1910.303(g)(1): “Space about electric equipment. Sufficient access and working space shall be provided and maintained about all electric equipment to permit ready and safe operation and maintenance of such equipment.”
1910.303(g)(1)(i): “Working space for equipment likely to require examination, adjustment, servicing, or maintenance while energized shall comply with the following dimensions, except as required or permitted elsewhere in this subpart:…”
I have always been taught that main electrical disconnects (circuit breakers, knife switches, LOTO Points) must be kept clear according to Table S-1, etc., for many reasons (Electricians need to have maintenance access, you don’t want to have obstructions if you need to access the disconnect in an emergency, you need to be able to stand to the left side of the panel while throwing the breaker, you don’t want a forklift to hit the panel, etc.). I recently came across a situation where a colleague suggested that as long as they are not working on the equipment while energized, 1910.303 (g)(1) does not apply. I question this interpretation.
What about troubleshooting? We don’t require our people to perform LOTO prior to troubleshooting. Do you need clearance for troubleshooting?
What about an emergency when you need to throw the breaker? Do you need adequate clearance to access the emergency disconnect?
If the energy comes into the breaker box from the buss way (even after you’ve thrown the disconnect), do you need the clearance required by Table S-1 based on your proximity to the energy in the conduit from the buss to the breaker box? I would be interested to know how you guys interpret and apply this regulation in your facilities. Are there other codes/standards that would help to reinforce my argument, or is he correct in his interpretation?
MY RESPONSE…
What do your Electrical Safety Related Work Practices call for? I find it hard to believe that a trained and “qualified electrical worker” would even try and question this – usually, this is their #1 complaint to the EHS dept..
Your ESRWPs should call for this clearance for ONE SIMPLE REASON – Grounded Conductors in the immediate area where he/she is doing electrical work is a MAJOR HAZARD to an electrical worker(s). We go to great lengths to ensure these electrical workers are NOT grounded while doing their electrical work. Should they come in contact with any type of ground (e.g., grounded conductor in the area), the path to ground NOW GOES THROUGH THEM, and thus they have a high likelihood of dying. Remember one BASIC FACT about electricity – an old friend (John Collier retired from OSHA and is deceased now – RIP John) explained it like this…
Electricity is lazy; it wants to find the quickest and easiest path to the ground so it can go there and lie down! If this path is through a worker, it spells trouble!
This is a perfect example of why the OSHA requirement needs to be explained to workers rather than trying to defend or justify an LOI or the std requirement. If you have so-called “qualified workers” pushing back on this essential electrical requirement, I would question how your business is “qualifying” the personnel who do electrical work. A truly “qualified electrical worker” will constantly complain about spending 10 minutes moving a bunch of “stuff” for a 30-second metering check. A properly trained electrical worker will know the risk to themselves with this “stuff” around their work area. Having one of them push back on this essential element would worry me and make me question their training.
I do not know the particulars of your specific situation. Still, when we see this type of issue in our compliance audits, we typically find a “magic wand” in the plant engineer’s office that was used to “qualify” the worker to work on electrical. This is not only a compliance issue; this is very dangerous. Also, arc flash training is NOT electrical safety training; rather, arc flash training is just one KEY COMPONENT of an electrical safety training program.
Your local electrical company is a great resource for you regarding electrical safety-related work practices. Your business spends a lot of $$$ with this company, and you would be surprised at the FREE help they will offer you to help you “control the product they are selling” to your business. Often times they will give you a copy of their ESRWPs and even come in and do training (maybe not all that is needed) for your employees.
Just some thoughts and tips. I hope this helps you in your daily safety battles in the plant. Keep up your good fight!