". Bottom line though, if nothing bad happens, nobody knows if you are out of compliance. It's a risk some people are willing to take, either for money or convenience. But all stakeholders should make themselves aware of all of the risks. Every time I bring this up to "management" types, you can see them shiver in their shoes at the mention of criminal charges. Most of them claim to have had no idea, but when they bring it up to their lawyers, they get the truth and jump all over putting out a program.

So taking this a step further: this law also cannot be "subrogated" meaning an employer cannot get around the requirements for having an electrical safety program by just hiring a contractor and making it their responsibility. So in a "commercial" setting, that implies the customer is an employer, which makes them subject to the federal worker safety statutes, regardless of whether they contracted it out or not. This is not to say that a commercial enterprise that never does electrical work must have this useless policy, it just means that when they contract with someone, they are responsible for ensuring THAT contractor has a policy that meets the OSHA standard. So that means any contractor doing commercial electrical work MUST have an electrical safety program in place, even if you are a one-man-show. Does every small commercial enterprise know this and make a point of ensuring that anyone they hire meets this criteria? No, but they should, and it might be buried in the insurance documents they signed for their business. Do some know but choose to ignore? Absolutely, but again, at their own personal risk, including that of criminal prosecution. This by the way is a great argument for someone trying to compete against an unlicensed contractor or handyman doing commercial work.

Then finally residential. If you are doing electrical work as an employee of a company, the company must have a program and you must follow it, including their PPE requirements. If you are a one-man-show and you ONLY do residential work, technically you can get away with not having a program. The homeowner is not an "employer", he is hiring you as an independent contractor. You are also not an employer if you have no employees. That's the ONLY way it works that "you don't need PPE for residential work". In reality if you love your family and want to protect them from the devastation of not having you to provide for them, you SHOULD be concerned with your PPE.

Recap: you ALWAYS need PPE if you are an employee. You ALWAYS need PPE if doing commercial or industrial work even if you work on your own. You ALWAYS should use appropriate PPE when doing residential work as an independent contractor, but if you chose not to, that's your own risk.

I have been aware of a lot of what you have mentioned here for a long time, thing is I still very seldom see much PPE, not just for electrical hazards but other general construction related safety issues as well like lack of fall arrest, confined space work, ladder/scaffold/lift issues, excavation safety issues, LOTO of all energy sources and not just electrical energy, even just eye protection is often not really enforced over a variety of trades/tasks.

Now bring all those requirements and many I haven't even mentioned to a small company of say only 10 employees or so, and that is where you don't always see much PPE in any of the areas I mentioned. You may have some usage that is voluntarily done just because the employees figure out on their own that it is a pretty high and fairly obvious risk for certain tasks if you don't wear those safety glasses or limited things of that nature. But otherwise such companies either figure they can't afford to follow all those rules, are ignorant to what those rules are, or more likely a little of both. Sometimes their insurance carrier is the driving force behind what safety standards they do have. About the only time I hear of fines from either OSHA or dept of labor etc. is after a severe injury or death in this region of the country anyway.

Larger business and some government organizations usually have more structure to safety policies, usually a business that has many locations, and state or federal government, the local government organizations are like the small businesses. many times their insurance carriers are what sparked what safety procedures they do practice.

 

[kwired]

One thing I have though about many times and see all the time is electrical inspectors (state employees) inspecting exposed live parts, and without putting on any additional PPE.

This would be one area you would think you might see more compliance with 70E, but only time they are wearing any additional PPE of any kind (from my observations anyway) is if the owner of the facility is strict about making visitors follow their safety policies.

Otherwise (and I have not studied all the 70E requirements but do read a lot of what is required on here) from my understanding if 70E is the standard being followed they couldn't even take a cover off a service panel in any occupancy unless the supply conductors were de-energized and LOTO or other assurances that they can't be energized are followed, and even then they must suit up and check voltage before they can take off the arc flash and shock hazard PPE. Never seen that happen.