The 2015 edition of Art 130 no longer discusses 'routine work' and the concept of a standing work permit.

I have five state licensed electricians performing maintenance, with each one using his voltmeter several times a day to perform troubleshooting. Historically, we would have a safety training session annual to outline the safety requirements to perform live work under our standing work permit. Routine work included: troubleshooting equipment which could only be done while energized, checking voltages inside panels, changes fuses, and a few other minor tasks that were considered low risk.

It seems now Art 130, is requiring a Live Work Permit for every task, even those that are routine. I didn't see reference in 2015 where they retracted the routine work exception, but rather just glazed over it like it never existed. Does it still exist? How are others dealing with it where you have an electrically intense work environment like a chem plant or refinery?

I believe that a state licensed electrician should have some ability to work independently an have nonrestrictive access to some task. The analogy to the NFPA is that your driving license is not sufficient for you to operate your auto from point A to point B, without first calling a policeman to verify your route and provide his approval, in writing, for you to proceed. I'm not advocating splicing 13.8KV cables live, but a licensed electrician should be able to use his voltmeter whenever and where ever the need arises without requiring a permit for routine low voltage troubleshooting.

What say you?

130.2(B)(3) Exemptions to Work Permit.

(1) Testing, troubleshooting, and voltage measuring

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Does this mean that the 'Standing Work Permit' is now eliminated?

Two different issues at hand here. 70E is recommending/requiring some kind of job hazard analysis/discussion to take place for essentially every task at this point. That has been the approach under 1910.269 for utilities for years now and is becoming common everywhere. It's the same thing we've always been doing whether it's called a tailgate discussion, morning meeting, etc., so practically nothing changes unless you want to throw bureacracy at it. Previously if you had routine work (ie, had a written procedure) no job review was required and now at least some verbal discussion is required.

This is DIFFERENT from an EEWP which is required for doing energized work with a number of obvious exceptions. The idea here is to require a permitting process to slow down/eliminate live work except when absolutely necessary to do so. One such obvious exception is testing/troubleshooting because you can't really test a voltage with the power off. But the process is intended for instance to eliminate drilling into and terminating onto live busses as an example rather than powering it down first since these kinds of activities frequently result in serious accidents. This is where the "standing EEWP" would come into play such as if you allow instrumentation that is frequently hard wired instead of plugged in to be de-terminated while energized. And "standing EEWP's" should only be used anyways where there is a fairly high level review process examining the hazards and then only if it falls into one of the exceptions. A typical example would be that shutting off power to older instrumentation where even fused terminal blocks are not available would entail operating a breaker where frankly, there is an arc flash hazard (however low) while lifting the wire is a much lower arcing hazard.

I'm running a chemical plant with a half dozen State licensed electricians. We would train annually on risks associated, and safe methods, for things like changing fuses in an Allen Bradley motor control center, inserting or removing MCC buckets into a live MCC, turning on or off a switchgear breaker, and other minor maintenance that they have performed on, or around, live parts for the last 30 years. We would do this under the Routine Standing Work Permit, because to these electricians, that was something they did daily and as such was routine. The risks and the safe approach to the work was discussed on an annual basis, and these are highly skilled in-house electricians. Do we now hire another person to do daily risk assessment, which will just be repeated over and over again as the risk remains the same, and also hire another electrician to deal with the loss productivity.

The concept of the routine work permit solved the issue of dealing with repetitive work, where the risk and the procedure remain the same. Is that now taken away. Are we really expected to shutdown a 20 section MCC line up so we can change a blown fuse in Size 1 starter bucket? Is there no provision to accommodate the large petro-chemical and pharmaceutical type industrial manufacturer for routine work without a daily hand holding session. I'm not trying to be Cavalier, but I get some snide looks when I try to explain the safe way to change a fuse in a MCC bucket from a 20 year vetern electrician, who holds a Master's License in three States.

First, you are reading WAY more into this than there actually is.

As far as the initial assessment stuff, like the annual meeting you are describing. That's a good start. I'd suggest you need to broaden the net though and include people that are experts in their own right on different subjects, such as a safety person or production personnel. But it's one part of it. You need to do a risk assessment. That's more than just an arc flash hazard assessment. A risk assessment has been an OSHA requirement for all tasks for YEARS, under 1910.132. The only thing that changed here is that prior to the 2015 edition, a risk assessment was implied by the definition of an arc flash hazard (a hazard exists provided that you are doing something to interact with the equipment in a way that could cause an arc). All safety standards these days require risk assessments. 70E was just making it more explicit in the 2015 edition and becoming homogenized with all other standards in this regard. Hence the change in terminology from arc flash HAZARD assessment (injury severity only) to arc flash RISK assessment (injury severity, and likelihood of injury).

There are several risk assessment procedures out there and they do NOT require a safety expert to do them. And furthermore, the whole point of the EEWP is to administratively make sure that only those activities which absolutely must be done while energized are done while energized. Again, this is different from a job briefing. A job briefing is a component of the EEWP procedure but is not the only thing required. The risk assessment for the EEWP is more complex and should involve more people. Part of the idea here is that if the plant manager/production manager signs off on a document authorizing someone to do something highly risky where they could potentially be held personally liable later, you'd be amazed to find out just how important it really is to keep equipment running instead of shutting it down so the work can be done safely. Even hospitals have been finding that when weighing the risk of a fatality against the inconvenience of shutting off power, the inconvenience doesn't seem so bad after all.



Do you actually have a quick "what are we doing today" meeting at shift change every day, or perhaps more than once a day? It requires all of about 2 minutes of discussion about the hazards involved, and 70E does not require you to go over the same thing time and time again. Mix it up. Google "tool box talks". There is lots of material out there. Involve the guys doing the work. This is pretty mundane stuff in almost all large petro-chemical, utility, pharmaceutical, etc., plants. There's a corny video out there called "Take Two" that describes the same sort of thing. You're already talking about the job and what needs to happen, any coordination that needs to happen, etc., Just take a couple extra minutes to first do a quick walk down of the area before beginning the job to look for anything unexpected or changed or any obvious issues that might exist. At roughly 5-8 jobs per day that adds up to somewhere around 10-15 minutes PER man per day. This is hardly onerous and does not require staffing up.

The reason for this is simple. Once you get past "green horn" injuries and things that are preventable ahead of time, the vast majority of injuries to seasoned professionals like you describe happen because they do the same things so often that they stop looking for things that have changed in their environment and proceed to do the job the same way they've done it countless times before. Then when something actually does legitimately change in the environment, they get caught unaware and bad things happen. It's human nature. We naturally tend to go on "auto-pilot" and do things routinely, saving the brain cells for the really hard/unexpected stuff.

That is the entire reason and point of having a job BRIEFING. That is worlds different from a risk assessment.

There is another concept that is becoming popular in the chemical industry lately called a JHA/JSA or some such. It's basically a risk assessment that is usually done by the crew/person doing the work that is generated on the spot. It's not formal or truly in depth but is supposed to be more effective than the job briefing. I'll reserve judgement because so far it seems to be a lot of bureaucracy with no proven improvement.

None of this is PSM. HAZOP reviews that you typically see in chemical plants are another whole level of process review used during major changes at a site, and the focus is on processes, not necessarily at a task level. This is the kind of review that should be happening in the initial and 5 year arc flash study review (the risk assessment), not every day. 70E itself only lists about 25 tasks and I doubt all those tasks apply to every plant site. Another dozen tasks are listed in 1910.269. The review should be done once initially and then periodically reviewed to validate the original study and 70E recommends every 5 years. This is not daily or per job/task. The output should be the procedures used, not generating procedures from scratch every time unless the task has never been done before.