I am weary from answering questions about what I consider to be clear and concise requirements. A majority of these types of questions are posed by someone who has never opened NFPA 70E®, Standard for Electrically Safety in the Workplace. If you have not read the standard, how can you expect to apply it to protect your employees from injury? Another type of question deals with the selective application of the requirements. Sometimes a sentence of a requirement is used without the benefit of the additional sentences. Occasionally, the question comes down to why someone can’t use a table, illustration, figure, or exhibit in a standard without following the actual requirements within the standard. This lack of understanding of how to properly apply a standard is not limited to NFPA 70E. It is an epidemic. It seems few have time to read a standard before using it. If they can find a table that seems to work, many just use it.
Luckily, a majority of you do everything possible to prevent electrical injuries within your workplace. Thank you for taking on the responsibility. Without your hard work there would be many more electrical injuries. However, there are many others who may think this subject does not apply to them but, based on the questions I have had to answer; it does. First, answer a few simple questions. Did you have equipment labeled HRC 0 using the 2012 edition? Have you ever completed an incident energy analysis by using PPE categories? Have you used the arc-flash PPE category table without first using risk controls? Have you ever used a table without reading the actual words of the requirement in NFPA 70E?
My experience has shown that several of you have truthfully answered yes to several of these questions. Answering that way means one thing; you are more than likely to be putting your employees at risk. Each yes answer means that you have not followed the minimum requirements of NFPA 70E. The one that is really bothersome is using PPE categories for an incident energy analysis. When it is pointed out that the standard specifically prohibits this the next question typically is; where does it say that? After pointing them to specific places as well as others that address when the tables are permitted to be used, many argue with me. It seems to make sense to them so they will use the tables that way.
Do you know why the standard has that restriction? What is the history of the tables? Do you know how and why the tables were generated? Do you know the conditions used to establish the tables? Do you know if there are any safety issues with ignoring the requirement? I am not going to go into the history of the requirement. All requirements have history. I certainly do not know all of it. What I expect is that the requirement was placed there for safety. The public has accepted the requirement since it was first put in. I am not aware of any standard that can be cherry picked for requirements to apply at leisure. If I don’t know why a requirement is what it is, I am not going to ignore it because the requirement doesn’t make sense to me. Certainly I will not do this when it comes to employee safety.
Several have commented that the tables are used that way (the incorrect way) in the real world. If those people are to be believed, several of you have applied a table in a manner that violates the actual requirement. Using a standard incorrectly because everyone (is it really everyone?) uses it incorrectly is not a good reason to ignore a requirement. If you follow that philosophy, how did your peers chose which requirement to ignore?
Until the words in a standard actually state what you think it says, want it to say, assume that it says, or have been told what it says, stick to the requirement as written. Doing anything otherwise, especially in the case of NFPA 70E, is a dangerous thing. However, first you have read the words.
Join me for a free webinar on Wednesday, July 12 from 10:00 – 10:30 AM EDT that will help explain a few proposed changes and provide an opportunity for participants to ask question about the revised NFPA 70E. If you haven't had the chance, there's still time to register.
Next time: The hierarchy of risk controls