While I prepare for the second draft meeting of NFPA 70E®, Standard for Electrical Safety in the Workplace®, I also begin to prepare for the next edition of the handbook. I review the questions received over the three year revision cycle to determine what needs to be further explained to help NFPA 70E users increase electrical safety at their company. Questions are varied but there have been three main recurring themes. In honor of National Electrical Safety Month this May, I thought I would go over those with you. The first is; does personal protective equipment (PPE) have to be used to perform this task? Second is; is this employee qualified to do this task? The third is; how is a risk assessment performed? The first two themes are not technical questions. It is expected that I will provide a definitive answer to remove the need for a decision by the questioner. The third theme although more technical is not addressed by NFPA 70E. There are hundreds of valid methods of performing a shock and arc flash risk assessment for the thousands of tasks that could be conducted on the millions of pieces of equipment available.
So what is the most frequently asked question? It is whether PPE is or is not necessary when operating a circuit breaker. To those reading this; NFPA staff cannot make a determination of conditions that require a visit to the facility. I am not able answer the question if PPE is not necessary for any task that you permit to be conducted as justified energized work. (Which begs the question; is energized work justified?) You are the one who does the required risk assessments for the tasks conducted on your equipment. Your risk assessment determines the need for PPE for any task an employee is scheduled to do. However, my answers to this question attempt to provide some education to those asking the question. This typical covers the broad application of NFPA 70E and refers to sections within Article 130.
The first thing is that circuit breakers are used in many pieces of equipment and the operation of a circuit breaker varies greatly with each application. A blanket statement regarding the need for PPE when operating a circuit breaker is not possible. Also, NFPA staff does not determine that the manual operation of any specific breaker in any specific equipment is acceptable. Which leads to a second point. The permission to operate equipment exists if the equipment is under normal operating conditions. I have addressed this several times. Refer to my blogs: The things needed before normal operation is consider safe (PART 1), the things needed before normal operation is consider safe (PART 2), normal operation and you, and is your equipment properly installed. If the equipment is under a normal operating conditions and is being operated properly, PPE is typically not necessary to perform the task. It is your risk assessment that determines that the equipment meets these requirements. It is not something that NFPA staff is able to do for you.
The next point is the requirement that equipment must be placed into an electrically safe work condition (ESWC) whenever an employee is within the limited approach boundary or is interacting with the equipment in a manner that increases the likelihood of an injury even if energized parts are not exposed. Energized parts must be exposed in order for there to be a limited approach boundary. Your risk assessment determines this. If the qualified employee will be within the restricted approach (or arc-flash) boundary then appropriate PPE is necessary. If the equipment is not under normal operating conditions, there typically will be an increased likelihood of injury. Operation of the equipment in such a state puts an employee at risk of injury. Your risk assessment may also determine that even if the equipment is under normal operating conditions that opening the circuit breaker raises the risk of an incident above a level that is acceptable to you. Your risk assessment would therefore identify the PPE necessary to perform the task.
Many still want an answer to the question; is PPE necessary to operate a circuit breaker? As stated above, I am not at your facility. I must consider the worst case situation where your equipment is not properly installed, is not properly maintained, and is used beyond the manufacturer’s requirements. Equipment covers are missing, equipment doors are open, the listing of the equipment is violated, and the equipment is exhibiting signs of impending failure. I will ponder that your employee is not properly trained even if you consider them to be qualified or to be an unqualified worker with proper training for the task. I will accept that you have no documented electrical safety program or procedures. I will assume that you and your contract employer have not discussed electrical safety issues. I will contemplate that the equipment is not being operated properly. I will not take your word that any of my assumptions are incorrect to provide you a definitive answer. I will only provide one answer in order to ensure protection of your employee. That answer is; yes, PPE is necessary for every task you authorize an employee to perform, including operating a circuit breaker or using a switch to turn a light on in an office. If you want a different answer train your employees and perform risk assessments.
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Next time: Second Draft Meeting for NFPA 70E, Standard for Electrical Safety in the Workplace.
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