I expect shortly someone will need me to affix an A4 paper at my monitor
saying "Monitor screen. Read here what computer tells you."
 
Best Regards
Piotr Galka
MicroMade
Poland
 

        ----- Original Message ----- 
        From: Flavin, John <mailto:john.fla...@teradata.com>  
        To: EMC-PSTC@LISTSERV.IEEE.ORG 
        Sent: Thursday, July 30, 2009 7:56 PM
        Subject: Workplace Safety Rules



        I like to know this group's experiences regarding the following, which 
has
been put into my lap to resolve. 

        Our plant manager recently arranged a class on electrical safety (based 
on
OSHA regulations and the NFPA 70E standard) for our engineering staff who work
in all of our labs. The instructor was given a tour of our facility, including
our Safety and EMI labs (due to the large size and power requirements of our
products, we have our own safety and EMI labs.  Safety testing is  witnessed
by a test engineer from an outside lab, which writes the CB reports for us;
our EMI lab is NVLAP accreditted). 

        During the course of the class, the instructor showed several 
"examples" of
items taken from both these labs as possible items which were "unsafe". For
example, he showed a power cord which had a section of the outer insulation
stripped off, so that the individual insulated conductors were visible, and
asked if this was safe. (How else do you put a current clamp around one
conductor in a 3phase, 5 wire cord?). Our plant manager wanted to know why a
32A pin and sleeve connector with the appropriate HAR cordage (which we use
when our product is sold in Europe) didn't have 6 gauge UL approved cordage.
Adapters to allow us to connect our EUT to LISNs and CDNs for EMI testing
likewise were suspect.


        There were other examples, but you get the idea. We're not talking about
using wire nuts and duct tape to kludge together some AC cords to provide 50A
service to our product. All these adapters have been built for a specific
purpose, and use the appropriate sized conductors for the rated current of the
plug/connector.

        The class also covered activities which can only be performed by a 
"qualified
worker" (as defined by OSHA). Examples given were using a voltmeter to read AC
line voltage, or replacing plugs/connectors on AC mains cords. As we test our
products for both domestic (60Hz) and European (50Hz), we have two large
synthetic power sources, and to avoid destroying very expensive racks of
equipment, we routinely check the AC voltage before we plug in our products.
Apparently, we are not qualified to do this.

        I understand our plant manager's concern that OSHA might cite some of 
these
things as safety violations, which would cost us $$$ to rectify, and would
probably shut down our lab from doing any work until we satisfy OSHA. His view
is that it's not sufficient that these two labs are restricted access (all of
us working in these labs have been issued numbered, "do not duplicate" keys),
but that there must be detailed instructions for the use of every item, and
for every type of measurement we make, and that any of this equipment should
be locked away within these locked labs (which is a non-trivial issue for our
EMI lab). He argued that these types of things are the proverbial "attractive
nuisance", prone to abuse.

        My questions are 

        1) If an OSHA inspector were to visit an EMI or safety lab, would he be
sufficiently knowledgeable as to what type of work is normally done there, or
would he essentially "go by the book", and if it isn't in the NEC or NFPA,
it's bad? Does anyone have any experience (good or bad) with this?

        2) The thought of having to write, in excruciating detail, a procedure 
for
every conceivable type of measurement we make, or could make hardly seems a
productive use of my time, considering that the intended audience are already
well versed in these practices, and that I couldn't possibly cover the
universe of measurements we may do in the future. As part of our EMI lab
training, we make a general statement that lab personnel shall be capable of
using lab equipment such as voltmeters, current probes, oscilloscopes,
spectrum analyzers etc. for debugging, which implies knowing how to use them
to make appropriate measurements. Is this good enough? What level of detail is
appropriate? What do other labs do to address this?


        John D. Flavin 
        Teradata TCP Engineering 
        17095 Via del Campo 
        San Diego, CA 92127 
        john.fla...@teradata.com 
        V: (858) 485-3874 
        F: (213) 337-5432 

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