Safety Protocols for Sewer Cameras
By: Grant Whittle
This is layman's attempt to write his personal understanding of the memorandum and is not to be construed as legal advice. Note that this is much more comprehensive than NASSCO's email sent out recently.
The OSHA memorandum was issued on 9/25/02 and only addresses non-man-entry, remote operation of sewer cameras. If confined space entry occurs, 1910.146 (which calls for Class I Div 1 equipment) will govern. This is not entirely expected, but since man-entry with energized equipment is not generally required, this is readily complied with.
If hazardous concentrations of gases are or may be present then the sewer must be classified as either Class I Div 2 or Class I Div 1. When hazardous concentrations have been shown to not be present and may not be present, then the sewer can be deemed an ORDINARY work location. This is in keeping with our historical, standard safety protocols and is in keeping with the published NASSCO position papers.
When a site has been deemed an ordinary work location, NRTL certification is still required, but only for protection against ordinary electrical hazards. In other words, standard sewer cameras do not have to be certified as intrinsically safe or "explosion proof", in order to be used in an ordinary work location. Many of us, including myself, have long recognized the NRTL certification requirement and have accepted and expected it. The position that NRTL certification of sewer cameras didn't require "intrinsically safe/explosion proof" equipment has been confirmed.
As expected, when fire hazardous locations are actually present, THEN the equipment must be certified as safe for such an environment (however, not necessarily "intrinsically safe/explosion proof" when used in a Class I Div 2 environment). Once again, this is reasonable and expected.
For existing equipment manufactured prior to 9/25/02, self-certification by the employer is apparently also acceptable where the employer has demonstrated that the equipment is safe for use in the classified hazardous location. An acceptable abatement plan for non-certified equipment will be developed in conjunction with stakeholder input. Pending further notice, no citations will be issued for employers using PREVIOUSLY manufactured and unapproved equipment. This is a reasonable solution for allowing the continued use of existing equipment until re-tooling to NRTL approved equipment can gradually be accomplished by the industry. Once again, this is in keeping with what the industry desired in the event that NRTL certification was required.
ALL new equipment sold as of 9/25/02 MUST be NRTL certified for their applicable uses. While the major equipment manufacturers are likely prepared for this change in enforcement policy, it may place a significant burden on smaller equipment manufacturers that may not be ready.
Where non-NRTL approved cameras are in use and employers have not self-certified the equipment as safe for the site conditions, then the employers must ensure employees are not exposed to hazardous conditions. OSHA specifically states that they recognize that most cameras are operated remotely away from the potential hazard. In such a case, 1910.307 does not apply and the equipment does not have to be hazardous location certified. However, operators must:
de-energize cameras during placement
utilize a lockout/tagout system to prevent worker exposure
demarcate a safe area and remain at a safe distance while energized.
I would imagine that in many cases, employers will choose to follow the above additional safety protocols (even in locations shown to be non-hazardous) to limit liability risk.
Another immediate potentially negative impact (in addition to the impact on camera manufacturers not already prepared with NRTL certification) regarding this memorandum is how non-NRTL certified "push cameras" will be affected. What will OSHA deem to be a "safe distance"? Push cameras, of course, must be operated from the edge of the manhole.
All will benefit if the industry (perhaps NASSCO) documents "Standard Safety Protocols for the use of Electrical Equipment in Sewers" in keeping with the new OSHA guidelines. Without such an industry consensus document, each employer will be forced to independently defend any safety protocol decisions they make.