My entire career has been dedicated to preventing injuries associated with electrical equipment. The injuries I have been concerned with were not only for an individual touching the equipment but an entire workforce at risk due to an explosion or mine collapse caused by the equipment. The goals were clear: keep people uninjured and don’t level the building. More often than not, to achieve that goal to my satisfaction I needed to go beyond the words in the code, standard, regulation, or insurance directive. Not one of those have ever included a requirement or statement that common sense be used. No standard kept reminding me to use the whole standard whenever I applied a requirement. The same is true for requirements in NFPA 70E, Standard for Electrical Safety in the Workplace®.
A recent glut of questions regarding the exemptions to the work permit prompted this blog. The exemptions to the work permit do not grant permission to ignore the rest of the standard. NFPA 70E requirements apply to the tasks listed in the exemptions. You only do not have to have generate that piece of paper. See my earlier blog on why you might want to do a work permit anyway.
The person conducting the exempt task must be qualified to perform that task on that piece of equipment. Knowing how to use an infrared camera to track wildlife does not qualify a person to use a thermal camera on open switchgear. The qualified person must know what safe work practices to follow and to use appropriate PPE if necessary. Even though thermography is included in the exemptions, the qualified person may be at risk of injury. A risk assessment is necessary to determine if shock or arc-flash hazards exist for that assigned task. For example, an open terminal box may not pose the same risk of an arc-flash incident as exposed, operating, open contacts. However, if someone else is interacting with or conducting other tasks in proximity to the terminal box, or if there are other exposed hazards in the area, the risk to the person using the camera is substantially different. If the person performing the thermal imaging is closely watching the opening of the enclosure rather than entering the area after the opening has been completed, the risk is substantially different. A scan from ten feet away does not pose the same shock hazard as one conducted from six inches away. Same task, different risks. The thermography task is included in the exemptions but the task is not necessarily what puts the person at risk. These types of issues are inherently included in the NFPA 70E requirement that employees be protected from electrical hazards.
Many complain, often without considering the entire standard, that the exemptions include the need to use PPE to conduct an exempt task. NFPA 70E only requires PPE when specific boundaries are crossed. If the thermal scan can be conducted from outside of the arc-flash boundary there is no requirement to use arc-rated PPE. The terminal box and open contacts are good examples of how a risk assessment could determine the presence of a shock or arc-flash hazard for the task. An assessment may require considering other tasks occurring simultaneously or other equipment operating in the area. The risk assessment determines the hazards, risks and need for PPE. The assessment may also lead to the need for an energized work permit to conduct the thermal scan. Policies and procedures have a great impact on how to address an exempt task on specific equipment or in a specific area.
Simply justifying work based on one of the tasks exempt from a work permit is not using the entire standard. A risk assessment is necessary anytime an employee is exposed to energized electrical circuits. The standard does not detail what or how to conduct a risk assessment. Many factors, such as those in the previous paragraphs, could influence an exempt task. A risk assessment should consider as many issues as you can identify. The goal of NFPA 70E is preventing injury to an employee conducting a task on electrical equipment. Keep that in mind when making a decision.
Next time: The 2018 Edition of NFPA 70E, Standard for Electrical Safety in the Workplace®