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Presented by Doug Tellin Electrical Safety Specialists LLC. OSHA’s Enforcement and Significant Changes in 2015 NFPA 70E

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Page 1: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

Presented by Doug Tellin Electrical Safety Specialists LLC.

OSHA’s

Enforcement and

Significant Changes

in 2015 NFPA 70E

Page 2: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

Aristotle

“Educating the mind without educating the heart is no education at all.”

Page 3: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

3

300,000 At-Risk Behaviors

30,000 Near Misses

300 Recordable Injuries

30 Lost-Time Injuries

1 Fatality

1 out of 300

Safety Overall

10 Recordable Injuries

1 Fatality

1 out of 10

Electrical Safety

Electrical Safety should be a MAJOR concern!

Page 4: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

4

Better to Plan and Prevent than to

Repair and Repent

Page 5: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

NFPA 70E 2015

And

OSHA

Have set the bar high!

5

NPFA70, NFPA 70E, NFPA 70B, NFPA 99 are all trade marks of the National Fire Protection Association, INC

Page 6: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

OSHA’S mission is not

SEEK AND DESTROY

OSHA’S mission is

IDENTIFY AND FIX

Page 7: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

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.

Page 8: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

OSHA’S EXPECTATIONS

1. Was an arc flash hazard analysis performed?

2. Were flash protection boundaries established?

3. Were all other potential electrical hazards identified?

4. Was a shock hazard analyses performed?

5. Were shock hazard boundaries established?

These are all Questions every EHS professional

should have an answer to.

Page 9: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

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.

Page 10: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

OSHA’S EXPECTATIONS

Go Home the way you came to work today. Don’t make your family the victim of complacency.

Page 11: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

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.

Page 12: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

OSHA’S INSPECTIONS

Inspector will "focus" on these four hazard areas:

• Falls

• Struck by

• Caught in/between

• Electrical

Employer May Qualify for a "Focused Inspection"

Page 13: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

OSHA’S INSPECTIONS Example OSHA Citation

Page 14: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

• 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

NFPA 70E Standard for electrical safety in the workplace

Page 15: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

Electrical Arc Flash/Blast

Copper Vapor: Solid to Vapor Expands by 67,000 times

Intense Light

Rapid Expansion of Hot Air

35,000 °F

Pressure Waves

Sound Waves

Molten Metal

Shrapnel

Page 16: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

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

130.5 Arc Flash Risk Assessment

Page 17: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

Tables VS. Analysis

19

Page 18: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

Tables VS. Analysis

20

Page 19: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

Table 130.4(D)(a).

21

Page 20: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

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 7 Square D QO 150 Amp 240 volt 1/0 awg 100’ long 2.97KA .029 SEC .24 CAL/CM² HRC O

CB 8 Square D QO 150 Amp 240 volt 1/0 awg 50’ long 3.34KA .023 SEC .23 CAL/CM² HRC 0

Page 21: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

Nominal Voltage

Arc Flash Boundary

Approach Boundaries

Incident Energy Analysis

PPE Requirements

Label Location

Date

Page 22: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

4 cal/cm²

Page 23: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

ARC Rating of 8 cal/cm² Cotton

Page 24: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

Hierarchy of Electrically Safe Workplace

Page 25: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

(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 (G) Risk Assessment Procedure

Page 26: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

110.1 Electrical Safety Program

• (B) Maintenance. The electrical safety program shall include elements that consider condition of maintenance of electrical equipment and systems.

Page 27: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

What are we going to Cover

– Training Requirements

– Qualified Persons

– Retraining Requirements

Page 28: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

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.

Proper Use of Test Instruments

Page 29: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

There are many effective ways to train

employees.

Page 30: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

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

Page 31: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

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

Page 32: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

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

Page 33: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

(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.

110.2 Training Requirements.

(C) Emergency Response Training

Page 34: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

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.

100 Definitions

Page 35: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

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.

OSHA Definitions

Page 36: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

• Trained

• Taught

• Learned

• Demonstrated ability to Perform task safely

Summary of Qualified Persons Skills

Page 37: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

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)

Summary of Qualified Persons Skills

Page 38: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

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) (e) Qualified Person.

Page 39: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

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)(1) (f) Qualified Person.

Page 40: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

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.

(D)(3) Retraining

Page 41: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

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.

110.2 Training Requirements.

(E) Training Documentation

Page 42: OSHA’s - NFMT · 3 300,000 At-Risk Behaviors 30,000 Near Misses 300 Recordable Injuries 30 Lost-Time Injuries 1 Fatality 1 out of 300 Safety Overall 10 Recordable Injuries

• Doug Tellin

[email protected]

• Greg Windisch

[email protected]

• Visit us on the web.

• Arcflashpro.com • Call for a free consultation

• (816) 925-0443

Questions? More Information?