Risk assement - install hot

Status
Not open for further replies.
D

Dan Kissel

Member
Location
st louis, mo
We have SqD I Line panels and buss duct in our facilities. The SqD equipment was designed to be able to install circuit breakers and bus plugs while the panel and/or bussduct is hot. That was true before NFPA 70E became a big issue. (I'd use the term "problem" - but some might take issue) My qualified electrical contractor said they have no problem doing it hot but our policy doesn't allow it because of MY interpretation of 70E.
Our distribution panels and bussduct power equipment that is common to the entire manufacturing facility. Bussducts can easily have over 80 calories of incident energy available. Can we have a risk assessment for wiring a buss plug that is already connected on the buss and determine that since it there is very limited opportunity to touch energized parts that it would be safe to land wires on the plug while the buss was hot without PPE. Reality is that we wear 8 cal clothing as a uniform but 80 cal doesn't exist.

Likewise - distribution panels can have 15+ calories. Sometimes after the circuit breaker is installed in the panel we would like to terminate onto it. If the wire is a manageable 1/0 for instance,can we do a risk assessment and determine that the CBs terminals are very assessment then we can terminate.

Essentially I am asking if a risk assessment can be done that would enable us to do work outside of our general safe work policy.
 
I think that the answer has to be that any exceptions, and the process for making them, would have to be spelled out in your safe work policy itself.
You cannot look to other standards or documents to provide exceptions to an adopted policy.
If your policy does not allow for exceptions, perhaps it should be ammended for flexibility, and perhaps not.
The decision, in the end, comes down to those responsible for adopting the policy in the first place.
If your safe work policy has, in effect, adopted 70E, then you can ask our members what they see as possible exceptions within 70E itself.
 
Dan Kissel said:
Our distribution panels and bussduct power equipment that is common to the entire manufacturing facility. Bussducts can easily have over 80 calories of incident energy available. Can we have a risk assessment for wiring a buss plug that is already connected on the buss and determine that since it there is very limited opportunity to touch energized parts that it would be safe to land wires on the plug while the buss was hot without PPE.
Click to expand...

Live work on a 80 cal/cm2 or better piece of gear with little or no PPE. I am speechless.:(

Reality is that we wear 8 cal clothing as a uniform but 80 cal doesn't exist.
Click to expand...

100 cal/cm2 PPE exists. Good for DNA tissue analysis/identification of someone caught in a 40 cal/cm2 or better arc blast.

http://www.salisburyonline.com/P-33...g-sk100.aspx?gclid=CKzA79Oeu9ICFVtMDQodSJEOVg
 
Dan Kissel said:
We have SqD I Line panels and buss duct in our facilities. The SqD equipment was designed to be able to install circuit breakers and bus plugs while the panel and/or bussduct is hot. That was true before NFPA 70E became a big issue. (I'd use the term "problem" - but some might take issue) My qualified electrical contractor said they have no problem doing it hot but our policy doesn't allow it because of MY interpretation of 70E.
Our distribution panels and bussduct power equipment that is common to the entire manufacturing facility. Bussducts can easily have over 80 calories of incident energy available. Can we have a risk assessment for wiring a buss plug that is already connected on the buss and determine that since it there is very limited opportunity to touch energized parts that it would be safe to land wires on the plug while the buss was hot without PPE. Reality is that we wear 8 cal clothing as a uniform but 80 cal doesn't exist.

Likewise - distribution panels can have 15+ calories. Sometimes after the circuit breaker is installed in the panel we would like to terminate onto it. If the wire is a manageable 1/0 for instance,can we do a risk assessment and determine that the CBs terminals are very assessment then we can terminate.

Essentially I am asking if a risk assessment can be done that would enable us to do work outside of our general safe work policy.
Click to expand...

First off you can't work on energized equipment. There are a few exceptions but the base RULE IS YOU CAN'T WORK ON ENERGIZED EQUIPMENT.

Now if you can find a way to make whatever you are doing fit one of the exceptions to the NO ENERGIZED WORK RULE, you might be able to find ways to reduce the incident energy enough that you could safely do so. Plenty of PEs out there who do this kind of thing for a living. Best bet is to hire one and listen to what he/she has to say.
 
You CAN work on energized equipment under SOME circumstances, but in general IF your situation qualifies under those circumstances, there are still other procedures that must take place. The Risk Assessment would start out with that determination of whether or not the energized work is truly justified. The allowable circumstances are few and somewhat subjective, so many employers simplify the process by just saying NO.

NFPA 70E is a "Consensus standard", so not specifically enforceable, but suggested by OSHA as a format for the required safety program. The enforceable standard is actually OSHA 29 CFR 1910, and specific to this issue, read 1910.333.
https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9910

It starts out saying "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. " After that are a LOT of details. In a nutshell, the idea behind using things like I-Line panels because they could be plugged / unplugged hot is a marketing concept that predates the more modern safe work practices. Or... "Just because you can doesn't mean you should".

Also just so you know, hiring a sub-contractor to do live work does NOT relieve the owner (and representatives) of the requirement for having a live electrical work safety policy that meets the OSHA standards and having EVERYONE abide by it, nor does it absolve them from responsibility if someone is hurt. So you are correct in questioning this. OSHA can criminally prosecute company owners, managers and supervisors for allowing work to transpire that was not covered under a safe practices doctrine.
 
I am surprised on the level of incident energy on the bus ducts. In doing studies for over 10 years I don't recall ever seeing a bus duct that high. If it is did anyone look at the coordination and what setting changes can be made to the feeder breaker? Many times an instantaneous setting can be turned down to reduce the incident energy.

That said, like others have said, you really need solid justification to work this hot.
 
Dan Kissel said:
We have SqD I Line panels and buss duct in our facilities. The SqD equipment was designed to be able to install circuit breakers and bus plugs while the panel and/or bussduct is hot....
Click to expand...
I don't know if that was actually a design criteria, but that's definitely not a position Square D currently supports.
Bussducts can easily have over 80 calories of incident energy available....
Click to expand...
Then unless workers have PPE rated at 80 calories, there is no way they can safely or legally work on this equipment while energized. 70E 130.5(B) clearly specifies that workers shall wear PPE rated for the incident energy to which they are exposed. The workers are exposed to very serious risk, and the company is exposed to very serious liability, by ignoring the existing arc flash survey.
Reality is that we wear 8 cal clothing as a uniform but 80 cal doesn't exist.
Click to expand...
I'm not gonna make any judgement about whether >40cal/cm PPE is effective, but it does exist.
Essentially I am asking if a risk assessment can be done that would enable us to do work outside of our general safe work policy.
Click to expand...
A risk assessment is not an allowance to expose workers to potential harm: A risk assessment that does not adequately reduce employee risk has not been correctly performed.

Take a look at Annex F for guidance on how to proceed. But the short answer is that unless you can justify energized work per 130.2(A) and also provide all necessary PPE that employees must have to perform that work, then you must de-energize this equipment prior to working on it.
 
At our site, for new installations of bus duct, we provide a disconnect switch to feed each section of bus duct. This allows us to de-energize the section of bus duct when we want to reconfigure it for changing loads or lab equipment. We don't permit inserting or removing modules from energized bus duct.
 
Jraef said:
Also just so you know, hiring a sub-contractor to do live work does NOT relieve the owner (and representatives) of the requirement for having a live electrical work safety policy that meets the OSHA standards and having EVERYONE abide by it, nor does it absolve them from responsibility if someone is hurt. So you are correct in questioning this. OSHA can criminally prosecute company owners, managers and supervisors for allowing work to transpire that was not covered under a safe practices doctrine.
Click to expand...

as i understand it, having an employee work hot, unless it's more dangerous to work it cold,
as in interruption to critical processes, is forbidden. period.

my understanding under the standard Darwinian candidate protocol is that if i want to
do it as the principal in a business, not as an employee, suit up, cupcake, and have at it.
OSHA doesn't apply to the owner of a business.

or, in field terminology.... "hold my beer, i've got this."
 
Fulthrotl said:
... my understanding under the standard Darwinian candidate protocol is that if i want to
do it as the principal in a business, not as an employee, suit up, cupcake, and have at it.
OSHA doesn't apply to the owner of a business.

or, in field terminology.... "hold my beer, i've got this."
Click to expand...
This is true, for YOU doing work on YOUR equipment.

If you are a contractor doing work at MY facility on MY equipment, the responsibility for ME to provide a safe working environment for YOU is not relieved.

If I hold your beer and you get it in the face, it's still my fault if it took place at my facility.
 
Status
Not open for further replies.
Top