While the use of Personal Protective Equipment (PPE) is a general requirement within the construction environment, it is worth reminding employers, and our members, that from the hierarchy of hazard control options available, PPE should be the last option chosen. In fact, most OSHA regulations specifically require the use of engineering and administrative controls before PPE options are selected.
When identifying overall risk of injury relative to a task, or working environment, two primary factors are measured. Probability of exposure to the hazard and Severity of outcome (injury). When PPE is selected, it only reduces the potential severity of injury. It doesn’t eliminate the hazard and, in some cases, it can arguably increase the probability of exposure. The use of voltage rated gloves and leather protectors during energized work tasks comes to mind.
One of my first experiences with V-rated gloves during energized work was with a pair of class 2 gloves that were way too big for my hands. We were exposed to 480 volts of electrical potential however, not only were the gloves too big, they were rated for 17000 volts and were too thick to allow the basic manual dexterity needed to manipulate tools and conductors.
The Center for Disease Control (CDC) / National Institute for Occupational Safety and Health (NIOSH) have ongoing research studies with a focus on improper fitment of PPE as a causal factor of injuries. NIOSH is the agency under the Department of Labor that conducts research and makes recommendations to OSHA for the prevention of work-related injury and illness.
In response to these recommendations regarding improper fit, OSHA again is proposing new regulations aimed at construction employers, those working under 29 CFR Part 1926 Subpart E, to clarify exactly what is required when PPE is chosen to mitigate risks. OSHA last updated their PPE rules in 2008 when they clarified exactly what types of PPE had to be provided and paid for by employers. This time, the focus is on adding language requiring proper fitment of PPE.
Currently, the construction regulations only hint at proper fitment compared to language found in OSHA’s General Industry PPE regulations, Subpart I. Here, it specifically states that employers must perform and document a written PPE Hazard Assessment and then select PPE that is appropriate for the hazard and properly fits each employee.
Public hearings wrapped up in late September and I would expect OSHA to adopt clarifying language before the end of 2023. As with the adoption of any new OSHA regulation, local OR – OSHA and WA-DOSH compliance officers will have a renewed interest in our employer’s PPE selection, including proper fitment, and training programs.
NIETC Update on NFPA 70B Relationship to NEC & 70E
The NIETC has developed an informative presentation to help contractors and members better understand the application of the new NFPA 70B, 2023, Standard for Electrical Equipment Maintenance. While not formally adopted by OSHA or other agency yet, providing guidance to owners of electrical equipment on the reasons why preventative maintenance is so critical can lead to improved safety for our teams and reliability of electrical systems for owners. Additional benefits include proper selective coordination, short circuit studies, arc flash hazard labels and additional work for our contractors and electricians. Contact Barry for more information.
Instrumentation Class
OSHA Again Clarifies PPE Requirements for Construction Employers
While the use of Personal Protective Equipment (PPE) is a general requirement within the construction environment, it is worth reminding employers, and our members, that from the hierarchy of hazard control options available, PPE should be the last option chosen. In fact, most OSHA regulations specifically require the use of engineering and administrative controls before PPE options are selected.
When identifying overall risk of injury relative to a task, or working environment, two primary factors are measured. Probability of exposure to the hazard and Severity of outcome (injury). When PPE is selected, it only reduces the potential severity of injury. It doesn’t eliminate the hazard and, in some cases, it can arguably increase the probability of exposure. The use of voltage rated gloves and leather protectors during energized work tasks comes to mind.
One of my first experiences with V-rated gloves during energized work was with a pair of class 2 gloves that were way too big for my hands. We were exposed to 480 volts of electrical potential however, not only were the gloves too big, they were rated for 17000 volts and were too thick to allow the basic manual dexterity needed to manipulate tools and conductors.
The Center for Disease Control (CDC) / National Institute for Occupational Safety and Health (NIOSH) have ongoing research studies with a focus on improper fitment of PPE as a causal factor of injuries. NIOSH is the agency under the Department of Labor that conducts research and makes recommendations to OSHA for the prevention of work-related injury and illness.
In response to these recommendations regarding improper fit, OSHA again is proposing new regulations aimed at construction employers, those working under 29 CFR Part 1926 Subpart E, to clarify exactly what is required when PPE is chosen to mitigate risks. OSHA last updated their PPE rules in 2008 when they clarified exactly what types of PPE had to be provided and paid for by employers. This time, the focus is on adding language requiring proper fitment of PPE.
Currently, the construction regulations only hint at proper fitment compared to language found in OSHA’s General Industry PPE regulations, Subpart I. Here, it specifically states that employers must perform and document a written PPE Hazard Assessment and then select PPE that is appropriate for the hazard and properly fits each employee.
Public hearings wrapped up in late September and I would expect OSHA to adopt clarifying language before the end of 2023. As with the adoption of any new OSHA regulation, local OR – OSHA and WA-DOSH compliance officers will have a renewed interest in our employer’s PPE selection, including proper fitment, and training programs.
NFPA 70E 2024 Revisions – Normal Operating Condition
NFPA 70E 2024 Revisions – Normal Operating Condition The evolution of the Standard for Electrical Safety in the Workplace, NFPA 70E, continues with the latest 2024 edition, which supersedes all previous versions even though we are still in 2023. As such, the NIETC Energized Electrical Work Sample Policy I maintain is in the process of […]
Apprentice Termination Notice ROF
Electrical Vehicle Infrastructure Training Program (EVITP)
EVITP- Get Certified “for free”
The BALMCC has offered to reimburse any member who has completed the EVITP online course and certification exam.
Members should register for the course now, as the sponsorship will end July 2023.
With an increased interest in “going green” and Electric vehicle Infrastructure at a local and National level, the EVITP certification is a worthy accomplishment that could open doors to future opportunities only available to Certified installers.
The Training Center will facilitate the documentation process of notifying the BALMCC upon course completion to reimburse those that have become Certified.
For course info: https://secure.tradeschoolinc.com/v5/nietc-org/classSchedule/index.php
Oregon to Washington Reciprocation
If you have an Oregon General Journeyman License you may reciprocate to Washington to acquire your Washington Certificate.
The following is from the Washington L&I website:
“Washington reciprocal certificates are generally available to those electricians who obtained their Oregon general journeyman electrician (J) licenses after completing 8,000-hour Apprenticeships requiring at least 576 classroom hours of education and passing Oregon exams. Anyone having an Oregon General Supervising Electrician (S) license obtained by Oregon examination is also eligible.
If this describes you, and you have never held a Washington (01) general journey level electrician certificate before, or failed to pass an exam for one in the last two years, and you are not otherwise disqualified by conditions in WAC 296-46B-942(20), you are likely eligible.”
To apply, submit an Application for a Reciprocal 01 General Journey Level Electrician Certificate (F500-148-000).
Here is the link: https://lni.wa.gov/forms-publications/F500-148-000.pdf
No waiting periods apply. Oregon license holders can apply any time after they receive their Oregon license.
For licensing verification from Oregon, submit Part C of the Washington reciprocal application to Oregon as follows:
By mail:
Department of Consumer and Business Services Building Codes Division
PO Box 14470
Salem, OR 97309
By fax: 503-378-2322
Oregon charges no fee to process verification requests. Once completed, the original form will be returned by mail if you do not provide instructions requesting it be returned by fax and a fax number to send it to. Please direct questions about Oregon licensing verification to:
license.bcd@oregon.gov.
NIETC Graduation Ceremony at the Hyatt Regency Hotel
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