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A Better Understanding of NFPA 70E: Operation of a light switch and the need for personal protective equipment (PPE)

Blog Post created by ccoache Employee on Jun 10, 2019

Talk about stirring up a hornet nest. A few blogs ago, the most frequently asked question was discussed. That blog concluded by stating: 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. Many took offense to the need for PPE to turn on a light. However, if you read the blog, it states that without a risk assessment, I must make the determination that PPE is necessary to operate a light switch. This does not mean that a risk assessment is necessary every time a light switch is operated within your facility. It does not mean that PPE is necessary to turn on any light switch nor does it mean that normal operation of a light switch is not possible. It does not mean that only qualified persons can perform that task. There are many other things that statement does not mean. I have stated several times that something may be presented to prove a point in a blog. So what was the point in that blog? The point was that I have no way of knowing what is happening in your facility.

Look at the normal operating conditions that permit operation of a piece of equipment. Now consider what could be happening on-site. There is no one verifying compliance with National Electrical Code® (NEC®) installation requirements. Installations are done with materials available in-house to quickly get the job done whether the material was specified or not. The 15-ampere switch is used beyond its ratings and is protected by a 30-ampere fuse. The conductors are 14 AWG and are improperly installed to the switch box. The switch is also inappropriately used as a motor controller. The switch is improperly installed so that the yoke is not grounded. The faceplate is damaged thereby exposing energized parts. The metal box for the switch is not grounded. There is visible arcing when the switch is operated. With the misuse of the switch, there is visible discoloration. The employee has not been trained to understand normal operating conditions or to recognize signs of impending failure. An employee is at risk of injury by simply flipping that switch. Although an arc flash is not likely to occur there are several signs that a shock hazard may be present. Even though the restricted approach boundary is avoid contact, the employee is required to make contact with the switch. The yoke, the faceplate screw (or faceplate itself if metal) or the box could be energized. The employee does not know to avoid contact with any metal part and is put at risk of electrocution

My answer is for conditions that I do not personally verify. When pushed to provide an answer to the question; is PPE necessary for a specific task to be conducted on specific equipment, my answer will always be; yes, PPE is required unless YOU determine otherwise. I will always consider that an employee is exposed to a hazard. For me to do otherwise may put that employee at risk of injury. You may determine that the normal operation of light switches or anything else in your facility does not require the use of PPE. It is not typical for such tasks to require PPE. This is true at our facility. Hopefully, it is true at yours as well. 

For more information on 70E, read my entire 70E blog series on Xchange

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Next time: Impending equipment failure.

Please Note: Any comments, suggested text changes, or technical issues related to NFPA Standards posted or raised in this communication are not submissions to the NFPA standards development process and therefore will not be considered by the technical committee(s) responsible for NFPA Standards development.  To learn how to participate in the NFPA standards development process and submit proposed text for consideration by the responsible technical committee(s), please go to www.nfpa.org/submitpi for instructions.

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