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 Post subject: Article 130.2 Electrically Safe Work Conditions
PostPosted: Tue Apr 10, 2018 5:52 am 
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Location: Rutland, VT
In reading Article 130.2, it appears that an Energized Work Permit may be required for the following work:

On an ATS, the test button is to be used to test the function of the ATS. However, there is no record of maintenance being performed on this ATS. Therefore, it appears that 130.2(A)(4)(2), "The equipment is properly maintained", is not satisfied so an energized work permit is required as per 130.2(B)(1). This seems excessive for a task such as pushing the test button on an ATS.

I may be overthinking it but it seems the same path could be used to state that resetting overloads with the push button on a MCC cubicle needs an energized work permit as the state of maintenance is most likely unknown. And it looks like this does not meet the exemptions to a work permit as stated in 130.2(B)(3).


Barry Donovan, P.E.

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 Post subject: Re: Article 130.2 Electrically Safe Work Conditions
PostPosted: Fri Apr 13, 2018 3:39 am 
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Close. Are you confusing "normal operation" with maintenance?

OSHA is somewhat confused on this issue, too because they have four categories: maintenance, minor servicing, operation, and construction and alteration. None of them are explicitly defined, but construction in particular is hard to separate from maintenance.

But in both resetting overloads and pushing a test button, these are controls and you are operating controls. It is no different than "operating a meter with a meter stick". No lockout would be required of either one (another tell tale sign that we've gone from operation to maintenance). It should even apply to "normal operation" of equipment which would include opening and closing disconnects, breakers, contactors, etc. OSHA and 70E both state that an overload can be reset when the condition is overload without maintenance activities. Basically all equipment can be considered one of three categories: out of service (not maintained), abnormal condition (requires maintenance), and normal operation (in service, not waiting on maintenance and not locked out). OSHA further allows for minor servicing and adjustments which do not require a lockout and are treated essentially as a form of operation. This would obviously include setting checks and changes to relays.

The exception here is when we have a trip, particularly from an unknown condition. Some equipment, such as Type 1 starter assemblies (using IEC terminology) and all molded case and insulated case breakers (as per NEMA AB-4 referenced by all manufacturers), and as per OSHA and 70E rules for recovering from a trip all require discovering the source of the trip AND doing a visual inspection on the equipment, particularly breakers, before resetting the trip and restarting the equipment. IEC Type 2 starters don't require the visual inspection before resetting as an example. The act of resetting and typically doing functional testing (see if it will run) are all maintenance activities. Up until that point the equipment is operating ABNORMALLY so "normal" operation doesn't apply.

So I think you are going WAY too far because you are defining everything that a maintenance crew might do as "maintenance" when in fact a lot of operation such as opening disconnects that are opening normally in the course of performing a LOTO even if it is for the purpose of doing maintenance, as well as online PM's, checking and adjusting settings, online lubrication, and so forth are not maintenance activities in the way that OSHA and 70E define them. Where we need to focus in on is whether or not the equipment is in an abnormal operational state such as either it hasn't been maintained or it just faulted or maybe even right after installation. In that state the condition is unknown so we err to the conservative side of things until we do the simple inspections to reveal condition.

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