This is the second of a two-part update on OSHA’s new rules on electric power generation, transmission, and distribution. This part looks at what’s revised, why, and the cost. Read part one of this article, Are new OSHA rules on electrical safety regular or supersize?
When the U.S. Occupational Safety and Health Administration (OSHA) released its changes to rules that affect electric power generation, transmission, and distribution, it was the culmination of a saga that began with a public release of proposed changes almost nine years ago. Agency rule changes send shockwaves of nervousness through the business sector it regulates. There are four sets of major OSHA changes in the new rules.
|Compliance Date||New or Revised Rule||Standard Reference|
|90 Days After Publication
( July 10, 2014)
Transferring information between host employer and contract employers
|1926.950(c) and 1910.269(a)(3)|
|April 1, 2015||2. Revised:
Provisions on the use of fall protection systems
|1926.954 (b)(3)(iii) and (b)(3)(iv) and
1910.269 (g)(2)(iv)(C), and (g)(2)(iv)(D)
|April 1, 2015||3. Revised:
Requirements for minimum approach distances (MAD)
|July 10, 2014||4. New:
Requirements for protecting employees from the hazards associated with electric arcs
|OSHA issues memorandum to delay enforcement pertaining to the new final rule
OSHA has issued a memorandum to both the construction and maintenance sectors to delay enforcement (hence citations) pertaining to the new final rule issued April 2014. Read Bob's recent blog post to learn more.
1. New: Transferring information between host employer and contract employers
Reason: Lack of communication was identified in several incident investigations. Communication is easy but must be consistent in content and coordination.
What the new rule says (1926.950 (c) and 1910.269 (a)(3) paraphrased):
1. Host employer transfers all information related to the safety of work performance:
e. capacity (fault currents).
2. Contract employer(s) responsibilities are to:
a. instruct their employees from the host employer information
b. contact host employer before work begins of any unique hazards not yet covered in their conversation
c. during work performance contact the host employer within two working days when unanticipated hazards arise (although not specifically mentioned, this would be an excellent place to include a “stop work authority” in the employer’s electrical safety program until a suitable resolution is found).
3. Host and contract employer are to coordinate their work rules so that all employees are protected according to these rules (1910.269 (a)(3)(C)(iii)).
Figure 1. Supervision of workers performing in a work area with overhead lines is a key aspect of safety compliance, regardless of the standard that is used.
These rules are much more prescriptive than the older rules and simply state as regulation a practice that is commonly now in place. NFPA 70E has similar wording in 2012 NFPA 70E, Article 110.1. Although the NFPA 70E does not place a two-working-day timeframe on communicating any deviations from the pre-job plans, it does add another important aspect the new OSHA rules do not. The host employer activities in NFPA 70E retain their responsibility throughout the job performance of some direct oversight and to include any observation of contract worker noncompliance (1910.269 and 1926.950 requires only coordination of each other’s work rules). Given the expected work area with overhead lines, this difference is completely understandable (Figure 1). Nonetheless, supervision of workers performing the work is a key aspect of safety compliance regardless the standard that is used. The 2012 NESC includes the idea of communication responsibility in its entire volume, although with less prescriptive terms.
One major area of both concern and discussion by the rule-making participants was where and how to find the available fault current that may be present on the system at the place of work performance. The electrical contractors following NFPA 70E on utilization equipment have long had the same concerns. New NEC requirements, which began in 2008, require that the calculated fault current be placed on the label at the service equipment. This was more for inspector use but had a very positive secondary effect of helping the electrical contractor know the fault current available when applying 70E hazard/risk categories tables for arc flash hazard analysis. This is a best work practice on each of the first disconnecting equipment connected to the secondary of a power transformer even in a facility installation. Where the fault current value is not known, the worker can go to the transformer feeding the system and quickly calculate a worst-case value by dividing the secondary current of the step-down transformer by the decimal equivalent of the transformer impedance. The preamble of the new rules gives the same suggestion when the electrical system fault is not known. Both NFPA 70E and 1910.269 / 1926.960 (Annex E in both OSHA rules) use a handy table to estimate worker protection. When using any of these tables, a worker must first determine maximum fault current and maximum clearing time of the upstream protective device in the system. This is critical information about the system design, which must be communicated by the host employer to the contract employer.