Q: Do I need an arc rated glove to perform work under 29 CFR OSHA 1910.269(l)(8)?
A: NO!! OSHA 1910.269 (l)(8)(v)(A) states:
"Arc-rated protection is not necessary for the employee's hands when the employee is wearing rubber insulating gloves with protectors or, if the estimated incident energy is no more than 14 cal/cm2, heavy-duty leather work gloves with a weight of at least 407 gm/m2 (12 oz/yd2)."
What does that mean? If the estimated incident energy is less than 14 cal/cm2, wear a good quality leather work glove (a good quality leather driving glove). If the estimated incident energy is 14 cal/cm2 or more, wear rated insulating rubber gloves and a leather protector. There is no reason to spend an additional 30% for an arc rated glove.
In fact, OSHA begins the above paragraph with "arc-rated protection is not necessary for the employee's hands…" specifically to assure the employer arc rated gloves are not required. The 2017 NESC 410 A.3.b states the exact verbiage as OSHA 1910.269 (l)(8)(v)(A).
The electric utility does not follow the NFPA 70E, however, NFPA 70E Table 130.(C)(10) specifies:
Hazard/Risk Category 3 & 4 covers work involving:
This work typically requires rated insulating gloves and protection, and Note 2 states:
"If rubber insulating gloves with leather protectors are required by Table 130.7(C)(9), additional leather or arc-rated gloves are not required. The combination of rubber insulating gloves with leather protectors satisfies the arc protection requirement"
So why are so many utilities paying the extra price, up to 30% more, for arc rated gloves when they are not required or necessary?
Fast talking glove sales representatives have convinced many that arc rated gloves are required. They are totally incorrect. These are the same sales people who said OSHA required arc rated harnesses, when that statement is totally false and incorrect also.
A good quality leather glove will provide as much arc flash protection as an advertised arc rated glove. And, the typical anticipated arc flash levels for energized T & D work is 8 cal/cm2, except 480-volt self-contained meters which require Class 0, insulating gloves and leather protectors.
During a recent visit to an ESCI customer I found what looked like a well-worn pair of Youngstown arc rated work gloves. The glove was made in Pakistan and carried an arc rating of 72 cal/cm2 (I would like to see the real test data)!!!
The workers stated the gloves last only a few days or weeks before they fall apart and were hoping to get their leather gloves back.
ASTM does have a standard for arc rated gloves. ASTM F2675/F2675M-19 "Standard Test Method for Determining Arc Ratings of Hand Protective Products Developed and Used for Electrical Arc Flash Protection," is the spec for this type of gloves. However, ASTM F2675/F2675M-19, Section 1.2.2 states:
"Hand protective products tested by this test method are new and ratings received by this method may be reduced or eliminated by hydrocarbon loading (gasoline, diesel fuel, transformer oil, etc.), sweat, dirt, grease, or other contaminants. The end user takes responsibility for use of hand protective products tested by this method when contaminated in such a manner that could reduce or eliminate the arc rating of the hand protective products."
So, the above paragraph testifies the arc rating of these gloves are only valid when they are brand new and still in a protective box. When the glove is taken out and used, the arc rating is eliminated.
David Wallis (ESCI Director of Standards and Work Rules) and I attended and participated in the Spring ASTM F18 Committee Meeting in Denver recently. A draft standard covering non-leather protectors has been in draft format for more than 7 years. The standard would cover non-leather protectors which have an arc rating, cut and puncture rating, and chemical rating. A glove meeting this standard currently does not exist and may never be developed, but some ASTM members are pushing for an arc rated protector (sales and testing organizations).
During the working group meeting on this draft, four of more than 10 negatives were discussed before our 2-hour time frame ran out. There are so many problems and inconstancies with the current draft, the draft has been sent to a small working group for a rewrite. A number on the committee, mostly end users (utilities) do not have any interest in the draft. I don't think this standard will ever see the light of day. But again, it is the arc flash people who are pushing this unnecessary standard.
If you are in leather gloves stay with what works and is cost effective. If you have moved to arc rated gloves, I strongly suggest you consider going back to leather gloves. And, it is always a wise to by U.S.-made gloves. Gloves and FR clothing from overseas often will state their product meets ASTM standards, but often do not. Unfortunately, we do not have any policing power on these products coming in from overseas.
Q: I understand there is a new temporary enforcement policy for crane operators.
A: Yes, Federal OSHA has again delayed the "Operator's Qualifications" enforcement till April 15, 2019. In a Federal OSHA enforcement memo, dated February 7, 2019, OSHA states:
"OSHA has received feedback from the construction industry indicating some employers may need more time to document evaluations of crane operators prior to the February 7, 2019, effective date. During the first 60 days of enforcement (until April 15, 2019), OSHA will evaluate good faith efforts taken by employers in their attempt to meet the new documentation requirements for operators of cranes used in construction. During this period, OSHA intends to offer compliance assistance, in lieu of enforcement, for those employers who have evaluated operators in accord with the final rule and are making good faith efforts to comply with the new documentation requirement. If, upon inspection, it is determined that an employer has failed to make sufficient efforts to comply, OSHA should cite for that deficiency."
What does this all mean?
If you have chosen to have employees qualified to operate cranes under 29 CFR Part 1926 "Cranes and Derricks in Construction," you have a bit more time to get this accomplished. However, you must be working toward that end.
In an ESCI letter to our customers dated November 26, 2018, I stated:
If you are a small or medium size utility, you don't want to go there. The processes to get an employee certified every five years, then develop an ongoing program to oversee their competency will be a major task.
Q: When did Federal OSHA revise OSHA 1910.269 and OSHA 1926 Subpart V?
A: On April 11, 2014, Federal OSHA published the updated OSHA 1910.269 and OSHA 1926 Subpart V.
Q: I am being told by some in the electric utility industry that my harness must be "arc-rated."
A: A quote from David Wallis, ESCI Director of Standards and Work Rules, and the author of 29 CFR OSHA 1910.259(l)(8):
"FR Body Protection which includes FR clothing and proper PPE is for the protection of the body. A harness does not provide arc flash protection for the body."
OSHA requires the harness to meet the ASTM F887-04 or later standard. For a harness to be compliant with ASTM F887 the manufacturer must expose the harness to a 40 cal arc flash, then immediately drop test it. If the harness passes, it is compliant with ASTM F887.
David recently answered a similar question with the following:
Q: 30 of the Q&A on the electric power standard (osha.gov/dsg/power_generation) states that harnesses and shock-absorbing lanyards meeting ASTM F887-04, or later versions of that standard through ASTM F887-13, be deemed to comply with the provisions requiring personal fall arrest equipment used by employees who are exposed to hazards from flames or electric arcs to be capable of passing a drop test after exposure to an electric arc with a heat energy of 40 ± 5 cal/cm2.
A: OSHA estimated that nearly all fall protection equipment in use in electric power industries in 2014 met ASTM F887-04 or later and that employers would not need to replace any fall protection equipment because of the new arc-related testing requirements. (The fall protection costs assumed in the economic analysis resulted from the purchase of work positioning equipment that would arrest an employee's fall.) Note that there is no such thing as fall protection equipment with an arc rating. OSHA relied on the definition of "arc rating" in ASTM F1506-02ae1, which read: "the maximum incident energy (E1) resistance demonstrated by a material prior to breakopen or at the onset of a second-degree burn."
To my knowledge, no fall protection equipment has been tested to achieve an arc rating meeting this definition by the test method in ASTM F1959. (Nor will this equipment meet ASTM F1506, which OSHA relies on for arc ratings.) In addition, the purpose of assigning an arc rating for a material is to determine that material's ability to protect an individual from the heat energy from an electric arc. Neither harnesses nor lanyards will provide such protection. Consequently, any "arc rating" provided by the manufacturer of such equipment would not be valid. The purpose of the arc-related requirements in §§1910.269(g)(2)(ii) and 1926.954(b)(1)(ii) is to ensure that the fall protection equipment will arrest a fall after exposure to an electric arc. It is not to protect an employee wearing the fall protection equipment from the heat energy from an electric arc.
Q: Two qualified workers cover-up all three phases of a 12.5 kV overhead pole including covering all three phases with rated plastic cover-up, the arms and pole with rated cover and even the common neutral. Both workers then return to the ground and one worker leaves the worksite. Can one qualified worker by them self go back up, enter MAD and install a cutout on the arm with everything completely covered with rated cover-up?
A: No, per OSHA 1910.269(L)(1), one qualified worker cannot enter MAD and do any work by them self, even with all the exposed conductors and equipment covered with rated cover-up. It requires two workers, one to perform the work and the second to be a safety watch for the first to perform any work within the MAD of a 12.5 kV line.
Q: A follow-up question to the one above. Can one qualified worker wearing rated gloves and sleeves enter MAD and install a cutout on the arm with everything completely covered with rated cover-up?
A: No, it does not matter if the worker is wearing rated gloves and sleeves and all exposed lines and equipment are covered with rated cover-up, it will take two workers to perform any work within MAD.
Q: There are a number of unanswered questions related to when rated FR clothing is required when performing particular tasks at our electric utility. Are meter readers who only read meters required to wear rated FR clothing? How about an engineer who is a qualified worker to enter a substation to perform engineering assessments and will not be operating any equipment?
A: The 2007 NESC 410.A requires the employer to perform a hazard assessment to determine if an arc flash could occur while performing various tasks. And, a hazard assessment would find no arc hazard potential for a meter reader simply reading meters. Also, a hazard assessment would find no arc hazard potential for an engineer who enters a substation to conduct simple engineering assessments. Neither the meter reader nor engineer in these two identified tasks would be required to wear rated FR clothing.
Q: I represent an electric utility company which owns generation, transmission, substations and a distribution system. Which FR clothing standard must my company follow; the 2017 NESC or the 2018 NFPA 70E?
A: As an electric utility company your facilities from the generator to the customer's service point is covered by the 2017 NESC and the FR clothing requirements of NESC 410.A. NFPA 70E has no jurisdiction from the generator to the customer service point. Where NFPA 70E has jurisdiction is on the customer's side of the service point. This also includes any electric utility facility which is not an integral part of the generation, transmission and distribution system. Your company's corporate office building, the engineering and operations service center buildings, the storeroom and other similar facilities are under NFPA 70E. Some utilities can, and do, apply the 2018 edition of NFPA 70E in generating plants to comply with OSHA's arc-flash protection requirements in §1910.269(l)(8). Also remember, if you send one of your qualified electrical workers trained under OSHA 1910.269 into the customer's home or facility, you are in the land of NFPA 70E and the National Electric Code (NEC) not the NESC.
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