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 Post subject: Does 70E require first aid, cpr, aed training?
PostPosted: Mon Feb 04, 2013 9:04 am 
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110.2(C) states "Employees kshall be regularly instructed in methods of first aid and emergecy procedures, such as approved methods of resuscitation, IF THEIR DUTIES WARRANT SUCH TRAINING"

I have encountered numerous safety folks that insist the training is required for everyone who may be exposed to an arc flash situation, I don't agree with that view.

Thanks


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PostPosted: Wed Feb 06, 2013 4:44 pm 
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1. If you have trained folks on staff that can respond quickly (OSHA 1910.269 uses 4 minute response time as a cutoff), then you can skip on the training in some cases. Even if not "required" I'd defer to the OSHA 1910.269 rule for guidance.
2. Frankly, arc flash is definitely not what I'd use as a criteria. The goal in an arc flash scenario should be to keep them alive long enough for EMT's/paramedics to get there and get them advanced medical care ASAP (within the golden hour). The big deal is not arc flash...it's shock. You've got about 4-8 minutes before permanent brain injury if someone goes into fibrillation due to shock. It doesn't take much of a shock to cause this. There is one case in MSHA jurisdiction reported at both 48 and 85 volts. At 120 V there are LOTS of examples. If they are not exposed to a shock hazard then I'd feel more comfortable with skipping the medical training. AED by the way is not "required" but only if you have them. Frankly your chances of survival without an AED are not really great. With it, it's pretty good.
3. OSHA 1910.269 applies to generation/transmission/distribution. In most industrial plants, a lot of the "high power" equipment is actually distribution and thus it falls under .269 rules, NOT Subchapter S. But generally speaking this is a grey area where you have some options. So far OSHA has only pushed .269 rules for utilities and those with cogen facilities. For everyone else, it's a grey area currently.


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PostPosted: Thu Feb 07, 2013 6:37 am 
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PaulEngr wrote:
1. If you have trained folks on staff that can respond quickly (OSHA 1910.269 uses 4 minute response time as a cutoff), then you can skip on the training in some cases. Even if not "required" I'd defer to the OSHA 1910.269 rule for guidance.
2. Frankly, arc flash is definitely not what I'd use as a criteria. The goal in an arc flash scenario should be to keep them alive long enough for EMT's/paramedics to get there and get them advanced medical care ASAP (within the golden hour). The big deal is not arc flash...it's shock. You've got about 4-8 minutes before permanent brain injury if someone goes into fibrillation due to shock. It doesn't take much of a shock to cause this. There is one case in MSHA jurisdiction reported at both 48 and 85 volts. At 120 V there are LOTS of examples. If they are not exposed to a shock hazard then I'd feel more comfortable with skipping the medical training. AED by the way is not "required" but only if you have them. Frankly your chances of survival without an AED are not really great. With it, it's pretty good.
3. OSHA 1910.269 applies to generation/transmission/distribution. In most industrial plants, a lot of the "high power" equipment is actually distribution and thus it falls under .269 rules, NOT Subchapter S. But generally speaking this is a grey area where you have some options. So far OSHA has only pushed .269 rules for utilities and those with cogen facilities. For everyone else, it's a grey area currently.


Thanks for your response, I am familiar with everything that you posted (I work for a utility) my question is simply does 70E require this training. Everyone I meet seems to think it does but, as I stated earlier I don't.

I have read many of your responses and they are always informative, looking forward to your take on this.

On a different note, I read in one of your posts a comment where I think you said that insulated tools can take the place of voltage rated gloves I would appreciate if you could expand on that topic. My local OSHA electrical specialists has always insisted that VR tools only supplement gloves they don't take the place of them.

On another note I can't remember exactly the post but you were explaining why you don't use hot sticks and VR gloves at certain voltages. I would like to hear more about that if you have the time.

Thanks again for your response


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PostPosted: Sat Feb 09, 2013 7:07 pm 
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PressQ wrote:
Thanks for your response, I am familiar with everything that you posted (I work for a utility) my question is simply does 70E require this training. Everyone I meet seems to think it does but, as I stated earlier I don't.


It doesn't say that you MUST have first aid training and neither does OSHA. If you have trained medical personnel available on say another crew that can render aid with a decent response time then you don't need first aid training. For example the site where I currently work is a major chemical plant. Due to the fact that local emergency services would be unable to even know how to respond to some of our emergencies, we have our own EMT's, ambulance, and fire truck, 24/7. Response time is 10 minutes. We give first responder training only (CPR, stop bleeding, etc.). We do not give full blown first aid because it is not warranted. At the job before that we didn't have EMT's on site. The electricians were the first responders for every shift and received first aid, CPR, and AED training. This is probably the more typical scenario for most sites that use 70E as a standard.

Quote:
Insulated tools can take the place of voltage rated gloves I would appreciate if you could expand on that topic. My local OSHA electrical specialists has always insisted that VR tools only supplement gloves they don't take the place of them.

On another note I can't remember exactly the post but you were explaining why you don't use hot sticks and VR gloves at certain voltages. I would like to hear more about that if you have the time.


Off topic but...

I did not say that insulated tools take the place of rubber gloves. Quite the opposite in fact.

NFPA 70E-2012, 130.4(C) is perhaps one of the most vague sections of the whole standard, except for the tongue twister exception in 130.2. It talks about using shock protection when crossing the restricted approach boundary, which is the same as the minimum approach distance (MAD) in OSHA regulations, NESC, and IEEE 516. All of these reference IEEE 516 as the standard for approach distances and work methods. In this section, it says to use insulation or a combination of insulation but doesn't state what work methods are acceptable. Then it gives 3 specifics where it talks about rubber gloves, insulated tools, and bare hand work methods. But nowhere does it ever state what specific work methods are acceptable and why. At best over in 130.7 it requires rubber gloves for PPE if there is a danger of shock, but this would be contradictory to say bare hands methods (130.4(C)(3)) where rubber gloves are never used. One can only conclude that this means just what it says...you must substitute rubber gloves if you don't do something else to eliminate a shock hazard.

Switching over to the far more understandable IEEE 516-2009, there are 3 kinds of insulation: principle, secondary, and supplemental. Supplemental is not important for this convesation. You can use one insulation layer which would be "principle" insulation in IEEE 516, or two. If the worker is between the two insulation systems such as working from a bucket truck while wearing gloves, the secondary insulation is the insulation between the worker and the ground and the principle insulation is between the worker and the live line. If the worker is "double insulating" such as wearing gloves and using a hot stick, then the secondary insulation is the insulation that is in contact with the energized part and the principle insulation is the insulation in contact with the worker. Both the principle and secondary insulation MUST exceed the working voltage. Why? Let's take the case of wearing gloves while working a 10 foot hot stick on a 69 kV line. The hot stickk is rated to 100 kV/foot so it is good for 1000 kV, well above the requirement. The highest available glove is 46 kV. So wearing 46 kV gloves and using a 10 foot hot stick is good for 1046 kV, right?

Let's change this up a bit. Let's say Bubba, super genius lineman, forgot to put the hot stick in the truck. So he gets out two pairs of gloves and puts one glove inside the other. So 46+46 kV = 92 kV so Bubba is safe, right?

No. The issue here is that we have two dielectrics which basically means we have a capacitive divider. Some of the voltage will appear across the principle insulation and some appears across the secondary insulation. How much? This is cimpletely unknown without testing and rating the combination. IEEE 516-2009 states specifically that BOTH the principle AND secondary insulation must be rated for the working voltage, unless someone tests and rates the combination. Since you can't control any number of variables in the interface and environmental conditions, nobody rates arbitrary combinations.

So...at 69 kV, the gloves are no longer rated for the working voltage and must come off in BOTH scenarios. The hot stick stays. And our fictional super genius Bubba is terminated before he gets himself or someone else killed.

IEEE 516-2009 lists several cases where only principle insulation is used in section 4.10. An obvious example is gloves only, or gloves and sleeves. Another less obvious example is working bare handed from a bucket truck or a helicopter. NFPA 70E 130.4(C)(3) specifically mentions this case. Still another case from IEEE 516-2009 is "live line tools" aka insulated tools. Working from a bucket truck with either gloves or a hot stick would be two insulation systems, and working without either one (bare handed) would be a single insulation system.

Finally, coming back to your question about insulated tools substituting for rubber gloves. Rubber gloves are PPE. All PPE does not reduce the likelihood of an injury. All that it ever does is to reduce the magnitude of the injury. Insulated tools on the other hand position the worker outside of the prohibited approach boundary and also usually outside of the restricted approach boundary. This approach drastically reduces the likelihood of injury rather than dealing with a reduction in magnitude of the injury. In some countries, it is not allowed to substitute PPE for other methods. This principle is called ALARP (as low as reasonably practicable). This rule would make it unacceptable to use rubber gloves as a substitute for insulated tools.


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PostPosted: Mon Feb 11, 2013 8:28 am 
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According to the National Safety Council:
If CPR / AED is used within 1 minute, recovery is > 90%
If CPR / AED is used within 5 minutes, recovery is 30% - 50%
I have our entire maintenance and facilities department trained in CPR and response to electrical injury first aid annually. We have trained EMTs on site but what is the chance that they can start CPR in less than 4 minutes. Let you conscience be your guide.


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PostPosted: Mon Feb 11, 2013 9:35 am 
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PressQ wrote:
Thanks for your response, I am familiar with everything that you posted (I work for a utility) my question is simply does 70E require this training.

Since 70E specifically excludes utilities in its scope, it does not require any training at all in your case.


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PostPosted: Mon Feb 11, 2013 12:06 pm 
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stevenal wrote:
Since 70E specifically excludes utilities in its scope, it does not require any training at all in your case.


Nice one! I also do work outside the utility industry and I have run into numerous "Experts" that insist the if you are working inside the confines of 70E you must be CPR AED trained.

BISAM wrote:
According to the National Safety Council:
If CPR / AED is used within 1 minute, recovery is > 90%
If CPR / AED is used within 5 minutes, recovery is 30% - 50%
I have our entire maintenance and facilities department trained in CPR and response to electrical injury first aid annually. We have trained EMTs on site but what is the chance that they can start CPR in less than 4 minutes. Let you conscience be your guide.


I agree 100%, like is stated prior, just checking to see if you guys thought it was MANDATORY. I have great faith in the info on this site and appreciate you guys taking the time to address this with me. Thanks


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PostPosted: Mon Feb 11, 2013 12:52 pm 
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PaulEngr wrote:
It doesn't say that you MUST have first aid training and neither does OSHA. If you have trained medical personnel available on say another crew that can render aid with a decent response time then you don't need first aid training. For example the site where I currently work is a major chemical plant. Due to the fact that local emergency services would be unable to even know how to respond to some of our emergencies, we have our own EMT's, ambulance, and fire truck, 24/7. Response time is 10 minutes. We give first responder training only (CPR, stop bleeding, etc.). We do not give full blown first aid because it is not warranted. At the job before that we didn't have EMT's on site. The electricians were the first responders for every shift and received first aid, CPR, and AED training. This is probably the more typical scenario for most sites that use 70E as a standard.



Off topic but...

I did not say that insulated tools take the place of rubber gloves. Quite the opposite in fact.

NFPA 70E-2012, 130.4(C) is perhaps one of the most vague sections of the whole standard, except for the tongue twister exception in 130.2. It talks about using shock protection when crossing the restricted approach boundary, which is the same as the minimum approach distance (MAD) in OSHA regulations, NESC, and IEEE 516. All of these reference IEEE 516 as the standard for approach distances and work methods. In this section, it says to use insulation or a combination of insulation but doesn't state what work methods are acceptable. Then it gives 3 specifics where it talks about rubber gloves, insulated tools, and bare hand work methods. But nowhere does it ever state what specific work methods are acceptable and why. At best over in 130.7 it requires rubber gloves for PPE if there is a danger of shock, but this would be contradictory to say bare hands methods (130.4(C)(3)) where rubber gloves are never used. One can only conclude that this means just what it says...you must substitute rubber gloves if you don't do something else to eliminate a shock hazard.

Switching over to the far more understandable IEEE 516-2009, there are 3 kinds of insulation: principle, secondary, and supplemental. Supplemental is not important for this convesation. You can use one insulation layer which would be "principle" insulation in IEEE 516, or two. If the worker is between the two insulation systems such as working from a bucket truck while wearing gloves, the secondary insulation is the insulation between the worker and the ground and the principle insulation is between the worker and the live line. If the worker is "double insulating" such as wearing gloves and using a hot stick, then the secondary insulation is the insulation that is in contact with the energized part and the principle insulation is the insulation in contact with the worker. Both the principle and secondary insulation MUST exceed the working voltage. Why? Let's take the case of wearing gloves while working a 10 foot hot stick on a 69 kV line. The hot stickk is rated to 100 kV/foot so it is good for 1000 kV, well above the requirement. The highest available glove is 46 kV. So wearing 46 kV gloves and using a 10 foot hot stick is good for 1046 kV, right?

Let's change this up a bit. Let's say Bubba, super genius lineman, forgot to put the hot stick in the truck. So he gets out two pairs of gloves and puts one glove inside the other. So 46+46 kV = 92 kV so Bubba is safe, right?

No. The issue here is that we have two dielectrics which basically means we have a capacitive divider. Some of the voltage will appear across the principle insulation and some appears across the secondary insulation. How much? This is cimpletely unknown without testing and rating the combination. IEEE 516-2009 states specifically that BOTH the principle AND secondary insulation must be rated for the working voltage, unless someone tests and rates the combination. Since you can't control any number of variables in the interface and environmental conditions, nobody rates arbitrary combinations.

So...at 69 kV, the gloves are no longer rated for the working voltage and must come off in BOTH scenarios. The hot stick stays. And our fictional super genius Bubba is terminated before he gets himself or someone else killed.

IEEE 516-2009 lists several cases where only principle insulation is used in section 4.10. An obvious example is gloves only, or gloves and sleeves. Another less obvious example is working bare handed from a bucket truck or a helicopter. NFPA 70E 130.4(C)(3) specifically mentions this case. Still another case from IEEE 516-2009 is "live line tools" aka insulated tools. Working from a bucket truck with either gloves or a hot stick would be two insulation systems, and working without either one (bare handed) would be a single insulation system.

Finally, coming back to your question about insulated tools substituting for rubber gloves. Rubber gloves are PPE. All PPE does not reduce the likelihood of an injury. All that it ever does is to reduce the magnitude of the injury. Insulated tools on the other hand position the worker outside of the prohibited approach boundary and also usually outside of the restricted approach boundary. This approach drastically reduces the likelihood of injury rather than dealing with a reduction in magnitude of the injury. In some countries, it is not allowed to substitute PPE for other methods. This principle is called ALARP (as low as reasonably practicable). This rule would make it unacceptable to use rubber gloves as a substitute for insulated tools.



Paul, Thank you very much for your response concerning the gloves and hot stick issue. I have been asking that question internally for years and no one could give me an answer.

Thanks again for sharing your insights


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PostPosted: Mon Feb 25, 2013 12:46 pm 
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PressQ wrote:
Paul, Thank you very much for your response concerning the gloves and hot stick issue. I have been asking that question internally for years and no one could give me an answer.


When I ask questions internally, I get a lot of 'I don't know' and 'That's a good question' answers as well. Consequently I end up researching the subject myself. I am not sure if that genuinely qualifies me as an expert, but now when our engineers have an Arc Flash question, they tend to ask me first.


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