Comment from Erga, Brian, ESCI Inc

I fully support OSHA adopting Draft 10 of IEEE 516, with the corrected "a," into the proposed revision of 29 CFR Parts 1910 and 1926. I have been a member of the IEEE/ESMO Committee who maintains IEEE 516 for 23 plus years. I also am an active member of the IEEE 516 Committee and a member of the 516-2008 Ballot Resolution Review Committee. The IEEE 516 committee realized the error in the existing publish tables due to the use of the phase-to-ground "a" instead of the use of the phase-to- phase "a." The IEEE 516 committee agreed at it's July 2008 meeting to make the revision to the tables in Draft 9 and 10 of IEEE 516. The IEEE 516 draft is in the final stages of being published with the corrected "a" and will soon be the published technical document for setting MAID and MAD for the industry. I know of no other methods accepted by the industry to develop MAID and MAD for live line work other than IEEE 516. The MAD for voltages above 72.6 kV should be based on the minimum tool distance as published in the 2007 NESC. Live line work is conducted with tools, workers and equipment within the electrical field of energized lines and equipment and the minimum tool distance is correct information to be provided to the industry. The final rule should include only the tables published in the proposed rule which includes the Minimum Approach Distance (MAD) for tools. Again, I recommend that OSHA adopt the revised MAD tables in Draft 10 of IEEE 516.