Hi Gregg:
I argue with some of your statements. :-)
> Dave's question - Does this apply to in-house test equipment?
>
> Hi Dave - Good question (Please see attached). I'm sorry about the file
> size but I took it from the Department of Labor web site several years ago
> when this topic first came up. (It repeats about every 6 months if my
memory
> serves)
I believe Dave's question was in regard to compliance
to local electrical codes, not to OSHA requirements.
Local electrical codes (e.g., NEC) require all
electrical equipment that comprises an electrical
installation to be "approved for the purpose."
This is taken to mean "listed" or otherwise certified
for safety. Codes are enforced by local inspectors
and by licensed electricians who perform the
installation.
Department of Labor (OSHA) regulations require that
the electrical equipment used by employees be
certified for safety by an NRTL. Regulations are
enforced by the employer as well as by periodically
by inspectors from OSHA.
While these two sets of rules are independent of
each other, one solution satisfies both rules:
listing.
> However - the BEST and MOST RELEVANT people to ask are your Corporate
> Insurers.
>
> It would be little good meeting the local code to find that there is small
> print in your corporate liability insurance leaves you with personal
> liability for any failure - injury or death!!!!!!!
> Even if you can avoid NRTL testing then you need to protect yourself - NOT
> YOUR COMPANY - (people go to jail - companies don't).
As a general rule, employees cannot be held
personally liable if they are doing work in
accordance with direction from the employer.
But, today's focus on profits motivates many
insurers to creatively find a way to prevent
payment of claims or to recover the loss from
some other source. However, recovering from
the likes of you and me would not come close
to covering the loss. There are bigger fish
and deeper pockets.
> Try to think of 'compliance' not as PASS or FAIL; but as a continuum from
> DEPLORABLE through ACCEPTABLE to the UNATTAINABLE.
These abstractions, DEPLORABLE, ACCEPTABLE, and
UNATTAINABLE, are difficult to use because they
are not very measurable. PASS and FAIL at least
provide a line by which to discriminate between
acceptable and unacceptable.
We, at HP and Agilent, use a "three-block model"
to evaluate safety:
+---------+ +---------+ +---------+
|hazardous| | | | |
|energy |--->|safeguard|--->| body |
|source | | | | |
+---------+ +---------+ +---------+
We say that, for every hazardous energy source,
there must be one or more safeguards interposed
between the source and the body.
The safeguard has a number of parameters that
must be controlled such that the safeguard
remains effective for the equipment lifetime.
If we do a thorough job, then we have a safe
product -- unless the safeguard is subjected
to influences greater than the design level.
This is a practical, powerful, and measurable
model for safety.
Best regards,
Rich
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