Curvas de gasto del Aliviadero y Desagües Profundos

Hazard Risk

No low voltage written program. High voltage program needs some improvements.

1.1 Observation

A high voltage (>600V) written program (QEW) exists that was officially adopted and signed by C&M Management in January 2012. The written program meets requirements; however, needs some minor improvements, as listed in the recommendations section.

A low voltage (50V – 600V) written program does not currently exist. Management stated they are in the early stages of writing a low voltage program.

References:

Note: FPN as listed in NFPA 70E stands for “Fine Print Note”

NFPA 70E 110.3 Electrical Safety Program.

(A) General. The employer shall implement and document an overall electrical safety program that directs activity appropriate for the electrical hazards, voltage, energy level, and circuit conditions.

FPN) No. 1: Safety-related work practices are just one component of an overall electrical safety program.

FPN No. 2: ANSI/AIHA Z10-2005, American National Standard for Occupational Safety and Health Management Systems, provides a framework for establishing a

comprehensive electrical safety program as a component of an employer’s occupational safety and health program.

(B) Awareness and Self-Discipline. The electrical safety program shall be designed to provide an awareness of the potential electrical hazards to employees who work in an environment with the presence of electrical hazards. The program shall be developed to provide the required self-discipline for all employees who must perform work that may involve electrical hazards.

The program shall instill safety principles and controls.

(E) Electrical Safety Program Procedures. An electrical safety program shall identify the procedures for working within the limited approach boundary and for working within the arc flash boundary before work is started.

(F) Hazard Identification and Risk Assessment Procedure. An electrical safety program shall include a hazard identification and a risk assessment procedure to be used before work is started within the limited approach boundary or within the arc flash boundary of energized electrical conductors and circuit parts operating at 50 volts or more or where an electrical hazard exists. The procedure shall identify the process to be used by the employee before work is started to identify hazards and assess risks, including potential risk mitigation strategies.

Recommended Corrective Actions:

Recommended corrective actions are discussed below. Note that an overall corrective actions table is presented in Appendix C.

High Voltage (QEW)

1. Qualified Electrical Worker definition and use of definition – The term “Qualified Electrical Worker” or QEW is used throughout the QEW Manual and multiple

definitions used, which are potentially conflicting. “Qualified Electrical Worker” is a legal definition as defined by CalOSHA, Title 8, Subchapter 5, Group 2 and the definition and use of this term should not vary from the legal definition. Those POLA employees that know the legal definition of QEW are confused or skeptical of the POLA definition or application of QEW.

As correctly noted in the definition of the QEW on page 3 of the QEW Manual, a QEW can be “qualified” to work on some equipment, but not others, and an individual who is going on-the-job training under the supervision of a QEW, and has

demonstrated an ability to safely perform the job, is considered a QEW. POLA tends to use QEW as a general “all or nothing” status or title that allows employees to work on all high voltage equipment. See Section 2 of this audit report for more information on further applying a QEW program.

Section 3 of the QEW Manual – Definitions - Page 3 has the appropriate legal definition, along with some added information by POLA. The information added by POLA should be removed from the middle of the definition. The training requirements should be moved to Section 7 and merged with the other training requirements.

Section 5.4 of the QEW Manual – page 3. Describes how qualification is made. This doesn’t belong in this section.

Section 7.2, page 2 of the QEW Manual has a partial definition of QEW, which is not

application.

QEW Policy Acknowledgement – page 2 of the QEW Manual. Here a completely different definition of a QEW has been created which the employee and supervisor must sign off on. This definition conflicts with the legal definition that should be used.

This should be changed to meet the suggested structure and wording below:

Suggested structure & wording –

a. Change the name of the document from Qualified Electrical Worker Manual to something like High Voltage Worker Manual or Port Qualified High Voltage Worker Manual. QEW is a subset of the overall High Voltage Worker

requirements by POLA. This manual contains more than just determining what a QEW is.

b. Define QEW once in the definitions, using the legal definition by CalOSHA.

You can add at the end of the definition: “A Qualified Electrical Worker for the Port of Los Angeles has additional requirements as outlined in this manual.”

From that point on, do not try to redefine QEW.

2. Section 3 – Definitions – page 3of the QEW Manual. Advanced Electrical Safety and Lockout / Tagout Training. It’s not certain what was meant by “advanced” here.

There is no course reference or training for “advanced” electrical safety.

3. Section 3 – Definitions – page 3 of the QEW Manual – Qualified Person. The definition given here for “Qualified Person” is pulled from the OSHA federal 1926 construction definitions, which isn’t in full alignment with OSHA federal 1910

electrical safety definitions nor CalOSHA Title 8, Subchapter 5, group 1 definition of a

“Qualified Person”.

Federal definitions of “Qualified Person” applies to workers working on all voltages whereas CalOSHA uses “Qualified Electrical Worker” for high voltage and “Qualified Person” for low voltage. Being that there is a split between the low and high voltage programs and documents, the term “Qualified Person” should probably be removed from the high voltage manual and be reserved for the low voltage manual. If

“Qualified Person” is used in this manual, it would be recommended to use the

NOTES:

1. Whether an employee is considered to be a "qualified person" will depend upon various circumstances in the workplace. For example, it is possible for an individual to be considered "qualified" with regard to certain equipment in the workplace, but

"unqualified" with other equipment.

2. An employee who is undergoing on-the-job training and who, in the course of such training, has demonstrated an ability to perform duties safely at his or her level of training and who is under the direct supervision of a qualified person is considered to be a qualified person for the performance of those duties.

4. There is not specific information present outlining emergency response procedures for victims of shock. Add emergency response for shock victims to QEW manual.

5. There is no specific information in Section 5.7 of the QEW Manual of Arc Rated personal protective equipment. PPE information should be specific as to what to wear and when.

Low Voltage (50v – 600v)

A comprehensive Written Electrical Safety Program needs to be developed. A third party with expertise in writing electrical safety plans should be hired to develop the document. This is a relatively low-cost project as most content is boiler plate. Training to the document should be required once completed.

Dissemination of Information & Access

The contents of the high voltage electrical safety program is not well-known by the PEMs.

The contents of both the existing high voltage and the forthcoming low voltage program should be included in future training. Employees should have easy access to the written programs.

SECTION 2 - QUALIFIED PERSONS & QUALIFIED ELECTRICAL WORKER