Take 5 for Safety

1
Take 5 for Safety

• 10CFR851 and Electrical Equipment Installation

2
When Does 10CFR851 Apply?

• DOE interpretation of 10CFR851
• The great majority of the referenced standards
  contain language indicating that they apply to
  design and construction or, in the case of the
  National Electrical Code, installationsnot to
  existing facilities or existing electrical
  systems. In addition, many of the standards
  clearly indicate that they are not intended to be
  applied retroactively.

3
More on 10CFR851

• DOE indicates if the contractor is not installing
  , then NFPA 70 does not apply
• In addition, the enforcement guidance states
  that
• Additions, alterations, or repairs to any
  building, structure, or premises shall conform to
  that required of a new building without requiring
  the existing building to comply with all the
  requirements of this code

4
OSHA and 10CFR851

• When 10CFR851 went into effect, it made OSHA a
  referenced standard
• On August 13, 2007, OSHA ruled that many
  electrical equipment rules are fully retroactive,
  and apply to particular types of installations
  regardless of when they were installed
• This contrasts with the common practice of OSHA
  and many other regulators to grandfather
  facilities or operations in place when a
  regulatory requirement takes effect

5
OSHA Requirements Made Retroactive

• Examination, installation, and use of equipment
• Splices
• Arcing parts
• Marking
• Identification of disconnecting means
• Guarding of live parts 600 volts (V) or less
• Grounding terminals and devices
• Over current protection (600 V nominal or less)
• Grounding systems, connections, path, supports
• Grounding non-electrical equipment
• Grounding methods for fixed equipment
• Uses of flexible cords and cables
• Splices for flexible cords and cables

6
US Naval Shipyard