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 Post subject: Energized work
PostPosted: Fri Aug 11, 2017 6:42 am 
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Joined: Tue Feb 17, 2009 8:38 am
Posts: 61
Location: Westminster, MD
Wouldn't it make a lot more sense if 130.2 (A) Energized Work was changed from "Energized work shall be permitted where the employer can demonstrate that de-energizing introduces additional hazards or increased risk" to something like: Energized work shall be permitted where qualified personnel can demonstrate that the work can be performed in a safe manner...?
Take the case where a Data Center wants to add a Remote Power Panel to a PDU and the 3P225A breaker can be turned off for termination of the feeder cable, and the worker can wear PPE suitable for exposure to the adjacent energized circuits.
I think the EEWP could be utilized in a case like this and it would be a much more sensible way to interact with energized systems. We do the analysis that gives the PPE requirements so it just makes sense to me that if the worker adheres to the PPE requirements that it can be performed safely.
I welcome any feedback.

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 Post subject: Re: Energized work
PostPosted: Fri Aug 11, 2017 7:49 am 
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Joined: Tue Oct 26, 2010 9:08 am
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Location: North Carolina
Two issues here. First off, it's not a matter of whether or not something can be done "safely" other words, you are suggesting simply wear PPE and this minimizes risk. This is a direct violation of the principle of ANSI Z10 hierarchy of controls. First we do whatever we can to eliminate the risk. If we can't do that, we minimize it or if we absolutely have to use signs and procedures although the latter two are known to be only modestly effective. Finally if all else fails then we go for the PPE.

PPE can and does fail. It is probably the least effective approach. In fact it is pretty obvious that even if you follow IEEE 1584/NFPA 70E/NESC to the letter as far as PPE goes and an arc flash occurs, the employee can obviously get a 1st degree burn, and has the potential for a second degree burn. This is hardly "working safely". And this doesn't even get into shock hazards which are obviously the larger concern in the case you described. So if you de-energize it all, there is zero chance of the PPE failure issue so the risk goes to zero vs. working on it while partly energized where there is a small risk.

There is obviously no such thing as a hazard-free environment EVER when working with electricity. So in the case you described if you shut off power and then test for absence of voltage, there is a very small chance that the breaker is defective and may explode. There is also a chance that even though the breaker "opened" that one phase is welded shut and stayed energized. And someone can easily brush up against energized circuits accidentally or be working with a defective meter and it turns out that for instance maybe one of the breaker contacts was welded shut (more common than you might imagine). So in general both de-energizing everything AND working energized might in fact turn out to be pretty dangerous with equipment that is not working the way you expect. So for example there is a tunnel at a plant where I used to work at with the starter and electrical controls for the ventilation fans located within the tunnel. For whatever reason this tunnel tends to fill up with H2S gas to lethal concentrations so shutting off the ventilation fans to work on them creates a hazardous atmosphere. So leaving them on and working energized does entail risk depending on the task, but so does turning them off. So for any given task on those fans there is always a very real consideration for whether it is safer to get out the respirators and work on it that way, or work on it energized.

Second, OSHA puts the onus on the employer. As a general principle employer/employee law arises out of master-servant law. The servant/employee is an idiot and it is up to the master/employer to make sure they do everything correctly and also to ensure that the workplace is reasonably free of hazards. Because the onus is on the employer it would turn the relationship on it's head to allow the employee (servant) to be responsible for anything. In a union environment where the union laws basically pit management against the workers by nature, this all makes logical sense. But in a modern work environment where it's more of a team effort, this holdover from the middle ages kind of flies in the face of how we view ourselves and our work.

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 Post subject: Re: Energized work
PostPosted: Mon Aug 14, 2017 2:55 pm 
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Joined: Tue Jul 01, 2014 8:40 am
Posts: 110
Hi Mayanees

I see what you are saying here and using the example of a data centre is fine. However this example of the datacentre would certainly fall into the other circumstamce where EEWP would apply and that is infeasible (not the same as inconvenient). I feel that using the statement "qualified personnel can demonstrate that the work can be performed in a safe manner" is to general and could lead to equipment damange and personal injury. Things can happen in the heat of the moment or in a busy plant where production can be paramount. Performing the job in a safe manner can be up for interpretation, especially when production is a factor. Obviously in a datacentre production is not a factor. What is, however could be a loss of important records or information. With completing the EEWP properly and considering both shock and arc flash hazards and the necessary PPE and other safety equipment, in a way, one is demonstrating that the job can be done in a safe manner with all of the safety equipment and procedures being put into place

Hope that this is of some help

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