http://origin.library.constantcontact.com/download/get/file/1101637591588-755/OSHA-269-Table-Comp-A1.pdf

This is a really great tool. Thanks Hugh.

Why do they continue to include rayon along with the meltables? I thought they would be correcting this?

Hugh,

And I assume a similar side-by-side of 1926 Sub V is in the works?

Thanks.

I don't know if it would even be instructive to do that. Old 1926 was so devoid of pretty much anything construction-wise for overhead lines that most companies simply adopted 1910.269 Subpart V as a guideline for both maintenance and construction. Reading through the text of the new 1926 Subpart V, it is almost a verbatim carbon copy of 1910.269 Subpart V except dropping the unrelated parts such as working on chlorine systems.

Thanks for the compliments. We did not do the 1926 for the reason cited. It is so much of a change and this was a freebie.

Hugh Hoagland
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On rayon in arc flash.

If you read the preamble, David did note that rayon was not a melting fiber non-FR rayon is easily ignited so it was left in the list of prohibited fibers. FR rayon like LenzingFR is perfectly acceptable.

All melting fibers are prohibited unless arc rated. Normally this can only occur if they are in a blend or a laminate. Most laminates which claim to be FR are not AR or capable of being AR.

Buyer's beware.

That would certainly simplify matters, but can we really adopt one and ignore the other? 1910.12 specifically directs to us 1926 for construction work, including the erection of new lines and equipment. Or are is 1910.269 conservative enough that conformance to 1926 will also occur if one complies with 1910.269? Thanks all.

Addition on edit:

(ii) Notwithstanding paragraph (a)(1)(i) of this section, §1910.269 of this Part does not apply:
(A) To construction work, as defined in §1910.12 of this Part...

Correct...compliance with 1910.269 will meet 1926.

OSHA has long maintained a difference between construction work and general industrial work (maintenance). However the difference is tenuous at best. There is no definition of "maintenance" and only a vague definition of "construction" in the regulations, and one or two letters of interpretation. Difficulties arise for instance when it gets into words like "overhauls" or "refurbishment". Many times "turn arounds" or major maintenance activities are effectively what OSHA would consider construction or alteration. It is thus probably best to follow both sets of regulations whenever possible.

If you are in for a laugh, look at the electrical LOTO in 1926 for general electrical work. It consists of 2 SENTENCES, nowhere near the early version of 70E that is contained in 1910 Subpart S. The only one that is different is that tags are not specifically required under Subchapter S but locks are almost always required. Conversely tags are specifically required under 1926 but usually considered optional under Subchapter S.

Fortunately 1910.269 rules are far more stringent than 1926 rules and are strictly a superset when it comes to pole line work. Thus compliance with 1910.269 automatically covers compliance with 1926 with regards to pole work. Differences would exist for instance in specific operation of say a crane/derrick around energized lines which has stricter requirements under the relatively recently revised section of 1926.

And if you think this is confusing, just try dealing with the mixed jurisdictions with utilization and distribution equipment, and then throw in a dose of maritime and mining regulations which fall under completely different agencies. Or to put it another way, welcome to my life with an air strip, port, ship, mine, and chemical plant in one facility, each with its own semi-unique set of regulations.

I'm wanting confirmation on the applicability of these changes...

When it says in paragraph (a)(1)(i)(A) that this applies to "Power generation, transmission, and distribution installations, including related equipment for the purpose of communication or metering that are accessible only to qualified employees" what is included? They later say utilities and plants that have similar equipment, but does "distribution" include the small commercial location that receives power at 480V from the utility to a couple of 3-phase panels?
Or is this only for power plants and large industries that have on-site generation?

Thanks!

Welcome to the IEEE/NFPA rivalry. NFPA specifically addresses utilization. IEEE specifically addresses distribution. OSHA follows their scoping, which no matter how many times you read it, is not clear at all. It is clear from OSHA that subchapter S is for utilization and 269 is for distribution. They clearly do not cover portable or backup/emergency generation under 269. So this means industrial sites with cogen capability fall under 269. It is also not clear whether for instance solar/wind farms are 269 or subchapter S. The line of demarcation in NEC is purposely defined as vague.

That being said one can make arguments about whether or not internal distribution equipment including potentially overhead power lines falls under one or the other. If you don't have permanent cogen/green power production, I would stick with the demarcation line between the facility and the utility and use that. I have never had an argument with anyone with that approach since it is consistent. But if you have a lot of overhead equipment and especially cogen equipment from a very practical point of view, 269 rules are easier. There is no EEWP rule under 269 and overhead equipment and most distribution equipment is designed for working live. Trying to maintain it under Subbchapter S rules would be troublesome at best. Until recently pole work would then fall under the 1936 rules which were inadequate. Under the new rules though there is less of a reason to want to use 269 if the facility has no distribution.

In a joint site discussion for a Fortune 500 company I had the only site that followed 269 and Subchapter S. It became clear that this was best for us with a cogen and 70 miles of overhead circuits. We had our own linemen, large cogen, distribution subs (double ended), and in short we have a private utility. The others, even with huge multi-megawatt demands, even with one sharing distribution systems with the neighbor (a large refinery) just did not make sense to follow 269.

Sorry for off topic but I wonder where I can purchase a new OSHA book including the new 1910.269?

Thanks
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