Training requirements
Hi folks,
I hope you all had a great time during the holidays.
I have two questions. First, when changing light bulbs in a highly traffic area, the most prudent way to do it is to have the area you are working in barricaded, correct? Also, the electricity needs to be turned off, independently the voltage of the light bulbs you are replacing?
My other question is, when using
a service elevator (with a pulley system) should training on proper use be provided? By whom? Should there be signage or any other information to help the user avoid facing an injury?
I would be very grateful if you could provide any resources related to these questions.
Comments (3)
OK I will take a shot:
For both:
The EHS textbook answer is both tasks should have a JSA or Hazard Analysis performed. There in lies the answers.
For the Light Bulb: First you do not say where the light bulb is other than "high traffic" Is it on the ceiling, on the wall, in a machine, in a light fixture, in a table lamp, or what? Is it a Regular old light bulb, fluorescent, high energy, or what? Where is the switch? How is it wired? How is a person going to get to the light bulb, just reach, use ladder, or manlift?
Let's say it is just an old light bulb on the hallway ceiling that a person may reach standing. If the light switch is in easy reach (control) of the person the switch must be off and you reach up and change it. Bang - Bang, job done. If the light switch is not in reach the switch needs to be locked out using a common lockout device and lock. As far as the traffic if it is hazardous to anyone barricades are a good idea. (One reason for a JSA). Basically the more hazards the more controls! You may have to consider the training of the assigned employee and even PPE in the right circumstances!
To my knowledge on the elevator not much in 1910 on elevators, possibly more in 1926 and I think there is more in 1917 if in Maritime. What there is in 1910 is in Subpart F. It is short. Again you need to do a Hazard Analysis and go from there.
https://www.ecfr.gov/current/title-29/subtitle-B/chapter-XVII/part-1910/subpart-F
Fitz covered most of it here, so good job, Fitz!
On your first question, yes, you're correct - it needs to be somehow barricaded if you can't do it from ground level. As Fitz mentioned, if you have to work from a ladder, MEWP, scaffold, etc. in a high-traffic area, you need to properly secure the area. Since you mentioned it's a high-traffic area, you need to evaluate whether a barricade is sufficient. Do you also need signage? An attendant? Signage and/or attendants are other protective measures used in electrical work in high-traffic areas when cones or other solid barricades aren't sufficient.
However, it's important to note that electrical work has its own set of LOTO requirements found in 1910.333, NOT 1910.147 (although OSHA still deems it "acceptable" to follow LOTO requirements of 1910.147 when performing elctrical work). With that being said, if you go by NFPA 70E and OSHA 1910 Subpart S, then changing out a light bulb is considered "energized work", therefore either requiring you to perform LOTO - unless it meets one of the four "justifications" for performing energized electrical work found in 1910 Subpart S/NFPA 70E (which I doubt it does), in which then you'd have to get an energized electrical work permit. The light switch can be used as a "disconnecting means" for LOTO as long as it meets the definition found in NFPA 70 (NEC). Remember - even if it's only 120VAC, a 120VAC shock hazard can still be fatal. It only takes around 100mA to be fatal.
Regarding your service elevator question, are you referring to manlifts used to transport personnel between floors of a building, which are covered by 1910.68? Or are you referring to something different?