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 Post subject: OSHA 1910.269 Who falls under?
PostPosted: Sat Nov 01, 2014 11:21 am 
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Location: Rutland, VT
I have heard terms such as if you have a utility like system, then OSHA 1910.269 applies to your system. For example: An employer may have some 34.5kV overhead conductors running for several pole sections from the primary metering point (typically the demarcation point between the utility and customer) going to several small substations consisting of an airbreak switch, fuses for transformer high side, LA's, power transformer, etc.

Would this portion of the system fall under 1910.269 regulations?

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 Post subject: Re: OSHA 1910.269 Who falls under?
PostPosted: Sun Nov 02, 2014 10:50 am 
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wbd wrote:
I have heard terms such as if you have a utility like system, then OSHA 1910.269 applies to your system. For example: An employer may have some 34.5kV overhead conductors running for several pole sections from the primary metering point (typically the demarcation point between the utility and customer) going to several small substations consisting of an airbreak switch, fuses for transformer high side, LA's, power transformer, etc.

Would this portion of the system fall under 1910.269 regulations?


This is where everyone puts on their team colors and typically goes to war. The NFPA (70/70B/70E) group and the corresponding IEEE group (C2 among others) definitely recognize the difference but there is something of a turf battle in the standards committees. Today even if you read their scopes, good luck figuring it out.

OSHA is no different. In one letter of interpretation they clearly state that cogen facilities would be considered 1910.269 but emergency backup generators do not. Annex A of 1910.269 gives some additional "help" and supports not only strict 1910.3xx and 1910.269 regulations but also supports "mixed" scenarios. For instance a lighting panel that contains breakers feeding protection circuits in a utility substation and some breakers that feed lighting and HVAC for instance would be a "mixed" scenario.

With generators then there is a clear line drawn in the sand. With other types of equipment though, it's a lot less clear. Lacking a clear guidnace when I analyzed it, I gave 3 possible options from the most restrictive definition to the most liberal one:
1. 269 includes equipment that is a continuously available power source. Once it is no longer part of the generation system, it is utilization. The generator and the power line connecting it back to the main sub is "269". Everything else is utilization.
2. Buildings that are restricted to electrical personnel only and are part of the system connecting to the generator and utility are 269. This means that the entire 23 kV distribution system at least going out to the 23 kV switch houses and associated power lines is "269". Once it hits a substation where we step down from 23 kV, it becomes utilization. The utility comes in at 230 kV and there are 23 switch-houses included in this definition.
3. Substations that only distribute power and do not have utilization/production equipment, that only consist of switchgear, are 269. Everything else is utilization. Note that this means that many lower voltage areas including some 480 V switchgear would be considered distribution.

We went with #2 by the way.

Now as to the practical impact of this decision, if you implement 70E fully as we have, purely from a work performance point of view (obviously there are design/engineering differences), the major differences are:
1. "EEWP" does not apply to "269" equipment. The practical reason for EEWP's still applies (don't work energized if you don't have to). Since EEWP applies everywhere else I think our crews are so conditioned to look for opportunities to avoid energized work that it is just a formality.
2. Pre-task safety meetings are REQUIRED for "269" areas. This seems to be a requirement in 70E too, and we were already doing this as part of unrelated safety programs so the practical implication was meaningless.
3. The "working alone" rule in 269 applies but not that the exceptions are so large in scope that it has almost no practical impact. So no "working alone" when doing say rubber-gloves only procedures that involve connecting or cutting jumpers. We don't do that (we use a hot stick) so again, no impact.
4. 269 changes the distance requirements depending on the voltage. Since we have 230 kV on the plant site, the simple "10 foot rule" for movable conductors is insufficient in the first place. The impact is relatively minor and just calls attention to the 230 kV lines for riggers.


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