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 Post subject: Lockout Jackets
PostPosted: Fri Dec 12, 2008 7:18 pm 
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Joined: Mon Nov 24, 2008 7:57 pm
Posts: 7
Location: Kentucky
In NFPA 70E table 130.7(c)(9) the requirement for operating a disconnect is level 0. Since most operators are not in 100% cotton or even long sleeves year round, is anyone using a lockout jacket?


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PostPosted: Sat Dec 13, 2008 3:02 pm 
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Location: New England
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.


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PostPosted: Sun Dec 14, 2008 6:30 am 
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Joined: Mon Jun 02, 2008 11:58 am
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Location: Charlotte, NC
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.


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PostPosted: Tue Jan 27, 2009 9:38 am 
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Joined: Fri Jan 16, 2009 1:07 pm
Posts: 67
Location: North Florida
Rayon

I've noticed a discrepancy between OSHA 1910 and NFPA 70E where OSHA specifically prohibits rayon for electrical workers but 70 specifically includes it as a natural fiber to be worn under AF clothing (Table 130.7(C)(11)). Has anyone else noticed this and is there any resolution to this?

TxEngr


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PostPosted: Mon Feb 23, 2009 4:51 pm 
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Osha got rayon wrong. Sounds like a space age meltable synthetic, but it is really made of cellulose (like paper). Burns pretty good, but doesn't melt. Should be fixed in the next Osha. Until then, don't wear it.


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PostPosted: Tue Feb 24, 2009 4:57 pm 
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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.


I would like to see documentation on the above statements. NFPA may not be a legal authority but they write the standards that are adopted by states (and the Federal government) as codes and enforced via the proper Authority Having Jurisdiction.

Does OSHA require the following of NFPA 70E and perhaps a local state OSH board may???

And a simple Google search found this
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25540

I would strongly suggest researching this in your own state, since each state may be different and more stringent then OSHA, where NFPA 70E could be law. Further complicating things is your state may not require NFPA 70E by law but the client, or thier insurance company, may require you to conform to it.


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