NFPA 70E 130.2(A)(2) Infeasiblity permits energized work if it can be demonstrated that the task to be performed is infeasible in a de-energized state.
Examples include:

- Diagnostics and testing that can only be performed while energized.
- Work on circuits that form an integral part of a continuous process that would otherwise need to be completely shut down in order to permit work on one circuit or piece of equipment.

This week’s question:

Have you performed energized work because de-energizing is infeasible?
Yes - Diagnostics and testing
Yes - Continuous process or similar
Yes - Something else
No

Select all that apply.

Stories and examples are always welcome!

Interesting that the wording has stayed the same through various versions. We asked a consultant about the continuous process exemption and the answer they got from OSHA is that you can only use that excuse for working live if shutting down the continuous process has a higher risk than working live. Has anyone else seen this from OSHA or other regulating bodies?

Having been to a number of chemical plants there are not a lot of them which create a risk to shut down. For the most part shutting them down is costly but not risky.

There are some continuous processes which if not run create risk such as water or wastewater treatment.

OSHA is pretty clear in the letter of interpretation that you can download off their web site. The term "continuous industrial process" basically is just a catch all. So say you have some kind of process where shutting down one part would trigger the infeasible or greater hazard clause but another part of the process isn't inherently an issue but causes a greater hazard issue. Loss of production isn't an acceptable reason. The letter of interpretation seems to hint at but doesn't say that shutting down the process itself creates a greater hazard which might for instance be a plant where startup or shutdown requires an evacuation. Hospitals for instance for years have pushed working live due to the potential loss of life support equipment, although a fatality that caused multiple fatalities is starting to cause them to rethink this. The hospital jobs I've done on operating room chillers had to be after hours and in stages but I did them all locked out.