DOE/EH-0389 --- Issue No. 94-06 --- 07/94

Interpretations (Interps) Line Provides Valuable Information Resources

New Interpretations Developed

Call 1-800-292-8061 to obtain interpretations of all Department of Energy (DOE) Occupational Safety and Health (OSH)-related standards. This toll-free line is available to all DOE and contractor staff.

Calls are received on numerous topics, including hazardous wastes, confined space entry, personnel protective equipment, electrical safety, ladders and scaffolds, dust monitoring, etc. The following are summaries on two new DOE interpretations that were developed in response to calls received on the 800 Interps Line.

Machine Guarding. This request for an interpretation questioned whether using magnetically-attached protective shields is acceptable as machine guarding under DOE-adopted Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1910.212(a)(2), or if the shields must be permanently affixed to the machine. Because the OSHA regulation does not specifically address how to apply machine guarding devices, OSHA encourages employers to abide by the most current industry consensus standards--in this case, American National Standards Institute (ANSI) standards.

ANSI B11.8-1983, "Machine Tools-Drilling, Milling, and Boring Machine-Safety Requirements for Construction, Care and Use," Section 5.6.4 states that "shields shall be effectively mounted through mechanical, magnetic, or other means." While magnetically-attached shields are acceptable, management should review each case individually to ensure that such shields are used correctly and provide acceptable protection.

Working Clearances. In response to a letter requesting a variance from the OSHA requirements contained in 29 CFR 1910.303(g)(1)(i) for working clearances in front of electrical components, this interpretation is provided in lieu of a variance.

Since the letter did not include information regarding the obstructions that limit the working clearances, for the purposes of this interpretation, it is assumed the obstructions are previously installed, permanently affixed structures and/or equipment. This is based upon the presumption that you require portable equipment and/or movable equipment/supplies, etc., to be stored or placed in such a manner as to meet the applicable standards.

The letter stated that an acceptable alternative to the requirement would be to install caution stickers on applicable electrical devices that do not have required working clearance that state "Caution. Electrical panel does not have required working clearance. Electricity must be disconnected before work is performed or work must be done in accordance with Health and Safety Procedures. "In 29 CFR 1910.303(g)(1)(i) it is stated that "...the dimension of the working space in the direction of access to live parts operating at 600 volts or less and likely to require examination, adjustment, servicing or maintenance while alive may not be less than indicated in table S-1."

Additionally, 29 CFR 1910.333(a)(1) states "Live parts to which an employee may be exposed shall be deenergized before the employee works on or near them, unless the employer can demonstrate that deenergizing introduces additional or increased hazards or is infeasible due to equipment design or operational limitations."

It is clear that any work upon electrical components must be done while such equipment is in a deenergized state and locked out or tagged out in accordance with 29 CFR 1910.333 and/or 29 CFR 1910.147. In situations where work must be done on energized parts, both the requirements of 29 CFR 1910.333(a)(2) and 29 CFR 1910.303(g) must be met to protect employees from energized parts.

However, since deenergized equipment does not expose the employee to live electrical circuits as addressed in 29 CFR 1910.303(g), a variance from its requirements is not necessary. While the caution signs described are acceptable to DOE, management must bear in mind that if the act of physically deenergizing the equipment exposes the employee to energized parts, this deenergizing work would be subject to the clearance requirements of 29 CFR 1910.303(g)(1)(i).

Following is a listing of "New DOE Interpretations Available" that were developed in response to calls since November 1992.

New DOE Interpretations Available

Number Topic D92-00-01 electrical panel box clearances D93-01-0301 inspections required for lockout/tagout D93-02-227a fall protection tie off requirements D93-02-227c applicability of lockout/tagout regulations to mixed work D93-02-227d lockout/tagout documentation D93-02-227e requirements for tagout devices D93-02-227f applicability of lockout/tagout regulations to turnover D93-02-227g applicability of lockout/tagout to energized electrical work D93-03-1501 lockout/tagout requirements and electrical disconnects D93-03-0101 guards for drill press chucks D93-03-1801 use of "shall" in 1910.179(e)(4) D93-04-3001 applicability of 1920.1030 to security police D93-04-0101 type B investigations for occupational illness D93-04-0102 recording restricted work days D93-04-0701 ladder step-across distance D93-06-2801 firewatcher as designated employee D93-06-2802 training requirements for fire watchers D93-07-2101 definition of "monthly" in 1910.180(g)(1) D93-08-0601 machine guarding requirements (magnetic) D93-08-006 site assessment w/confined space requirements D93-08-008 confined space requirements D93-08-009 non-permit confined space D93-08-010 motor vehicle seat belts D93-08-011 1926 definition: safety hooks D93-08-012 personnel platforms: 2-block prevention D93-08-015 OSHA poster requirements D93-08-015b fire door requirements D93-08-017 procedures writing D93-08-019 language in contractor safety and health plans D93-08-2301 shower requirements under 1910.120 D93-08-028 electrical panel dead front gap size D93-08-033 crane loads: operator knowledge of load D93-08-035 protective gloves with rotating machinery D93-08-037 respirator selection D93-08-040 radiation protection for female workers D93-08-041 level of training for DOE emergency responders D93-08-045 lifting with track hoe D93-09-010 walking surfaces/hand rails on a tank truck D93-09-014 grounding: motor control circuit D93-09-015 monorails: load testing requirements D93-09-026 confined space monitoring D93-09-032 caution tags in OSHA vs. conduct of operations D93-10-004 means of egress D93-10-014 rollover protection requirements for fork lift truck D93-10-023 lead standard D93-10-026 lead standard: source material D93-10-035 lockout/tagout: human guard D93-10-037 ladder side rails: acceptability of a channel D93-10-038 lockout/tagout requirements for electrical equipment D93-10-039 drench showers: frequency of testing D93-10-053 lead in construction hazard determination D93-10-052 group lockout/tagout D93-10-055 clearance in front of electrical components D93-10-058 marking floor load limits D93-10-058 marking load limits D93-11-012 respirator air cylinder testing D94-01-019 requirements for Ground Fault Circuit Interrupters D94-02-065 asbestos respirator quantitative fit test

If you would like to obtain the complete interpretation on any DOE-adopted or -developed interpretation, call 1-800-292-8061, Monday through Friday, 8:00 AM to 4:00 PM EST.

Guide Offers Updated Interpretations of DOE Standards

Based on the increasing number of unprecedented DOE interpretations, the Office of Environment, Safety and Health (EH) distributed the first update of the Interpretations Guide to OSH Standards in February 1994 to keep DOE personnel and contractors informed of the most current interpretations. A second update to the Guide, distributed in May 1994, contains 123 formal interpretations generated by OSHA and 38 generated by DOE. The entire Guide is available on the Technical Information Services (TIS), an interactive network which provides access to environment-, safety- and health-related databases.

For more information on 1-800-292-8061 or the Guide, contact Jeff Finch (EH-312) at (301) 903-6720.

This Safety & Health Note is one in a series of publications issued by EH to share occupational safety and health information throughout the DOE complex. To be added to the Distribution List or to obtain copies of the publication, call (301) 916-4444. For additional information regarding the publications, call Barbara Bowers, Safety Performance Indicator Division, Office of Environment, Safety and Health, U.S. Department of Energy, Washington, DC 20585, (301) 903-3016
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