Residential electrical procedures and PPE

[scottwnuwer]

I am struggling to find a solution for my dilemma, and feel as though it's a common occurrence. My situation involves residential electrical service for single phase 120/240v. I have been in the field of electrical for over 15 years, and I am now an electrical contractor (5 years running). I am more or less the only employee of my company, but I would like to hire employees and have a safety protocol in place before I even consider hiring.
My concern is the practical nature of my career and the regulations which have recently been made known to me through sifting this forum and two others regarding "de-energized parts" for 29 CFR 1910.333.
From my understanding, there is no possible scenario or exception for me or other employees to work near energized parts. Since most of the residential main breaker panels/load centers around my area (Southwest Florida) include all the branch circuit breakers, there would be no way for me to de-energize the electrical panel/load center apart from the local utilities. I also believe that I cannot use the table method or even perform an incident energy exposure calculation, risk hazard assessment, shock hazard assessment, fill out an energized electrical work permit, etc... That is only for times when it is "impracticable" (impossible) to de-energize.
Is this to say that for every installation requiring me to remove the electrical panel cover/dead front requires a disconnect/reconnect from the local utilities?

Examples might be:

Replacing a bad circuit breaker
Fixing a double tap circuit breaker
Installing a new circuit


Thanks.

~ Scott

 

[ramsy]

Letters of interpretation for various scenarios described in 29 CFR 1910.333 are helpful, but your State may adopt more specific guidance.

For main-breaker failures, my policy is to remove meter or delay work until utility can unlock meter ring. Clients can go elsewhere if they're impatient, since I need to make my next service call before risking injury for you.

If utility became unreliable then getting my own meter-ring keys would be investigated.

 

[scottwnuwer]

I assume that there are some individuals on this forum who probably have dealings with residential electrical. Some probably use PPE in an attempt to perform the job in a "safe manner", when in reality, there is no need for arc flash protection or shock protection since the electrical must be de-energized prior to removal of the electrical panel/load center cover.

Small jobs such as fixing a double tapped circuit breaker in an electrical panel, replacing a bad circuit breaker, or installing a circuit into a main breaker electrical panel/load center requires a disconnect/reconnect from the local utilities for a five to thirty minute job. Sometimes the closest available date for scheduling on the local utilities online portal is two to three months out. It does not bother me waiting so long in order to perform the work in a safe manner. The problem comes with the patience of the homeowner. If I tell the homeowner that it is going to take two to three months for any of the aforementioned smaller jobs, they will simply contact another electrical contractor (whether it's another local contractor, or "Always on time, you'll see...) who is willing to perform the work in an energized panel. To me, this essentially negates the point (from a residential electrical perspective) of requiring electrical contractors to adhere to the regulations. Honest electrical contractors are left with the decision to restructure their business to only accepting certain jobs which can be streamlined with OSHA regulations, or violate OSHA policy. Making attempts to de-energize circuits for smaller jobs leaves me perplexed as to why OSHA could not have imposed their authority on the local utilities to either:

1 - Hire more local utility employees to perform disconnect/reconnects for electrical contractors.
A fee based amount could be charged to the electrical contractor per disconnect/reconnect, or the total cost per kWh could be increased to accommodate the additional employees.
2 - Impose the local utilities to authorize electrical contractors to be able to perform a disconnect/reconnect.
It seems counterintuitive that the electrical contractor would be allowed to "pull the meter", considering the point of de-energizing is to avoid any possibility of injury from electrical shock hazards and/or arc flash. However, I am sure the manufacturers could create a "hot stick" with a 500/1000V rated claw attachment specifically for pushing/pulling meters. This could also be a fee based amount charged to the electrical contractor.

Any thoughts?

As you can imagine, I am a violator of OSHA standards on a daily basis. Even a service upgrade/change can sometimes run long, which I am in violation of 29CFR 1910.333 (Once the local utility worker comes back after the inspection to plug in the meter, and I am still torquing branch circuits).

~ Scott

 

[hillbilly1]

You still have to wear PPE until AFTER you have verified it de-energized using a meter (not a hot stick) . Regardless if you pulled the meter.

 

[scottwnuwer]

Is that what you do after the utilities performs a disconnect? Do you decide the PPE based on the incident energy exposure method?

 

[infinity]

I assume that there are some individuals on this forum who probably have dealings with residential electrical. Some probably use PPE in an attempt to perform the job in a "safe manner", when in reality, there is no need for arc flash protection or shock protection since the electrical must be de-energized prior to removal of the electrical panel/load center cover.

Where is this written?

 

[scottwnuwer]

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.

 

[mtnelect]

In the City of Glendale, they charge a "Reconnection Fee" on all their meters. Once the fee is paid, they will come out the next day and remove the locking ring and put a 30-day Warning Notice on the unlocked service. If necessary, they will extend that time frame with good reason. You are then allowed to remove the meter at your convenience but replace it for the next workday.

 

[infinity]

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.

If you shut off the main how are you exposed to live parts?

 

[mtnelect]

Also, the Southern California Edison Company will also do the same, without charge for a licensed contractor with a valid permit. This of course is only for service upgrades.

 

[BillyMac59]

Please correct me if I'm wrong but ... my arc flash training (in Ontario, Canada) said that a voltage in excess of 250V ac was needed to sustain an arc. For residential applications, the greatest danger , by far, is shock/electrocution. Once the meter is pulled and capped/locked off and a last voltage check is made with whatever PPE is compulsory by your boss etc., it can be treated as dead and visors, gloves go back in the bag.

 

[hillbilly1]

If you shut off the main how are you exposed to live parts?

If the main is in the panel, the exposure is the utility side of the breaker. You can work in it, but PPE is required to be worn when within that exposure area.

 

[hillbilly1]

Please correct me if I'm wrong but ... my arc flash training (in Ontario, Canada) said that a voltage in excess of 250V ac was needed to sustain an arc. For residential applications, the greatest danger , by far, is shock/electrocution. Once the meter is pulled and capped/locked off and a last voltage check is made with whatever PPE is compulsory by your boss etc., it can be treated as dead and visors, gloves go back in the bag.

To sustain an arc, yes, but to have a flash condition that sprays molten metal, no. As long as the main is not in the enclosure you are working in, then yes, the gloves can go back in the bag. But if the main is also in that same enclosure, then you have to remain suited up, even though the load side buss is dead.

 

[scottwnuwer]

Are you saying that the main breaker can be opened, and I can:

Fix a double tapped circuit breaker
Replace a bad circuit breaker
Install a new circuit

...and so long as I am wearing the proper PPE, I meet OSHA regulations?

How would I determine what PPE I need? Since the main breaker is open, if something goes wrong, I would need to know certain information to perform an incident energy exposure. Am I wrong?

 

[hillbilly1]

Yes, but generally a live work permit is issued by your safety guy (you in this case) because of the exposure. Your not really working it live in the sense your in contact with live parts, but because you are working near them. This also helps if you have employees, so that safety procedures can be discussed before they start. A lot of people will install a snap in breaker on a live buss, but they are hidden dangers. I denied a permit because one of my guys wanted to just snap one in like he always had done in the past. He was replacing a bad breaker in a Dollar General, and did not want to shut the store down. The manager agreed to a short shutdown, and he proceeded. He called me back later, thanking me for making him shut it down. When he pulled the old breaker out, part of the buss came with it. It would have been an arc flash event. He had to leave the store partially down while he hunted another interior, but it could have been much worse.

 

[hillbilly1]

Here is an article that will help explaining arc flash boundaries.

Understanding the Arc Flash Boundary | Fluke

The arc flash boundary is the minimum “safe” distance from exposed energized conductors or circuit parts that has the potential for an arc flash. The required arc-rated clothing and PPE increases rapidly as a worker approaches the potential source of an arc flash

www.fluke.com

 

[scottwnuwer]

Here is one of letters of clarification from the link you posted:

Scenario: An employee is to perform work inside an electrical panel. The electrical disconnect is open and has been properly locked out. The electrical circuitry below the disconnect has been confirmed to be in a zero energy state by a qualified person using test equipment.

Question 1: Is the panel considered de-energized even though there is voltage to one side of the open disconnect? if the panel is not de-energized, would an employee be required to not only disconnect and lockout the power at the electrical panel, in this case a panel at floor level [Location B], but also to disconnect electrical service on-leg or panel upstream in the electrical system [Location A]?

Response: Section 1910.333(a)(1) establishes prerequisite criteria that live parts to which an employee may be exposed must be de-energized before an employee works on or near them, unless it is infeasible to do so.1 If locking and tagging out the circuit at the point of work (i.e., the panel to be worked on) does not de-energize the live parts an employee may contact, the employer needs to assess, on a case-by-case basis, the feasibility of locking and tagging out the circuit further upstream since doing so would de-energize the live parts. If upstream de-energization is infeasible, then the employer is required to use other safety-related work practices, such as the use of electrical protective equipment (e.g., barriers, rubber insulation blankets, gloves, sleeves, covers, insulated tools or handling equipment, in accordance with §1910.137 and §1910.335). Also, if upstream de-energization creates additional or increased hazards, per §1910.333(a)(1) de-energization is not required, and the employer must use other safety-related work practices. In any event, an employee is not required to lockout more than one panel governing the same circuit, if all exposed electrical components in a panel can be de-energized by locking/tagging out a single energy isolation device (at Location A or Location B) that is upstream from where the work is being performed.

The panel in your scenario may be considered de-energized depending on the design of the equipment and the work to be performed. In your scenario, the panel, while not technically de-energized as there is still power to the supply side of the disconnect, provides adequate employee protection if the design and installation of the panelboard is of dead-front construction — i.e., it prevents, through guarding, accidental contact of the employee or conductive objects with energized parts (e.g., the contact points on the fixed side of the switch designed to receive the contact points on the movable portion of the switch, conductor attachment points, conductors with compromised insulation, etc.). if the panel is not of dead-front construction or if the employee removes the panelboard guard, thus exposing live parts, the panel would be considered energized and thus be subject to the requirements of §1910.333(a)(2) (which requires the use of other safety-related work practices) and §1910.333(c)(2) (which allows only qualified persons to work on energized parts.2

From the perspective of OSHA, I was always under the impression that there was no difference between working "near" and working "on" live energized parts. They do not allow either, unless it falls under the few exceptions. From reading the letters of clarification, I am only more confused as to what is allowed.

The defining term being "infeasible" or "impracticable". Some dictionaries describe it as "impossible", others say "not possible to do so easily or effectively".

Is this to say that the best practice from a residential electrical perspective for a main breaker load center is to:
(In order)
Suit up in proper PPE
Turn off branch circuit breakers
Turn off main breaker
Remove cover
Perform work
Replace cover
Turn on main breaker
Turn on branch circuit breakers
Remove PPE

How would I determine what PPE I need? Since the main breaker is open, if something goes wrong, wouldn't I need to know certain information to perform an incident energy exposure?

I am only making certain because I would like to hire employees, and want to make certain that I am performing the proper safety procedures everytime. I want to have a streamline business and also be OSHA and NFPA70E compliant. Most of my work is at single family residences with the main breaker included with all the branch circuit breakers. Apart from that, the only "commercial" work I do is inside condo units or apartment complexes, which have a main breaker located elsewhere.

 

[hillbilly1]

Here is one of letters of clarification from the link you posted:

Scenario: An employee is to perform work inside an electrical panel. The electrical disconnect is open and has been properly locked out. The electrical circuitry below the disconnect has been confirmed to be in a zero energy state by a qualified person using test equipment.

Question 1: Is the panel considered de-energized even though there is voltage to one side of the open disconnect? if the panel is not de-energized, would an employee be required to not only disconnect and lockout the power at the electrical panel, in this case a panel at floor level [Location B], but also to disconnect electrical service on-leg or panel upstream in the electrical system [Location A]?

Response: Section 1910.333(a)(1) establishes prerequisite criteria that live parts to which an employee may be exposed must be de-energized before an employee works on or near them, unless it is infeasible to do so.1 If locking and tagging out the circuit at the point of work (i.e., the panel to be worked on) does not de-energize the live parts an employee may contact, the employer needs to assess, on a case-by-case basis, the feasibility of locking and tagging out the circuit further upstream since doing so would de-energize the live parts. If upstream de-energization is infeasible, then the employer is required to use other safety-related work practices, such as the use of electrical protective equipment (e.g., barriers, rubber insulation blankets, gloves, sleeves, covers, insulated tools or handling equipment, in accordance with §1910.137 and §1910.335). Also, if upstream de-energization creates additional or increased hazards, per §1910.333(a)(1) de-energization is not required, and the employer must use other safety-related work practices. In any event, an employee is not required to lockout more than one panel governing the same circuit, if all exposed electrical components in a panel can be de-energized by locking/tagging out a single energy isolation device (at Location A or Location B) that is upstream from where the work is being performed.

The panel in your scenario may be considered de-energized depending on the design of the equipment and the work to be performed. In your scenario, the panel, while not technically de-energized as there is still power to the supply side of the disconnect, provides adequate employee protection if the design and installation of the panelboard is of dead-front construction — i.e., it prevents, through guarding, accidental contact of the employee or conductive objects with energized parts (e.g., the contact points on the fixed side of the switch designed to receive the contact points on the movable portion of the switch, conductor attachment points, conductors with compromised insulation, etc.). if the panel is not of dead-front construction or if the employee removes the panelboard guard, thus exposing live parts, the panel would be considered energized and thus be subject to the requirements of §1910.333(a)(2) (which requires the use of other safety-related work practices) and §1910.333(c)(2) (which allows only qualified persons to work on energized parts.2

From the perspective of OSHA, I was always under the impression that there was no difference between working "near" and working "on" live energized parts. They do not allow either, unless it falls under the few exceptions. From reading the letters of clarification, I am only more confused as to what is allowed.

The defining term being "infeasible" or "impracticable". Some dictionaries describe it as "impossible", others say "not possible to do so easily or effectively".

Is this to say that the best practice from a residential electrical perspective for a main breaker load center is to:
(In order)
Suit up in proper PPE
Turn off branch circuit breakers
Turn off main breaker
Remove cover
Perform work
Replace cover
Turn on main breaker
Turn on branch circuit breakers
Remove PPE

How would I determine what PPE I need? Since the main breaker is open, if something goes wrong, wouldn't I need to know certain information to perform an incident energy exposure?

I am only making certain because I would like to hire employees, and want to make certain that I am performing the proper safety procedures everytime. I want to have a streamline business and also be OSHA and NFPA70E compliant. Most of my work is at single family residences with the main breaker included with all the branch circuit breakers. Apart from that, the only "commercial" work I do is inside condo units or apartment complexes, which have a main breaker located elsewhere.

There lies within the live work permit requirement. If you are removing the dead front to replace a breaker, then you are exposing the line lugs, back to wearing the PPE. New panels now have barriers that are installed after termination to mitigate that exposure.

 

[Buck Parrish]

Real world residential PPE equipment -

Pull your floor mat out of your truck. Make sure the main breaker is off. Put your sunglasses on stand on the floor matt grab the meter and pull it. Bingo, power is off.

Most electricians in NC that have been through a Hurricane, or an Ice Storm know what I am talking about.

Come on man...

 

[hillbilly1]

Real world residential PPE equipment -

Pull your floor mat out of your truck. Make sure the main breaker is off. Put your sunglasses on stand on the floor matt grab the meter and pull it. Bingo, power is off.

Most electricians in NC that have been through a Hurricane, or an Ice Storm know what I am talking about.

Come on man...

I’ve had different districts of Georgia Power tell me different things. In one district “Can’t you pull it? We will be back out to reseal it.” Others, “You electricians need to quit pulling our meters”