Complient esp with Osha

A meeting with a safety manager again about our esp went no where. He insist that they can have a esp with the loto from osha. these are his words , a employee can just verify a motor is running and shut disco off and try starting motor to confirm no power , place loto and done. Use the table out of 70e as our working guide " without analysis" . He said all we need is a esp to be complient with Osha and nothing says we have to follow 70e although we are using just their tables.
Does anyone have referrance as to what osha wants in regards to an esp?

Puckman,
While his approach may satisfy an OSHA inspection initially, you could have a real problem if something does happen.
In an event, OSHA, not to mention the lawyers for the injured party, is not just going to look at what you did and what OSHA says, they are going to look at what you knew. If you know that better systems are out there, and don't try to follow them, or at least analyze their suggestions as it applies to your operation, you will have a hard time defending your program.

I'm not sure specifically what you are questioning. I get the general feeling that the manager is saying that operators can perform LOTO without FR. If that is the case then I would recommend you read this post.

http://arcflashforum.com/showthread.php?t=904

70E Article 130 is for 'live work' with the exception of dead front work with high change of energy state. Obviously, the manager is willing to accept some risk and understands the liability. IF there is an accident OSHA is going to ask to see your program. If you have a program in place you can't be fined under the general duty clause. Following 70E 130 is considered compliance. But, since there is so many voids and contradictions in 130, NFPA versus IEEE, exemption for <125KVA xfrms, etc, that if you establish your policy, and define what deadfront equipment is going to be allowed to operate, then I think you will be meeting the OSHA requirement. If anyone gets hurts, you have liability, doens't matter who is at fault, so you have look for the most reasonable solutions that offers the best compromise.

Can a company use 70e tables when they know their electrical service is not in the parameters to use the tables and would their esp be complient with osha?
thank you.

If I understand you correctly you do not have a ESP written towards arc flash safety, mitigation, EWP or PPE?

You do have a written LOTO policy and management says that's all that is required by OSHA.

Your organization only approach to arc flash is the 70E table.

In my unprofessional opinion your management has stated some truths. OSHA has not placed arc flash regulations to say in the book as the written word. I believe, an OSHA's rulings are very difficult to get put in black and white (goverment red tape) and depend on other authorities for help.

Most likely very few companies now will be fined for no arc flash program, UNLESS someone get killed or involves sever injury of several personnel. This is where management can and will have OSHA related problems not to say personnel legal issues.

At that point the General Duty Clause comes into play and the game is on. Search for OSHA General Duty Clause on Google.

Always protect yourself. I always say don’t depend on others for your protection. Study the NFPA 70 and OSHA along with other regulatory groups to learn for yourself.

We do have a eewsp with loto being from osha and hrc from 70e even though our electric service is to large to use tables. To work on a piece of equipment the maintenance machanics don't have to test for power to deenegized , just shut off disco and loto. Nothing higher than 2* . We have been pushing for an analysis on system but as stated in previous post company says there is nothing in Osha that says we have to.

Loto

I think we are confusing two separate LOTO's.

1910.147 Covers LOTO for servicing and maintenance. It reduces the chance of an accidental release of energy. If you are never exposed to a conductor that has not been verified at zero energy, it will suffice. Such tasks as lubrication, alignment, and other mechanical tasks use it all the time.

Now if we have exposed electrical conductors, you cannot verify zero energy w/o PPE. At this point you need to perform a flash hazard analysis.

Why can't you use Table C(9)?

If you don't have incident energy analysis completed why can't you use the Table Method of arc flash hazard analysis. What voltage and what is the work task description.

When you use ESP, do you mean Electrical Service Person or Electrical Safety Program.

We need Supervisors to understand their personal risk with respect to OSHA and OH&S Regulations in Canada.

In Canada CSA Z462 is not adopted into law, and in the United States NFPA 70E isn't adopted formally into law either, BUT OSHA does recognize it. By the way Ken Mustrollo who used to be with NFPA as one of their 70E Experts is not with OSHA and one of the things he does in train OSHS Inspectors on NFPA 70E.

Terry Becker, P.Eng.
ESPS Electrical Safety Program Solutions INC.
terry.becker@espsi.ca
403-465-3777

Mastrullo

Ken Mastrullo is with OSHA. He is driving the Electrical Safety initiative. He is training their field agents on 70E as one of the methods of mitigating hazards.

terry , i believe 70e says you have to have a analysis on electrical system and it has to be in the parameters to use the tables. i don't know if osha abids by that rule . our eewsp has osha listed for loto and the tables as a guide to work from. confusingnyes.

Osha 29cfr

Read OSHA 29CFR 1910.132...

The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). If such hazards are present, or likely to be present, the employer shall:

It goes on to state provide PPE etc.

Then read 1910.147 where it specifically says the Control of Hazardous Energy Standard (normal LOTO) does not apply to:

Exposure to electrical hazards from work on, near, or with conductors or equipment in electric utilization installations, which is covered by Subpart S of this part; and YADA YADA YADA

With these 2 codes, I surmise that an arc flash analysis must be done (NFPA 70E tables or detailed) and a LOTO procedure must be developed for work on or near electrical hazards. If it's not documented, it didn't happen... if it's not in writing, it won't happen.

I win a lot of Cokes from safety professionals on these 2 standards!

Just 2 more cents worth.