Scenario,
I am an Electrician who is troubleshooting a Motor Control Bucket in an MCC that is running a Production Process. ARC Flash PPE is on, I open the MCC bucket use my DMM to determine that the MCC Bucket disconnect is indeed open and the Voltage on the Motor Controls in this particular bucket are in a ESWC (Electrically Safe Work Condition). My [1st question is, Can I now take my PPE off and continue working in this bucket or Do I need to keep My PPE on do to the fact that the line side of the Disconnect in this bucket is hot even though it is guarded. MY 2nd question is, is this considered Hot work because the line side of the breaker is still hot therefore requiring me to fill out am Electrical Hot Work Permit?

I would say the 2nd part of your question is easier to answer: since what you are doing is diagnostic, an EEWP is not required. You should however, still do a JHA/AHA/etc. to understand the hazards, etc.

For your first question: That would be the decision of your safety group and a risk analysis.

Mike

I believe this is a great, real life question. I also believe this effects many people but is just not talked about. Because this is such a frustrating challenge...

I agree this is troubleshooting, so no permit is required until the problem is found and then needs repaired. Then a permit will be needed. The first part of the question applies either way.

Regarding PPE, I believe qualified personnel have the knowledge to perform a quick Risk Assessment before they do anything. This should be part of their training, and I believe they should be able to perform this themselves at each and every task. When that is done they will look for shock and flash hazards. I believe that if the top of the lugs are exposed (i.e. NOT covered or finger safe), then there is a shock hazard and gloves must be worn since the person will likely be closer than 12". If the lugs are finger safe, then I believe there is not a shock hazard and shock protection is not required. Similarly, if there is a risk that an incident is "likely to occur" (the magical NFPA phrase), then flash PPE must be worn. But in most cases I believe it is correct in saying if the lugs and all energized parts are not accessible and the equipment is not running (which it is not because the breaker is off), then a flash is not likely and PPE can come off. To protect the individual from discipline I believe the technician should have this CLEARLY approved by the safety group and in training, which rightly puts the burden on Safety and Engineering. Safety and Engineering SHOULD be aware of these tasks, and ensure risk assessments are being done properly. All that being said, I do believe the task can be completed safely without PPE assuming exposed parts are guarded.

This is a great example of the challenge of ensuring safety, following codes, and supporting technicians in the field. The technicians deserve this clarity - whatever the answer is. The easy answer of "you must wear all PPE all the time" is only easy on the policy maker. Working on small items with all that PPE can make things more difficult, leading to work not being accomplished as well as they could have without it, and could even start to encourage ignoring that part of the policy. Once that happens, it encourages making it OK to ignore other policies. If it is not really making things safer for the technician in the field then that is fault of the policy makers.

I don't know what the answer is to that question, but that is my belief. I wish it was made more explicit in NFPA one way or the other. I'd love to hear other responses. I don't want to be perceived as reckless, and I certainly don't want to see anyone get hurt. I just want to make systems that work.

I know of some MCC designs that have a small gap between their buckets. I saw the results of one such MCC where the electrician had removed the control power transformer fuses and placed them inside the bucket. One of the fuses decided to roll through the gap between buckets and fall onto the bus stabs of the lower starter. This definitely resulted in an arc flash event, however no one was nearby when it happened,