Subcontractor Electrical Safety NFPA 70 E Stand a

Subcontractor Electrical Safety & NFPA 70 E Stand a r d for Electr i Requi cal Safety rem Emplo yee W ents for orkpl 2004 E aces dition Electrical Safety for Subcontractors and Subcontract Technical Representatives EFCOG Electrical Safety Task Group Module 8

Objective § To provide understanding of electrical safety § § requirements for the Subcontract Technical Representative and the Subcontractor To facilitate communications of requirements to the subcontractor To serve as an aid in assessing a subcontractors performance October 16, 2007 EFCOG Electrical Safety Task Group 2

NFPA 70 E, Standard for Electrical Safety in the Workplace § Why is NFPA 70 E a subcontractor requirement? – DOE Order 440. 1 A, Worker Protection Management For DOE And Contractor Employees Requires Implementation – OSHA General Duty Clause requires “workplace free from recognized hazards”. OSHA has cited General Duty Clause for failure to comply with 70 E – 10 CFR 851 requires compliance with NFPA 70 E – NFPA 70 E, Section 110. 4 Multiemployer Relationship • (A) Safe Work Practices. On multiemployer worksites (in all industry sectors), more than one employer may be responsible for hazardous conditions that violate safe work practices. • (B) Outside Personnel (Contractors, etc. )… the on-site October 16, 2007 employer and the outside employer(s) shall inform each other of existing hazards, personal protective equipment/clothing requirements, safe work practice procedures… applicable to EFCOG Electrical Safety Task Group the work to be performed. 3

Can OSHA Cite NFPA 70 E? § OSHA regulations are often described as the “Shall” and NFPA 70 E as the “How” for electrical safety in the workplace. § OSHA commonly cites the General Duty Clause and uses NFPA 70 E as evidence of compliance § From an OSHA Letter of Interpretation dated July 23, 2003: “Industry consensus standards, such as NFPA 70 E, can be used by employers as guides to making the assessments and equipment selections required by the standard. Similarly, in OSHA enforcement actions, they can be used as evidence of whether the employer acted reasonably. ” October 16, 2007 EFCOG Electrical Safety Task Group 4

NFPA 70 E, Standard for Electrical Safety in the Workplace § How does NFPA 70 E differ from the National Electric Code (NEC)? – NFPA 70 E is intended to provide work practices to minimize the worker from electrical energy when using or working on or near electrical equipment and conductors – The NEC is intended to provide a safe electrical installation so that equipment is safe when operating normally October 16, 2007 EFCOG Electrical Safety Task Group 5

NFPA 70 E, Standard for Electrical Safety in the Workplace § What work practices does NFPA 70 E require? – Chapter 1, Safety-Related Work Practices • Article 100, Definitions • Article 110, General Requirements for electrical Safety-Related Work Practices • Article 120, Establishing an Electrically Safe Work Condition • Article 130, Working On or Near Live Parts October 16, 2007 EFCOG Electrical Safety Task Group 6

NFPA 70 E Training Requirements Employees shall be trained to understand specific hazards associated with electrical energy – Trained in safety related work practices and procedural requirements for specific job or task – Trained to understand relationship between electrical hazards and possible injury – Training shall be classroom or on-the-job type or combination – Employees working on or near energized conductors shall be trained in release of victims from contact EFCOG Electrical Safety Task Group October 16, 2007 7

NFPA 70 E Qualified Person A qualified person shall be trained and knowledgeable of construction and operation of equipment or work method and trained to recognize and avoid hazard (110. 6(D)(1)) – Familiar with precautionary techniques, personal protective equipment including arc flash, insulating and shielding materials, insulated tools and test equipment – Distinguish exposed energized parts from other parts – Determine nominal voltage of live parts – Understand safe approach distances in Table 130. 2 C October 16, 2007 EFCOG Electrical Safety Task Group 8 – Determine personal protective equipment for task

NFPA 70 E Job Briefing Before starting each job, employee in charge shall conduct a job briefing with employees involved. (110. 7 G) – – – Identify hazards Identify procedures to be followed Special precautions Energy source controls Personal protective equipment October 16, 2007 EFCOG Electrical Safety Task Group 9

Electrical Safe Work Condition Live parts to which an employee might be exposed shall be put into an electrically safe work condition before an employee works on of near them unless the employee can demonstrate work on energized components can be justified (110. 8 A) – Deenergizing introduces additional or increased hazards (Examples include interruption of life support equipment, deactivation of emergency alarm systems, shutdown of hazardous location ventilation equipment) – Deenergizing is infeasible due to equipment design or operational limitations. (Examples October 16, 2007 EFCOG Electrical Safety Task Group include start-up or troubleshooting diagnostics 10

Electrically Safe Work Condition § Infeasible – adj : not capable of being carried out or put into practice § Inconvenient – adj : not suited to your comfort, purpose or needs § “Financial considerations are not an adequate reason to work on or near energized circuits” (Std. 1584 -2002 IEEE) October 16, 2007 EFCOG Electrical Safety Task Group 11

Achieving an Electrically Safe Work Condition An Electrically Safe Condition shall be achieved by completing all the following § Determine all sources of electrical supply (Drawings, diagrams) § Open disconnecting device for each source § Visually verify all blades of disconnecting devices are fully open or drawout-type breakers are withdrawn § Apply lockout/tagout devices in accordance with policy § Test each phase conductor using adequately rated voltage detector § Ground phase conductors where possibility exists October 16, 2007 EFCOG Electrical Safety Task Group 12 for induced or stored energy

Achieving an Electrically Safe Work Condition Electrical conductors and circuit parts that have been disconnected but not under lockout/tagout, tested and grounded (where appropriate) shall not be considered to be in an electrically safe work condition – Safe work practices shall be used in this case identical to working on or near exposed live parts – Applies regardless of whether equipment is temporary, permanent or portable October 16, 2007 EFCOG Electrical Safety Task Group 13

Energized Electrical Work If live parts are not placed in an electrically safe work condition, work shall be considered energized electrical work – A written Energized Electrical Work Permit shall be required where live parts are not placed in an electrically safe work condition. – Exemption: work such as testing, troubleshooting, voltage measurement shall be permitted to be performed without an energized electrical work permit provided appropriate safe work practices and PPE are provided and used. October 16, 2007 EFCOG Electrical Safety Task Group 14

Elements of Energized Electrical Work Permit § Permit shall include the following items – Description of circuit and equipment to be worked – Justification for performing work in energized condition – Description of safe work practices – Results of shock hazard and flash hazard analysis – Shock protection boundary – Personal protective equipment – Means to restrict access to unqualified persons – Evidence of job briefing – Work approval signatures October 16, 2007 EFCOG Electrical Safety Task Group 15

Working on or Near Exposed Electrical Conductors or Circuit Parts Perform electrical hazard analysis if live parts (50 volts or more) can not be placed in an electrically safe work condition § Shock Hazard Analysis (Determine limited, restricted and prohibited approach boundaries and shock PPE) § Flash Hazard Analysis (Determine arc flash boundary and PPE for personnel within this boundary) § Use Energized Electrical Work Permit October 16, 2007 EFCOG Electrical Safety Task Group 16

Shock and Arc Boundaries October 16, 2007 EFCOG Electrical Safety Task Group 17

Limits of Approach – Limited Approach Boundary Prohibite d Restricted Limited Energize d panel (301 V to 750 V) 3 feet 6 inches for 480 V October 16, 2007 EFCOG Electrical Safety Task Group The closest distance an “unqualified” person can approach, unless escorted by a “qualified” person. 18

Limits of Approach – Restricted Approach Boundary Prohibite d Energize d part October 16, 2007 Restricted 12 inches for 480 volts The closest distance to exposed live parts a “qualified” person can approach w/out proper PPE and tools. To cross this boundary, the qualified person must wear PPE and EFCOG Electrical Safety Task Group have proper tools. 19

Limits of Approach - Shock Prohibite d Energize d part 1 inch for 480 volts October 16, 2007 Crossed ONLY by a “qualified” person, which when crossed by body part or object, requires the same protection as if direct contact was made with the live part. EFCOG Electrical Safety Task Group 20

Approach Boundaries for Shock Protection October 16, 2007 EFCOG Electrical Safety Task Group 21

Limits of Approach – Flash Protection Boundary Flash Protecti on Prohibite Restricted Limited Bounda d ry Energize d part Calculated distance October 16, 2007 EFCOG Electrical Safety Task Group • The distance from exposed live parts within which a person could receive a second degree burn if an arc flash were to occur. • Arc flash PPE is required within this boundary. • Note: Distance may be less than or greater than the shock protection boundaries. 22

Flash Hazard Analysis § An arc flash hazard analysis shall be done to § § § protect personnel from injury by arc flash exposure This analysis determines the flash protection boundary and potential thermal exposure to personnel working on or near exposure live parts within the boundary Personal protective clothing and protective equipment for workers inside the flash protection boundary are then selected to mitigate potential thermal exposure Equipment may be labeled with the results of 23 EFCOG Electrical Safety Task Group the arc flash hazard analysis and shock October 16, 2007

Typical Equipment Label October 16, 2007 EFCOG Electrical Safety Task Group 24

Personal Protective Clothing October 16, 2007 EFCOG Electrical Safety Task Group 25

Examples of PPE Hazard Risk Category 0 October 16, 2007 Hazard Risk Category 1 Hazard Risk Category 2 Hazard Risk Category 3 EFCOG Electrical Safety Task Group Hazard Risk Category 4 26

Alternative to Flash Hazard Analysis § The PPE requirements of NFPA 70 E, 130. 7(C)(9)(a) shall be permitted in lieu of the detailed flash hazard analysis – Use Table 130. 7(C)(9)(a) to determine hazard/risk category for task – Ensure the short circuit capacities and fault clearing time for task listed in the text and notes are not exceeded – Use Table 130. 7(C)(10) to determine the PPE for the task October 16, 2007 EFCOG Electrical Safety Task Group 27

Table 130. 7(C)(9)(A) October 16, 2007 EFCOG Electrical Safety Task Group 28

Table 130. 7(C)(10) October 16, 2007 EFCOG Electrical Safety Task Group 29

Example Using Alternative Method Work task involves testing for absence of voltage inside a 480 volt MCC cubicle to establish a lockout point. – – What is the Hazard/Risk Category? What notes apply to the task? Are V-rated glove and tools required? What PPE is required for the Qualified Worker? October 16, 2007 EFCOG Electrical Safety Task Group 30

Example Using Alternative Method Answer § Refer to “ 600 V Class Motor Control Centers” section in Table 130. 7(C)(9)(A) and choose task for “work on energized parts, including voltage testing. Hazard/Risk Category is 2* § Notes 2 and 3 apply to this task. Confirm with Engineering that short circuit current of 65 k. A and 0. 03 fault clearing time not exceeded. If short circuit current < 10 k. A, hazard/risk category can be reduced by one number § V-rated gloves and tools are required October 16, 2007 EFCOG Electrical Safety Task Group 31

Example Using Alternative Method Using Table 130. 7(C)(10), identify PPE requirement listed under Category 2 – – – T-shirt Long sleeve FR shirt and pants or coveralls Hard hat Safety glasses or safety goggles Flash suit hood and hearing protection (2* footnote to Table 130. 7(C)(9)(A) requires hood for this task) – Leather gloves over voltage rated gloves – Leather work shoes October 16, 2007 EFCOG Electrical Safety Task Group 32

Personal Protective Equipment Care § Clothing shall be inspected prior to use by user. – Clothing or flash suits that are damaged shall not be used. – Clothing that become contaminated with grease, oil or flammable liquids or combustible materials shall not be used. § V-rated gloves shall be inspected prior to use by user. Shall be tested and certified before first use and every 6 months thereafter. October 16, 2007 EFCOG Electrical Safety Task Group 33

Inspecting Voltage Rated Gloves in Field • Visual Inspection • Inflation • Reverse glove and repeat • Store in appropriate glove bag October 16, 2007 EFCOG Electrical Safety Task Group 34

Precautions Working on or Near Live Parts § Don’t reach blindly into areas that might § § § contain exposed live parts Provide illumination in spaces to enable safe work Conductive articles of jewelry and clothing such as watchbands, bracelets, necklaces shall not be worn Use only insulated tools rated for voltage when working inside the Limited Approach Boundary of exposed live parts where contact might EFCOG be made Electrical Safety Task Group 35 October 16, 2007

Typical Voltage Rated Insulated Tools October 16, 2007 EFCOG Electrical Safety Task Group 36

Alerting and Barricades § How to protect the shock and arc flash approach boundaries from an unqualified person? – – – Barrier tape Orange cones Signage Plastic chain Use an attendant to warn others approaching the area October 16, 2007 EFCOG Electrical Safety Task Group 37

NFPA 70 E Compliance for Subcontractors § Summary – NFPA 70 E is more than just “Arc Flash” requirements – Elements provided, but entire standard may be applicable – Chapter 1 provides Safety-Related Work Practices – Subcontractor responsible for own personnel safety – Communication both ways is imperative October 16, 2007 EFCOG Electrical Safety Task Group 38