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 Post subject: Exemptions to Energized Electrical Work Permit
PostPosted: Wed Oct 10, 2012 8:26 am 

Joined: Thu Jul 14, 2011 1:16 pm
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Hello all, my first post, and would like to thank all who take the time to reply and share valuable information. Great forum!

I am struggling with many of our facilities that claim that checking for phase rotation of a motor or phasing across a tie breaker is the same as performing tasks such as testing, troubleshooting, and voltage measurements that are all permitted to be performed without and energized electrical work permit.

Since there is no voltage level associated with these tasks, is it correct to assume that phasing across a medium voltage breaker with hot sticks, or clipping a roto-meter on a 480V MCC breaker is an exemption to the EEWP? The argument is that if we do not require an EEWP for voltage testing, then phasing is essentially the same. I can almost go with that, but was looking for some opinions here to ground myself. The more I think about it the more turned around I get.

Thanks all.


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PostPosted: Wed Oct 10, 2012 4:51 pm 
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The "exception" for testing is pretty straight forward. You can't do voltage/current measurements on the equipment if it's not energized. So it makes no sense to try to require filing a permit asking for an exception to the rule of doing work de-energized if it is always going to be approved anyways based on the "infeasible" execption.

So...EEWP not required for doing voltage and current testing.

It also avoids another silly situation...electrically safe work requires testing for absence of voltage as the last step. It would be silly to then require an EEWP in order to establish that working condition. This is a case where the equipment is actually de-energized but is considered energized (until tested).


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PostPosted: Thu Oct 11, 2012 5:33 am 

Joined: Tue Oct 09, 2012 4:55 am
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Location: Michigan
We don't require the permit, but we do require full PPE as if it were energized. Does that seem reasonable and compliant to you?


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PostPosted: Thu Oct 11, 2012 11:22 am 

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EHSS wrote:
We don't require the permit, but we do require full PPE as if it were energized. Does that seem reasonable and compliant to you?


Thanks for the reply. Yes, this does make perfect sense to me, and as Paul points out above it will dilute the purpose of the EEWP if it were to be required and be approved each time without thinking about it. We would require full PPE to do this task, however there are some that feel that using hot sticks to phase higher voltages is increasingly risky due to the fact in some cases, you need to lift the shutters and poke the sticks multiple times.

I can see the point of the hot sticks increasing the risk that something might happen, but if we go down that path, then it will end up confusing something that I thought was pretty straight forward regarding the requirements of the EEWP.

Thanks again to both you and Paul for the replies.


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PostPosted: Thu Nov 08, 2012 10:54 pm 

Joined: Wed Sep 05, 2012 4:42 am
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Location: Plymouth
Personal protective equipment is really important when you need to deal with hot sticks. I guess the permit isn’t required, but for higher voltages, there must surely be an additional safety consideration to remember.


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PostPosted: Sat Nov 10, 2012 6:06 am 
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I look at the EEWP as an administrative protection (google "ALARP" for the concept). It forces you to go through having a discussion and get more than one person involved in making a decision to work on something energized when it may not be necessary to do so. If you can't justify what you are doing based on the 2 exceptions (the 50 volt rule is kind of meaningless since that's also an exemption), you shouldn't be doing it. Also there is an OSHA letter of interpretation that makes it very clear that the "continuous process" example is being misread. That exemption is simply an extension of the greater hazard rule.

When considering this though there are plenty of good examples of where an EEWP is required and may in fact be a good idea. There is a tunnel where I work that has ventilation fans. If you shut off the ventilation, it fills with H2S and you rapidly approach the point where SCBA's are the only way to access the area. If the work has to be done on say the lighting circuit then the arc flash and shock hazards are pretty minimal but cutting control power and going in with SCBA's opens up a lot more things that can go wrong.

Another classic example is working on a 120 V PLC control circuit which is individually fused or has a breaker. The arc flash hazard to begin with is almost always <1.2 cal/cm^2. The shock hazard is not considered very great if using insulated tools or gloves. Nearby circuits are not a hazard. With a large enough 120 V transformer powering it, opening the main breaker that powers the whole system may carry a significant arc flash hazard though the likelihood of a molded case breaker having an arcing fault is pretty small. In this case though the important thing to realize is that there is a greater risk in operating the main breaker and powering down the panel than doing the work.

Another classic example is working within the limited approach boundary but outside the restricted approach boundary. This is something that commonly occurs in industrial machinery panels where mixed voltages and "open" (IP20 style) starters or drives are present. Frequently there is exposed wiring nearby but not at the "work site" part of the panel. This is a classic situation where 70E says that no PPE is required (outside the restricted approach boundary) and essentially the only danger is to unqualified personnel (barricades required). It also invokes an EEWP. In this case again since the hazards present are almost a nonce and there is a greater risk in operating the disconnect for the whole panel, an EEWP should be approved because it's really a situation where the wording of the Code leads to unexpected conclusions.


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PostPosted: Mon Nov 12, 2012 9:17 am 
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PaulEngr wrote:
I look at the EEWP as an administrative protection (google "ALARP" for the concept). It forces you to go through having a discussion and get more than one person involved in making a decision to work on something energized when it may not be necessary to do so.

Exactly! This is what I hear all the time. It forces the discussion so we can get away from "but that's the way we've always done it" Now we have to think about it a bit more and often there is another alternative - but sometimes energized work is our only option - at least then we have explored the other options.


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PostPosted: Wed Nov 14, 2012 9:39 am 
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Location: Illinois
The EEWP is required any time the equipment is energized and you have the cabinet door open.

However We have connected our Fluke 435 Power Quality Analyzer in the starter cabinet (logging mode) while the equipment is shut off . (Fluke 435 has a built in Rechargable Battery).

Closed the Cabinet and turned on the starter for a brief period of time with the Fluke 435 connected
and recording.

Turned off the Starter removed the Fluke 435 and read the loged: voltage, Current, Harmonics, Phasor diagram, etc.


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PostPosted: Wed Nov 14, 2012 6:58 pm 
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rickbba2 wrote:
The EEWP is required any time the equipment is energized and you have the cabinet door open.


Not true. Not required for diagnostic work such as the example you described, nor for visual observation, nor for energizing/de-energizing for LOTO purposes. Those are just some basic examples. This is pretty well documented in 70E. It would quickly erode and destroy the purpose of an EEWP if I had to sign off on them every time an electrician was troubleshooting. After a while it would just become routine and the purpose would break down.


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PostPosted: Fri Nov 30, 2012 12:48 pm 
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Glad I do not work at your place rickbba2 I would have a nervious breakdown. What kind of equipment I suppose you are speaking of?


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PostPosted: Thu Mar 14, 2013 9:48 am 

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This is where companies can impose greater requirements than that of the NFPA 70E or OSHA. We have imposed the rule that any DIRECT or INDIRECT work ON or NEAR electrical that IS or MAY be energized requires the electrical work permit.

I've had the most kickback from persons on the questions of exceptions and the logical response back is as follows.

The fundamental purpose of the EWP is to challenge the qualified worker to perform the work in the safest fashion possible. And since in those cases above still requires PPE, if is an assurance to the Employer the qualified employee has properly recognized the PPE requirements based upon the potential hazards. Whereas in the absence of the EWP, there is no assurance that the hazards have been recognized or minimized, including the proper use of PPE. Additionally this instills a culture and repeat behavior without question. Otherwise there is less confidence that the employee has or is fully compliant with the program.

The only relaxation that is given in the work permit process is the required approvals for the activity.

I think this over conservatism is also prudent given the limited maturity of the industry related to the OSHA expectations of electrical safety. It is not the same old same old practice.


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