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 Post subject: Industry Norm #1 Standing Permit Duration
PostPosted: Tue Sep 30, 2008 8:17 pm 
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Art 130 talks about a 'standing permit' for performing routine live work without a permit. They don't actually use the term 'standing permit' but in the Handbook they site an example of a qualified person trained in routine tasks like changing fuses not needing a permit for an extended period of time, for example 3 months.

I think 3 months is too short and don't really understand what they expect to happen at the end of that period. So, as a member of the governed industry I hereby declare that the industry norm for the time duration is 12 months. The renewal of the time period resets with refresher arc flash training for the personnel performing the routine task. There is a 3 month grace period. The refresher classes I have conducted have been 2 hours. First time training is usually 8 hours.

In my site we have our own employee electricians who are licensed by the State and Arc Flash Trained. We have a wide array of tasks that we consider routine. In fact, what we have done is to define the tasks that we do NOT consider routine, and only those tasks require a separate Live Work Permit. Some of the tasks that are not routine are:
All work at voltages 601V and above.
Touching hands or tools to a live bus at voltages to ground 277V and greater.
Inserting or extracting switchgear breakers.

There's a list of them.

We debated removing or extracting MCC buckets. In our site we use a lot of Allen Bradley 1/2 space factor Size 1 FVNR starters. To access the little CC fuse for the 120V control transformer you have to pull the bucket out. So we do it routinely. Plus the electricians argued that MCC exchanges have been routine to them for years. Of course now they are in PPE.

We operate 24/7/365 in a batch/semi continuous chemical process. De-energizing MCC sections is not possible except for total shutdowns. We the above approach, we fill out about 10 permits a year. If we were to get a permit for every task above 50V energized, I would estimate 1000 to 2000 permits a year over the six electricians. Tell me that wouldn't be a hardship to production.

Is there any consensus from other industry members? If you disagree, what would you modify?


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PostPosted: Wed Oct 01, 2008 5:26 am 
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I agree with your reasoning, however I dont think racking breakers requires an EEWP, but that could be debated (Did you notice the tables require HRC 4 for LV breaker racking even with the doors closed now?).

We use standing permits (Still print them out and post them at the work site) for the following:

Battery work
Transformer oil samples
IR scanning
Corona scanning
PD testing

We review them every 12 months, but had to review them early this year with the 2009 70E release.


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PostPosted: Wed Oct 01, 2008 11:52 am 
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The next step may be to debate what the industry considers 'routine'. For now I wanted to establish an industry norm that 12 months with a 3 month grace is the industry norm for standing permits. The refresher course in Arc Flash review resets the time clock.


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PostPosted: Wed Oct 29, 2008 8:25 am 
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Haze10 or Zog,

Could you elaborate on this standing permit. I could not find any mention of routine work in 70E. I do not have the handbook.

Jeff


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PostPosted: Wed Oct 29, 2008 9:58 am 
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It is in the handbook, does not say anything specific for duration, says "A long period of time" and later say "for instance, a 3 month period"


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PostPosted: Wed Oct 29, 2008 12:28 pm 
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Correct me if I am wrong but the handbook is not the offical 70E.
It is written by people other than NFPA. That sounds like a big discrepancy between 70E and the handbook on this permit.


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PostPosted: Wed Oct 29, 2008 12:45 pm 
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J Bernard wrote:
Correct me if I am wrong but the handbook is not the offical 70E.
It is written by people other than NFPA. That sounds like a big discrepancy between 70E and the handbook on this permit.


The handbook is written and published by NFPA, it is the comments from the 70E committe for further understanding of the actual standard. You are right, the notes in the handbook are not enforceable.

However I asked the 70E commitee chairman (At the time) for clarification on the standing permit and hea said they were fine, but wouldnt put a duration limit on them. For the examples I used I asked if a yearly review of them would be reasonable and he agreed that it was.


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PostPosted: Wed Oct 29, 2008 5:37 pm 
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This week I had opportunity to talk about Arc Flash with a Pharma Manufacturer and a Non Utility Power Generator. Both are using 12 months as their standing permit times.

The point of creating the Industry Norm Threads, is that we don't need NFPA to sanction our recommendations. NFPA is not in the industry of manufacturing. We are only held to their standard because we lack standardized guidelines within the industry. If enough of us post that we are using the standing permit concept for routine work, and we are doing it for 12 months intervals with 3 month grace periods - we are then creating the industry norm. The General Duty Clause is not about compliance to NFPA guidelines, its about conforming to industry norms. We are the industry.


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PostPosted: Thu Oct 30, 2008 8:16 am 
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Why are the notes in the handbook not enforceable? The same company that makes the code book, also publishes the handbook. The handbook provided interpretations and examples of the code. Those examples and intrpretations are by definition and design specifically detailing the code. They have to be enforceable because they are writen by the same body. The only way they would not be is some third party, like AcmeNFPA, decided to provide an interpretation and sell it in a handbook and NFPA never recognized it. If NFPA sells the 3rd party book on their website, they are then by action acknowledging that it is accurate.

NFPA can't have it both way.

Do you know of some court case or OSHA incident where there is evident that the handbook intrepretations are not enforceable?


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PostPosted: Thu Oct 30, 2008 9:59 am 
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2004 70E handook preface

"Explanatory comentary immediately follows the text of the standard and is set in blue type for easy identifacation. The commentary in the handbook is offered only as a guidance to the user and is therefore written in nonmandatory language. The commentary was written by the editors to help the user understand how to apply the requirements of the NFPA 70E. It is not a substitute for the actual wording of the standard or the text of the codes and standards that are incorporated by reference."


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PostPosted: Thu Oct 30, 2008 2:26 pm 
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Haze10, its in the fine print in the front of your handbook.
What are you two putting for a reason you cannot shutdown?
You know that if something happens no reason will be acceptable.


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PostPosted: Thu Oct 30, 2008 4:44 pm 
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I'm not a lawyer but I don't know if that statement makes sense. No part of of the code is enforceable. NFPA is a for profit organization, they have no governmental authority behind them. Only codes in OSHA are enforceable. So if NFPA provides a detailed explanation of their own guideline, how is it possible to say the explanation was contrary to the intent of the guideline. Since this is only enforceable by OSHA under general duty, if the industry has a common practice of taking the handbook explanations as the interpretation of the guideline - then that also becomes a norm and an acceptable practice under the general duty clause.

The Art130 guideline is full of discrepancies. In order to make it operational in the real world some modifications are necessary. OSHA says that the will not 'cite' an employer if there is an accident if the employer is following the NFPA guideline. I think if you have a Program that deomonstrates training, labelling, policy, procedures, live work permits, etc, etc... that OSHA would have a hard time trying to pick out and cite you for one deficiency where you used the handbook interpretation, and OSHA saids 'but that isn't what the code says?'


As for why you can justify live work - troubleshooting equipment (can't troubleshoot why the chiller shed won't suck in the contactor if I can't do voltage checking at the interlocks; life safety (you don't shut down a hostiple ward because you need to snap in a QO breaker for a new receptacle); continuous manufacturing (you don't shut down the refinery because you need to add a new size 1 bucket in the MCC lineup); and I would take this to include batch operations where shutting down is not feasible do to the continuous around the clock work schedule.


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PostPosted: Thu Oct 30, 2008 5:02 pm 
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I'm not a lawyer but I don't know if that statement makes sense. No part of of the code is enforceable. NFPA is a for profit organization, they have no governmental authority behind them. Only codes in OSHA are enforceable. So if NFPA provides a detailed explanation of their own guideline, how is it possible to say the explanation was contrary to the intent of the guideline. Since this is only enforceable by OSHA under general duty, if the industry has a common practice of taking the handbook explanations as the interpretation of the guideline - then that also becomes a norm and an acceptable practice under the general duty clause. I don't care what NFPA puts in this book regarding the content of the intrepretations. They are collecting money for the service so they have responsibility to provide competent content. Imagine the service garage with a sign in its window, "We are not responsible for damage we cause while attempting to repair you care" Does the presence of the sign make the statement enforceable?

The Art130 guideline is full of discrepancies. In order to make it operational in the real world some modifications are necessary. OSHA says that they will not 'cite' an employer if there is an accident if the employer is following the NFPA guideline. I think if you have a Program that deomonstrates training, labelling, policy, procedures, live work permits, etc, etc... that OSHA would have a hard time trying to pick out and cite you for one deficiency where you used the handbook interpretation, and OSHA saids 'but that isn't what the code text says?' The intrepretation is by definition, what the code text is saying.

I think we will see this put to the test sometime soon. Most businesses in the US is small businesses. They are not going to be spending, or can they afford to spend, $50K on a PE fault and AF analysis. They are going to follow the Task Table 130C9A. In 2009, your labels have to have either IE or PPE. I bet you will see Brady come out with labels that says, "PPE as per NFPA Table 130C9A". After all, NFPA put a lot of effort into updating the tables, surely they would not have done that if the code says only an analysis is permitted. Now this employer wants to follow the code and be compliant, so he sends all his electricians to get a AF certificate in a 4 hour course, creates a 20 page policy, implements an annual safety audit procedure, creates a live work permit for non-routine work, defines what is non-routine work in his policy, etc, etc. On the surface very complete. But after the AF and the electrician has received 2nd degree burns (in spite of having AF clothing as per Table 130) there is an investigation. The analysis reveals that the overcurrent device TCC shows the breaker clearing in 6 cycles and not the 2 cycles as per the Table footnote. Now tell me - do you really think this employer is going to be fined for violation of the code? God save us all if they are, for then the only thing this country will be able to manufacturer - is lawyers!.


As for why you can justify live work - troubleshooting equipment (can't troubleshoot why the chiller shed won't suck in the contactor if I can't do voltage checking at the interlocks; life safety (you don't shut down a hostiple ward because you need to snap in a QO breaker for a new receptacle); continuous manufacturing (you don't shut down the refinery because you need to add a new size 1 bucket in the MCC lineup); and I would take this to include batch operations where shutting down is not feasible do to the continuous around the clock work schedule.


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PostPosted: Fri Nov 07, 2008 6:59 am 
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Sorry for the gap I just got back from Powerlogic university. 70 e lists two reasons for working live; a greater hazard and infeasable (troubleshooting)
I work in a semi-conductor fab, we have a large electrical system where shut downs are rare. I agree that a trained person should be able to do routine work without deenergizing but I do not see where it's allowed. I know of a fab that asked OSHA if stoping production was a reason for working live, the anwser was a flat no. I feel this is unrealistic to what is and will go on. Electrical work has inherent risks. I do believe in deenergizing as much as possible. I have been challanging tradition for a long time on we do live.
I also do not think that production ( money ) is worth someones safety but we take risks every day crossing the street or climbing a ladder.


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PostPosted: Fri Nov 07, 2008 6:42 pm 
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NFPA says there are two reasons but according to the rules of grammar they list three:
1) deenergizing introduces additional hazards
2) equipment design or
3) operational limitation.

In the handbook they include '... work on circuits that form an integral part of a continuous process that would otherwise need to be completely shut down in order to permit work on one circuit or piece of equipment....' also '...an example of infeasible...might be that removing the source of voltage for a single instrument circuit would require a complete shutdown of a continuous process...'

The code goes on to talk about inconvenient versus infeasible. It is infeasible to shut down a lighting panel in a manufacturing plant that operate 24/7 because doing shutdown a process. If the manufacturing is only 24/5 and you do it live because you don't want to pay Saturday overtime, then you are acting for convenience.

NFPA uses the wrong terms when they say 'continuous process' as there are truely few processes that are absolutely continuous. What if you have six continous manufacturing processes in parallel. Do you have to shut down the one process or is it still exempt. Is the sequential stepping through multiple batch processes to form what has the appearance of a continuous throughput of product, constitute a continuous process.

The other thing we do here is to establish our own industry norm that says we are not going to shutdown any manufacturing for routine and simple tasks, like inserting an MCC bucket, but we will for the dangerous ones, like adding a MCC section to a lineup.


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