Live working LV - Required controls to satisfy EAWR 1989 Reg 14 2

[ekuegler]

Can anyone outline what is required in terms of controls to conform to the EAWR 1989 Reg 14 - live work on LV system/in the proximity of live conductors.

Your help would be appreciated

 

[ScottyUK]

It's a great piece of legislation isn't it!

No person shall be engaged in any work activity on or so near any live conductor (other than one suitably covered with insulating material so as to prevent danger) that danger may arise unless–
(a)it is unreasonable in all the circumstances for it to be dead; and
(b)it is reasonable in all the circumstances for him to be at work on or near it while it is live; and
(c)suitable precautions (including where necessary the provision of suitable protective equipment) are taken to prevent injury.

You need to be able to demonstrate, possibly in court if things turn to crap, that:

- there are good reasons why the work has to be performed live, for example isolating the equipment to allow dead working might introduce a geater risk elsewhere.

- methods exist which allow the work to be undertaken in a safe manner

- the risks associated with performing the work live can be adequately managed and reduced to an acceptable level

In common with much of the UK's safety legislation, the judgement of what is or isn't an acceptable level of risk in your specific circumstances is yours to make. That's unless something goes wrong, then the judgement gets made by someone else, in court, based on evidence from the HSE. One of the most important questions to ask yourself is 'Could I explain my decisions or my actions to a jury?', and if you find that you can't answer that question comfortably then perhaps you need to re-evaluate what you're doing or what you're considering doing.


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If we learn from our mistakes I'm getting a great education!

 

[ScottyUK]

Have a read of the relevant section of

http://www.hse.gov.uk/pubns/priced/hsr25.pdf

Says more-or-less what I said above but phrases it better. The HSE wrote it, so I would consider it a highly credible source.


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If we learn from our mistakes I'm getting a great education!

 

[ekuegler]

Scotty,

Thanks for the reply, much appreciated.

Have you any info or knowledge of when live working is unacceptable, circumstances or situations.

 

[ScottyUK]

In the eyes of the HSE it is unacceptable pretty much all of the time. You need to have a really, really good reason why it is acceptable to work 'live'. Convenience isn't on the list, neither is production downtime, nor lost profit.


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If we learn from our mistakes I'm getting a great education!

 

[ekuegler]

So with respect to purely HV testing, I.e proving dead prior to implementing the application of a CME, because it is unknown prior to proving dead that the system isn't actually live, my question is that as part of an isolation you apply a CME, but should you also have for proving such a system dead a work control certificate/permit to work To control this.....?

 

[ScottyUK]

Ah! A question!

It's down to how you choose to control your work. Some organisations will require a permit to prove dead, some will allow the proving dead to be undertaken by the permit issuer. The HSE will expect a risk assessment to have been done, but not necessarily a permit. Proving dead should be considered as 'live working' until the circuit is proven dead.


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If we learn from our mistakes I'm getting a great education!

 

[davidbeach]

Wonderful catch 22, that. Must only work dead, can't prove dead without live work.

 

[Marmite]

The way the UK power industry gets around this dilemma is to separate testing from work. Testing is not regarded as work. There are two main safety documents in use, a sanction for test and a permit to work. Both can only be issued once the system has been isolated and earthed. Proving dead before the application of a CME is normally carried out as an item on a switching schedule issued via the control authority centrally or locally. The operator carrying out the test has to be trained, authorised, familiar with the test device etc and would carry out a risk assessment prior to testing. The testing device is proved before and after the test using a proving device. Once proven dead, then you can apply the earths.
Live working on low voltage systems is routinely carried out. Customers expect the power to be on 100% of the time and cable jointing on the existing system is almost always done live.
Regards
Marmite

 

[ScottyUK]

David,

Yes!


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If we learn from our mistakes I'm getting a great education!

 

[ekuegler]

Marmite thanks for reply.

Regarding elect safe working practices, a stipulation to pre planning for breakdown work scopes is mentioned. As each breakdown may differ in complex a routine template for such work in a sense dosnt control or ID all hazards/reducing risk to alarp. How can control be gained, are you aware of any procedure for breakdown work to allow immediate response time/at the same time work be documented/Risk assessed.

 

[ekuegler]

So as such a generalised plan to cover all elect hazards. Not really feasible is my thoughts so risk assessing each time/to allow correct haz ID prior to breakdown work commencing - at the same time delaying response - although complying with EAWR 1989. when pressure is on not always case- I want to try implement safe practice/reduce downtime.

 

[ScottyUK]

You should be able to risk assess the task of proving dead on a particular type of switchgear in advance and document the proving dead procedure. These standard documents would be adequate as a method statement and risk assessment for the task. If written appropriately and followed correctly these should allow you to comply with the EAWR. Obviously if the equipment has been compromised by a fault then you need to look at the specific risks introduced by working on it in a damaged state, or ideally isolate it upstream.

I would caution against rushing in trying to provide an 'immediate response'. That is how mistakes are made and people are hurt. Do what is needed at a pace where you are making considered decisions which you have had time evaluate the outcome. Snap decisions often lead to unexpected consequences.



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If we learn from our mistakes I'm getting a great education!

 

[ekuegler]

Much appreciated Scotty. Exactly same thoughts. I will however implement a routine control certificate for proving dead HV switchgear, the hazards can be pre-emptied and assessed.

Thanks

 

[ekuegler]

Another question guys. Proving dead any system should be regarded as live working until proven otherwise. Do we need to consider for LV/HV for proving dead purposes/testing live the use of Arc flash suits, and having an analysis done to identify boundaries/levels.

Thoughts appreciated as at present no analysis has been carried out nor do we posess any arc flash gear/had any training. UK based FYI.