Occasionally the concept of exceptions to the energized work permit comes into question. Being a consensus standard, NFPA 70E® has four exemptions to requiring a work permit. Although a work permit “shall not be required” for the exemptions it does not state that you are forbidden from doing one (remember back to my posts on consensus standards and best practices.) An exemption to the work permit is allowed for testing, troubleshooting, and voltage measuring. The other three exemptions are for nonelectrical work being conducted outside of the restricted approach boundary. There is a saying that “if it has not been documented it did not happen.” Would I go without an energized work permit?
Before covering whether I would or would not do a work permit look at the terms used in the exemption: TESTING – TROUBLESHOOTING – VOLTAGE MEASUREMENT. Everyone has the idea of what these terms mean. I have spent some time in the instrument and test field so I have my own opinion. Not one of these terms means repair. Some may disagree and consider repair as part of troubleshooting. General terms are not defined in NFPA standards. The definitions come from general sources. Just typing the words into an online dictionary here are the first definitions I saw. I hope I don’t have to look up voltage measurement.
Testing - the means by which the presence, quality, or genuineness of anything is determined; a means of trial.
Troubleshooting – discovering the cause of trouble in mechanical equipment, power lines, etc. (A troubleshooter eliminates the trouble.)
Regardless of your stance on this, this blog is discussing the need for a work permit. With or without a work permit, the qualified person has to be provided with and use appropriate safe work practices. If the task is voltage measurement, the employee must be informed of that fact. They must have the correct test instrument. They must wear the appropriate shock and arc-flash PPE. They must know the procedures for conducting voltage measurements on that specific piece of equipment.
You might say that since the person is qualified an energized work permit is not necessary. The minimum requirements of the standard permit that. I, on the other hand, probably would require a work permit. Why? What procedures, test instrument, PPE, etc. were used for the task? I can tell you. Who conducted the work? I can tell you. We all know that qualified or not people do unexpected things. A loose lug was seen during a voltage measurement. It was tightened and the equipment was damaged. Was that part of the task? I can tell you. Can you tell me? Going back to “if it has not been documented it did not happen.” Justified electrical work does not mean that the task will be completed without an incident or injury. What do you do when tightening that loose lug initiates an arc-flash? The facts of what was believed to have occurred prior to an incident often get muddled up after the incident.
I am not saying that I would always require a work permit. A lot you may not since you consider the work to be so menial or routine. Before you never require one under the exemptions, think about it.
Next time: The conditions which permit normal operation.