More specifically, look at 1910 Subpart S – Electrical. These rules focus on industrial (stamping, vehicle manufacturing, airports, food processing, packaging, general manufacturing, hospitals, etc.) and light commercial operations (administration buildings, warehouses, hotels, entertainment areas, etc.). Utilities and residential are largely excluded from the rule set.
What is the industry consensus for PPE requirements for workers that may pass through an electrical switchgear room or such areas with energized electrical enclosures, where no active work is going on, thus presenting no shock hazard or elevated arc flash risk? NFPA 70E references house keeping practices not requiring an EEWP with the associated caveats, nothing really states arc rated day wear requirements for non electrical workers that pass by energized electrical enclosures during the performance of their duties
Timothy, I have had this question arise often in industrial and utility settings. The answer varies from site owner to site owner. I have seen companies allow anyone to walk through these areas, even with nylon or polyester fabric, and I’ve seen the other extreme of allowing no one into the room, even just to pass through, without a minimum of, for example, 8 calories per square centimeter arc-rated PPE. The answer that you find in NFPA 70E would be found in Table 130.5(C), where the user is instructed to estimate the likelihood of an arc flash incident. This, of course, is assuming all equipment is properly grounded and bonded, thus presenting no shock hazard by just walking through the room. In the case you presented, no active work is being performed to increase the risk of an arcing event. However, we must look fully at Table 130.5(C) and its intent. An asterisk appears on the top right side of the table, adjacent to the words “Likelihood of Occurrence.” This asterisks is found on the next page, and defines the two components of risk as (1) likelihood of occurrence, and (2) severity of injury or damage to health IF an event does occur.
This is where the concept of Best Practice must fall upon the site ownership/employer and electrical safety policies. If I owned an electrical room that had 38 cal/cm2 panels, I would certainly not allow melting fabric to be worn in that room, even by a passer-by. I am a big believer in daily-wear arc flash clothing, or at a minimum, natural fabric clothing in these circumstances. It is amazing to watch how quickly melting fabric ignites during arc testing, but I cannot say it “violates” a standard if someone is allowed into an electrical room dressed like this while performing non-electrical tasks. One could argue, however, that a subsequent injury or fatality, one that could have been prevented by requiring a minimum PPE level to enter such rooms, could violate OSHA’s General Duty clause to protect workers from all known hazards.
You would get 30 differing opinions from 30 so-called experts in this area, and ultimately the responsibility, as always, lies at the feet of the employer. Due diligence is the best approach, and that involves a proper hazard analysis and a follow-up risk analysis when making these decisions.