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 Post subject: Need for an attendant/qualified person
PostPosted: Thu Oct 09, 2014 6:35 am 

Joined: Thu Oct 09, 2014 6:07 am
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I am new to the forums and seeking assistance. Any help with specific code references would be most appreciated.

In reference to NFPA 70E Article 110.2 (C)

In a situation when you have only one qualified person onsite and they are having to perform live work and the next qualified person is at least 10 minutes (after the phone call), the local fire & rescue is also 10 minutes away but are not qualified or knowledgeable in electrical rescue, what would be the answer? If the person performing the work becomes part of the circuit or involved in an arc flash couldn't this become a major injury or at this point doesn’t that become a body recovery? The only answers I can see is either: a) having a qualified person onsite or b) do not perform the work live.

In reference to NFPA 70E Article 130.7(2)

If we rely on administrative controls (signs and barricades), which is near the bottom of the hierarchy of controls, to maintain a boundary while live work is taking place, as the person performing the work cannot monitor the boundary while working, are we not putting ourselves at risk without having an attendant to ensure that no one accidently comes within the boundary area? Not all of our cabinets are in low traffic areas, in fact many are on the production floor near the equipment in question.

Thank you in advance for any support you can provide.


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 Post subject: Re: Need for an attendant/qualified person
PostPosted: Thu Oct 09, 2014 7:38 am 
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Quote:
In reference to NFPA 70E Article 110.2 (C)

In a situation when you have only one qualified person onsite and they are having to perform live work and the next qualified person is at least 10 minutes (after the phone call), the local fire & rescue is also 10 minutes away but are not qualified or knowledgeable in electrical rescue, what would be the answer? If the person performing the work becomes part of the circuit or involved in an arc flash couldn't this become a major injury or at this point doesn’t that become a body recovery? The only answers I can see is either: a) having a qualified person onsite or b) do not perform the work live.


Article 110.2(C) is specifically related to Training for Emergency Response and Employee Training. It does not address the issue of the number of qualified employees needed on site to perform live work. The need for a second person would be addressed as part of the Risk Assessment Procedure that would be part of Electrical Safety Program that is contained in Article 110.1. There is an Informational Note 2 to Article 110.1(G) that discusses a second person.

Another resource for when a second person is needed may be in OSHA.

Quote:
In reference to NFPA 70E Article 130.7(2)

If we rely on administrative controls (signs and barricades), which is near the bottom of the hierarchy of controls, to maintain a boundary while live work is taking place, as the person performing the work cannot monitor the boundary while working, are we not putting ourselves at risk without having an attendant to ensure that no one accidently comes within the boundary area? Not all of our cabinets are in low traffic areas, in fact many are on the production floor near the equipment in question.


The next article down from your referenced article, Article 130.7(3), addresses Attendants where if signs and barricades do not provide sufficient
warning and protection. The need for attendant could also be contained in your Electrical Safety Program and discussed in a Job Briefing for the specific job.

Note that all my comments are based on NFPA 70E-2015.


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 Post subject: Re: Need for an attendant/qualified person
PostPosted: Fri Oct 10, 2014 11:18 am 
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MBaldwinNC wrote:
I am new to the forums and seeking assistance. Any help with specific code references would be most appreciated.

In reference to NFPA 70E Article 110.2 (C)

In a situation when you have only one qualified person onsite and they are having to perform live work and the next qualified person is at least 10 minutes (after the phone call), the local fire & rescue is also 10 minutes away but are not qualified or knowledgeable in electrical rescue, what would be the answer? If the person performing the work becomes part of the circuit or involved in an arc flash couldn't this become a major injury or at this point doesn’t that become a body recovery? The only answers I can see is either: a) having a qualified person onsite or b) do not perform the work live.


This section essentially refers to who requires training, not work practices. The emergency release section is notoriously unclear as this requirement does not really exist anywhere else in any standard. As you read 70E it becomes clear that the only procedure supported by the standard for emergency release is shutting off the power. All other emergency techniques such as "rescue hooks", using insulated gloves or tools, ropes, boards, all have various issues as to the safety of the procedure itself for the rescuer. It's all a grey area mostly because 70E is intended to set up a set of work rules where no one has to ever be in a situation of determining the best way to rescue someone in the first place. On the other hand, we all know that things happen, sometimes bad luck, but more often because some other part of 70E was ignored.

Second with respect to CPR, first aid, and AED's. This is pretty standard. As you work through the various scenarios it becomes obvious that all qualified personnel at some point are in a situation where they need to be trained for this.

As to the issue of working alone, 70E really doesn't talk about this. MSHA states that no one should be working alone "when hazards are present" and offers options such as carrying a radio but for electrical work, that's likely to be useless. In 1910.269 (distribution rules) there is also a "working alone" rule but the exception is so broad thta it becomes meaningless. In Europe certain jobs require a "man down" radio. These are expensive but essentially automatically "ping" the radio from a master radio. If the person working alone doesn't key the "I'm OK" button, it automatically alarms at the master radio.

In my company our "working alone" rule for electricians is simple. If you require an EEWP then you can't be working alone. That's all it says. There's definitely a risk for the jobs that fall under EEWP "exceptions" (troubleshooting for instance) but that's the best we could come up with, especially in light of the MSHA rule and since we are a mine.

Quote:
In reference to NFPA 70E Article 130.7(2)

If we rely on administrative controls (signs and barricades), which is near the bottom of the hierarchy of controls, to maintain a boundary while live work is taking place, as the person performing the work cannot monitor the boundary while working, are we not putting ourselves at risk without having an attendant to ensure that no one accidently comes within the boundary area? Not all of our cabinets are in low traffic areas, in fact many are on the production floor near the equipment in question.


70E is saying that you have to alert unqualified personnel to stay out of the area. This is the same requirement for a variety of other work involving hazards. "Barricade tape" or "caution tape" is pretty common such sa "wet floors", "overhead work", etc. This is acceptable under most safety standards when the purpose is to warn others that there is a potential hazard present, not when there is an impending hazard. In the latter case, an actual physical "barricade" which physically bars access is required. For instance in National Electric Code in numerous places where maintenance work is not going on, there are requirements depending on the voltage to physically prevent access to energized parts with some sort of physical barrier that would require some kind of tool (screwdriver, wrench, or even padlock key) to enter. These are intended for areas where an impending danger exists, not where one might exist.

Since the hazard at a work site is temporary in nature, temporary warning devices are accepted (cones, barricade tape, etc.). Although they might certainly be more effective, an attendant is not specifically required. Although an attendant is used interchangeably with warning devices in most cases and since the attendant is usually a pretty good "active" defense as long as they are doing their job and not chit chatting, smoking, chewing tobacco, sleeping, etc., they are much better than just simple tape.

I will also tell you from experience that sometimes the job site turns into a virtual mine field of various tape barriers and it becomes either challenging to work or workers become complicit when the tape gets ridiculous. As a case in point one week ago I was involved in startup of a 3000 HP pumping station. When it came time to check out all the various motors, we just erected barricade tape to warn of potential unepexcted movement of machinery, and a second row of barricade tape around the electrical house where we had panels open, jumpers sticking out, etc. This was much more efficient since the commissioning team did not go near the motors in the first place and because we were all qualified as far as the electrical hazards go. Otherwise we would have to play the lockout game with over two dozen locks involved. We cycled through each one in a matter of minutes rather than hours. When he came to look at the site, the general site manager noticed I was sitting on the "inside" of the red tape boundary studying a schematic for a drive and asked whether I was on the wrong side of the tape line. Since I was on the commissioning team, I was freely entering and exiting the area just as anyone else on the crew was. I explained that if he wanted to enter the electrical area I'd be happy to escort him around. He was satisfied with the answer and moved on.


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