OSHA's Here… Don't Panic
Having the Occupational Safety and Health Administration (OSHA) show up at a manufacturing facility doesn’t have to be as painful as a root canal, if the right steps are taken. Some need to be completed before the OSHA inspector walks in, and others need to be done while the inspector is present.
One of the keys is to be compliant, particularly where new regulations and laws are concerned. They’ll naturally attract the most attention and so it’s important to be up-to-date. For control engineers a recent ruling could have a major impact. In early August, arc flash protection will move from being a standard to a regulation. Thus, appropriate warning labels and protective clothing will become more than just a good idea. They’ll be the law.
Arc flash hazards are part of National Fire Protection Association, or NFPA, standards and it’s through that association that they’re now part of government regulations. NFPA 70 has been added to the body of OSHA’s CFR 1910 Subpart S regulations, and NFPA 70 outlines electrically safe work conditions, seeking to avoid or minimize electrocutions and burns. Some of the requirements include disconnecting circuits and conductors from power sources or powered parts, locking and tagging in accordance with standards, testing to ensure the absence of voltage and grounding if necessary.
As a result of the new ruling, the regulations will call for labels of switchboards, panelboards, industrial control panels, motor control centers, and meter socket enclosures, with field marking to warn of potential arc flash hazards. Consequently, after August an inspector will look for such labels and note when they’re not present.
As for what needs to be labeled, tables in NFPA 70E 2004 specify limited, restricted, and prohibited approach boundaries for nominal system voltage ranges, phase to phase, of as low as 50 volts and as high as 36 kilovolts. Thus, in a typical manufacturing line there might have to be labels warning of arc flash hazards on a great many machines and in a number of locations on any given machine. What’s more, those labels will require assessing the hazard and determining the location of the appropriate boundary.
Because of other requirements in OSHA’s regulations, both personal protective equipment and training are also impacted, although that will come at some date after the August implementation of labeling requirements. With regard to personal protective equipment, control engineers will have to wear specific clothing, depending upon the hazard category. The apparel could range from the relatively normal for the lowest hazard level, that of zero, to a full flame retardant multilayer flash suit for the highest, that of four. Inspectors will notice if the right gear isn’t available or being worn.
As for training, the effect of the arc flash rules arises because of what is termed a qualified person. Such an individual has the skills to distinguish live parts from others, determine the nominal system voltage of exposed live parts, know the minimum approach distance and use special techniques, tools, and protective equipment. The employer has to document the training that makes a qualified person qualified and maintain that documentation. A control engineer that falls into the qualified person category, a likely scenario, will face the same training and documentation mandates as anyone else. Again, the inspector will notice if training hasn’t been done and documented.
Following the latest regulations– such as those associated with arch flash protection – ensures that the necessary steps that should be taken before the inspector shows up have been taken. What should be done, though, when OSHA is actually present?
The answer is simple. Be cooperative and things will turn out much better. Hiding something– or giving the appearance of trying to hide something – is an invitation to disaster. Actually hiding something will lead to greater punishment and scrutiny if and when the deception comes to light. As for appearing to be hiding something, such actions can make the inspector suspicious and determined to dig deeper.
Don’t assume that the inspector is a technical know-nothing who can be fooled into not spotting a problem, either. That’s not the case and acting like it is may show who the real fool is.
Cooperation doesn’t imply total surrender, however. For example, recording interviews of workers and others by the inspector is a good idea, and ideally the recording will include both video and audio. Another good idea is taking pictures of equipment cited by the inspector. With such actions, there will be two records of what goes into the final report, lessening the possibility for an honest dispute about the facts to escalate into a full blown confrontation.
So, control engineers have some work to do before OSHA shows up, especially in light of newly implemented regulations regarding arc flash protection. These tasks include labeling machines and wearing the right personal protection equipment, as well as undergoing and documenting training. With preparation beforehand and cooperation during an audit, it’s easy to be calm when OSHA walks in. With neither, it’s easy to panic.
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When OSHA Arrives