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 Post subject: Two Person Work Rule
PostPosted: Tue Oct 02, 2012 12:53 pm 

Joined: Wed Aug 01, 2012 10:44 am
Posts: 8
Location: Washington State
Hey guys I have been researching the requirements for the "two person" rule. So far from what I can find from OSHA and our State Regs (which mirrors OSHA) is that the two qualified person rule applies only to work over 600V. We are an industrial establishment and not a Utility but have underground distribution up to 13.8kV and some overhead at 2300V. The question we are trying to answer is exactly when two persons are required and if/when is the second person required to be a qualified electrical worker. I have found some info in the US Dept of Energy Electrical Safety Handbook but that is not a legal requirement. NFPA 70E simplay says that a hazard assessment determine if a second person is required.

Anyone have any additional information as to the legal requirements? What are your practices?


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PostPosted: Wed Oct 03, 2012 3:52 am 
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Be careful. The two person rule is entirely within Subchapter R which is not for "over 600 V" per se, but specifically for generation/transmission/distribution work. If you read NEC it seems to be "utilities" but then when you read the corresponding NESC the cutoff for the two is significantly different. OSHA does not define where this cutoff is especially in distribution equipment, and NEC and NESC are also just as vague. At best I've seen things saying that it is dependent on local agreements, custom, jurisdictions, etc. Frankly at my site we have a large cogen facility and we count the "LV" equipment plus the section of line going into the main sub at 22.9 kV but not beyond that as "G/T/D".

From a practical point of view the biggest reason for adopting G/T/D rules is when working on underground distribution or overhead lines where NEC and NFPA 70E are not really written for those.

MSHA ([url="http://www.msha.gov"]www.msha.gov[/url]) has a "working alone" rule which is identical to "two person". Two people is not absolute. The issue is whether or not that there is a hazard where an individual could become incapacitated and potentially needs either someone to check on them on a regular basis or immediate assistance (4 minutes is the rule in Subchapter R when a shock is a potential hazard). If you are de-energizing though and locking out before doing any work, and you also may have to consider the conditions during troubleshooting activity, the "2 person rule" may not be required. Read carefully because it refers to hazards/tasks, not an absolute rule.


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PostPosted: Wed Oct 03, 2012 7:45 am 

Joined: Wed Aug 01, 2012 10:44 am
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Location: Washington State
Paul,

Thanks for the info. Subpart R all also states "as well as equivalent installations of industrial establishments". We have a pretty large 13.8kV underground distribution system fed from a 115kV Substation that we own. The two person rule has been brought and we are trying to determine when two peaople would be required and when not. So far with our State Regs they divide the line at 600V. Looking at DOE they have a pretty extensive matrix they use for determination but then again that is not the law. And while we are trying to determine the legal requirements we also want to ensure our electricians safety. For instance it is our practice when pulling a 480V MCC Bucket out of a live MCC to not only have the correct PPE for the incident energy level but we also have a 2nd electrician standing by. So I was wondering what others practices are just for informational purposes and any insights such as yours are helpful as well.


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PostPosted: Wed Oct 03, 2012 8:38 am 
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The first question to ask is can I justify doing this work live? If so proceed with the EEWP and PPE requirements in 70E, live work should be a rare thing, and generally if an EEWP is required it is a good idea to have a 2nd man there.

Another thing to consider in a large industrial facility is the availability of 1st aid/CPR responders in 4 minutes. A rooftop substation may make it impossible for your normal 1st responders to get there in 4 minutes, in which case you need to have someone 1st aid/CPR qualified in the sub, most industrial plants I have worked with provide CPR training to all electricians that have access to substations.


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PostPosted: Wed Oct 03, 2012 9:55 am 
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Where does the 4 minute language originate?


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PostPosted: Wed Oct 03, 2012 11:50 am 

Joined: Wed Aug 01, 2012 10:44 am
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Location: Washington State
4 minute CPR rule is in OSHA 1910.269

All of our electricians and operators are CPR qualified so that is not an issue. The big question we are getting involves pulling a bucket, racking a CB etc. We will usually have a 2nd person there but they may not be an Electrician especially for an after hours/weekend call out. We are not working withing the Prohibited Boundary and not actually placing a tool on a live part when we do this but are wearing the appropriate PPE for the incident enrgy level. We are currently looking at it as Zog suggested- if an EEP is required then we will have a "Safety Watch' to use the DOE terminology i.e. a fully qualified electrician.


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PostPosted: Wed Oct 03, 2012 6:39 pm 
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The second person is indeed there for safety reasons. Biggest reason I can see them there is to act as a first responder. As far as being a qualified electrician the biggest issue here is what if something does happen. Is that person trained in emergency release procedures, as required in 70E? Not that there's a good definition of what that means since emergency release by definition is almost always makeshift in some ways. If that is a requirement then the person should be trained and knowledgeable to either kill power or use a technique to manhandle the person off the live equipment they are in/on. If you can do that outside the limited approach boundary, that's one thing. If you are using the escort rule to allow an unqualified person up to the restricted approach boundary, that may be quite another. Or perhaps you can have someone trained for the specific rescue tasks at hand, especially killing power, emergency release, first responder, and condiiton assessment, so that would as far as I'm concerned make them qualified to act as the second person for safety reasons.

Also thinking practically...how many times would it be useful for the second person to actually DO something useful other than stand around if they have to be there anyways? With hole watchers in confined space, they are really limited in what they can do. At least with the electrical version, you can just pretend to be Noah and make them all go to jobs two by two.

Another operation in Georgia used a lot of tank cars and had to clean them every time they returned. Hole watching became a truly burdensome problem for the tank washing crew. They found some special "man down" radios where in the event that the radio tilts on it's side, it automatically broadcasts a man down beacon to the single "hole watch" (foreman) for the whole crew. Crew members all carried the radio on their belt and didn't actually have to signal if they were in trouble. I see no practical reason that this can't be applied to electrical work because those radios as I recall were pretty sensitive to even accidentally tilting them over a little while climbing in/out of a car or leaning over.

We do have the same problem locally. Due to personnel cut backs, there is only one electrician during off shifts so they are completely dependent on mine production personnel for dealing with "not working alone" situations.

I've had more than my fair share in much smaller operations where I was the foreman/electrician/mechanic where I had to work with unqualified mechanic helpers or mechanics in electrical equipment. We did things safely but it wasn't easy sometimes especially when you are dealing with a very nervous unqualified person and there's just no other way to do the job.

At the current time I just timed it myself yesterday and it took about 25 minutes to get from the location where the ERT's are stationed to the farthest point in the mine. So obviously everyone needs first responder training. Where we currently stop is that we don't do AED training simply because we have full fledged EMT's on staff who are qualified and equipped with manual defibs. So unlike 99.9% of the first responder training out there the training we give includes everything except that we skip AED training and our focus is only on a 20-30 minute window. This means that for instance there is no need for splinting limbs, and some of the other procedures normally taught to first responders.


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PostPosted: Mon Oct 08, 2012 8:05 am 

Joined: Thu Feb 04, 2010 5:00 pm
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Location: Camp hill Pa
When , I worked as a lowly electrician helper years ago, Bethlehem Steel always sent a electrician and helper on a job. The only time I worked alone for them,was the summer when I was a lamp and battery maintenance man, and was only replacing light bulbs and watering batteries. Even the muckers worked in groups of two or more. Four minutes is a very long time for an unconscious person and can result in a minor incident becoming a fatality.


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