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 Post subject: Ppe
PostPosted: Wed Jun 16, 2010 12:10 pm 
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job task description: Employees were working inside an I/O removing de-energized pigtails. The cabinet was 6'x6'x24" and there were 3 120v-fused individually at a 1/2 amp. The entire cabinet was fed by a single 10kva x-former. We were 2' away from the LAB/PAB (avoid contact) and our job task never required us to come any closer.
PPE being worn at the time:hardhat, safety glasses, earplugs, ATA sleeves (FR rated 8 cal) that extend from your hands all the way up to your shoulder, sturdy leather gloves over the ATA sleeves, sturdy leather work boots and 11 calorie FR rated coveralls. Why is this not sufficient?


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PostPosted: Thu Jun 17, 2010 6:29 am 
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Barry wrote:
job task description: Employees were working inside an I/O removing de-energized pigtails. The cabinet was 6'x6'x24" and there were 3 energized circiuts @ 120v-fused individually at a 1/2 amp. The entire cabinet was fed by a single 10kva x-former. We were 2' away from the LAB/PAB (avoid contact) and our job task never required us to come any closer.
PPE being worn at the time:hardhat, safety glasses, earplugs, ATA sleeves (FR rated 8 cal) that extend from your hands all the way up to your shoulder, sturdy leather gloves over the ATA sleeves, sturdy leather work boots and 11 calorie FR rated coveralls. Why is this not sufficient?
or I guess my question should be...is this sufficient?


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PostPosted: Wed Jun 23, 2010 5:11 pm 
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The PPE seems overly conservative... Is this a trick question?


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PostPosted: Thu Jun 24, 2010 2:01 pm 
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no..we have been issued a citation and I am confused at to why.


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PostPosted: Thu Jun 24, 2010 2:06 pm 
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Barry wrote:
no..we have been issued a citation and I am confused at to why.


Who issued the citation?

What was the citation for?

Did the citation itself provide any detail?


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PostPosted: Thu Jun 24, 2010 2:13 pm 
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OSHA isued citation and we were cited under 1926.416 (a)(1)
Failure to isolate or cover live parts, even though we were two feet away


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PostPosted: Thu Jun 24, 2010 3:02 pm 
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It doesn't sound like they are using the practices in NFPA 70E as a basis for the citation. It also sounds like you are asking whether 70E could be used to contest the citation. If you are all qualified workers, stayed outside the RAB and wore both shock and flash protection in excess of that recommended by the tables, perhaps you could. I've never personally dealt with this situation, maybe someone with relevant experience could comment.

In any case this seems like an "aggressive" enforcement. Did you insult the guy's mother or something?

---

1926.416(a)(1)

No employer shall permit an employee to work in such proximity to any part of an electric power circuit that the employee could contact the electric power circuit in the course of work, unless the employee is protected against electric shock by deenergizing the circuit and grounding it or by guarding it effectively by insulation or other means.


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PostPosted: Thu Jun 24, 2010 4:40 pm 
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the compliance officer seems to think we should have been wearing rubber gloves w/leather protectors even though 70E doesn't require it for the task. Any thoughts?


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PostPosted: Thu Jun 24, 2010 5:16 pm 
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Barry wrote:
the compliance officer seems to think we should have been wearing rubber gloves w/leather protectors even though 70E doesn't require it for the task. Any thoughts?


Apparently his reasoning is that you might "contact the electric power circuit in the course of work" without having shock protection.

Exposure to 120V shock through HRC2 arc flash PPE seems like a lame citation.

You could use the NFPA task tables to argue for a reduction. 70E doesn't require rubber insulating gloves for inspections at <240V.

Hopefully this amounts to a slap on the wrist.


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PostPosted: Fri Jun 25, 2010 9:57 am 
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Citation

Wonder if the citing OSHA officer thought that the pigtails could have received induced voltage? The requirement for 70E would have been to have on arc flash protection for the hands but no shock protection would be required until you were in the Restricted Boundary or the MAD depending on the standard applied.


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PostPosted: Fri Jun 25, 2010 10:41 am 
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elihuiv wrote:
Wonder if the citing OSHA officer thought that the pigtails could have received induced voltage? The requirement for 70E would have been to have on arc flash protection for the hands but no shock protection would be required until you were in the Restricted Boundary or the MAD depending on the standard applied.


Technically I suppose that shock protection would be required for work on the pigtails until an "electrically safe" work condition was established. But since the citation was based on the uncovered 120V sources it doesn't sound like he cited for that...


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PostPosted: Sun Jun 27, 2010 2:10 pm 
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I agree with your comments. If we can be cited for not following 70E and also cited for following 70E...where do we go from here? Frustrated to say the the least.


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PostPosted: Mon Jun 28, 2010 8:48 am 
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Barry wrote:
I agree with your comments. If we can be cited for not following 70E and also cited for following 70E...where do we go from here? Frustrated to say the the least.


If you decide to contest the citation I am interested in how it turns out.

What I'm getting out of this is that it is not permissible to do work adjacent to exposed live equipment even if you follow NFPA 70E guidance on PPE. I was not aware of that...


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PostPosted: Mon Jun 28, 2010 10:05 am 
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Do you know of any MAD (minimum approach distance) in the construction standards for 300v or less? By the way we have contested the citation.


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PostPosted: Mon Jun 28, 2010 10:46 am 
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MAD for Low Voltage

OSHA MAD below 1000V is avoid contact.

They also have a "working near" term but it has no definition. That's the only thing I can see from what I understand of what you were doing. IF the pigtails were considered NOT in an electrically safe work condition, then you would need the gloves but if you could see they were disconnected and had no probabality of induced voltage. I can't understand the citation.


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PostPosted: Wed Jun 30, 2010 5:15 am 
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Where in the construction standard is a MAD even mentioned? That would be a big help. 1910 has a MAD listed but I cannot find it in 1926, which is the standard we were cited under.


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PostPosted: Thu Jul 01, 2010 5:51 am 
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1926.416(a)(1)

"No employer shall permit an employee to work in such proximity to any part of an electric power circuit..."

Good you are contesting this. Proximity is not defined in this language however NFPA 70E is often used to provide this type of detail, that was the whole point of its development. In any case, I would think this should be an easy challenge.

The "avoid contact" language for this voltage level in NFPA 70E makes sense otherwise you could not plug in a toaster because your hand would be in "such proximity" to the prongs as they make contact with the receptacle.

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