The following requirements apply only to subcontractors and subcontractor activities specifically related to the moves to GPL and SERC.
Berkeley Lab LOTO requirements can be found in PUB-3000 Chapter 18.
Prerequisites for Obtaining a Subcontractor LOTO Permit
- Subcontractors who require a LOTO permit shall first submit their company LOTO program or equivalent company policy document to the EHS Electrical Safety Group. This document must be evaluated for basic compliance to OSHA 1910.147 and NFPA 70E requirements.
- In addition, the subcontractor company must submit a signed statement on company letterhead (see suggested template) certifying that all their employees have been trained as LOTO Authorized Persons in the context of OSHA 1910.147(c)(7). The statement must further specify that subcontractor employees, whether permanently employed, temporarily employed, or sub-tier contracted, must not participate in a LOTO or perform work at Berkeley Lab without obtaining this training.
- Only electrically qualified subcontractors who have been separately and individually authorized by the EHS Electrical Safety Program Manager may perform their own verification of zero voltage on electrical lockouts. See “Electrical Work Requirements” below for further information.
- All subcontractors shall additionally receive a subcontractor LOTO orientation that covers the specific process requirements used at Berkeley Lab.
Electrical Work Requirements:
Berkeley Lab applies strict controls on electrical work on equipment above the thresholds in the following table. Performance of non-electrical work (such as mechanical work or work on electrical circuits below the shock hazard thresholds of the Table) does not require a Qualified Electrical Worker (QEW).
|AC||50-60 Hz nominal||≥ 50 V and ≥ 5 mA|
|DC||All||≥ 100 V and ≥ 40 mA|
|Capacitors||All||≥ 100 V and ≥ 1 J, or≥ 400 V and ≥ 0.25 J|
|Batteries||All||≥ 100 V|
All non-construction subcontractors who perform electrical work are required to be accepted by the Berkeley Lab Electrical Authority Having Jurisdiction (AHJ) for Safe Work Practices as Subcontractor QEWs. This includes both live and deenergized work, for build, service, maintenance, and repair of equipment. “Accepted” means that the AHJ has reviewed the Subcontractor Employer’s Statement of Electrical Qualification, accepted it as valid for use at the Berkeley Lab, and the applicant has demonstrated proficiency by passing the practical certification examination. However, it is the responsibility of the Subcontractor Employer to approve their personnel as QEWs for their work.
The following exceptions will be applied to non-construction subcontractors performing work specifically for the GPL/SERC move. Non-construction subcontractor personnel under these exceptions will not be required to be accepted as QEWs:
- Non-construction subcontractors who only perform electrical work on cord-and-plug equipment are not required to be accepted as QEWs provided:
- The equipment is unplugged.
- The equipment meets the requirements for the cord-and-plug exemption to LOTO in accordance with the Lockout/Tagout Program, Work Process C, Cord-and-Plug Equipment.
- The non-construction subcontractors are trained and authorized by their employer to perform the electrical work on that specific equipment.
- Non-construction subcontractors who only perform electrical work on hard-wired equipment that has been placed in an Electrically Safe Work Condition are not required to be accepted as QEWs provided that:
- A Berkeley Lab QEW places the equipment in an Electrically Safe Work Condition.
- All non-construction subcontractors join the LOTO Permit in accordance with the Lockout/Tagout Program, Work Process I, Subcontractor LOTO Permit.
- The Berkeley Lab QEW provides direct field supervision of any electrical work performed while in an Electrically Safe Work Condition.
- The Berkeley Lab QEW performs Test Before Touch every time job continuity is interrupted.
- The non-construction subcontractors are trained and authorized by their employer to perform the work on that specific equipment.
For all other cases, any non-construction subcontractor performing either live and deenergized work, for build, service, maintenance, or repair of equipment that does not meet the exceptions above must be accepted as a QEW for this work by the Berkeley Lab Electrical AHJ for Safe Work Practices. These requirements cascade down to all sub-tiered contractors of a prime contractor, including vendors, OEM representatives, etc.
In order to verify non-construction subcontractor QEW credentials, the Subcontractor Employer shall provide a Statement of Electrical Qualification with supporting materials for each individual, which are then reviewed by the Electrical AHJ for Safe Work Practices. These include:
- If available, a copy of the Subcontractor’s Electrical Safety Program, which LBNL will retain on file.
- Contact information (phone number and email) of the Subcontractor’s safety representative who can address questions and concerns that might come up during the course of work at the Lab.
- A company letterhead, officially signed document, stating that the named employees are considered by the Subcontractor to be Qualified Electrical Workers under the definition of OSHA and NFPA 70E. For each employee, the document should state:
- Type and length of job experience, basically describing why the person is considered to have the required experience for the tasks in the scope of work.
- Any restrictions on their scope of work (such as voltage or type of equipment).
- Confirmation of NFPA 70E electrical safety training for each employee. The training shall be of the classroom or on-the-job type, minimum 4 hours (if arc flash hazards are not part of the scope of work) or 8 hours (if arc flash hazards are part of the scope of work), taken within the last 36 months. Training shall also include a practical demonstration of absence of voltage verification, with selection of appropriately rated test equipment and appropriately rated PPE.
- Confirmation of current First Aid/CPR/AED training with expiration date for at least one person if more than one person is assigned.
- Each person applying for QEW status will be required to successfully pass a practical certification administered onsite by the Electrical Safety Group and must be scheduled in advance.