Hello all! Just a disclaimer: I have very limited technical knowledge of anything electrical, but work in environmental health and safety for a university and am part of the effort to develop an electrical safety program in accordance with NFPA 70E.

http://ecmweb.com/content/streamlining- ... it-process

I was wondering if I could get opinions on the approach to permits described in the above article. To summarize, it proposes that tasks be split into routine and non-routine, and permits for routine tasks could cover a year long period, whereas permits for non-routine tasks would expire after task completion.

Additionally, it's been a while since I've thoroughly read through the standard, and I'm now finding myself confused about the relationship between risk assessment and use of permits in general.

Could we potentially satisfy the risk assessment requirements by creating routine and non-routine permits for all tasks that require a permit? Since the results of the shock and arc flash risk assessments are required components of the permit, I'm having a hard time deciphering if we are meant to do them regardless of whether a permit is required or not.

Am I making this more complicated and confusing than need be? Any help would be much, much appreciated! Thanks so much.

Katie

Not confusing at all. A university at least in the U.S. falls under OSHA and in Canada it falls under OH&S. Other jurisdictions may be different but with both of them the regulatory requirement is that employers must take reasonable steps to protect workers against recognized hazards. Shock and arc flash are two of them. Note that although it is sometime explicit and sometimes implied, a risk assessment must be done. Older versions of 70E are somewhat circumspect about this but the current (2015) version is very explicit in this regard. 70E is also harmonious with ANSI Z10 which specifies doing risk assessments as well as specifying a hierarchy of controls of risks, of which PPE is the last resort.

There are some differences though. It has long been standing practice to do a "field" version of a risk assessment (a JHA or JSA or PTP...pre-task planning goes by many names) with most utilities and some other industries for some time now. In versions of 70E prior to the 2015 version this practice was bypassed in favor of a detail work procedure for "routine" work (those for which procedures exist and are routinely implemented). Starting with the 2015 version the field pre-task plan was required for all tasks. Not saying that I agree with this because research shows that the field risk assessments tend to work best for new workers and when approaching nonroutine work but become a paperwork exercise for routine tasks as workers just want to "get it over with" and tend to ignore changes to the environment...the precise thing that causes injuries and is precisely what the task planning is supposed to prevent. I wish I could find a good research paper on this but so far I've come up empty handed except for a few papers where this opinion is being expressed.

Certainly OSHA recognizes the difference and certainly they encourage and in some cases require risk assessments for all tasks. In PSM industries (ie, petrochemical plants) where OSHA is concerned about the risk of a major fire/explosion/toxic chemical leak of the kind that ends up reported on national news, the risk assessment process is much more refined. It generally follows the procedures laid out by AiChE's CCSP (Center for Chemical Process Safety), especially the LOPA and HAZOP procedures. You will also see it clearly with robotics equipment following the ANSI/RIA procedure as well as commonly in Europe under a host of EN/ISO/IEC standards such as IEC 61511, IEC 61508, and sometimes especially around automotive under ANSI TR3. When it comes to electrical hazards, the injury rates are very low but the seriousness of the injuries is almost always very high. Thus I recommend using the CCPS approach (LOPA) since the others are based on much more frequent exposures and/or much lower injury rates, or are hard to translate to "generic" conditions.

It is important to put together a cross functional team to evaluate risks and to use a facilitator familiar with the process. Most of the arc flash consultants out there want to produce engineering studies and frankly do a great job of "scare tactics" when it comes to training but very poorly when it comes to evaluating risk, which is specifically the area you are going after.

So yes in the end there's realistically no problem with doing this but understand where you are headed and what you are doing. OSHA doesn't require field risk assessments and neither did 70E up until the last update cycle.

1. The Standard breaks down into two areas - de-energized work and energized work.
2. De-energized work is normally done using Lock, Tag and Try procedures. This means you have to have some kind of written policy/procedure that everyone is trained on. This procedure/policy would identify actions and PPE required. As long as they follow it, you are home free.
3. Energized work goes into two areas: a. Where it is infeasible to turn it off and b. diagnostics.
3a. Where someone wants to do it live or wants to do it live. This is where you need a permit. The permit is long and tedious and it requires someone to approve it that is higher on the institutional foodchain. If they have any brains, they won't sign it. Instead, they will tell their personnel to figure out some way to secure the power and get the work done de-energized. Many times that means after-hours or early in the morning.
3b. For diagnostics - you don't need a permit, but you do need training and PPE to protect workers from the hazards (shock and arc flash) that they are exposed to.

The part where you have the tiger by the tail is that everybody includes everyone that is getting a check from the university. They are all employees. This includes all of the tradespeople, professors, instructors, grad student assistants, everyone that is an employee of the university and anyone else that is paid like contractors and their subs. They are all covered by OSHA. Everything they do at the university is covered - including anything they are doing "on-their-own." They are going to have to be trained to develop and follow JHAs and to be trained what PPE to use and when to use it.

I don't know what is required to protect students. I doubt they are covered by OSHA since they are not employees. Certainly, they will see people dressed out in PPE when they are in labs. It would be a good idea to train them at the same time.

Students aren't covered. They are the same as "general public" or visitors in any other jurisdiction. Either they are restricted from access to certain areas or escorted if that's the case.

The one group not mentioned is contractors. Contractors have to implement the same policies and procedures and 70E has provisions to handle the contractor relationship as to whose policies apply.

There will always been questions about "routine" energized electrical work. Most prefer and OSHA requires "electrically safe work" whenever practicable.

That being said, the article describes what many companies do. It is not prohibited by the standard but the idea is not mentioned. The concept of "annual" work permits have been around for quite some time.

Here is a layout of the process:

1. Annually evaluate at the "routine" task with a qualified person and determine if this must be done energized using the OSHA and NFPA 70E criteria.
2. Justify in writing why this must be done energized. This may be location specific.
3. Evaluate the work processes and the individual work qualifications to assure that the processes and the workers training and PPE meet all the shock and arc flash requirements of NFPA 70E.
4. Be certain the written JSA/JHA includes protection requirements for unqualified personnel.
5. Document agreement/signoff of management, an electrically knowledgeable person and individual worker qualified to do this work. Some recommend this be signed by the highest executive for the site to assure this is known to management.
6. Evidence of Job Briefing (typically companies using an "annual" work permit have a space of the work order or JSA/JHA for documenting the location job briefing).

Anyone can add to the above but this is likely the minimum. In any case, an "annual" work permit still must meet all the requirements of NFPA 70E and OSHA for energized work to be allowable.

Hugh Hoagland
e-Hazard.com