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OSHA Memo on Explosion Proof Cameras and Peripherals

The following memo comes from the Assistant Secretary of the United States Department of Labor. All persons working in sewers and use video inspection equipment, need to read this document in it's entirety. Standards have changed regarding the type of equipment that can be used in sewers.

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Subject: OSHA Memorandum: "Approved Video-Monitoring Equipment for Sewers"

Issued by United States Department of Labor
Assistant Secretary for Occupational Safety and Health
Washington, DC 20210

Electronic Transmittal

MEMORANDUM FOR: ALL REGIONAL ADMINISTRATORS STATE DESIGNEES

FROM: JOHN L. HENSHAW Assistant Secretary

SUBJECT: Approved Video-Monitoring Equipment for Sewers

This memorandum is in response to a series of inquiries regarding the use of electronic video-monitoring equipment ("sewer cameras") commonly used in maintaining and rehabilitating underground sewer systems, i.e., waste water or storm water drainage pipes. It has come to our attention that many of these sewer cameras in use today have not been tested and approved by nationally recognized testing laboratories (NRTLs). The primary issues addressed in this memorandum are (a) classification of sewer systems, and (b) whether sewer cameras must be approved by a NRTL to protect employees who operate them.

In this memorandum, we address only situations in which workers do not enter sewer systems and the sewer camera is operated remotely at a safe distance from any existing or potential fire or explosion hazard. Please note that if an employee must enter a sewer to install or use the sewer cameras, then that entry is regulated by the requirements of the Permit-Required Confined Space standard, 1910.146.

Classification of Sewer Systems

Sewer systems contain, or may contain, methane and other explosive gases that are hazardous to employees. Chemical spills that drain into sewer systems also are hazardous. Under "1910.307(a), when a hazardous concentration of a flammable gas or vapor (i.e., an explosive or flammable atmosphere of gas or vapor) is or may be present in the sewer section in which employees are working, the employer must classify that section as a Class I, Division 1 or Class I, Division 2 hazardous location using the definitions provided by "1910.399. When no such hazards are or may be present, the employer may classify the sewer section as an ordinary work location.

Applicable Electrical Standards

After carefully reviewing the conditions present in sewer systems, we conclude that two electrical standards, "1910.303 and 1910.307, apply among others to the sewer cameras built for use in these systems. The following paragraphs provide the basis for this conclusion.

29 CFR 1910.303(a). This paragraph specifies that electrical equipment and conductors required by subpart S must be acceptable. For most electrical equipment, including the sewer cameras at issue here, the term "acceptable" as defined by 1910.399 means "accepted, certified, listed, labeled, or otherwise determined to be safe by a [NRTL]." This standard applies to the ordinary or general use of electrical equipment for the purpose of protecting employees against electrical shock and burns that can occur in any location, including wet and damp locations that are not classified. Therefore, this provision requires that a NRTL approve any electronic video-monitoring equipment, including sewer cameras, for protection against ordinary electrical hazards. For example, sewer cameras that are set up and tested outside of a hazardous location such as a sewer are subject to this standard.

29 CFR 1910.307. This section regulates the use of electrical equipment and conductors in hazardous (classified) locations (e.g., a Class I, Division 1 hazardous location). Employers must not use electrical equipment, wiring, and installations in these locations unless they are either intrinsically safe, approved for the hazardous location, or safe for the hazardous location. Therefore, in addition to approval under 303(a), when an employer installs and uses an electrically energized sewer camera in a sewer system that contains or may contain an explosive or flammable atmosphere of gas or vapor, the sewer camera must meet one of the following:

While the first two provisions require NRTL approval for use in a classified location, the last provision [1910.307(b)(3)] is a non-NRTL option that allows an employer to demonstrate that the equipment will protect employees from the combustible and flammable hazards that are, or may be, present in the sewer system.

Compliance Issues

29 CFR 1910.303(a). We understand that many manufacturers of sewer cameras currently in use did not obtain approval by a NRTL for ordinary use under "1910.303(a). In view of the large number of these cameras, and significant resources likely to be involved in resolving this issue, we plan to meet with manufacturers and users of the cameras' representatives to discuss development of an acceptable abatement plan with respect to 1910.303(a). Pending further notice, OSHA will not issue citations under 1910.303(a) for employers using previously manufactured and unapproved sewer cameras. This policy does not apply to newly manufactured cameras. Should you encounter unapproved sewer cameras in operation during an inspection, please inform Art Buchanan, Director, Office of General Industry Enforcement, Directorate of Enforcement Programs (202-693-1868; arthur.buchanan@osha.gov).

We note that, apart from 1910.303(a), under Subpart S, employers are responsible for ensuring that any electrical equipment they use is free of recognized electrical hazards that are likely to cause death or serious physical harm to employees. 1910.303(b)(1). In this regard, electrical equipment must be inspected and maintained to prevent equipment damage or wear conditions that could cause shock or fire hazard. If CSHOs encounter sewer cameras that expose employees to a serious recognized electrical hazard, they should use 1910.303(b)(1) for enforcement purposes.

State Plan States are encouraged to adopt a similar policy with regard to 1910.303(a) and sewer cameras, pending a determination on an appropriate means of abatement. Any state interested in participating in discussions with the industry and NRTLs should contact Tom Galassi, Deputy Director, Directorate of Enforcement Programs, (202 693- 2127; thomas.galassi@osha.gov.)

Employee Exposure. Assuming that a sewer camera is not NRTL approved under 1910.307(b)(1) or (b)(2) for use in hazardous locations, and that the employer has not demonstrated the safety of the cameras for such locations under 1910.307(b)(3), then it must ensure that employees are not exposed to the hazardous conditions. In this regard, we understand that most sewer cameras are operated remotely, away from any existing or potential fire or explosion hazard.

When an employer operates the cameras remotely and can provide assurance that no employees, including employees of other employers, are exposed to hazardous classified locations, then the requirements of 1910.307 would not apply. For example, the requirements of 1910.307 would not apply when employers: (a) Fully de-energize the cameras while placing them in the sewer; (b) take measures (e.g., implement a lockout/tagout system) to ensure that the cameras are not energized until the affected employees are at a safe distance from the sewer hazards; and (c) ensure that employees remain at a safe distance from these hazards (e.g., by demarcating the safe area) until the camera is de-energized.

I hope you find this information useful. If you have any comments or questions regarding this matter, please contact Mr. Buchanan, Office of General Industry Enforcement at (202) 693-1868.

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