As you know, NFPA 70E®, Standard for Electrical Safety in the Workplace® does not determine what normal operation of your equipment entails. NFPA 70E details the normal operating conditions necessary before someone can safely operate that equipment. So, in that regard, which of these do you consider to be normal operation of the equipment?
- Flipping a light switch in an office.
- Placing a light bulb into a socket.
- Opening a motor disconnect.
- Placing an ammeter into a circuit to measure current.
- Operating a circuit breaker in a panelboard after opening the hinged cover.
- Placing a fuse into a fuse holder.
- Replacing a ballast in a luminaire.
- Placing an appliance plug into a receptacle.
- Pushing an emergency stop on equipment.
- Racking a circuit breaker out of a cabinet.
- Plugging a circuit breaker into a panelboard.
- Replacing a damaged receptacle.
- Pulling conductors through rigid metal conduit.
- Programming a variable frequency drive.
Remember that the tasks you consider to be “normal operation” of the equipment should be able to be done while energized and without the need to use personal protective equipment (PPE). If you are required to use PPE it generally means that the equipment is not under normal operating conditions and therefore, the task is not normal operation. Opting not to wear PPE while performing a task does not make the task “normal operation.” Here in the United States of America, it is not believed that equipment meeting the normal operating condition requirements is inherently unsafe to the person properly operating the equipment. No interaction would be permitted with any electrical equipment if it were. Pulling the trigger on a hand tool, using a computer, charging a cell phone, or playing a video game would pose risks and hazards that could cause injury. Such a condition would require PPE for all of those tasks. Only qualified persons could perform those tasks. Luckily, society has agreed that such precautions are not necessary.
All the tasks listed are necessary for the equipment to function as designed. I am pretty sure you will find manufacturer’s instructions that include the above tasks or the equipment is specifically designed to permit performance of the task. And if it is in the instructions or if the equipment is designed to do it, does that make the task normal operation of that equipment? Your decision to deem something to be “normal operation” plays a big part in protecting employees from injury. I am not going to state which of the above tasks are normal operation. That is not my call. That is not NFPA 70E’s call. It is your call.
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