R.
James Seffrin Jersey
Infrared Consultants
P.O. Box 39
Burlington, NJ 08016
609-386-1281
Presented
at IR/INFO '96
Orlando, Florida
Abstract
Although infrared
inspections of electrical equipment are a widely accepted
maintenance procedure, considerable debate persists among
thermographers concerning their legality under OSHA. This
paper addresses the Occupational Safety and Health Act of
1970, the role of the Occupational Safety and Health Administration
and the Occupational Safety and Health Standards which apply
to infrared inspection of electrical equipment.
Introduction
Infrared inspections of electrical distribution
equipment are now a widely accepted maintenance procedure.
Since electrical panels must be removed, thermographers often
come in close proximity to energized electrical equipment.
This paper addresses the Occupational Safety
and Health Act of 1970, the role of the Occupational Safety
and Health Administration and the standards which apply to
infrared inspection of electrical equipment.
This paper is based upon research of existing
standards at the time of publication.
It is not intended to cover all standards
and situations which a thermographer could encounter in the
course of his/her work. It also should be noted that thermographers
who perform additional tasks other than thermography (removal
of panel covers, ammeter readings) may be subject to additional
standards other than those discussed here.
Thermographers and their employers must be
familiar with the current applicable Occupational Safety and
Health Standards and should consult with their local OSHA
office to ensure compliance.
The
Occupational Safety and Health Act of 1970
In 1970 the United States Congress investigated
worker safety and health in the work place. Finding "... that
personal injuries and illnesses arising out of work situations
impose a substantial burden upon, and are a hindrance to interstate
commerce...," the United States Congress passed Public Law
91-596 on December 29, 1970. This Act is commonly referred
to as the "Occupational Safety and Health Act of 1970." This
Act was later amended on November 5, 1990.
Under the Occupational Safety and Health
Act of 1970, Congress declared its policy "... to assure ...
every working man and woman in the Nation safe and healthful
working conditions...." The Occupational Safety and Health
Act of 1970 seeks to accomplish this goal by several means
including training, standards development and usage, research
and enforcement.
The OSH Act covers nearly all employers in
the private sector within the States, the District of Columbia,
the Commonwealth of Puerto Rico, the Virgin Islands, American
Samoa, Guam, the Trust Territory of the Pacific Islands, Wake
Island, Outer Continental Shelf Lands, Johnston Island and
the Canal Zone.
The OSH Act applies to employers with one
or more employees with the exception of miners, transportation
workers, many federal workers, clergy, and domestic household
workers.
The Act also states that each employer "...
shall furnish employment and a place of employment free from
recognized hazards that are causing or are likely to cause
death or serious physical harm to his employees." Since the
OSH Act is law, the employer must comply with all occupational
safety and health standards promulgated by the Act. Employees
must also comply with these standards which are applicable
to his own actions and conduct.
The
Role of the Occupational Safety and Health Administration
The mission of OSHA is to save lives, prevent
injuries and protect the health of America's workers. To accomplish
this, federal and state governments work in partnership with
over 100 million workers and their 6.5 million employers covered
under the OSH Act of 1970.
OSHA and its state partners have approximately
2100 inspectors, plus complaint and discrimination investigators,
engineers, physicians, educators, standards writers, and other
technical and support personnel spread over more than 200
offices throughout the country. This staff establishes the
protective standards, enforces those standards, and reaches
out to employers and employees through technical assistance
and consultation programs.
Administration of the OSH Act is carried
out by the Occupational Safety and Health Administration and
falls under the United States Secretary of Labor. Violations
of the OSH Act carry substantial fines (up to $70,000 for
a willful violation) and criminal penalties depending upon
the nature and seriousness of the violation.
Occupational
Safety and Health Standards
There are two main sets of Occupational Safety
and Health Standards in use today. They are as follows:
Occupational Safety and Health Standards
for the Construction Industry, 29 CFR, Part 1926
Occupational Safety and Health Standards
for General Industry, 29 CFR, Part 1910
Each set of the above standards covers several
safety topics and spells out specific requirements. While
there is some overlap of topics, the standards are different.
Since thermography is not construction work, Part 1910 is
the applicable standard for infrared inspection of electrical
systems.
Part 1910 is divided into several Subparts
labeled A through Z. They are as follows:
1910 Subpart A General
1910 Subpart B Adoption and Extension
of Federal Standards
1910 Subpart C General Safety and Health
Provisions
1910 Subpart D Walking-Working Surfaces
1910 Subpart E Means of Egress
1910 Subpart F Powered Platforms, Manlifts,
and Vehicle-Mounted Work Platforms
1910 Subpart G Occupational Health and
Environmental Control
1910 Subpart H Hazardous Material
1910 Subpart I Personal Protective Equipment
1910 Subpart J General Environmental Controls
1910 Subpart K Medical and First Aid
1910 Subpart L Fire Protection - Other
Fire Protection Systems
1910 Subpart M Compressed Gas and Compressed
Air Equipment
1910 Subpart N Materials Handling and
Storage
1910 Subpart O Machinery and Machine Guarding
1910 Subpart P Hand and Portable Powered
Tools and Other Hand-Held Equipment
1910 Subpart Q Welding, Cutting and Brazing
1910 Subpart R Special Industries
1910 Subpart S Electrical - Definitions
1910 Subpart T Commercial Diving Operations
- Recordkeeping
1910 Subpart U [Reserved]
1910 Subpart V [Reserved]
1910 Subpart W [Reserved]
1910 Subpart X [Reserved]
1910 Subpart Y [Reserved]
1910 Subpart Z Toxic and Hazardous Substance
1910 Subpart S and Infrared
Electrical Inspections
This subpart
addresses electrical safety requirements that are necessary
for the practical safeguarding of employees in their workplaces
and is divided into five major divisions as follows:
(a) Design safety standards for electrical
systems. These regulations are included in 1910.302 through
1910.330. Included in this category are all electric equipment
and installations used to provide electric power and light
for employee workplaces.
(b) Safety-related work practices. These
regulations are contained in 1910.331 through 1910.360.
(c) Safety-related maintenance requirements.
These regulations are contained in 1910.361 through 1910.380.
(d) Safety requirements for special equipment.
These regulations are contained in 1910.381 through 1910.398.
(e) Definitions. Definitions applicable
to each division are contained in 1910.399.
1910.331 defines the scope of Subpart S.
It covers work for (1) premises wiring (within or on buildings
or other structures, and on other premises such as yards,
carnival, parking, and other lots and industrial substations),
(2) wiring for connection to supply, (3) other outside wiring
and (4) optical fiber cable which is installed along with
electrical conductors.
Specifically excluded from Subpart S is work
by qualified persons in generation, transmission, and distribution
of electric energy located in buildings used for such purposes
or located outdoors. Work of this type is covered under Subpart
R. Also excluded is work by qualified persons in communications
installations (also covered under Subpart R), installations
in vehicles and railway installations. Other special industries
are also covered by Subpart R. Employers in the listed industries
should consult this Subpart to ensure compliance.
Qualified persons There are many references
to "qualified" and "unqualified" persons within 1910. From
1910.399 - Definitions and 1910.332, we respectively find:
"Qualified person." One familiar with the
construction and operation of the equipment and the hazards
involved.
"Unqualified person." One with little or
no such training as the qualified person.
1910.333 states that only qualified persons
may work on or near energized electric circuits. Since infrared
inspections of electrical equipment will require a thermographer
to come in close proximity to exposed live conductors, thermographers
must be Qualified Persons in order to comply with OSH Standards.
Training 1910.332 requires that qualified
persons who work on energized equipment be trained in and
familiar with the safety-related work practices as required
by 1910.331 through 1910.335 that pertain to their respective
job assignments. They must also be trained in and familiar
with:
(i) The skills and techniques necessary
to distinguish live parts from other parts of electric equipment.
(ii) The skills and techniques necessary
to determine the nominal voltage of exposed live parts,
and
(iii) The clearance distances specified
in 1910.335 (c) to which the qualified person will be exposed.
Under 1910.333, qualified persons must also
be familiar with the proper use of special precautionary techniques,
personal protective equipment, insulating and shielding materials,
and insulated tools.
Training may be conducted within the classroom
or through on-the-job training.
Selection and Use of Work Practices 1910.333
states that safety-related work practices shall be employed
to prevent electric shock when work is performed on or near
energized circuits. Work practices must protect employees
from direct bodily contact or contact through a conductive
object. Work practices must be suitable for the work conditions
under which the work is being performed and for the voltage
levels of the exposed circuits.
Several work practices are addressed for
those who work on or near exposed energized parts. These include
lockout/tagging, overhead lines, illumination, confined or
enclosed work spaces, conductive material and equipment, portable
ladders, conductive apparel, housekeeping duties, and interlocks.
Thermographers must comply with all work practices which are
applicable to their work.
Of the above work practices, the applicability
of "Lockout and Tagging" confuses many thermographers. Simply
put, Lockout/Tagout is designed to prevent electrocution and
injury while a circuit is being worked on. Lockout/Tagout
renders a circuit inoperative.
Since thermography requires that circuits
be energized, Lockout/Tagout does not directly affect thermography
other than deenergizing certain equipment. Thermographers
should be aware of the importance of Lockout/Tagout and must
never remove or tamper with tags and locks unless they are
qualified to do so.
Use of Equipment 1910.334 states that only
qualified persons may perform testing work on electric circuits
or equipment. All test equipment must be visually inspected
for external damage and defects prior to each use. Equipment
found to be damaged or defective must be removed from service
until it is repaired and rendered safe for use. Test equipment
must be rated for the circuits being tested and operated only
in the environments for which they are designed.
Safeguards for Personnel Protection 1910.335
states that employees working in areas where there are potential
electrical hazards shall be provided with, and shall use,
electrical protective equipment that is appropriate for the
specific parts of the body to be protected and for the work
to be performed. Specific requirements are listed in Subpart
I.
Protective equipment must be maintained in
a safe, reliable condition and shall be periodically inspected
or tested. Nonconductive head protection is required when
there is a danger of contact with exposed energized parts.
Employees are required to wear protective
equipment for the eyes or face wherever there is a danger
of injury to the eyes or face from electrical arcs or flashes
or from flying objects resulting from an explosion.
When normally enclosed live parts are exposed
for maintenance or repair, they shall be guarded to protect
unqualified persons from contact with the live parts. The
use of safety signs and tags warning about electrical hazards
and barricades are required to warn and protect employees.
An attendant is required when signs and barriers do not provide
sufficient warning and protection.
1910
Subpart R and Electric Power Generation, Transmission and
Distribution
Section 1910.269
covers the operation and maintenance of electric power generation,
control, transformation, transmission, and distribution lines
and equipment. These provisions apply to power generation,
transmission, and distribution installations, including related
equipment for the purpose of communication and metering, which
are accessible only to qualified employees. Covered facilities
include utilities and equivalent industrial establishments.
Other covered installations at an electric
power generating station as follows:
1. Fuel and ash handling and processing installations.
2. Water and steam installations providing
an energy source for electric generators.
3. Chlorine and hydrogen systems.
Also included are test sites where electrical
testing involving temporary measurements associated with electric
power generation, transmission, and distribution is performed
in laboratories, in the field, in substations, and on lines.
1910.269 applies in addition to all other applicable standards
in Part 1910.
Training 1910.269 requires that employees
be trained in and familiar with the safety-related work practices,
safety procedures and other safety requirements in this section
as required by their respective job assignments. They must
also be trained in and familiar with any other safety practices,
including applicable emergency procedures (e.g. pole-top rescue)
that are related to their work. Qualified employees must also
be trained and competent in:
(i) The skills and techniques necessary
to distinguish live parts from other parts of electric equipment.
(ii) The skills and techniques necessary
to determine the nominal voltage of exposed live parts,
and
(iii) The minimum approach distances specified
in 1910.269 corresponding to the voltages to which the qualified
employee will be exposed, and
(iv) The proper use of special precautionary
techniques, personal protective equipment, insulating and
shielding materials, and insulated tools for working on
or near exposed energized parts of electrical equipment.
(v) The employer shall determine, through
regular supervision and inspections conducted on at least
an annual basis, that each employee is complying with the
safety-related work practices required by 1910.269.
Employees must be retrained or additionally
trained if supervision and annual inspections indicate that
the employee is not complying with safety-related work practices,
or if new technology, new equipment or procedural changes
necessitate new safety-related work practices. Training may
be conducted within the classroom or through on-the-job training.
Training shall establish employee proficiency
in the required work practices and shall introduce the procedures
necessary for compliance with this section. Once the employee
demonstrates proficiency in the required work practices, the
employer must certify that each employee has received the
necessary training. This certification is maintained for the
duration of employment.
Existing Conditions Prior to the commencement
of any work, all existing conditions related to the safety
of the work must be determined. Additionally, medical and
first aid services must be provided for, including persons
trained in first aid and CPR when the work is on or near exposed
lines or equipment energized at greater than 50 volts. First
aid supplies must be protected from the weather and inspected
frequently to ensure that expended items are replaced.
Job Briefings Job briefings are required
before the start of each job. Briefings are required at least
once per shift for repetitive work or more frequently if significant
work changes occur. Briefings can be short if employees understand
through training and experience the hazards involved; or more
extensive if the work is complicated or hazardous or the employee
cannot be expected to recognize and avoid the hazards involved
in the job. Employees working alone need not conduct a job
briefing. However, the employer shall ensure that the tasks
to be performed are planned as if a briefing were required.
Consultation
Services for the Employer
Employers who want help in recognizing and
correcting safety and health hazards and in improving their
safety and health programs can get it from a free consultation
service funded by OSHA. The service is delivered by State
governments using professional staff.
The consultation program not only addresses
immediate problems but also offers advice and help in maintaining
continued effective protection. The service is confidential.
Additionally no citations are issued as a result of consultation
as long as the employer agrees to correct them in a timely
manner. In order to participate in this program, employers
must contact their regional OSHA office.
The
New OSHA
OSHA and its 25 State partners have had substantial
success. Since 1970, the overall workplace death rate has
been cut in half. OSHA's cotton dust standard virtually eliminated
brown lung disease in the textile industry; deaths from trench
cave-ins declined by 35%; OSHA's lead standard reduced blood
poisoning in battery plant and smelter workers by two-thirds.
Despite these accomplishments, each year
6000 Americans continue to die from workplace injuries; an
estimated 50,000 people die from illnesses caused by workplace
exposure to chemicals, and 6 million people suffer non-fatal
workplace injuries. Injuries alone cost the economy more than
$110 billion a year.
Additionally, in the public's view, OSHA
has been driven too often by numbers and rules, not by smart
enforcement and results. Business complains about overzealous
enforcement and burdensome rules. Many people see OSHA as
an agency so enmeshed in its own red tape that it has lost
sight of its own mission.
In order to increase worker protection and
decrease red tape and paperwork, the Clinton Administration
announced three sets of regulatory reform initiatives in 1995.
These are:
€ The New OSHA: OSHA will change its fundamental
operating paradigm from one of command and control to one
that provides employers a choice between a partnership and
a traditional enforcement relationship.
€ Common Sense Regulation: OSHA will change
its approach to regulations by identifying clear and sensible
priorities, focusing on key building block rules, eliminating
or fixing out-of-date and confusing standards, and emphasizing
interaction with business and labor in the development of
rules.
€ Results, Not Red Tape: OSHA will change
the way it works on a day-to-day basis by focusing on the
most serious hazards and the most dangerous workplaces and
by insisting on results instead of red tape.
Designed to move
OSHA through its next twenty-five years, these changes represent
an opportunity to make workplaces safer while making OSH regulations
and their enforcement less cumbersome. Traditional enforcement
procedures will continue for those employers who neglect safety
and endanger their workers; however, compliance can be simpler
and more effective for conscientious employers.
Conclusion
At the time of publication, there appears
to be nothing that prohibits the infrared inspection of electrical
distribution systems under the current Occupational Safety
and Health Act and its related Occupational Safety and Health
Standards. Confusion among thermographers most likely occurs
in the misquoting/misunderstanding of information or application
of the incorrect standard.
While some of the requirements may seem cumbersome,
many appear to be common- sense principles. Thermographers
and their employers must identify which OSH Standards apply
to their work and ensure that they are in compliance. Failure
to comply can result in serious fines and criminal penalties.
Under the Clinton Administration, OSHA's
mission and role could radically change. Despite these changes,
OSHA will continue to be law and compliance is mandatory.
References
OSHA Home Page, U. S. Department of Labor,
Occupational Safety and Health Administration, http: / / www.osha.gov
Public Law 91-596, Occupational Safety and
Health Act of 1970, amended November 5,1990.
Occupational Safety and Health Standards
for General Industry, Part 1910, U. S. Department of Labor,
Occupational Safety and Health Administration, http: / / www.osha.gov
Occupational Safety and Health Standards
for Construction, Part 1926, U. S. Department of Labor, Occupational
Safety and Health Administration, http: / / www.osha.gov
