Electrical and Arc Flash Safety » OSHA Electrical Safety Interpretations

Am I Responsible for Other Employer’s Electrical Cords on a Construction Site? OSHA Says, “You Could Be.”

Hugh Hoagland — Tue, 20 Jul 2010 22:44:05 +0000

Multi-employer sites don’t get “buys”. Being vigilant is the key. Document other’s violations and work together for a safe workplace. We are only as good as our weakest link.

Click here to read the recent OSHA Interpretation on Multi-employer responsibility for electrical cords on construction sites.

Interpretation: OSHA Can Cite the General Duty Clause for Electrical Hazards and Recommend NFPA 70E for Abatement

Hugh Hoagland — Thu, 01 Jul 2010 15:53:19 +0000

This interpretation makes it clear that OSHA can cite electrical hazards which are “recognized” under the “General Duty Clause”. This interpretation also clarifies the responsibilities of the “controlling employer”. This is one of the first mentions of NFPA 70E by OSHA and we are seeing the results of the citations today.

OSHA states in the interpretation, “Industry consensus standards, such as NFPA 70E, can be used by employers as guides to making the assessments and equipment selections required by the standard. Similarly, in OSHA enforcement actions, they can be used as evidence of whether the employer acted reasonably.”

Click here to read the entire interpretation of citations under the general duty clause for electrical hazards using NFPA 70E and the special case of multiemployer citations.

OSHA Interpretation on FR Logos Puts Responsibility on the Employer

Hugh Hoagland — Wed, 23 Jun 2010 21:16:50 +0000

OSHA actually addressed logos for flame resistant clothing related to arc flash in an interpretation letter. This is interesting. They didn’t give specific guidance but indicated the employer is responsible.

For arc flash issues some use a non-melting thread like Nomex, Kermel or Conex. Other options are coming online all the time. I’d bet a modacrylic thread is available. Colors used to the the big limitation and non-melting threads were often more brittle. This is much easier to work with today with new thread technologies. Atlantic Thread is a supplier of these in the US and others are out there.

Non-FR embroidery works as long as the size is small. The burns I have seen are not from embroidery ignition but from sweat build up UNDER the embroidery which can happen with any embroidery. One manufacturer recommends nothing over a business card size and that seems like a good limit but the standards like ASTM F1506 do not put this limitation on the logo.

If cost is an issue, you will probably see that it isn’t much more than a dollar more for non-melting thread. The ones who charge more don’t usually do it much.

Click here to read the OSHA interpretation.

Click here to read the RiversideFR blog article on this same subject. Will did a good job on this subject.

Click here to see the ASTM F1506 Standard which complies with NFPA 70E.

Click here to see the NFPA 2112 Standard for flash fire with its FR logo requirements.

NFPA 70E and AZ OSHA (ADOSH) Interpretation

Hugh Hoagland — Fri, 28 May 2010 17:59:10 +0000

This letter of interpretation is based on the Ford Motor Citation from 2000 as to how it affects ADOSH citations. The letter addresses an AZ OSHA Interpretation of the effect of the Ford citation and NFPA 70E on future citations.

Click Here to Read See the Complete Letter of Interpretation.

Flame Resistant Clothing Requirements Pushed for Oil and Gas Well Drilling, Servicing & Production Operations

Hugh Hoagland — Wed, 26 May 2010 15:39:01 +0000

"OSHA's policy for citing the general industry standard for personal protective equipment (PPE), 29 CFR 1910.132(a), for the failure to provide and use flame-resistant clothing (FRC) in oil and gas well drilling, servicing, and production-related operations. For the purpose of this memo, FRC includes both flame-resistant and fire retardant treated clothing. Clarification of the need to provide and use FRC during certain drilling, servicing, and production-related operations is necessary to resolve its inconsistent use among drilling contractors, well servicing contractors, and oil and gas companies that employ thousands of workers in these operations. OSHA inspection history and current information, including consensus standards, scientific evidence, and accident and injury data, indicate a potential for flash fires during certain well drilling, servicing, and production-related operations.... Citation Guidance for 29 CFR 1910.132(a) Where appropriate, CSHOs shall cite 29 CFR 1910.132(a) for the failure to provide and ensure the use of FRC in oil and gas drilling, well servicing, or production-related operations when there is a potential for flash fire hazards as discussed below. Drilling Operations FRC is usually not needed during initial rig up and normal drilling operations prior to reaching active hydrocarbon zones, unless other activities warrant their use; e.g., fracing a previously drilled well while rigging a well in close proximity. A potential for flash fire exists once active gas or hydrocarbon zones are reached. Appropriate FRC shall be worn by exposed employees working on the well site prior to drilling into identified gas or hydrocarbon zones. CSHOs should verify that employees are wearing FRC in advance of reaching such zones. Appropriate FRC should also be worn when there is a history of fluid or gas kicks from underground producing zones. Once FRC is identified for use as provided above, employees should wear appropriate FRC until the final casing is cemented and the well is effectively closed. Well Servicing Operations CSHOs shall determine whether FRC is provided and worn during well servicing or workover operations, such as: Pulling wet string tubing Snubbing tubing Swabbing operations Fracturing or perforating the well Using bridge plugs or packers Open hole work Flow testing, blowing down or venting the well Plugging an abandoned well Flowback operations Cementing Stimulation Wireline operations Any operation working with wellhead or wellbore under pressure Production-Related Operations In OSHA's experience, the potential for flash fire also exists in production-related operations that fall outside of drilling and well servicing. CSHOs shall determine whether FRC is provided and worn during production-related operations, such as: Equipment openings (e.g., line breaking or valve changes) Gauging Transfer of hydrocarbons Maintenance operations on production equipment Hot work operations Tank heating Using open flame Start-up operations"

Whether an employer can repair an extension cord under 29 CFR 1926, Subpart K according to OSHA electrical safety regs.

Hugh Hoagland — Wed, 12 May 2010 13:37:20 +0000

"Question: Under what circumstances may an employer located in Minnesota repair a damaged extension cord under 29 CFR 1926, Subpart K? Answer: Paragraph 1926.405(g)(2)(iii) provides: Flexible cords shall be used only in continuous lengths without splice or tap. Hard service flexible cords No. 12 or larger may be repaired if spliced so that the splice retains the insulation, outer sheath properties, and usage characteristics of the cord being spliced. This standard permits you to repair an extension cord, under the conditions set forth, provided the cord is a flexible cord that is No. 12 or larger. Additionally, 1926.403(a) requires all electrical conductors used by employers on a construction site to be "approved." Section 1926.449 defines "approved" as: Acceptable to the authority enforcing this subpart. The authority enforcing this subpart is the Assistant Secretary of Labor for the Occupational Safety and Health. The definition of "acceptable" indicates what is acceptable to the Assistant Secretary of Labor, and therefore approved within the meaning of this subpart. Section 1926.449 defines "acceptable" as: An installation or equipment is acceptable to the Assistant Secretary of Labor, and approved within the meaning of this subpart K: (a) If it is accepted, or certified, or listed, or labeled, or otherwise determined to be safe by a qualified testing laboratory capable of determining the suitability of materials and equipment for installation and use in accordance with this standard; or (b) With respect to an installation or equipment of a kind which no qualified testing laboratory accepts, certifies, lists, labels, or determines to be safe, if it is inspected or tested by another Federal agency, or by a State, municipal, or other local authority responsible for enforcing occupational safety provisions of the National Electrical Code, and found in compliance with those provisions; or (c) With respect to custom-made equipment or related installations which are designed, fabricated for, and intended for use by a particular customer, if it is determined to be safe for its intended use by its manufacturer on the basis of test data which the employer keeps and makes available for inspection to the Assistant Secretary and his authorized representatives. Assuming the extension cord you are repairing was initially "acceptable," §1926.403(a) precludes you from using a repaired cord if the cord is significantly altered as a result of the repair. For example, you are precluded from using a repaired cord if the repair changes the cord's original flexibility.1 As you may be aware, the State of Minnesota operates its own occupational safety and health program under a plan approved by Federal OSHA. Under this plan, the Minnesota Department of Labor promulgates and enforces occupational safety and health standards under authority of State law, and posts them on its website at http://www.dli.mn.gov/mnosha.asp. Although some of Minnesota's standards are different, both its standards and interpretations must be at least as effective as Federal OSHA's. For information on Minnesota's Electrical standard and its enforcement, we suggest that you contact: James Krueger, Compliance Director 443 Lafayette Road North St. Paul, Minnesota 55155-4307 PH: (651) 284-5050 TOLL FREE: (877) 470-6742 FAX: (651) 284-5741"