Racking in medium voltage breakers. Who should do it?

[Sarge7]

I am an operator at a large chemical plant. I am looking for information on racking in medium voltage NEMA E2 starter/switchgear. All panels are equipped with multiplex electronic amp meter or a analog amp meter on the panel. They also all have a control load switch (on and off). Some of this equipment has been on the plant for more then 40 years and some as new as 10 years old.

My company is now requiring all the operators on the plant to attend a two hour training on racking in this equipment. Many of us objected to the training and task as we feel it is unsafe. We all stated that we are not electricians. Electricians perform this task right now and in pairs (one suited out in arc flash gear 50 cal and the other suit with everything but the hood in the event he needs to call for help and come to the need of his coworker. They usually get a third person to standby a trip switch for the breaker feeding that starter in the event something goes wrong.

My question is what is the industry standard for racking in this type of equipment? Do your location require only electricians perform this task or do they allow operation personal to perform this task after minimal training?

I wrote a written letter of objection to the manager of my unit and top top staff at the plant, the health and safety committee and the local union. I was called in by the HR department and question on my letter. I stated in my letter, I felt that this task was best performed by electricians since they work around electrical devices everyday of their career; where an operator may on rack this equipment once or twice a year. They stated that when they implement the new policy/procedure we will all have been trained and qualified to perform this task. I rebutalled that qualified does not mean proficient. I backed my letter up with quotes and incidents on the companies own web pages.

I need more ammunition to fight this on so please respond back with who you feel should be performing the racking of medium voltage electrical gear.

 

[celtic]

I would cite :

110.31 Enclosure for Electrical Installations.
Electrical installations in a vault, room, or closet or in an area surrounded by a wall, screen, or fence, access to which is controlled by lock and key or other approved means, shall be considered to be accessible to qualified persons only. The type of enclosure used in a given case shall be designed and constructed according to the nature and degree of the hazard(s) associated with the installation.

(from 2002 NEC)

The key phrase here:
....accessible to qualified persons only.

What is a "qualified person"?

Qualified Person. One who has skills and knowledge related to the construction and operation of the electrical equipment and installations and has received safety training on the hazards involved.

(2002 NEC, Article 100 ~ Definitions)

Key phrase here:
....has received safety training on the hazards involved.

Seems your employer has attempted to find a "loop hole" here to protect them and give you new duties/responsibilities.


BUT....read that definition again:
One who has skills and knowledge ...

Training, IMHO, is NOT skills and/or knowledge.


What is the electricians position on this? I'm sure - if they are covered by a collective bargining agreement - there will be some unhappy campers.

What does your contract state about this type of work?

You might also consider a visit to OSHA's website (osha.gov).
Here are a couple of searchs to get you started;



1) Electrical Safety

2) Medium Voltage


Just be warned....if this is what your employer has decided to do - right or wrong - and you do not agree with this new policy/procedure/responsibility, you will face an uphill battle.

I had a situation where the company I worked for wanted us (the electricians) to clean out the manholes. I knew there was asbestos (among other carcinogens) in these holes - but I couldn't prove it (lack of funding as it would have been on MY dime). The foreman's attitude was "I've been in them - you'll be in them" and "It's been like that for 100 years, it'll be that way for another 100". I was labeled a "trouble maker", had co-workers refuse to speak to me, etc. Eventually I quit....but not before I personally witnessed an asbestos abatement company come in and clean every single manhole and then encapsulate the walls, floors and ceilings....but I was the "trouble maker".
I lost my job (by choice and am happy for that), lost some friends (if you want to call them friends), BUT...I ensured THEY would be able to see their grandkids and more importantly to ME - I retained my integrity.

Just be careful what you wish for....

...it might swallow you up.

 

[don_resqcapt19]

Celtic,
There is nothing in the code wording that you cited that would require that metal enclosed switchgear to be "in an area surrounded by a wall, screen, or fence, access to which is controlled by a lock(s) or other approved means." Look at 110.31(B)(1). Also I doubt if the gear in question is even covered by this section. This section only applies to over 600 volts.

As far as the original question, I see no problem with trained operators using the correct procedures and PPE opening and closing these breakers as part of a lock out. Operators should never attempt to reclose a device after it has automatically opened.
Don

 

[Sarge7]

thanks for the reply

thanks for the reply

We do have a collective bargaining agreement and the electricians have ben trying to keep this from happening since last November when the company stated their position.

Fact is none of our substations where this gear is kept is under lock and key but do have locks on them. The required signs that say authorized personal only are posted on the doors. The substations contain both 480 volt, 600 volt and 2200 volt breakers, switchgear and the E2 starters.

I have seen the results of a flash arc injury from a 220 volt 200 amp residential service line. My father was burned from the waist up with third degree burns and if it was not for his co-workers with him on the job he would be dead. They revived him with CPR.

My concerns are inadequate training, no CPR training, no backup personnel (they are requiring one operator versus two electricians), and proficiency. I also attacked them on a survey of what our local area industry procedures are. We would be the only location in a 100 mile radius that will allow their operators to rack medium voltage equipment. Our policy states that the company will follow best work practices. It clarifies this in writing that this is not just among our own company but across the industry.

I showed them the video of a flash arc when they called me into HR. The head electrical manager put his head down. I also quote from their own web page that the head corporate electrical engineer has stated that it is the industry trend to have electricians perform this work.

 

[Sarge7]

medium voltage

medium voltage

Don,

The gear I am refereing to is 600 volt and 2200 volt systems.

 

[charlie b]

The key phrase here: ....accessible to qualified persons only.

That phrase does not forbid access to, or operation by, persons who are not electricians. The NEC gives us a break (meaning that it relaxes certain requirements), if we can show that the public and other persons who should not be near the equipment are, in fact, being kept out, by some appropriate means. Provide the right collection of doors, fences, chains, and locks, and the NEC will accept the space as being ....accessible to qualified persons only.

However, if the owner wishes to train someone to perform certain duties in that space, and gives them the key, the NEC article you cited will not forbid them to do so.

 

[ramsy]

Celtic and Charlie's point resonate with me. By itself the NEC carries little weight. Federal enforcement comes by tiing OSHA's general duty clause Section 5(a)(1) to the requirements of NFPA 70E, as detailed in these articles found at nfpa.org

1) OSHA, NEC?, and NFPA 70E
http://www.nfpa.org/displayContent.asp?categoryID=1005

2) Personal Protective Equipment
http://www.nfpa.org/displayContent.asp?categoryID=1003

3) Choosing the right personal protective equipment
http://www.nfpa.org/displayContent.asp?categoryID=1008

One article mentions about 50% of the industry is complying with the above standards combo. For the other half that do not comply, perhaps their read of the NEC by itself is inadequete, as Charlie and Celtic pointed out.

With my read of industrial exceptions that riddle the NEC at every rule, it seems factories can just about be burning to the ground as long as its supervised.

Using other areas for example, with NEC's current exceptions for industrial bonding & grounding, or by 100 foot tap rule exceptions for transformers rising to higher floors, it could be expected, anyone touching a drinking fountain bonded to plumping or urinating on a likewise metal drain, and creating a shorter current route, could become part of the energized path through the building.

Graduating amoung the best business schools in my state 10 years ago, I was trained that lability-cost analysis was for the legal department, and high turnovers of personell to keep up with falling labor rates was my department.

IMO, when industrial accidents injur maintanance supervision the "Help Wanted" ads take their place, designed after variable-cost-reduction strategies, to replace by attrition the more expensive maintenence personell.

With corporate American enjoying unprecidented regulatory immunity and a feeding frenzy of cheep labor from the current administration, risk-prevention practices or expensive safety corrections may be naturally viewed as cost reduction targets.

 

[ramsy]

In the absence of a legal Dpt. to direct some enforceable compliance evidence, in writting, I agree with Celtic. The consensus amoung the working stiffs in my organized electrical trade is that any combo. of high-stress forman, budget overrun, or slipped schedule, can produce risk takers that set the pace for the entire job.

If participating in such risk goes against your personal limits and boundaries, its your responsibility to refuse, and set the fisrt example by articulating that refusal to others.

I started out taking the risks with everyone else, handling energized 12kva+ conduits, watching my lead struck with 277 while working energized lighting, and working in all sorts of crumbling trenches with or without niagra falls pouring in. I escaped only when formen could see by the terror on my face and my inability to show up on time, it was time to let me go.

Business school never taught me how to test my limits or work with the other animals, which is neccessary without my own licence and client base. In this environment I've learned the hard way that being an expendable commodity is unavoidable, until my recent tactic of proving how jeapardizing my welfare hurts them worse, and being more prepared to excercise my walking rights.

 

[celtic]

However, if the owner wishes to train someone to perform certain duties in that space, and gives them the key, the NEC article you cited will not forbid them to do so.

Seems your employer has attempted to find a "loop hole" here to protect them and give you new duties/responsibilities.

The NEC is not an operations manual though, is it? It is also not a "safety manual", right?
Seems to me, the company is just trying to cover all the bases/angles - and seem to be pretty well versed in it.

My concerns are inadequate training, no CPR training, no backup personnel (they are requiring one operator versus two electricians), and proficiency.

Have you done some homework at the OSHA site?

I also attacked them on a survey of what our local area industry procedures are. We would be the only location in a 100 mile radius that will allow their operators to rack medium voltage equipment. Our policy states that the company will follow best work practices. It clarifies this in writing that this is not just among our own company but across the industry.

I showed them the video of a flash arc when they called me into HR. The head electrical manager put his head down. I also quote from their own web page that the head corporate electrical engineer has stated that it is the industry trend to have electricians perform this work.

Be very careful in trying to play pin the tale on the donkey with the donkey's own tail...the donkey still has teeth and 4 legs!

If participating in such risk goes against your personal limits and boundaries, its your responsibility to refuse, and set the fisrt example by articulating that refusal to others.

In this environment I've learned the hard way that being an expendable commodity is unavoidable, until my recent tactic of proving how jeapardizing my welfare hurts them worse, and being more prepared to excercise my walking rights.

"being an expendable commodity is unavoidable"...exactly.

You'll have to explain a bit of the "recent tactic".

 

[ramsy]

"being an expendable commodity is unavoidable"...exactly.

You'll have to explain a bit of the "recent tactic".

With my local OSHA rep's fax & email in hand and a small camera, when reasonable efforts to safeguard hazards are ignored and evidence of the violation or practice can be plainly photographed, the mult-thousand-dollar fine can make the point before injury is necessary. I met my rep during a local 10-Hour OSHA certificaton class.

 

[petersonra]

My first thought is I do not want persons with minimal training doing what should be done by experienced and trained people. Two hours does not sound like a lot of training to me.

My second thought was just what does he mean by "racking in" the breakers? This means different things to different people.

I would want to know more about just what your company has in mind for both operating these breakers and the training involved before condemning this action. I could see how some operation of these breakers by operators with limited training could be done safely, but personally I am leery of anything having to do with MV equipment in general.

 

[realolman]

My second thought was just what does he mean by "racking in" the breakers? This means different things to different people.

.

Thank you petersonra. I'm glad you said that.

I wanted to know myself what they meant, however I uncharacteristically denied myself an opportunity to demonstrate my ignorance.


Are you talking about nothing other than turning them on and off?

 

[davidv]

Sarge,
if I'am in your position, if the company still pursues the policy, I will ask for a reassignment, or just quit. My life is more important that a job that includes rackin' and poping G knows when. Company like that aint worth working with.
Just the way the very electricians prepare for the procedures, tells the potential danger involved. panic can do much harm on every person.
but if you quit other lives will be at risk, higher authorities or strength in numbers might work. I don't know which is worst.

davidv
es

 

[Sarge7]

Racking definition

Racking definition

Our set up is this. This only appplies to 600 volts to 2400 volts systems.
Our E2 starters are all older equipment. When you turn the handle the starter engages the live bus bar making contact. The olny safety built into this equipment is a control power on and off switch which cuts power going to the field on and off switch and a multiplex amp meter. The required PPE has been purchased (20 Cal or 40 Cal) depending on which MV equipment you are racking.

All of our 480 volt equipment have a brekaer to disconnect electrically.

The only reason they want an operator to do this is to save a few call outs a year. That statement is in writing when an electrician filed a safety complaint on their intentions last year. I have documented everything and have continued to fight them.

We have had several incidents since the early 80's with MV voltage equipment. Many were caused by operators or electricians not following safe work practices and forcing it to rack in when the interlocks were trying to stop it.

We have had at least one incident that resulted in a lost time because the interlocks failed allowing it to rack in while the field start switch was stuck in the on position.

I have looked into this on both the internet and the company intranet and even the head elctrical engineer for the company stated from his survey of the industry the trend is for an electrician to complete this task.

We were told we would be doing this task by ourselves and we have not been taught all the that is needed to know. Our electricians use a safety audit form before every electrical job. This form states what they need to look at and also states where the next swicth is to kill the power to the equipment they are working on is at. They form requires two electricians to sign off on it so you have two sets of eyes looking at this equipment. Our electricians have been CPR trained and operations has not.

After my 3 page letter of protest as a union steward to the company, I have some heavy thinking going on. I have been called to meet with HR twice. Both times, they questions the facts stated in the letter and and everytime I give them something else to bite on. The last meeting had two electrical engineers and the plant manager sitting in on it. Right now I figure they are plotting their next move.

 

[ramsy]

I tried to plug your facts into the OSHA LOTO Plus Expert System. Note the last sentance on this linked page:

If you have safety or health problems in your workplace, please contact your local OSHA Area Office or OSHA Consultation Program Office.

                    OSHA LOCKOUT/TAGOUT EXPERT ADVISOR
                                 REPORT
                             March, 25 2006
             ======================================================
This is the NOVEMBER, 1999 PUBLIC TEST release of this Advisor, made available for public comment prior to release. You may not rely upon it for guidance.

     This summary report contains the conclusions that the program reached based on the information provided.   Also included is a summary description of any regulations that apply to the situation you described.
            ======================================================

 THESE ARE THE CONCLUSIONS THAT THE LOTO ADVISOR REACHED 
_________________________________________________________

 Industry
=============
Your firm is subject to General Industry standards.

Your workers are NOT considered 'qualified' for electrical work in generation, transmission, or distribution facilities because they have NOT met one of the six key tests:
....trained and familiar with safety work practices for this 
    assignment,
....trained and familiar with related emergency procedures,
....trained and competent in the identification of exposed live 
    parts,
....trained and competent to determine the nominal voltage of 
    live parts,
....trained and competent in the minimum approach distance, and
....trained and competent in special techniques, PPE, insulating 
    materials and tools appropriate for this assignment.
ALSO, they did NOT meet the three training conditions:
 ....currently receiving on-the-job training,
 ....demonstrated ability to work safely at the current level of 
     training, and
 ....work under the direct supervision of a qualified employee.

Because your workers are not qualified, based on the guidance of 1910.269(x), to perform specialized power transmission, generation and distribution electrical work, they must comply with the safe work practices in Subpart S, 1910.332 -.335.  (Subpart S removed here)

Notice this 1999 system omits OSHA's general duty clause Section 5(a)(1) that links NFPA 70E requirements, or first Aid & CPR training, etc..

Also notice if OSHA finds this kind of Recognition of Electrical Hazard how it results in $135,000 in fines.

This tact does not consider a "Chicken Switch" system, perhaps reserving qualified persons for failure of the safely-removed, remote function. However, if management prefers to unlawfully jeopardize unqualified personell, in flash / blast proximities, OSHA enforcement may be your only option. You should probably run this by your local OSHA Area Office anyway.

 

[Sarge7]

Thanks for information

Thanks for information

Thank you for everyones input and information. I have a little more information then what I started with and have written a letter to OSHA requesting how they would rule if a process techician was hurt performing this task based off off the training that was given. Letter was mailed Saturday so I now wait on a reply.

 

[eric stromberg]

Sarge,
I, too, work for a large Chemical company and am very familiar with the procedures. I read, in disbelief, what your company is trying to do. Where i work, the only people who can rack breakers in and out are our Power-distribution group. And then, only after electrical safe work permits have been written. Turning the breakers on and off is done at a remote panel so that no one is standing in front of the breaker when it closes or opens.

Having an operator do this would be like sending an electrical person to make process decisions on how to operate the plant. Wow. Keep us posted as to what happens.

Best of luck to you.

 

[hockeyoligist2]

training

training

Are they also training you on how to check for the fault? If it trips there is a "reason" and a qualified person needs to determine the fault. You don't just rack it back in without checking for "why" it happened! And only a qualified person can determine that! We have operators that will reset breakers just because they need the equipment and burn up motors etc. I can't imagine them racking in something like that. I still get the "Willies" when I push that button and I've done it for 32 years!

 

[busman]

For us Residential/Light Commercial Electricians, is it possible someone could give a short description of "racking in". Do the breakers actually separate from the busbars?

Thanks,

Mark

 

[Sarge7]

Reseting and racking

Reseting and racking

Under our procedure they are trying to put in place we will be allowed 2 overload resets of medium voltage electrical gear and 2 resets and overloads on 480 volt systems.

In the class their was no mention of fauts only how to properly don the PPE and what PPE would be required. How turn off the control power switch and look at the mulitplex for zero amps before racking in or out the equipment. This is on equipment from 600 volts to 2400 volts. We are not allowed to open the cubicles.

They never mentioned what can happen if a mechcanical interlock fails to to keep the breaker from racking in or out. No mention of making sure that this is done in one swift movement. Only mention about the movement is that it should move easy if not there could be a problem.

Racking out does separate the starter breaker from the bus bar.