NFPA 70E Series: Are you putting your employees at undue risk

Blog Post created by ccoache Employee on Dec 1, 2016

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I am shocked at the number of questions received regarding a misuse of NFPA 70E®. The questions were not on a specific issue but it was the subsequent conversations that sent a shiver down my spine. The crux of the concern is that the tables provided in the standard are being used to falsely “justify” energized electrical work and that a label on equipment is an allowance to work energized. It seems that many believe that it is acceptable to ignore a majority of the standard by going right to the tables and that PPE provides adequate protection for their employee. If it is on the table isn’t that justification enough to perform energized work? If the employee is protected why is there a need to establish an electrically safe work condition?  There are so many things wrong with this thought process that I will not go into them here except for what should have been the obvious ones. What I will address is how the tables are meant to be applied when energized work has been justified.

First, let me point out the obvious flaws with that mind set. The primary method of providing electrically safety for the employee must be establishing an electrically safe work condition regardless of the energy level, the voltage level or the ability to wear protective gear. These people assumed that there is justification for the work to be performed while energized most likely without the benefit of a risk assessment. They determined that no other hierarchy of risk controls would be employed to provide additional protection for the worker. They determined that only the lowest level of control (arc-flash PPE) would be employed as the default for worker protection.  Although properly selected arc-flash PPE minimizes the severity of an injury it does not necessarily prevent an injury. Due to the explosive effect of some arcing events, physical trauma injuries could occur. The PPE requirements do not address protection against physical trauma other than exposure to the thermal effects of an arc flash. The use of PPE also does not prevent damage to the equipment. A proper label on equipment should be primarily used to establish an electrically safe work condition not as permission to perform energized work.

Now on to the use of the tables. The first thing is to determine that there is justification for the energized work to be performed. This does not mean that the equipment is included in the table. One of the justification criteria must be met. The next thing is to determine the likelihood of an arc flash occurring (This is included in the task table in 2015 which will become a new table in 2018). After exhausting the hierarchy of risk controls down to the PPE level, the appropriate PPE category table is used to determine the required PPE level.  This table is not only equipment specific but parameter specific. The PPE category method cannot be used if the equipment is not on the table or if even one parameter is exceeded.  Once the PPE category is assigned, the table defining what is required to make up this PPE category is consulted to specify the necessary gear.

There is no allowance for justifying energized work solely based on equipment labeling or simply by conducting a risk assessment that results in a hazard. The main requirement in both NFPA 70E and federal regulations is that equipment be placed into an electrically safe work condition. The entire standard must be used to protect the worker. When energized work is justified, using the table without complying with all the requirements disregards the steps designed to protect your worker. Doing so places your employees at an unnecessary and greater risk of injury. 

Next time: Why does a "qualified person" create such a problem?