The employer has the duty to establish, document, and implement an electrically safe work policy [110.2(A).]
This policy must meet two objectives:
- Require hazard elimination to be the first priority in the implementation of safety-related work practices.
- Comply with Subsection 110.2(B).
Let’s look at what these entail, starting with the first requirement. To understand that requirement, we must go to the hierarchy of risk control methods [110.2(H)(3)].
Elimination is not moderation. Just because you reduce the exposure or use better personal protective equipment does not mean you have eliminated the hazard. OSHA says, “Elimination makes sure the hazard no longer exists.”
Some examples in electrical work include:
- Eliminating the arc flash hazard by installing an infrared window.
- Eliminating live terminal hazards during voltage measurements by use remote measurement or a local panel meter.
- Eliminating a slew of hazards by scheduling the work during a shutdown, shift change, or other significant window in which entire lines or entire areas can be de-energized.
Subsection 110.2(B) tells you when energized electrical circuits must be put into an electrically safe condition. Subsection 110.2(B) starts by saying this applies to energized electrical conductors and circuit parts that operate at voltages equal to or greater than 50V. Then it says you need only one of these two conditions to be true for this requirement to apply:
- The employee is within the limited approach boundary.
- The employee interacts with equipment where conductors or circuit parts are not exposed but an increased likelihood of injury from exposure to an arc flash hazard exists.
This seems simple and straightforward, but next is where things start to get tricky. There are five exceptions — and those are not so simple and straightforward.
Exception No. 1. Normal operation of the electrical equipment is permitted where a normal operating condition exists. But what is a normal operating condition? It’s one that meets all seven of the conditions enumerated in the Exception. For example, equipment covers are in place and secured. Another requirement is the equipment must be properly installed; Informational Note 1 provides some guidance on what this means.
Exception No. 2. You can operate an energized disconnecting means or isolating element to achieve an electrically safe condition. But you must perform a risk assessment that results in no unacceptable risk being identified.
Exception No. 3. You can work it hot. But only where the employer can demonstrate that the task to be performed is infeasible in a de-energized state. The Informational Note following this exception provides some examples.
Exception No. 4. The employer can demonstrate that it is more hazardous to work it de-energized rather than hot. The Informational Note following this exception provides some examples.
Exception No. 5. At first glance, this appears to restate what Subsection 110.2(B) says about 50V or over, just in a different way. That’s not really the case. All circuits operating at 50V or more fall under the aegis of 110.2. But for those operating below 50V, additional considerations must be made.
Exception No. 5 isn’t the usual exception to the rule — it’s an exception to the limits of the rule. The “50 and over” are always covered by the rule (except for the other four exceptions). Some “under 50” installations might also be covered by it. You can be badly burned by a 12V battery. Many UPS systems contain batteries operating at 48V.
This exception wants you to consider the capacity of the source and to consider any overcurrent protection between the source and the worker. And then determine if there is increased exposure to electrical burns or explosion due to electrical arcs.
Section 110.2 closes by stating you can’t consider electrical conductors and circuit parts to be safe until all conditions of Section 110.2 are met [110.2(C)].
