People tend to get hung up on whether or not it is safe to work on a specific piece of electrical equipment. Often the hang up is caused by an attempt to classify a task as electrical work or non-electrical work. Working on electrical equipment or performing non-electrical work are really just terms. When it comes to electrical safety the task being performed does play a role in the steps to be taken in protecting the employee. However, the electrical hazard is really the issue. What doesn’t change, regardless of what the assigned task is considered, is whether or not the employee is exposed to an electrical hazard.
Consider the exposure to electrical hazards without classifying a set of tasks as electrical or non-electrical. An equipment label indicates that the restricted approach boundary is 2 feet, 2 inches, the limited approach boundary is 5 feet and the arc-flash boundary is 14 feet. An employee is removing the bolts to open the enclosure although the equipment is not yet placed into an electrical safe work condition. Another employee who will do a thermography scan and a maintenance worker assigned to vacuum out the equipment are standing 4 feet away. Another worker is standing 2 feet away ready to establish an electrically safe work condition after the thermography scan is completed. Another worker is painting the ceiling 10 feet away. There will be exposed electrical hazards when the enclosure is opened. What does 130.2 require? It requires that an electrical equipment be placed in an electrically safe work condition whenever the exposed voltage will be above 50 volts or when someone is interacting with equipment that increases the likelihood of an arc-flash unless the exposure is justified. Section 130.3 requires that employees be protected when working while exposed to electrical hazards. What exposed hazards will put each of these employees at risk?
Start with the employee unbolting the enclosure’s cover. This employee will be within the restricted approach boundary during the removal of the cover. Not only will the employee be inside the arc-flash boundary at that time but will be interacting with the equipment in such a way to increase the likelihood of an arc-flash. The employee who is responsible for establishing the electrically safe work condition is also within all three boundaries. The thermography and maintenance employees are within the limited approach boundary as well as the arc-flash boundary. What of the worker whose back is to the equipment while painting the ceiling? That worker is within the arc-flash boundary and may not know what is occurring behind her.
There are so many things that I would do differently, but this blog is to illustrate a point. NFPA 70E, Standard for Electrical Safety in the Workplace does not deem a task as electrical or non-electrical work. It requires that all employees be protected from electrical hazards. There are specific requirements on how to do so based on the boundary being crossed. Who is permitted to cross a specific boundary and what should occur upon doing so is also addressed. It does not matter if an employee’s title is mechanic, electrician, maintenance worker, technician, contractor, or painter. NFPA 70E uses the terms qualified and unqualified person. All five employees are at risk of being injured by an arc-flash. Two of the employees are at increased risk of being shocked (electrocuted) and two more are exposed to a shock hazard.
How you classify a task at your facility is semantics when it comes to electrical safety. What will be your justification for the painter’s injury following an arc-flash incident? That she was not working on the electrical equipment will not be acceptable. It will not matter that the thermographer was doing something deemed non-electrical when the arc-flash occurred. Is the injury different because the employee removing the cover is a technician when he is electrocuted due to a loose, energized wire? If you want to get hung up on an electrical term, make it hazards. Adequately protect all employees performing any task around any electrical hazard. Even better, don’t expose an employee to an electrical hazard.
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Next time: Arc-flash label replacement and risk assessment reviews.