haze10 wrote:
If the operator is not in 100% cotton, then donning the jacket would not be correct either. You are not supposed to have clothing with meltable fibers under FR clothing.
You can also take the stand that Arc Flash Art 130 does not apply. Arc Flash is stipulated for work on or near exposed live parts, or high energy switched devices. The latter is not define but most of us are taking it to be switchgear.
The disconnect is energized but had no exposed live parts. So AF regs do not apply. The NFPA table is a guide. NFPA clearly displays the preference for analysis with the table as a backup to those who don't do the analysis.
You have to remember that NFPA is not a legal authority. Industry only is required to conform with AF under the General Duty Clause. This means each employer is obligated to follow with accepted Industry norms of safety. NFPA is a guide used in lieu of an organized and published industry norm. In our site we supply uniforms that are not FR and contain polyester. A discussion with management and our Safety Director resulted in a decision that we would continue to allow operators to lockout MCC and disconnects, doors closed only, in their non FR uniform. Only electricians exposed to live work are in FR.
Maybe we need to establish this as an Industry Norm #2.
Others will disagree with this stand, but NFPA does not state contrary to this, other then the reference in the task table. Plus OSHA has stated that they will not cite a violation for an AF accident if the site was following the AF guideline. I think that OSHA would have a hard time discrediting an organization that follows all the PPE requirements for live work, but permits operators to continue lockout of deadfront devices. I would say that if you put it in your policy that it is permitted after review and examination, then that is part of your AF program, so you are in compliance.
OSHA requires emplyees that are expaosed to arc flash hazards not waer clothing with meltable fibers (Polyester. nylon, rayon, etc) and has since 1981, this is nothing new. So your employess wearing the polyester uniforms operating the MCC;s are in violation of OSHA. (Notice I didn't mention the 70E once in this thread, becuase I don't need to)
1910.269(l)(6) "Apparel."
(l)(6)(ii) The employer shall train each employee who is exposed to the hazards of flames or electric arcs in the hazards involved.
(l)(6)(iii) The employer shall ensure that each employee who is exposed to the hazards of flames or electric arcs does not wear clothing that, when exposed to flames or electric arcs, could increase the extent of injury that would be sustained by the employee.
Note: Clothing made from the following types of fabrics, either alone or in blends, is prohibited by this paragraph, unless the employer can demonstrate that the fabric has been treated to withstand the conditions that may be encountered or that the clothing is worn in such a manner as to eliminate the hazard involved: acetate, nylon, polyester, rayon.