Citation Details


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Section: 56.12028
Date: 03/04/2013
District: NC
Negligence: Moderate
Injury or Illness: Unlikely
Injury or illness could be expected to be: Fatal
Significant and Substantial: No

Condition or Practice: The continuity and resistance tests for the 110 volt outlets located throughout the plant, did not have the grounding tests recorded in ohms. If a ground fault were to occur, it could result in fatal injuries from electrocution. The outlets appeared to be maintained and in good condition. Management was aware of the continuity and resistance standard, but not aware that the readings for each circuit needed to be indicated in ohms as per MSHA policy.

Action to Terminate:

Why this concerns you: The outlets are visually inspected and tested with a GFCI. The overall theme here is I believe they are contending that each outlet be tested annually in ohms.

MSHA’s Program Policy Manual states: “Conductors in fixed installations, such as rigid conduit, armored cable, raceways, cable trays, etc., that are not subjected to vibrations, flexing or corrosive environments may be examined annually by visual observation to check for damage in lieu of the annual resistance test.”

Wouldn’t 110 outlets fall into this exemption? When a visual observation is made how does MSHA recommend recording results in Ohms? The field office Supervisor states that any outlet in the plant is subject to the elements such as buildings with screens usually have vibrations due to the screens, or other similar equipment, the argument was made and question posed to show in the PPM where this was located, and his reply was that is how MSHA interprets the definition. He also stated that even in the office one must take readings first and record all outlets less than 1 ohm or best practice record every outlet, then after that you can visually inspect them, again where does it say this and response was not clear it is not in the standard or PPM.

Under Gravity B. – The citation is categorized as fatal. In the PPM it states “With the exception of fixed installations, numerous fatalities and injuries have occurred due to high resistance or lack of continuity in equipment ground systems”. Wouldn’t fixed installations include permanently installed outlets? If so shouldn’t the citation be categorized as No Lost Workdays? Based on his comments, if the site did not have outlets subject to elements (mining operations), inside or outside, then most likely not fatal. The overall message is that outlets exposed to mining operations versus vibration, flexing, or corrosive environment or the definition of vibration, flexing, and corrosive environments in mining operations including dirt???

The other interesting comment he made was if you have an identification system using colored tape for the annual tests and the tape falls off say a cord, then you must have the readings for that particular cord, whereas by the standard and PPM you do not have to record each individual cord in ohms.



Abatement Suggestions From Industry


AS A RETIRED MSHA ELECTRICAL INSPECTOR, THE REQUIREMENT THAT IS BEING INTERPRETED BY THE MSHA FIELD OFFICE IS NOT IN THE STANDARD, PPM, INSPECTION MANUAL, OR THE CITATION/ORDER WRITING MANUAL.
I HAVE READ THAT THIS ADDED REQUIREMENT IS BEING PUSHED BY CERTAIN INSPECTORS TO EXPAND THE INTERPRETED MEANING OF THE STANDARD AND ADD AN ADDITIONAL CITATION POTENTIAL. THIS WILL CONTINUE UNTIL A "ALJ" COURT CASE WILL SETTLE THE PROBLEM.
- posted on 11/08/2015


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