Removal of ligting exception for Energized work

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brother

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I'm trying to find when OSHA removed the exception to work 'hot' because of lack of lighting or illumination.

Illumination use to be a 'justification' but I remember it being removed. I was sharing this info with someone else because they had the old rules that allowed that justification for hot work.

Any help in finding it would be greatly appreciated.
 
I fail to see how illumination can be justification. To begin with, if you would have a fault condition that ends up removing power, you will no longer have illumination.

Portable and temporary illumination is not that hard to come up with in general and allows to work the existing illumination de energized.

How does one ever get the general illumination up and going initially? - With portable, temporary illumination, or natural light.

Flashlights are portable illumination, and if they are sufficient to get the job done then nothing is wrong with them.
 
Here is a cut and paste directly from OSHA web site

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.
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It can be found here http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9910

It currently still mentions illumination, however this not a free pass. It does not mean as long as some lights might go out you can work hot. It means if the removal of the illumination is more hazardous than working hot.

Now who gets to decide that? Those on the job and as long as nothing goes wrong it will not be questioned.

On the other hand if someone is injured by working hot you can bet that decision would be questioned.

Why did the work have to be done when the lights where needed?

Why could you not provide temporary lighting arrangements?
 
iwire said:
Here is a cut and paste directly from OSHA web site



It can be found here http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9910

It currently still mentions illumination, however this not a free pass. It does not mean as long as some lights might go out you can work hot. It means if the removal of the illumination is more hazardous than working hot.

Now who gets to decide that? Those on the job and as long as nothing goes wrong it will not be questioned.

On the other hand if someone is injured by working hot you can bet that decision would be questioned.

Why did the work have to be done when the lights where needed?

Why could you not provide temporary lighting arrangements?
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Thanks for the link, but I remember reading somewhere that it was either OSHA or NFPA 70e had taken out that justification. Mainly because of the same reasons you give, temporary lighting is used all the time, or why cant the work be scheduled when lights are not needed.
 
kwired said:
I fail to see how illumination can be justification. To begin with, if you would have a fault condition that ends up removing power, you will no longer have illumination.

Portable and temporary illumination is not that hard to come up with in general and allows to work the existing illumination de energized.

How does one ever get the general illumination up and going initially? - With portable, temporary illumination, or natural light.

Flashlights are portable illumination, and if they are sufficient to get the job done then nothing is wrong with them.
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As I read it, the exception applies when shutting down power would cut off illumination to an area which requires illumination for safety, not necessarily the illumination for the work area. An example would be the corridor and room lighting in a ward of a hospital. Even if you do the work during the day, some illumination may be necessary for spaces without windows.
Sure you could evacuate the area for the duration of the work, but that may involve a hazard by itself, not just an inconvenience.
And sure you could provide temporary lighting for all of the affected rooms, but that would take some time to set up.

If the only issue were the lighting in the immediate area of your hot work, then I agree that it is no justification.
 
brother said:
Thanks for the link, but I remember reading somewhere that it was either OSHA or NFPA 70e had taken out that justification.
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I have heard people talk about the possibility of it happening but you are the first I have heard say it has happened.

Maybe 70E but not OSHA yet.
 
brother said:
Thanks for the link, but I remember reading somewhere that it was either OSHA or NFPA 70e had taken out that justification. Mainly because of the same reasons you give, temporary lighting is used all the time, or why cant the work be scheduled when lights are not needed.
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It is still in OSHA, that section has not been revised since 1994 or so, the 70E gets revised every few years (With OSHA people being involved in that revision cycle) and the illimunimation part was removed with the 2009 edition. It was just a poor excuse, was often abused, and should have never been there in the first place.
 
GoldDigger said:
As I read it, the exception applies when shutting down power would cut off illumination to an area which requires illumination for safety, not necessarily the illumination for the work area. An example would be the corridor and room lighting in a ward of a hospital. Even if you do the work during the day, some illumination may be necessary for spaces without windows.
Sure you could evacuate the area for the duration of the work, but that may involve a hazard by itself, not just an inconvenience.
And sure you could provide temporary lighting for all of the affected rooms, but that would take some time to set up.
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You are right, it could take time and money to set up. As far as I can tell OSHA does not base their decisions based on either of those issues.

In my opinion you have to imagine defending whatever decision you make in a court over a death of the worker. I know that sounds extreme but it is the truth.


'John Smith was electrocuted while working hot because temporary lighting could not be provided' is going to be a weak defense in my opinion.
 
iwire said:
You are right, it could take time and money to set up. As far as I can tell OSHA does not base their decisions based on either of those issues.

In my opinion you have to imagine defending whatever decision you make in a court over a death of the worker. I know that sounds extreme but it is the truth.


'John Smith was electrocuted while working hot because temporary lighting could not be provided' is going to be a weak defense in my opinion.
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Takes 2 minutes to set up a light stand, sheesh.
 
zog said:
It is still in OSHA, that section has not been revised since 1994 or so, the 70E gets revised every few years (With OSHA people being involved in that revision cycle) and the illimunimation part was removed with the 2009 edition. It was just a poor excuse, was often abused, and should have never been there in the first place.
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Thanks ZOG. I knew it had to be one or the other. But it's my understanding that by default of the general duty clause OSHA uses and enforces NFPA 70e. Is that not true?

So even if the illimuniation part was still in the OSHA rule but not in the NFPA 70e, a person could still be fined under that.
 
iwire said:
You are right, it could take time and money to set up. As far as I can tell OSHA does not base their decisions based on either of those issues.

In my opinion you have to imagine defending whatever decision you make in a court over a death of the worker. I know that sounds extreme but it is the truth.


'John Smith was electrocuted while working hot because temporary lighting could not be provided' is going to be a weak defense in my opinion.
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There is a range of acceptable and relative risk in this area.
If we accept without reservation your argument that cost and inconvenience are not an issue, then you can just as easily throw out the rest of the exceptions too:
Examples of increased or additional hazards include interruption of life support equipment, deactivation of emergency alarm systems, shutdown of hazardous location ventilation equipment,
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You could install alternate ventilation, shut down the vapor producing process so that the location is no longer hazardous, set up battery power for the life support equipment, shut the building down so that the emergency alarms are not needed, etc.

What is not mentioned in the wording of the exception that should play a part in a real life situation is what the risks are of not doing the repair or correction (hot work) immediately.
That is, the difference between the time to set up a light stand versus waiting for daylight may play a role in a reasonable decision. (And I know that may cut no ice when the lawyers get involved.)
 
GoldDigger said:
What is not mentioned in the wording of the exception that should play a part in a real life situation is what the risks are of not doing the repair or correction (hot work) immediately.
That is, the difference between the time to set up a light stand versus waiting for daylight may play a role in a reasonable decision. (And I know that may cut no ice when the lawyers get involved.)
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Now you are going somewhere with this, but ultimately in an incident involving a death, you are very likely to still have to justify the decision in a court.


You may have a situation where the life of many may seem like it is worth risking the life of one, I just hope I never have to make such a decision myself, but it does happen, and not just decisions involving electrical hazards either.


The majority of the time most of us are not putting others in jeopardy by shutting something down for maintenance purposes, it is when there is a true unscheduled emergency incident that these decisions are more critical.
 
GoldDigger said:
There is a range of acceptable and relative risk in this area.
If we accept without reservation your argument that cost and inconvenience are not an issue, then you can just as easily throw out the rest of the exceptions too:


You could install alternate ventilation, shut down the vapor producing process so that the location is no longer hazardous, set up battery power for the life support equipment, shut the building down so that the emergency alarms are not needed, etc.

What is not mentioned in the wording of the exception that should play a part in a real life situation is what the risks are of not doing the repair or correction (hot work) immediately.
That is, the difference between the time to set up a light stand versus waiting for daylight may play a role in a reasonable decision. (And I know that may cut no ice when the lawyers get involved.)
Click to expand...

I wouldn't say cost is not an issue in any scenerio, but from my experience it was few and far between! I've done work in a hospital where they have of course life support etc... So far the only work (both cost and convience considered) I've seen to really need to be worked hot was 'voltage testing, amp reading, infrared readings and trouble shooting/diagnostic' mainly because it is impossible to take a voltage reading etc.. without the power being on ;) . This is even for emergency circuits/power.

Corridor lighting had temp lighting strung across the ceiling. Most stairs and other areas that would be dark had emergency lighting that had battery back ups.

Maybe a nuclear power plant or chemical plant would have more of a justification dealing with the costs and inconvience, other than that I cannot think of any other jobs that would justify hot work other than reasons I gave above, voltage testing etc... My issue is this, if you are changing a breaker hot and for some unknown reason it shorts out and trips the main or cause damage, and you have an unscheduled shutdown, then what???
 
GoldDigger said:
There is a range of acceptable and relative risk in this area.
If we accept without reservation your argument that cost and inconvenience are not an issue, then you can just as easily throw out the rest of the exceptions too:


You could install alternate ventilation, shut down the vapor producing process so that the location is no longer hazardous, set up battery power for the life support equipment, shut the building down so that the emergency alarms are not needed, etc.
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You are absoulutly correct and I do apply the same argument to all of those items.

If someone is killed or injured it will be tough to justify, morally, civilly or financially.

Zog can provide the info about how much it does cost a company when a fatal injry does occur.




What is not mentioned in the wording of the exception that should play a part in a real life situation is what the risks are of not doing the repair or correction (hot work) immediately.
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What is the risk in waiting?

If it is that dangerous it should be shut down immediately even if that means an inconvenient and costly evacuation/


That is, the difference between the time to set up a light stand versus waiting for daylight may play a role in a reasonable decision. (And I know that may cut no ice when the lawyers get involved.)
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Would it cut any ice with you if the dead person was a family member?
 
iwire said:
Would it cut any ice with you if the dead person was a family member?
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Of course. Logically it should not make any difference, but I am human. :)

In the end, even if the exception is there in the OSHA rules, the decision on whether or not to apply that exception and do the work hot (yourself or one of your employees) is ultimately your responsibility based on your own moral and business judgement. You are not forced to blindly perform hot work just because it is allowed by the rules.

If as an employee your only protection against being forced to do questionable hot work is the OSHA rules, then that is one of the situations that the rules exist to address, and you have a different problem. You are clearly not that kind of employer.
 
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