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 in which a colleague suggested that as long as they are not working on the equipment while energized, then 1910.303 (g)(1) does not apply. I question this interpretation.
What about trouble shooting? We don’t require our people to perform LOTO prior to trouble shooting. Do you need clearance for trouble shooting?
What about an emergency when you need to throw the breaker? Do you need adequate clearance to access the emergency disconnect?
If energy is coming 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?
Thank you in advance for your help,
What does 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 ESRWP's 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 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 deceased now - RIP John) explained it like this....Electricity is lazy; it wants to find the quickest and easiest path to ground, so it can go to ground and lay down! If this path is thru 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 a LOI or the std requirement. If you have so called "qualified workers" pushing back on this most basic electrical requirement I would be questioning how your business is "qualifying" the personnel who do electrical work. A truly "qualified electrical worker" will be complaining all the time about having to spend 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" lying around their work area. Having one of them push back on this basic element would worry me and make me question their training.
I do not know the particulars of your specific situation, but when we see this type of issue in our compliance audits we typical find a "magic wand" in the plant engineers 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; but rather arc flash training is just one KEY COMPONENT of an electrical safety training program.
A great resource for you in regards to an electrical safety related work practices is your local electrical company. 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!