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| Compliance with OSHA's Electrical Safety Standards, Recently Proposed Changes and NFPA 70E

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On June 15, 2005 OSHA proposed new and revised electrical safety rules that should be of concern to every employer governed by OSHA standards. Under the proposed rules, OSHA would complicate the highly controversial area of multi-employer worksite liability. The rules would require communications between the host employer and the contractor regarding the existence and correction of contractor violations of OSHA standards. These written communications, which could be requested by OSHA inspectors, could make it easier for OSHA to impose liability under the multi-employer worksite doctrine. The proposed rules would also permit OSHA to cite a contractor for failing to enforce safety requirements in the contract with the host employer that go beyond OSHA requirements.
The proposed rules would update the current electrical practices for power generation, transmission and distribution to incorporate recent changes in NFPA 70E related to protection of employees working on electrical equipment from hazards associated with electric arcs. They would also overhaul the construction industry rules so that they generally follow the general industry rules governing power generation, transmission and distribution. Substantial changes in practices and protective equipment could be required if the changes are adopted as proposed.
Meanwhile, there is an internal debate at OSHA as to whether compliance with some aspects of the flame-resistant clothing requirements of NFPA 70E is already required by OSHA’s General Personal Protective Equipment Standard. Finally, OSHA is expected to issue and request public comment on the draft of its overhauled and greatly expanded compliance instruction on lockout/tagout shortly.
Be prepared to ask questions pertinent to your facilities and activities. |
| Learning Outcomes
- List host-contractor communications required under the proposal, and the potential impact on Multi-Employer Worksite Issues
- Describe the potential effect of OSHA enforcement of safety-related work rules in private contracts
- Identify new training requirements that would be imposed by the changes
- Define changes that would be required by adoption of the NFPA 70E requirements, the hazards addressed by the proposal, and the potential costs associated with implementing those changes
- Describe general electrical safety practices and how those practices would have to change to conform to the proposed rules
- Recognize the changes in protective equipment that would be required and balancing the risks
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| Who Should Purchase this CD?
- Safety Managers
- Safety Engineers
- Industrial Hygienists
- Nursing and Other Licensed Health Care Providers
- Operations Managers and Supervisor
- Corporate Counsel
- Human Resource Managers
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Industry Experts
Daivd W. Bogart, CSP
President
David W. Bogart Associates
David W. Bogart founded David W. Bogart Associates, Inc. in June of 1988. D.W. Bogart Associates is an Occupational Health and Safety Consulting firm, specializing in the development of individualized Health and Safety Management programs for a variety of industrial and governmental clients. The services provided to the clients include: Workplace Safety Inspections and Audits; Incident Investigations; Workplace Demands Analysis; Risk Assessments, Ergonomic Evaluations; Project Safety Reviews, Machine Guarding surveys and Behavioral Safety Program development. In addition, Mr. Bogart has provided Expert Witness testimony on Product Liability cases.
Prior to founding D.W. Bogart Associates, Mr. Bogart held a variety of positions in private industry. These included: Senior Safety Consultant with M&M PC, a division of Marsh & McLennan; Manager of Accident Prevention and Employees Health at Lederle Laboratories, a division of American Cyanamid; Safety Manager for FMC Corporation's Agricultural Chemicals Division; Safety Engineer at General Motors - Harrison Radiator Division; Resident Field Engineer for Factory Mutual Engineering Association and Senior Loss Control Representative with Liberty Mutual Insurance Company.
Mr. Bogart is an Exam Certified Safety Professional and a Certified Hazard Control Manager. He has degrees in both Industrial and Mechanical Technology.
In addition to other professional accomplishments, he has taught at several community colleges and state universities. He is a professional member of the American Society of Safety Engineers, the Canadian Society of Safety Engineers, the National Safety Council and the National Fire Protection Association. Mr. Bogart has had several articles published in Professional Safety and other safety magazines.
Larry Halprin, Esq.
Keller and Heckman LLP
Mr. Halprin draws on his technical and business background to counsel individual companies and trade associations in a broad range of workplace health and safety, environmental, product safety, and business transactions issues. He has a hands-on familiarity with the manufacturing environment and has represented clients in the aerospace, chemical, construction, electronics, food, machines, paper and forest products, pharmaceuticals, plastics, steel, telecommunications and transportation industries.
Mr. Halprin works with clients in developing, implementing and auditing environmental, health and safety management programs; he advises on legal compliance issues; and he represents clients in a broad range of enforcement and rulemaking proceedings at the federal and state levels. Mr. Halprin has been a strong advocate of re-inventing government, particularly with respect to regulatory reform. He has testified before Congress and participated in numerous government rulemakings in an effort to limit agency rules to what is necessary, practical and justified by appropriate risk assessment and cost-benefit analysis. Mr. Halprin is a frequent writer and speaker on regulatory reform and a broad range of environmental, health and safety management issues.
In his transactional practice, Mr. Halprin has provided counsel and negotiated: real estate purchase and leasing agreements for residential and commercial properties; real estate financing agreements for commercial office buildings; asset sales agreements; and telecommunications system design, construction and operating agreements. Before joining Keller and Heckman, Mr. Halprin clerked for the Honorable Charles R. Johnston of the U.S. Tax Court.
Mr. Halprin is a member of the District of Columbia and Pennsylvania Bars.
University of Pennsylvania (B.S.Ch.E., with honors, 1974); Duquesne University (J.D., 1977); George Washington University (M.B.A. in Finance and Investments, 1984, Beta Gamma Sigma).
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