What is Readily Accessible?

Recently I was contacted by a customer requesting clarification of a statement I mentioned during one of our Overhead Crane Inspection Classes (ISP-301) regarding Bus Bars as a method of supplying power to the runway conductors on Overhead Crane Systems.   

While conducting training classes, we discuss disconnects at length due to their importance and we encourage class participation and open dialogue on numerous issues Inspectors encounter at various customer locations.

First and foremost, our class participants are instructed to “read into” the intended meanings behind OSHA, ASME, CMAA and NEC regulations, as they are often misunderstood or interpreted incorrectly.

“Bus Bars” are a common means to supply power to equipment, the code for Overhead Cranes plainly states that disconnects shall be “readily accessible from the floor”.

OSHA defines “Readily accessible” as “capable of being reached quickly for operation, renewal, or inspections, without requiring those to whom ready access is requisite to climb over or remove obstacles or to resort to portable ladders, chairs, etc.”

Yes, you can pull a rope and turn off a Bus Bar disconnect, but as “Crane Inspectors” we encourage our students to be confident in their ability to “identify and predict” problems and possible unsafe conditions along with recommending solutions based upon their individual training, experience, and code interpretation.

OSHA’s intent is obvious, Will an employee get a ladder to lock out a Bus Bar disconnect?

What if a ladder isn’t available?  What if the mobile elevated work platform is located outdoors in bad weather?  What if the pull rope is dry rotted?  Is the pull device made of  non-conductive materials? How does he/she ensure all conductors are open?

The variables are endless, the consequences are critical…

Within view of the conductors” is another code requirement that isn’t followed regularly.

Many disconnects are located in other areas of the facility, other rooms, inside Motor Control Centers (MCC), upstairs, downstairs, etc etc this is a code violation plain and simple.

OSHA’s intent, I believe, is to take the “human element” out of the equation.

If the disconnect is accessible from floor level, it is more likely the required LOTO procedures will be followed, but if an employee, particularly a maintenance employee who may be under pressure to get equipment up and running, he or she may resort to a shortcut and ignore LOTO procedures.

OSHA’s Top 10 Violations always, without fail, include Lock Out Tag Out citations

Supporting documentation:

  • OSHA 1910.179 (g)(5) Electrical Equipment / Switches
  • OSHA 1910.147 Lock Out Tag Out
  • NEC 610-D31 Disconnecting Means

Dave Hallow is a Technical Trainer / Consultant for Qualified Crane Training and Consulting LLC