The million dollar question…

Can you just use the PPE Charts in the NFPA?

If I had a dollar for every time I’ve been asked that question… it seems like a fair question while discussing the need to conduct an Arc Flash Analysis. After all, the NFPA 70E states that a person “Can” use those charts to simply choose what PPE to wear while working in an electrical enclosure. OSHA makes it very clear that a worker must have and use the correct PPE. In fact, as we have seen so many in recent years they will fine employers up to a half million dollars should the employee be caught without the correct PPE.

Having been faced with the opportunity to discuss this issue with several facility Safety Directors who, for some strange reason want to argue about keeping their workers safe, I thought I would shed some very important light on this subject.

Let’s take a close look at the regulation…

NFPA 70E Section 130.7(9) says you are allowed to use the PPE chart in lieu of an Arc Flash Hazard Analysis if… and here is the big “IF”… The electrical supply circuit upstream has a minimum requirement of “a maximum of 25,000 short circuit amps, AND the clearing time of the protection device is less than 2 cycles”.

First off, without a short circuit study, there is no way to know the short circuit current upstream to every point that your workers may be exposed, and without a protective device study there is very little way to know the clearing time of the protective devices in the circuit. This information is what is calculated and studied in an “Arc Flash Analysis”.

So, in short, while the NFPA does give you another method to determine the level of PPE needed at every panel, you still need the information gathered by a typical Arc Flash Analysis to determine if you can in fact use the PPE Chart!

Dave Carpenter, Electrical Engineer

ITU President

The Occupational Safety and Health Administration’s (OSHA) Severe Violators Enforcement Program (SVEP) directive becomes effective June 18th. The agency announced in April that it was implementing the program to focus enforcement efforts on employers who willfully and repeatedly endanger workers by exposing them to serious hazards. The directive establishes procedures and enforcement actions, including increased inspections and mandatory follow-up inspections for work sites where a company has a pattern of violations at other sites. click to dowload: OSHA Instruction PDF

Region 3 News Release: 10-772-PHI (osha 10-82) June 8, 2010 Contact: Leni Fortson Phone: 215-861-5102 E-mail: uddyback-fortson.lenore@dol.gov
US Labor Department’s OSHA fines US Postal Service nearly $300,000 for exposing workers to electrical hazards at Pittsburgh, Pa., facility
PITTSBURGH, Pa. – The U.S. Department of Labor’s Occupational Safety and Health Administration has cited the U.S. Postal Service for workplace safety violations related to electrical hazards found at the Pittsburgh mail processing facility located at 1001 California Ave. Proposed penalties total $299,500. OSHA initiated an inspection in October 2009 in response to a complaint alleging the hazards. Inspectors cited the Postal Service with four willful violations carrying a penalty of $265,000; one repeat violation, with a penalty of $25,000; and two serious violations with a penalty of $9,500. “The Postal Service’s blatant disregard for workplace safety standards has left workers at this facility exposed to unnecessary risk of serious injury,” said Assistant Secretary of Labor for OSHA Dr. David Michaels. The willful violations include inadequate training for employees exposed to electrical hazards, failure to provide electrical protective equipment to protect employees from arc-flash hazards and electrical current, and failure to use appropriate safety signs, safety symbols or accident prevent tags to warn employees about electrical hazards. OSHA defines a willful violation as one committed with plain indifference to or intentional disregard for employee safety and health. The repeat violation is due to the facility’s failure to use approved covers for electrical junction boxes. A repeat citation is issued when a substantially similar violation is found at any of an employer’s facilities in federal enforcement states within three years of a previous citation. The serious violations include the use of an unapproved junction box in a wet and damp location, and a failure to provide voltage-rated tools. OSHA issues a serious citation when there is substantial probability that death or serious physical harm could result and the employer knew, or should have known, of the hazard. The Postal Service has 15 business days from receipt of its citations to comply, meet with the OSHA area director or contest the findings before the independent Occupational Safety and Health Review Commission. This inspection was conducted by OSHA’s Pittsburgh Area Office; telephone 412-395-4903. To report workplace accidents, fatalities or situations posing imminent danger to workers, call OSHA’s toll-free hotline at 800-321-6742. Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees. OSHA’s role is to assure these conditions for America’s working men and women by setting and enforcing standards, and providing training, education and assistance. For more information visit http://www.osha.gov.

Over the past few years, I have encountered people who are charged with the “Safety” programs, or who are acting as “Safety” managers in facilities. Some have led me to question their sole purpose. What I mean is while those individuals are qualified to read the NFPA,

they seem to forget their entire purpose… which is to provide a safe work environment for the workers at their facility. We see on the network news from time to time, the results of these people. From those who lost their lives in the deep min

es in Virginia, to the sad loss of life down in the Gulf on BP’s oil rig explosion. In most cases, it’s the “save money – not lives” attitude that gets these companies in trouble almost every time.

Let’s take the Electrical Safety issues for instance. Recently, a large organization was in the process of complying with OSHA’s requirements for electrical safety based on OSHA 1910.333. Those being to provide the “Proper” PPE for workers charged with repairing and maintaining electrical systems and equipment in their facilities. In the midst of the implementation of proper Arc Flash Surveys, or Arc Flash Analysis as some call it, a young lady was hired as the new safety person from a another company (after you read this you may figure out why the other company let her go). This new person was “Dead” set on stopping the entire process… I suppose to save money… and asserted that the Arc Flash Analysis was not needed. She was proud to announce that she had found a “Magic Loophole” in the NFPA requirements called on by OSHA as the “Industry Consensus” to provide a safe electrical work environment. She had found the two big “Exceptions” in NFPA 130.3, for those of you who may not have found this “Magic” way of avoiding having and arc flash analysis, here are the basic details. Exception #1- If your electrical system is so small it doesn’t have enough wallop to hurt someone, and then you don’t have to do an arc flash analysis. Exception #2- If you put on a whole bunch of PPE every time you work on something, then you don’t have to do an arc flash analysis.  How about that! Finally a way around the Arc Flash Survey debacle!

While the exception number one seems easy enough to understand, it’s the second exception that seems to get us into trouble… or at least it’s what got her into trouble. That exception actually states that if the requirements of NFPA table 130.7(C)(9) AND 130.7(C)(10) AND 130.7(C)(11) are met and followed… you don’t have to do and arc flash study, arc flash analysis, or arc flash survey ( all the same thing ). Sounds great doesn’t it… finally a way around doing the expensive arc flash surveys! Well… there is only one little thing I have to show you… The charts that this NFPA exception are talking about have some very specific things that need to be done in order to allow a company to get by without an arc flash survey. Let’s look at the first table… assuming that your electrical equipment is 600 volt class equipment as is most of the electrical equipment found in industry, You will read that you can read panel meters , do thermography, operate switches, switch breakers on and off, and other things wearing very minimal PPE. However, in every case, when you open doors or covers to expose energized electrical conductors, you must wear Category 4 PPE. The second chart tells us that we must wear the following; Arc-rated long sleeved shirt, Arc-rated long pants, Arc-rated coveralls, 40 calorie arc flash suit jacket, 40 calorie arc flash suit hood, 40 calorie arc flash suit pants, Arc-rated rain wear as needed, a hard hat, FR hard hat liner, Safety glasses or goggles, hearing protection, Arc rated gloves, and leather work shoes. The NFPA Handbook states that you still have to know the “available fault current”, “duration of the arcing fault”, and “distance between the worker and the arcing fault”. To get this data, you need and arc flash analysis.

So there you have it… you don’t need to do an arc flash analysis! Simply supply every worker with those 13 items listed there, and make sure they wear it any time they open any one of those electrical cabinets and you’re in the clear!  Seriously, I believe what the NFPA has intended by giving us this exception, is to be able to repair or work on an electrical cabinet that has not yet been surveyed or does not have the Arc Flash data label on it. You just have to put on all the PPE you can!

Dave Carpenter

(Dave is an Electrical Engineer and President of Industrial Training University, and a featured speaker, and instructor on issues regarding electrical safety and safety regulations. Dave and ITU is a leading supplier of OSHA electrical compliance services such as arc flash analysis in the United States and abroad. With clients such as General Electric, Coca-Cola, US Navy, US Army, Prairie Farms, Hospitals, Airports, Major office buildings, as well as hundreds of major brands and companies across the globe.)

Region 10 News Release: 10-820-SEA (10-179) June 21, 2010 Contact: Jeannine Lupton Phone: 206-553-7620
US Labor Department’s OSHA proposes $77,500 in fines against US Postal Service for electrical hazards at Portland, Ore., mail processing facility
SEATTLE – The U.S. Department of Labor’s Occupational Safety and Health Administration has cited the U.S. Postal Service for alleged willful and serious violations of safety standards at the Portland, Ore., Processing and Distribution Center, located at 715 N.W. Hoyt St. An OSHA inspection conducted in response to employee complaints resulted in a total of $77,500 in fines for electrical hazards and a failure to adequately lock out machines’ power sources to prevent unexpected startups. “The Postal Service disregarded basic electrical safety practices, which left workers at this facility exposed to unnecessary risk of serious injury,” said Richard S. Terrill, OSHA regional administrator in Seattle. OSHA’s inspection found workers were performing tests on live electrical equipment and doing so without adequate personal protective equipment, safety-related work practices and warning signs, as well as working on equipment that had not first been de-energized. As a result of these conditions, OSHA has issued the Postal Service one willful citation with a proposed fine of $70,000. OSHA defines a willful violation as one committed with plain indifference to or intentional disregard for employee safety and health. In addition, two serious citations with $7,500 in fines have been issued for failure to adequately lock out machines’ power sources to prevent unexpected startup during servicing and for inadequate insulation on electric cables. OSHA issues serious citations when death or serious physical harm is likely to result from hazards about which an employer knew or should have known. The Postal Service has 15 business days from receipt of its citations and proposed penalties to comply, meet with the OSHA area director or contest the findings before the independent Occupational Safety and Health Review Commission. This inspection was conducted by OSHA’s Portland Area Office; telephone 503-326-2251. To report workplace accidents, fatalities or situations posing imminent danger to workers, call OSHA’s toll-free hotline at 800-321-6742. Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees. OSHA’s role is to assure these conditions for America’s working men and women by setting and enforcing standards, and providing training, education and assistance. For more information, visit http://www.osha.gov.

An Ohio contractor was electrocuted Thursday morning at a Hazle Township plastics plant, according to state police.

Steven A. Koffel, 47, of Canton, Ohio, was fatally shocked when his hand touched a live wire in a control panel while repairing an air compressor inside Pretium Printing, state police at Hazleton said Monday. Koffel, a service technician employed by Gardner Denver, was called to Pretium Printing in the Humboldt Industrial Park to repair machinery, plant manager Jack Brown said.

Hazle Township Fire Chief Scott Kostician said the department was called in for assistance around 1:30 p.m. Thursday. The department set up a landing zone for a medical helicopter but Koffel was taken to Hazleton General Hospital by ambulance. He was pronounced dead at the hospital.