| WISHA Regional Directive 91-14 |  | |
WRD 91-14
Electrical Safety-Related Work Practices--Inspection Procedures and Interpretive
Guidelines
Date Issued: December 24, 1991
I. Purpose: This directive establishes inspection procedures and provides guidelines to ensure uniform enforcement of the Electrical Safety-Related Work Practices standard, WAC 296-24-960 through WAC 296-24-985.
II. Background: The standard for electrical safety-related work practices was adopted from the Occupational Safety and Health Administration (OSHA). OSHA published the rules in the Federal Register, Volume 55, Number 151, dated August 6, 1990. OSHA Instruction STD 1-16.7 has been used as a guide in preparing this directive.
A. The current electrical standards in Chapter 296-24 WAC, Part L (hereinafter referred to as Part L), the General Safety and Health Standards, cover electrical equipment and installations but not work practices. The electrical safety-related work practices standards that do exist are located in other parts of Chapter 296-24 WAC. Although unsafe work practices appear to be involved in most work place electrocutions, the Division of Industrial Safety and Health (DISH) has very few regulations addressing work practices necessary for electrical safety. Because of this, DISH has determined that standards are needed to minimize the hazards.
B. The new rule addresses practices and procedures that are necessary to protect employees working on or near exposed energized and deenergized parts of electric equipment. The new rule also promotes uniformity and reduces redundancy among the general industry standards. This new rule is based on NFPA 70E, Part II.
C. Washington Industrial Safety and Health Act (WISHA) standards for the control of hazardous energy (lockout/tagout) WAC 296-24-110 became effective on November 15, 1990.
1. That standard addresses practices and procedures necessary to deenergize machinery or equipment, preventing the release of potentially hazardous energy, while maintenance and servicing activities are conducted.
2. Part A-4 of Chapter 296-24 WAC (hereinafter referred to as Part A-4) is related to electrical energy. Portions of Part A-4 may exclude "exposure to electrical hazards from work on, near, or with conductors or equipment in electric utilization installations," that is covered by Part L. The lockout/tagout standard (Part A-4) does not cover electrical hazards.
D. The final electrical safety-related work practices standard obtains maximum safety by deenergizing parts when lockout/tagout is used. It must be done to ensure the deenergized state is maintained.
III. Application: If possible, the compliance officer shall integrate inspection procedures for this standard with those in Part A-4 (lockout/tagout standard).
A. The following guidelines provide a general framework to assist the compliance officer during all inspections:
1. The employer's written procedures required by WAC 296-24-975 (2)(b)(i) shall be reviewed to ensure they cover the hazards likely to be encountered.
a. A copy of subsection WAC 296-24-975(2) maintained by the employer will fulfill this requirement.
b. A copy of the written procedures for locking and tagging out in Part A-4 will comply with this requirement. Those procedures must address the electrical safety hazards in Part L and conform to WAC 296-24-975(2).
c. If the employer chooses to use procedures that comply with Part A-4 for electrical and other hazards, the procedures must include the requirements in WAC 296-24-975.
2. Effective December 24, 1991, the employer's training shall be evaluated to determine it is proper for qualified and unqualified employees.
a. Employees that may be injured by electrical shock shall be trained according to the requirements of Part L.
b. In addition to "a." above, unqualified employees shall be trained in the inherent hazards of electricity. (Examples: High voltage, electrical current, arching, grounding, and lack of guarding). Any safety practices not addressed in this part, but necessary for a work condition, shall be included.
c. The minimum training of qualified employees must include the following:
(1) The ability to distinguish exposed live parts from other parts of electric equipment.
(2) The ability to determine the nominal voltage of live parts.
(3) The knowledge of clearance and approach distances specified in WAC 296-24-960.
d. Compliance officers shall determine if the electrical-related work is conforming to the employer's written procedures and Part L. (See section IV of this directive.)
e. Any violations found must be documented adequately, including the actual voltage level.
B. Interpretive Guidance: The following guidelines are for specific parts of the electrical safety-related work practices standard.
1. Definitions - Qualified/Unqualified Persons:
a. The standard defines a qualified person as one familiar with the construction and operation of the equipment and the hazards involved. Qualified persons are intended to be only those people well acquainted with and thoroughly conversant in the electric equipment and electrical hazards involved with the work being performed.
(1) Whether an employee is considered to be a "qualified person" will depend on various circumstances in the work place. It is possible and, in fact, likely for an individual to be considered "qualified" with regard to certain equipment in the work place, but "unqualified" as to other equipment. (See WAC 296-24-970(2)(c) for training requirements that specifically apply to qualified persons.) Only qualified persons may place and remove locks and tags.
(2) An employee who is undergoing on-the-job training, who, in the course of such training, has demonstrated an ability to perform duties safely at his or her level of training, and who is under the direct supervision of a qualified person is considered to be a qualified person for the performance of those duties.
b. Training requirements apply to all employees in occupations that carry a risk of injury due to electrical hazards that are not sufficiently controlled under Part L.
2. Scope/Coverage of the Standard:
a. The provisions of the standard cover all employees working on, near or with premises wiring, wiring for connection to supply, other wiring, (such as outside conductors on the premises and optical fiber cable) where the filter cable installations are made along with electric conductors and the optical fiber types are those that contain noncurrent carrying conductive members (such as metallic strength members and metallic vapor barriers).
b. The standard does not cover qualified workers (but does cover unqualified workers) performing work on the following:
(1) Electric power generation, transmission, and distribution installations located in buildings used for such purposes or located outdoors.
NOTE: Work on the specified electrical installations is excluded, but work on other electric equipment in the buildings is not excluded.
(2) Communications installations covered under Chapter 296-32 WAC.
(3) Installations in ships, water craft, railway rolling stock, aircraft, or automotive vehicles other than mobile homes and recreational vehicles.
(4) Installations of railways for generation, transformation, transmission, or distribution of electric power used exclusively for operation stock or installations of rolling stock, or installations of railways used exclusively for signaling and communication purposes.
c. The standard for electrical safety-related work practices was developed to complement the existing electrical standards. The new standard includes requirements for work performed on or near exposed energized and deenergized parts of electric equipment, the use of electrical protective equipment, and safe use of electric equipment.
d. Exposure to unexpected electrical energy release that could result in electric shock or burns or in an explosion caused by an electric arc is covered by the standard for electrical safety-related work practices. Safeguarding workers from other hazards related to the unexpected release of hazardous energy during servicing and maintenance operations is covered by Part A-4.
(1) WAC 296-24-975(f)(i)(a) requires that live parts be deenergized before a potentially exposed employee works on or near them. DISH prefers this method for protecting employees from electrical hazards. The employer is permitted to allow employees to work on or near exposed live parts only:
(A) If the employer can demonstrate that deenergizing introduces additional or increased hazards, or
(B) The employer can demonstrate that deenergizing is infeasible due to equipment design or operational limitations.
(2) Under WAC 296-24-975(l)(b), if the employer does not deenergize (under the circumstances permitted in WAC 296-24-975(l)(a)), then suitable safe work practices for the conditions under which the work is to be performed shall be included in the written procedures and strictly enforced. These work practices are given in WAC 296-24-960 and WAC 296-24-980.
(3) Only qualified persons shall be allowed to work on energized parts or equipment.
3. Working on Deenergized Parts:
a. Circuit parts that cannot be deenergized using the procedure outlined in WAC 296-24-975(2)(b) must be treated as energized (as specified in WAC 296-24-975(2)(a)), regardless of whether the parts are deenergized.
b. Deenergized parts are required to be locked and tagged unless exempted under WAC 296-24-975(2)(b)(iii)(c) and (e) discussed below. If exempted, a lock or tag is required.
(1) If a tag is used without a lock, it shall be supplemented by at least one additional safety measure equivalent to a lock. Examples of additional safety measures include the removal of an extra disconnecting device.
(2) A lock may be placed without a tag only under the following conditions:
(A) Only one circuit or piece of equipment is deenergized, and
(B) The lockout period does not extend beyond the work shift, and
(C) Employees exposed to the hazards associated with reenergizing the circuit or equipment are familiar with this procedure.
4. Verification of Deenergizing is Mandatory: This verification must be done by a qualified person.
a. The qualified person shall activate the equipment operating controls or otherwise verify that the equipment cannot be restarted.
b. Test equipment shall be used to ensure that electrical circuit elements have been deenergized.
c. Testing instruments and equipment shall be visually inspected for external defects or damage before being used to determine deenergization, WAC 296-24-985(3)(b).
d. For circuits over 600 volts nominal, the test equipment shall be checked for proper operation immediately before and immediately after the test.
5. Reeneraization: The following requirements shall be met, in the order given, before circuits or equipment are reenergized, even temporarily.
a. A qualified person shall conduct tests and visual inspections to verify that all tools, electrical jumpers, shorts, grounds, and other devices have been removed so the circuits and equipment can be safely energized.
b. Potentially exposed employees shall be warned to stay clear of circuits and equipment prior to reenergizing.
c. Each lock and tag shall be removed by the employee who applied it. If the employee is absent from the work place, the lock or tag may be removed by a qualified person designated to perform this task provided that the employer ensures:
(1) That the employee who applied the lock or tag is not available at the work place, and
(2) That the employee is informed that the lock or tag has been removed before he or she resumes work at the work place.
(3) There is a visual determination that all employees are clear of the circuits and equipment prior to lock and tag removal.
6. Working On or Near Overhead Power Lines, WAC 296-24- 965(5):
a. DISH believes that the preferred method of protecting employees working near overhead power lines is to deenergize and ground the lines when work is to be performed near them.
b. In addition to other operations, this standard applies to tree trimming operations performed by tree workers who are not "qualified persons." In this respect, the exclusion in WAC 296-24-965(3)(a) applies only to "qualified persons" performing line-clearance tree trimming (trimming trees that are closer than 10 feet to overhead power lines.)
c. The standard does not prohibit workers who are not "qualified persons" from working in a tree that is closer than 10 feet to power lines so long as that person or any object they may be using does not come within 10 feet of a power line. However, it would require "qualified persons" to perform the work if the worker or any object they may be using will come within 10 feet of an exposed energized part or if a branch being cut may be expected to come within 10 feet of an exposed energized part while falling from the tree. (See WAC 296-24-960(7))
d. The purpose of the approach distance requirements of Chapter 296-24-960 WAC is to prevent contact with, or arching from, energized overhead power lines. The approach distance applies to tools used by employees and employees themselves.
e. Employees working on or around vehicles and mechanical equipment, (such as gin-pole trucks, forklifts, cherry pickers, garbage trucks, cranes and elevating platforms) who are potentially exposed to hazards related to equipment component contact with overhead lines, shall have been trained by their employers in the inherent hazards of electricity and means of avoiding exposure to such hazards.
f. The standard for electrical safety-related work practices can be applied to electrical hazards related to any size, utilization, or configuration of overhead power lines in general industry; e.g., residential power lines, remotely located overhead power lines, temporarily rigged overhead power lines, and overhead power lines along streets and alleys.
7. Portable Ladders: Ladders shall not have conductive side rails where the employee or ladder could contact exposed energized parts. All ladders shall be in compliance with other standards in Chapter 296-24 WAC.
8. Conductive Apparel: Articles of jewelry and clothing such as watch bands, bracelets, rings, key chains, necklaces, metalized aprons, cloth with conductive thread, or metal headgear shall not be worn if there is a possibility of contacting exposed energized parts.
9. Housekeeping Duties: The employer shall provide adequate safeguards (such as insulating equipment or barriers) where live parts present an electrical hazard to employees performing housekeeping duties. Electrically conductive cleaning materials (such as steel wool, metalized cloth, and silicon carbide, and conductive liquid solutions) shall not be used in proximity to energized parts unless procedures are followed to prevent electrical contact.
10. Electrical Safety Interlocks: Interlocks found on panels, covers, and guards are designed to deenergize circuits and prevent electric shock.
11. Cord-and-Plug Connected Equipment: Energized equipment here means either the equipment, he receptacle, or both into which it is being plugged. (WAC 296-24-985(i)(e)(i))
12. Eye and Face Protection: WAC 296-24-980(l)(a)(v) requires employees to wear protective equipment for the eyes or face wherever there is danger of injury to the eyes or face from electric arcs or flashes or from flying objects resulting from electrical explosion.
13. Insulated Tool: This means a tool encased within material of composition and thickness that is recognized as electrical insulation.
IV. Enforcement/Citation Guidance:
1. A deficiency in the employer's program that could contribute to a potential exposure capable of producing serious physical harm or death shall be cited as a serious violation.
2. The failure to train "qualified" and "unqualified" employees as required for their respective classifications shall normally be cited as a serious violation.
3. Paperwork deficiencies in the safe work practice program where effective safe work practice procedures are in place shall be cited as other-than-serious.
V. Action: Program managers and regional administrators shall ensure the policies and interpretive guidelines in this directive are followed.
VI. Effective Date: This WISHA Regional Directive is effective December 24, 1991, and will remain in effect for eighteen months or until canceled.
J.N. Kirchoff, Assistant Director
Division of Industrial Safety and Health
Department of Labor and Industries
Post Office Box 207
Olympia, Washington 98504
Telephone: (206) 753-6500
