A few NESC revs back, a proposal was made to include limited approach boundaries for other than qualified workers, but the proposal was rejected. See attached. I thought it was a reasonable proposal at the time but now think it might be appropriate to reconsider for the next rev cycle. The last two rev cycles have been silent on the subject.

Since many customer owned distribution systems leverage guidance from the NESC for operation of their medium voltage distribution systems, because the applicable NFPA 70E doesn't address operation of the MV distribution systems the way the NESC does, it seems like the time has come for the NESC to reconsider addressing "limited approach boundaries" and "other than qualified workers".

Any concurring or dissenting opinions?

Agreed. The OSHA 10' rule doesn't work. An "unqualified" person should be able to open the control cabinet of a grounded, dead front piece of equipment in a substation to check counter reads for example. This act will generally put them within 10' of unguarded energized conductors connecting that equipment, and porcelain surfaces might be only 8.5 ft away.

I find the nomenclature "qualified" versus "unqualified" a bit problematic. All should be qualified for the tasks they perform.

OSHA already has boundaries for "limited approach". They just never give it a specific name. The "public" is where it comes into play since 1910.269 plainly states essentially everyone must be qualified but for instance go out of their way setting up regulations for landscapers working around substations.

Furthermore, qualified vs. unqualified is not a general term, except in reference to someone whose training is not verified (the public). You are qualified by the work methods you are trained on. For instance few distribution linemen are trained in be a hands/live line work methods that are common with transmission lines, and they aren't typically trained on working inside relay cabinets which often have lots of exposed low voltage 120 V terminals and other surfaces around. So it is not practical to only group people into just 2 broad categories.