My last blog posed the question whether a second-degree burn should be considered an acceptable employee injury. Why 1.2 cal/cm2 was selected as the point when the arc-flash hazard needed to be addressed was also covered. NFPA 70E® still applies where the incident energy is below this level but does not require arc-flash PPE to be worn. When HRC 0 was removed from the standard in 2015 it caused a lot of concern for the standard users. Many of you felt that left no guidelines on what was required to be worn when applying NFPA 70E. You felt your employee could wear whatever they wanted and you could not prevent it. I will attempt to address why this should not have caused as big of a concern as it did.
HRC 0 was not arc-flash PPE. HRC 0 was essentially what an employee should wear for every day work clothes. It required non-melting materials, long sleeve shirts, and long pants. It also required that you make a selection for safety glasses, hearing protection and heavy duty leather gloves. Remember, a second-degree burn is acceptable so no arc-rating was necessary. The specification was that clothes not melt onto the employee during an incident at lower incident energies. What should be done now that HRC 0 is gone?
You should be aware of 130.7 Personal and Other Protective Equipment. If NFPA 70E is being used because there is an electrical hazard then 130.7 applies. Section 130.7 clearly requires that employees working in areas where electrical hazards are present be provided with, and use, protective equipment that is designed and constructed for the specific part of the body to be protected and for the work to be performed. Notice that this statement is not for a specific incident energy or voltage level. You do not have to use the minimum 1.2 cal/cm2 requirement of the standard. You could consider a burn hazard to be anything over the potential of a first-degree burn. You could consider that any work conducted on energized equipment regardless of voltage or incident energy requires nonflammable clothing. If you are protecting you employee from whatever you consider to be a hazard, you have the ability to require that they be protected from that hazard.
Further along in 130.7(C)(12) there is another statement that is not tied to incident energy. It states that clothing and other apparel that do not meet an arc-rating must be made of non-melting or flammability rated material. That alone should cover a major part of the concerns about the removal of HRC 0. Are long sleeve shirts and long pants necessary? That is a decision that you as the employer should be making. It is not truly an electrical safety issue if an employee does not wear eye or hearing protection for these conditions. Steel toed shoes and hard hats are also not electrical safety issues. Does that mean if this protection were necessary for another reason that you as the employer would not require its use? Even if a standard provides no guidance on the issue, you as the employer still need to have some policies in place to address general work apparel. NFPA 70E only covers limited conditions. What protection is necessary for other conditions is something that you always had to determine.
Next time: Have you earned your employee’s trust?