This variance provides us with some detailed insight in what OSHA accepts as an “alternative” to LOTO. Facilities do not have to request a variance for their “minor servicing” exception; however, this variance does provide us with some valuable insights into what OSHA believes is an “acceptable alternative” to LOTO when using these alternate methods to protect employees/contractors. Many will be shocked at the level of detail OSHA expects and their layered approach to protecting the workers who perform this deviated task. I was also surprised that OSHA did not just require the business to install a LOCAL DISCONNECT that the worker could use; as the entire premise of this “variance” is based on the energy isolation device (EID) is located in the a Motor Control Room (MRC) or as some will call them a Motor Control Center (MCC). The business claims the workers who do the maintenance/servicing task are NOT qualified electrical workers and thus should not be using the EID in the MCR due to their exposures to arc flash??? I am guessing this steel mill may have some very old electrical rooms and thus there is an exposure to arc flash hazards by merely being in the MRC/MCC. If these electrical boxes are enclosed like most modern MRC/MCC rooms I am at a loss as to how there is an Arc Flash Hazard. If this is indeed OSHA’s position that ONLY qualified electrical workers can throw disconnects/breakers that are safely enclosed in an electrical enclosure then we just made our Electrical Department the “Masters of LOTO” and we better be hiring a heck of lot more of these folks as many LOTOs involve isolating electrical energy sources in these electrical enclosures. None the less, take a look at this variance and we can see the lengths at which OSHA made this business go to to replace LOTO…
PLEASE NOTE: This is in NO WAY an endorsement of this practice or the safety systems mentioned in this article.