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OSHA’s Enforcement and Significant Changes in 2015 NFPA 70E Presented by Doug Tellin Electrical Safety Specialists LLC. Aristotle “Educating the mind without educating the heart is no education at all.” 1 out of 300 Safety Overall 1 out of 10 1 Fatality 1 Fatality Electrical Safety 30 Lost-Time Injuries 300 Recordable Injuries 10 Recordable Injuries 30,000 Near Misses 300,000 At-Risk Behaviors Electrical Safety should be a MAJOR concern! 3 Better to Plan and Prevent than to Repair and Repent 4 NFPA 70E 2015 And OSHA Have set the bar high! NPFA70, NFPA 70E, NFPA 70B, NFPA 99 are all trade marks of the National Fire Protection Association, INC 5 OSHA’S mission is not SEEK AND DESTROY OSHA’S mission is IDENTIFY AND FIX OSHA’S EXPECTATIONS Never work on live circuits unless it is absolutely necessary. OSHA has strict guidelines for working live circuits. Production or inconvenience is not justification for working energized. Not having the authority to shut off power, cannot be used as an excuse for workers. OSHA’S EXPECTATIONS 1. 2. 3. 4. 5. Was an arc flash hazard analysis performed? Were flash protection boundaries established? Were all other potential electrical hazards identified? Was a shock hazard analyses performed? Were shock hazard boundaries established? These are all Questions every EHS professional should have an answer to. OSHA’S EXPECTATIONS • This can be a very complex task for most facilities. • OSHA inspectors are trained to ask if these analyses were performed • This is the only way for electrical hazards to be reduced to a manageable level. OSHA’S EXPECTATIONS Go Home the way you came to work today. Don’t make your family the victim of complacency. OSHA’S EXPECTATIONS The employer must show proof of the appropriate training and certifications for a person to be deemed qualified in OSHA’s Eyes • This is achieved by training, even for the experienced electrician. OSHA’S INSPECTIONS Employer May Qualify for a "Focused Inspection" Inspector will "focus" on these four hazard areas: • Falls • Struck by • Caught in/between • Electrical OSHA’S INSPECTIONS Example OSHA Citation NFPA 70E Standard for electrical safety in the workplace • Arc Flash Assessments and reviews every 5 years! • Only qualified persons working within the limited approach boundary energized parts! • Retraining every 3 years! • Annual audits of performance! • CPR/AED annually! • Release of victims training annually! 16 Electrical Arc Flash/Blast 35,000 °F Molten Metal Pressure Waves Sound Waves Copper Vapor: Solid to Vapor Expands by 67,000 times Shrapnel Rapid Expansion of Hot Air Intense Light 130.5 Arc Flash Risk Assessment An arc flash risk assessment shall be performed and shall: (1) Determine if an arc flash hazard exists. If an arc flash hazard exists, the risk assessment shall determine: a. Appropriate safety-related work practices b. The arc flash boundary c. The PPE to be used within the arc flash boundary Tables VS. Analysis 19 Tables VS. Analysis 20 Table 130.4(D)(a). 21 TIME CURRENT CURVE (TCC) CB 3 Square D QO 150 Amp 240 volt 1/0 awg 150’ long 2.67KA 2.0 SEC 15.53 CAL/CM² HRC 3 CB 8 Square D QO 150 Amp 240 volt 1/0 awg 50’ long 3.34KA .023 SEC .23 CAL/CM² HRC 0 CB 7 Square D QO 150 Amp 240 volt 1/0 awg 100’ long 2.97KA .029 SEC .24 CAL/CM² HRC O Arc Flash Boundary Incident Energy Analysis PPE Requirements Label Location Nominal Voltage Approach Boundaries Date 4 cal/cm² ARC Rating of 8 cal/cm² Cotton Hierarchy of Electrically Safe Workplace 110.1 (G) Risk Assessment Procedure (1) Identify hazards (2) Assess risks (3) Implement risk control according to a hierarchy of methods: (1) Elimination (2) Substitution (3) Engineering controls (4) Awareness (5) Administrative controls (6) PPE 110.1 Electrical Safety Program • (B) Maintenance. The electrical safety program shall include elements that consider condition of maintenance of electrical equipment and systems. What are we going to Cover – Training Requirements – Qualified Persons – Retraining Requirements Proper Use of Test Instruments Article 110.4(1) Testing Only qualified persons shall perform tasks such as testing, troubleshooting, and voltage measuring within the LAB or energized electrical conductors or circuit parts operating at 50 volts or more or where an electrical hazard exists. There are many effective ways to train employees. 110.2 Training Requirements. (C) Emergency Response Training Employees shall be trained: (1) Contact Release. Employees exposed to shock hazards shall be trained in methods of safe release of victims from contact with exposed energized electrical conductors or circuit parts. Refresher training shall occur annually. 110.2 Training Requirements. (C) Emergency Response Training Employees shall be trained: (2) First Aid, Emergency Response, and Resuscitation. (a) Employees responsible for responding to medical emergencies shall be trained in first aid and emergency procedures. (Periodically) (b) Employees responsible for responding to medical emergencies shall be trained in cardiopulmonary resuscitation (CPR). Refresher training shall occur annually. 110.2 Training Requirements. (C) Emergency Response Training Employees shall be trained: (2) First Aid, Emergency Response, and Resuscitation. (Continued) (c) Employees responsible for responding to medical emergencies shall be trained in the use of an automated external defibrillator (AED) if an employer’s emergency response plan includes the use of this device. Refresher training shall occur annually. 110.2 Training Requirements. (C) Emergency Response Training (3) Training Verification. Employers shall verify at least annually that employee training required by this section is current. (4) Documentation. The employer shall document that the training required by this section has occurred. 100 Definitions Qualified Person. One who has demonstrated skills and knowledge related to the construction and operation of electrical equipment and installations and has received safety training to identify and avoid the hazards involved. OSHA Definitions Qualified Person. The latest revision of the OSHA definition for qualified person (1910.399 8/07) includes the phrase “has demonstrated skills.” To meet this requirement, the person has to actually demonstrate that he/she can perform the task. Summary of Qualified Persons Skills • Trained • Taught • Learned • Demonstrated ability to Perform task safely Summary of Qualified Persons Skills Is permitted to work • Operating at 50 volts or more • Within the limited approach boundary of • Energized conductors and circuit parts (this is what system and equipment is made of) 110.2 Training Requirements. (D)(1) (e) Qualified Person. Employees shall be trained to select an appropriate test instrument and shall demonstrate how to use a device to verify the absence of voltage, including interpreting indications provided by the device. The training shall include information that enables the employee to understand all limitations of each test instrument that might be used. 110.2 Training Requirements. (D)(1) (f) Qualified Person. The employer shall determine through regular supervision or through inspections conducted on at least an annual basis that each employee is complying with the safety-related work practices required by this standard. 110.2 Training Requirements. (D)(3) Retraining Retraining in safety-related work practices and applicable changes in this standard shall be performed at intervals not to exceed three years. 110.2 Training Requirements. (E) Training Documentation The employer shall document that each employee has received the training required by 110.2(D). This documentation shall be made when the employee demonstrates proficiency in the work practices involved and shall be maintained for the duration of the employee’s employment. The documentation shall contain the content of the training, each employee’s name, and dates of training. Questions? More Information? • • • • • Doug Tellin [email protected] Greg Windisch [email protected] Visit us on the web. • Arcflashpro.com • Call for a free consultation • (816) 925-0443