Working Alone

Current PCS Policies

SP 212, Personnel may not re-enter an area alone, where hydrogen sulfide gas may be present, without a personal monitor. SP 250, When an employee is required to work alone for a period of two hours or more, he/she shall have some form of communication readily available to them. It shall be the responsibility of the immediate supervisor, or a designated person to periodically check on all employees that are working alone, even if the employee has communication capabilities. SP 424, Any time contract electrician(s) is/are working under an EEWP, a PotashCorp representative shall be present for the duration of that permitted work. SP 424, Everyone working on energized electrical equipment for which a permit is issued must sign under Qualified Employee. In addition, a second qualified person must assist in, or be an attendant to, the work.

MSHA Regulation
56.18020. No employee shall be assigned, or allowed, or be required to perform work alone in any area where hazardous conditions exist that would endanger his safety unless he can communicate with others, can be heard, or can be seen.

OSHA 1910.269(l) Distribution

1910.269(l)(1)(i)at least two employees shall be present while the following types of work are being performed:
Installation, removal, or repair of lines that are energized at more than 600 volts, Installation, removal, or repair of deenergized lines if an employee is exposed to contact with other parts energized at more than 600 volts, Installation, removal, or repair of equipment, such as transformers, capacitors, and regulators, if an employee is exposed to contact with parts energized at more than 600 volts, Work involving the use of mechanical equipment, other than insulated aerial lifts, near parts energized at more than 600 volts, and Other work that exposes an employee to electrical hazards greater than or equal to those4 above cases above.

OSHA 1910.269(l)(1)(i) Exceptions

269 only applies to generation, transmission, and distribution equipment
Applies to 23 kV, 230 kV, mine subs Does not apply to MVCs, MCCs, or emergency backup generators

Does not apply to:

Routine switching of circuits, if the employer can demonstrate that conditions at the site allow this work to be performed safely, Work performed with live-line tools if the employee is positioned so that he or she is neither within reach of nor otherwise exposed to contact with energized parts, and Emergency repairs to the extent necessary to safeguard the general public.

Standards
NESC-2012, 443B. In inclement weather or at night, no employee shall work alone outdoors on or dangerously in the vicinity of energized conductors or parts of more than 750 V between conductors.
EXCEPTION: This shall not preclude a qualified employee, working alone, from cutting trouble in the clear, switching, replacing fuses, or similar work if such work can be performed safely.

NFPA 70E, 130.7 Note 3: When incident energy exceeds 40 cal/cm2 at the working distance, greater emphasis may be necessary with respect to de-energizing before working within the limited approach boundary of the exposed electrical conductors or circuit parts.

Strict Interpretation
269: On generation/transmission/distribution work when using rubber gloves as the only protection (no hot stick or insulated bucket truck), a second qualified person is required
NESC: Also any case of working in bad weather or at night above 750 V, except for switching activities All switching activities are exempted by regulation and standards

In the mine where hazardous conditions exist a second person is required. For electrical work this would be similar to the above case (working on exposed, energized equipment using rubber gloves only) 70E requires greater emphasis for >40 cal/cm2. We provide this by requiring a management review (EEWP).

Liberal Interpretation
MSHA and OSHA working alone rules generally viewed with respect to man down cases in letters of intrepretation. OSHA 269 requires training to receive first aid/CPR within 4 minutes.
Survival rate from fibrillation is >90% if CPR/AED is available within 1 minute Survival rate is 30-50% if CPR/AED is available within 3-5 minutes Survival rate from burns improves greatly if aid is received during the golden hour

Corporate standard is to maintain fatality rates at <0.001%/year (aka remote chance).

Likelihood of fatality exceeded for:
Racking draw-out breakers in or out without adequate arc flash PPE on nonresistance grounded systems Inserting/removing MCC buckets Rubber glove-only work Energized work where the risk of arc flash is entirely dependent on the skill of the employee without adequate arc flash PPE such as cutting energized wires loose or connecting/disconnecting wires onto energized lugs/bus/lines

Minimum Standby Man

Two requirements
Not in any standard but would not be an effective standby without the minimum Trained in at least one emergency release method: Disconnect power. Trained in CPR Have communication available (cell phone, radio)

Question: Would unqualified employees have the minimum required training?