R. James Seffrin
Jersey Infrared ConsultantsP.O. Box 39, Burlington, NJ 08016 609-386-1281
Presented at IR/INFO ’96, Orlando, Florida
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.
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.
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.
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
OSHA Handbook for Small Businesses, OSHA 2209, U. S. Department of Labor, © 1992.
Training Requirements in OSHA Standards and Training Guidelines, OSHA 2254, U. S. Department of Labor, © 1992.