Skip navigation
All Places > NFPA Today > Blog > Author: ccoache
1 2 3 4 5 Previous Next

NFPA Today

70 Posts authored by: ccoache Employee

70E BLOG.png

 

I am shocked at the number of questions received regarding a misuse of NFPA 70E®. The questions were not on a specific issue but it was the subsequent conversations that sent a shiver down my spine. The crux of the concern is that the tables provided in the standard are being used to falsely “justify” energized electrical work and that a label on equipment is an allowance to work energized. It seems that many believe that it is acceptable to ignore a majority of the standard by going right to the tables and that PPE provides adequate protection for their employee. If it is on the table isn’t that justification enough to perform energized work? If the employee is protected why is there a need to establish an electrically safe work condition?  There are so many things wrong with this thought process that I will not go into them here except for what should have been the obvious ones. What I will address is how the tables are meant to be applied when energized work has been justified.

First, let me point out the obvious flaws with that mind set. The primary method of providing electrically safety for the employee must be establishing an electrically safe work condition regardless of the energy level, the voltage level or the ability to wear protective gear. These people assumed that there is justification for the work to be performed while energized most likely without the benefit of a risk assessment. They determined that no other hierarchy of risk controls would be employed to provide additional protection for the worker. They determined that only the lowest level of control (arc-flash PPE) would be employed as the default for worker protection.  Although properly selected arc-flash PPE minimizes the severity of an injury it does not necessarily prevent an injury. Due to the explosive effect of some arcing events, physical trauma injuries could occur. The PPE requirements do not address protection against physical trauma other than exposure to the thermal effects of an arc flash. The use of PPE also does not prevent damage to the equipment. A proper label on equipment should be primarily used to establish an electrically safe work condition not as permission to perform energized work.

Now on to the use of the tables. The first thing is to determine that there is justification for the energized work to be performed. This does not mean that the equipment is included in the table. One of the justification criteria must be met. The next thing is to determine the likelihood of an arc flash occurring (This is included in the task table in 2015 which will become a new table in 2018). After exhausting the hierarchy of risk controls down to the PPE level, the appropriate PPE category table is used to determine the required PPE level.  This table is not only equipment specific but parameter specific. The PPE category method cannot be used if the equipment is not on the table or if even one parameter is exceeded.  Once the PPE category is assigned, the table defining what is required to make up this PPE category is consulted to specify the necessary gear.

There is no allowance for justifying energized work solely based on equipment labeling or simply by conducting a risk assessment that results in a hazard. The main requirement in both NFPA 70E and federal regulations is that equipment be placed into an electrically safe work condition. The entire standard must be used to protect the worker. When energized work is justified, using the table without complying with all the requirements disregards the steps designed to protect your worker. Doing so places your employees at an unnecessary and greater risk of injury. 

Next time: Why does a "qualified person" create such a problem?

70E BLOG.png

There are many statements being made in the field that NFPA 70E® has a preference to use the incident energy analysis method over the PPE category method. One of the stated reasons for this has been that it is first in the standard and the first requirement is always the preferred method.  None of this is true.  Either method can be used if applicable. Something is only a hierarchy if the standard states the list is in a discrete order (think hierarchy of risk controls which are in a specific descending order of effectiveness or that the explicit primary requirement is that an electrically safe work condition be established.)

NFPA 70E permits the use of either the PPE category method or the incident energy analysis method. The standard does not have a preference since each method has its merits and its limitations. Both achieve a level safety for the worker when energized work is justified. Why use one method over the other? Let’s look at some reasons for each. First, both require that the hierarchy of risk controls be used.  Both require that you know the available short-circuit current and fault-clearing time. From there the methods diverge.

To use the PPE category method the equipment must be listed on the table. The specific parameters for that piece of equipment cannot be exceeded. The PPE category and the arc-flash boundary are given. A benefit of the table method is that it does not require that an extensive incident energy evaluation be conducted. It is potentially a quick and effective way to properly label equipment. It provides a simple four level system for required PPE within the facility.

There are limitations in the use of the table method. If the equipment is not on the table or if even one parameter is exceeded the method cannot be used. If the working distance will be closer than specified the method cannot be used.  A detriment is that if the actual circuit parameters are well below those specified the PPE category remains the same. Although the hierarchy of risk controls may lower the risk to the worker the PPE category remains the same. The table is either GO or NO GO. There is no interpolation.

A benefit of using the incident energy analysis method is that it can be used on any piece of electrical equipment. It allows a finer pinpoint on the incident energy rather than the broad range of the category method. It can be adjusted for a change in current, clearing time or working distance.  One detriment is that it is a very detailed process typically requiring the assistance of an outside consultant or the use of a computer program to perform the calculation. Although no specific method of calculation is required by NFPA 70E, the incident energy analysis method requires that you select the most appropriate calculation method for the type of circuit. This method is often a longer process than the table method. Depending on your viewpoint, having the ability to specify individual PPE for each piece of equipment may be a benefit or detriment.

There are other benefits, detriments and shortcomings of both methods. Regardless of the method selected, of the reason for selecting one method over the other, or other issues associated with a particular method, the main concern is protecting the worker. NFPA 70E allows both methods to used equally. Both may be used in the same facility but must not be used on the same piece of equipment.  You must decide which one is applicable for your equipment.

Next time: A misuse of the PPE category tables.

 

Often when I reiterate that the primary protection scheme must be establishing an electrically work condition (ESWC), a comment is made that a worker is put at risk during this process. The maker of that comment often continues on to defend why they do not require ESWCs in their facility. NFPA 70E® requires that you to conduct risk assessments to determine the hazard, and the risk and severity of possible injury. The standard then requires that you to exhaust the hierarchy of risk controls to protect the worker. This is true whether you intend justify energized work or require that an ESWC be established. If you have determined that there are no hazards, there is nothing to protect the worker from.

If there are hazards, the worker must be protected from injury. Getting to the PPE level in the hierarchy of risk controls means that you have done everything you can to minimize the hazard and the risk of injury. IT DOES NOT MEAN THAT ENERGIZED WORK IS JUSTIFIED. It means that you have determined that there is still a hazard present which requires the worker to wear protective gear when interacting with the equipment under proper justification. The hazard could be shock, arc-flash or both. You will either justify energized work or require that an ESWC be established. I hope the following will clarify the difference of what I mean when an ESWC and justified energized electrical work are mentioned in my blog.

The first reason I make the distinction is for brevity. The reason for and act of establishing an ESWC should be well understood. That a worker is put at risk, must wear protective gear, and must follow work practices are inherently included in this task. To explain this every time is unnecessary. There is no way to establish an ESWC without some risk of exposure to a potential hazard. Until you know for sure that there is no energy present you have to assume that there is energy present. By right, with a proper risk assessment and under the conditions which permit normal operation, establishing an ESWC should remove the hazard before the voltage measurement is made. The ESWC voltage measurement should always be zero. Although establishing an ESWC condition must be considered energized work it actually should not be exposing the worker to an energized circuit. The process is to protect the worker if something has gone wrong.

The second reason is to differentiate between the ESWC tasks and other similar energized work tasks. A voltage measurement may be made for the sole purpose of establishing an ESWC. A voltage measurement may also be made to verify operation of equipment without any intent to put it into an ESWC. Both tasks are exempt from a work permit but there are obvious differences in the two. When establishing an ESWC, the risk of an arc-flash, electrical shock or unanticipated equipment outage is greatly reduced as compared to other tasks. For the ESWC, the worker has limited exposure to the hazard (see first paragraph) whereas for other tasks there is an unlimited exposure to the known hazard or risk of injury. For conditions other than the ESWC the worker is constantly at risk of having an incident occur. Without an ESWC you are using the PPE to protect the worker from a known and present hazard while energized work is being performed. That is a substantial difference from the ESWC task.

The last reason for the distinction is that after the ESWC has been established the worker can remove the PPE. They could conduct the remainder of the work bare handed, wearing every day work clothes without a visibility or hearing impediment. For the other types of energized tasks all the PPE must be worn while the worker is “working” on the equipment (see my two previous blogs regarding the burden of wearing PPE.) The PPE must be worn until the equipment is put back into a normal operating condition. Anyone entering the arc-flash boundary or a shock protection boundary is put at risk and must be protected. The distinction is also made because many voltage measurements for the operation or troubleshooting of equipment evolve into other tasks. Unfortunately this sometimes occurs without generating a new energized work permit covering the new hazard, risk or task. Establishing an ESWC cannot evolve into another task.

I understand that establishing an ESWC is considered to be energized work. Until the task is completed a worker is exposed to hazards and potential injury since there is no assurance that the equipment is properly de-energized. I also understand that establishing an ESWC is justified under infeasibility and that the voltage verification would be included in the work permit exemptions. Up to this point there really is no difference between establishing an ESWC and conducting a voltage measurement. There is a HUGE difference after the voltage measurement is made. Hopefully you see the difference between a worker establishing an ESWC and a worker performing tasks, including other voltage measurements, on energized equipment. Your primary safe work procedure must be to establish an ESWC. Doing otherwise places a worker at risk of injury.

Next time: A rumor that NFPA 70E has a preference on how to conduct a risk assessment.

 

This is a continuation of my last blog which covered the burden of being protected against the first electrical hazard (shock) addressed by NFPA 70E®. The second hazard addressed is an arc-flash. Essentially an arc-flash causes a burn injury. If you look at medical records, insurance reports, etc. that provide data on electric burn injuries you will find that they are very traumatic, very expensive, have an extremely long recovery time and are difficult to survive when severe.  A dropped tool, a loose connection, and a slip of the hand have all initiated an arc-flash. Many workers who decided to roll the dice were sure that it would not happen to them when they started the task or took a shortcut. Others could not comment because they bet their life and lost. NFPA 70E requirements are to protect you from this type of injury. An arc-flash can occur in less time than it takes to blink your eye. You will not avoid it. It is the final line of defense (arc-flash PPE) that NFPA 70E requires you to wear that will save your life.

The burden you must endure is wearing arc-rated PPE. It may make the task more difficult. It can get quite warm in a full arc-flash suit. Remember that if the electrical equipment was placed into an electrically safe work condition that this “burdensome” gear would be unnecessary when you are working on the equipment. Some of you may consider it to be a hassle to don all the required gear. The decision to skip wearing some of the gear entails deciding which part of your body may not be that important to you. If the incident energy is above 1.2 cal/cm2 you should plan on spending time in the hospital. Roll the dice. Live or die by the outcome.

There have been some great advancements in the materials, flexibility, weight, etc. of this gear. Selecting and actually wearing the appropriate PPE, as well as allowing sufficient time to safely perform a justified task, are steps that should not be overlooked. One thing that increases your odds of returning home after an incident is the protective equipment that NFPA 70E requires you to wear. Think about what this gear is intended to do. It is to protect you from a burn injury when a ball or wall of flame hits you. Can you reconcile the decision not to wear protective gear with your confidence that you will not become a statistic?

Working on energized electrical equipment is not a craps game. If it were it has some of the highest stakes. Your life can change or end in a split second. Don’t wager that an incident will never happen to you. Don’t let a toss of the dice determine if you will return home. Accidents happen. Unexpected things occur. Qualified people make mistakes. Don’t consider electrical safety to be a burden. By the nature of what is trying to be achieved, gear designed to protect you from an electrical injury will be more robust and require more to be worn than every day work clothes. This is especially true for higher energy or voltage levels. Remember to shut it off first. If that is impossible, the PPE requirements in NFPA 70E provide the best odds that you will return home when you perform justified energized electrical work.

Next time: The difference in establishing an electrically safe work condition and performing justified energized work.

70E BLOGgggg.png

 

Are you a craps player? You toss the dice and get a random outcome. Some outcomes have better odds of occurring than others. Sometimes it pays and sometimes you roll craps. Think of what you do at work. Are you rolling the dice to determine if you will be going home at the end of the day? Some of you consider the requirements in NFPA 70E® to be a burden especially if you are the one performing the energized work. NFPA 70E is intended to keep you reasonably safe from an electrical injury. The primary method which is to not have you exposed to electrical hazards in the first place. As the worker, think about what NFPA 70E requires of you.  It requires that you be able to perform a task on the equipment in a safe manner from the hazards you will be justifiably exposed to. I hope that working safely so that you can return home at the end of the day is not a burden.

 

What does NFPA 70E require for any scheduled electrical work? If you didn’t answer that the equipment be placed into an electrically safe work condition (ESWC) please look into what that means. There is no electrical hazard when equipment is in an ESWC. You will not be harmed by electrical energy. You can wear whatever you choose. Wouldn’t you be more comfortable wearing a t-shirt, shorts and flip-flops? (Note that this only applies to the electrical hazard.) Is it a burden to ask why the assigned task must be done while energized? Management’s or your own decision to have you perform energized electrical work is what burdens you to wear more gear. Is it a burden to find out why you are being put in harm’s way? If your employer is following federal regulations and NFPA 70E requirements there are only three justifiable reasons to expose you to risk of an electrical injury. These are greater hazard, greater risk and infeasibility. If revenue (in any form) is the improper justification for the energized work, your safety has been given a monetary value. I hope it is a high one since that will be your wager when the dice are thrown.

 

Assuming that energized electrical work is justified, what are the hazards that NFPA 70E is written to protect you from? Currently, it is to protect you from two hazards. The first is electric shock. During a shock, electrical current may travel hand to hand or hand to foot. Sometimes it is hand to head, chest, back or buttocks. When an electrical current is passing through your body you are rolling the dice. If it takes a critical path, hits at just the right cycle of the heartbeat sequence, lasts just a little too long, is on a high line circuit rather than low line, or enters through a cut in the skin that shock could become an electrocution. The level could also be high enough so that it just doesn’t matter what the conditions are or the path it takes. Electrocution is just a stone’s throw away rom an electrical shock. Electrocution has occurred at 120 volts. To my knowledge no one has ever survived an electrocution (check the definition). When you ignore NFPA 70E requirements for shock protection you are betting your life that you will only get a shock (this time).

 

Here are some generally accepted thresholds for a 60 Hz current passing through a 150 pound, healthy male:  Painful shock – 9 mA; Let-go threshold (start) – 16 mA; Impaired breathing and loss of muscle control – 23 mA; Possible ventricular fibrillation – 100 mA (3 second shock); Heart muscle failure – 500 mA, Burnt tissue and organs – 1500 mA.  The resistance of dry, undamaged, outer layer of skin ranges between 1,000-100,000 ohms. A typical human body model uses 500 ohms per limb and 100 ohms for the core.  Calculate the anticipated current levels at 120 volts. Are they higher than you thought? You probably perform energized work on 208 volt or higher systems. What do the numbers come to for your justified, energized work environment? The circuit current limiting device is most likely rated at least 20 amperes. Do you still want to gamble that you will not accidentally make contact?

 

My father was an old school electrician who was taught to test by touch and work bare-handed. One day he got “hung up”. Lucky for him, a co-worker realized that he had not moved for what seemed to be a long time. By my father’s account being helpless while feeling a painful, burning sensation made it seem like an eternity. He tells it that the co-worker could see it in his eyes that something was wrong. There was no other communication method for him. That co-worker most likely saved my father’s life. What would have happened if that co-worker did not notice? My father’s body could have stayed there until he went unconscious and fell away. He might have silently agonized until the electrical system opened the circuit for some other reason. He may not have survived. Almost every electrical worker knows someone who has rolled the dice and luckily only experienced a shock if they themselves did not. Several of you know someone who tossed the dice and lost. Hopefully, the next generation of electrical workers will not have the same experience.

 

So, the burden that you perceive to be put upon you by NFPA 70E are the requirements intended to save your life. You have to use tools anyway so why not use properly rated, undamaged, insulated tools? When you schedule the work you should know what is necessary to protect you from shock hazards for the specific task. You should not be modifying the energized electrical work permit in the field. It may be difficult to perform some tasks while wearing gloves so that must be one of your perceived burdens. Gloves are not the only method that can limit the risk of a shock injury but if they are necessary use them. The additional protection would not be necessary if the equipment were in an ESWC as primarily required. There should be no need to return to the truck to get the correct tool for a properly scheduled task but if that trip is necessary it should be taken rather than rolling the dice once again.

 

Next time: The burden of being protected (Part II).

70E BLOG.pngIt is surprising that users of a consensus standard think that by applying the requirements they are always following best practices. Although standards are a starting point they are more often than not only a starting point. In other words, the requirements of a standard or code are at a level that the public or industry came to a consensus on. Some wanted it to do more and some wanted it to do less. Of course, there is a practical limit to a return on the investment. You could spend billions of dollars to achieve a negligible increase in electrical safety. That is also a factor when it comes to a best practice. In any event, I am not aware of any available standard which requires the absolute most that can be done. NFPA 70E® is no exception since it is a consensus standard.

 

If NFPA 70E®, Standard for Electrical Safety in the Workplace® were the “best practice” it would only need to contain one requirement. That requirement would simply state ENERGIZED ELECTRICAL WORK SHALL NOT BE PERMITTED.  That would be it. End of standard. Use an on/off switch. An inexpensive way to achieve an extremely high level of electrical safety. If there is no electricity then there should be no electrical hazard. That would be the best available practice (FACT: it is the primary method of protecting an employee required by both NFPA 70E and federal regulations). Doing anything other than this would not be the best practice since it would only serve to increase the risk of injury to the employee.  Everyone should agree that something that greatly increases the potential for a negative outcome should not be considered to be the best practice.

 

We all know that it is not an option to have this one requirement. So, the consensus standard provides a compromise of what can be done if the best practice is not applied. Again, these compromises are not the limit of what can be done and should not be considered as such. The requirements serve to establish an accepted consensus level of safety. I cannot think of any code or standard that prohibits you from doing more than what is required. There are many things that could be used to illustrate this point but I will pick one.  Think about what you do when you have justified energized electrical work, have exhausted the hierarchy of risk controls and are at the step of specifying arc-flash PPE. Do you use the minimum of the standard or do you go beyond it?

 

You have done an incident energy analysis and have determined through calculation that the incident energy will be 11.8 cal/cm2 at a working distance of 18 inches. If available do you permit the use of gear rated 11.8 cal/cm2? Do you round it up to 12 cal/cm2. The standard would allow either. Do you try to rationalize that the calculated energy should be a higher value than the real world arc-flash were one to occur? Do you keep it at less than 12 cal/cm2 because an arc-flash hood is necessary if it were greater? Do you specify something else? Maybe something rated even higher? Think about your answer before continuing on.

 

Thought about what you would do? Now consider how you arrived at this point. You applied risk controls which included administrative and behavioral controls. You selected one calculation method which used the expected parameters and relied upon the function of several pieces of electrical equipment. This provided you with an anticipated incident energy at a very specific working distance. You will specify arc-flash PPE which has a 50% chance of the wearer receiving a 2nd degree burn based on testing of samples at a specific incident energy.  Is it a “best practice” to use 11.8 cal/cm2 rated PPE for a calculated incident energy of 11.8 cal/cm2? Would the answer be the same if you were the one wearing the gear to perform the energized work?

 

Standards are written through a consensus process involving all types of interests, industries and the public. Some of these entities will have needs which exceed the requirements of a general standard. Standards and codes have to provide some guidance but only you can decide if the requirements are your “best practice.”

 

Next time: The burden of increasing the likelihood that you return home each day.

70E BLOG.png

 

My first blog covered why YOU should consider yourself to be an AHJ when it comes to applying the requirements in NFPA 70E®. To refresh your memory, the main reason is that NFPA 70E must be applied proactively not reactively. There is no governmental agency that visits your facility to set up a safe work program for you. No agency audits the work procedures or watches over you while you are performing work. You are left to your own devices until an incident occurs. By then it is too late for the employee who was injured or their family dealing with their death.


Look at the requirements in NFPA 70E. They must be used before an employee is put at risk of an electrical injury. This requires proactive involvement of the entire organization starting at the top. An AHJ is broadly defined as “an organization, office, or individual responsible for enforcing the requirements of a code or standard, or for approving equipment, materials, an installation, or a procedure.” Throughout an organization there are many people responsible for various NFPA 70E requirements. So you are the AHJ in some regard whether you are in upper management, middle management, a supervisor or the employee.

 

The employer must provide safety related work practices and train the employee. Upper management must set the course for a culture of electrical safety. They must establish policies for protecting the employee which would include allowing an electrically safe work condition to established rather than placing revenue above worker safety. They are responsible for overseeing that the core electrical safety principles are not undermined. They must address contract employees performing work within their facility.

 

Middle management must allow for time for work to be safely conducted. They must make sure that processes and procedures provide protection for the employee. They are often the one given the responsibility of applying their signature to an energized work permit and must make sure that the work is properly justified. They may need to modify the electric safety work program when conditions at the facility change.

 

Supervisors must make sure that qualified employees are assigned to conduct the specified tasks. They should confirm that the job briefing is conducted before work is begun. They must verify that the appropriate personal protective equipment (PPE) is issued to or used by the employee. They must understand the safety issues brought to them by a worker who has expressed concerns regarding the assigned task.

 

The employee is required to implement the employer’s training and practices. They are responsible for their own actions. They must acknowledge the fact that they may not be qualified for the task assigned to them. The employee must be able to recognize that the equipment has not been maintained as expected. They are the only one capable of realizing that pulling a double shift has decreased their awareness to the point that they can no longer work safely and are now at a greater risk of an injury. The employee is solely responsible for final assurance that the work can be and is performed safely.

 

A single AHJ most often will not be identifiable when it comes to electrical safety in the workplace even if there is an assigned safety manager. These were just some examples of how the requirements in NFPA 70E become the responsibility of various persons thereby making each an AHJ. The main thing to remember is that NFPA 70E is about providing a safe electrical work environment for the employee. Without top to bottom buy in to this fact, the best laid plans are rendered ineffective. Electrical safety is everyone’s job. Where do you fit in?

 

Next time: The misconception of what a consensus standard is.

70E BLOG.png

NFPA 70E Series: Where's the Authority Having Jurisdiction (AHJ)?

 

It is coming up on Labor Day. A day for honoring the American worker. It seems an appropriate time to launch a new blog series on NFPA 70E®, Standard for Electrical Safety in the Workplace®. If nothing else, NFPA 70E is about protecting the worker.

 

Until I run out of topics to have a tirade about, I intend to offer some personal observations that have been made since I have become the staff liaison for NFPA 70E. I expect these to be posted every few weeks for several months. Some may be short. Some will be lengthy. It is expected that you will not agree with all of my views especially since some will take a very simplistic view to make a point. Hopefully they will provide a different angle on some issues you face and something to think about when using NFPA 70E. My ultimate goal is to make you think before signing an energized work permit.

 

Recent conversations with users of NFPA 70E have lead me to the realization that many do not know who is responsible for enforcing the requirements. Unlike other standards like the National Electrical Code® (NEC®), the Life Safety Code® (NFPA 101®) or the Standard for the Installation of Fire Sprinklers (NFPA® 13), NFPA 70E is not an adopted or legislated standard. It does not have a governmental authority for enforcing the requirements. 

 

Many believe that the Occupational Safety and Health Administration (OSHA) is responsible for enforcing NFPA 70E. While OSHA regulations provide the law that American workers be provided a safe work environment, it is not responsible for enforcing NFPA 70E. OSHA enforces the requirements in the Code of Federal Regulations (CFR). OSHA expects that you have complied with the law. They typically do not audit every facility in the United States of America prior to an employee conducting any task. They may use NFPA 70E to show where your program is lacking after an incident. Using NFPA 70E requires proactive application of the requirements to be effective so OSHA is not really the AHJ. An AHJ is broadly defined as “an organization, office, or individual responsible for enforcing the requirements of a code or standard, or for approving equipment, materials, an installation, or a procedure.”

 

Consider the analogy that there are laws against stealing. You might get caught your first time or your hundredth time.  You steal
things for years or are never caught. Does this negate the need to actually follow the law? Does this mean there is no enforcement? The court system provides punishment if you happen to get caught violating the law. Likewise, OSHA has laws for providing a safe work environment for your employees. You decide to ignore the laws requiring safe work practices. You put your employees at
risk.  Hundreds of minor injuries or near misses occur. Nothing is reported. Ultimately there is a serious injury or a fatality. OSHA punishes you for not following the law. Did OSHA make you comply with the worker safety law? Did the court system or police department make you comply with the law against theft?  No, they did not.  Each reacted to you not following the law. They did not proactively ensure that you actually follow the law. Only you can do that.

 

One way to proactively address worker safety is to utilize NFPA 70E to assist in providing a work environment that has followed the guidelines of a national consensus standard when your electrical safety program is established and when it is being utilized throughout the facility. You would not only be proactively applying practices and procedures to minimize the risk of electrical injury to your employee but proactively setting workplace guidelines that help you comply with the federal mandate that your employees not be subjected to undue risk of electrical injuries.

 

The saying is “ignorance of the law is no excuse.” Ignorance of industry and national standards is also no excuse. If an industry has identified hazards and risks, and implemented methods to minimize those, it is expected you will apply them. NFPA 70E is written for the recognized electrical hazards in the workplace and ways to avoid them. Only the AHJ can proactively verify that employees are
protected from those hazards.

 

Who is the AHJ for NFPA 70E. The answer is YOU!

 

Next time: I will go into what that statement means.

The second draft meeting for NFPA 70E was held in Salt Lake City on July 18th through July 21st. There were 173 public comments acted on at the meeting. There are a few proposed changes to the standard that were acted upon that may garner the most attention.

 

NOTE:  The official position of the committee has not been given through the formal ballot. This blog only addresses preliminary revisions proposed by the public and committee.

 

The first is that the layout of Article 120 Establishing an Electrically Safe Work Condition has been reorganized to better address the logical sequence of events. The steps, principles, and program for lockout/tagout have been moved to be the first sections of Article 120 since these are necessary before verifying the condition.  The verification steps have been moved to the end of Article 120 since these are the last steps for establishing the electrically safe work condition.

 

A second change is to place further emphasis on the risk assessment and put the hierarchy of controls into mandatory language.  The use of personal protective equipment (PPE) has always been and remains to be the last method selected when providing protection for the worker exposed to hazards when conducting justified energized work. The revised text clarifies this principle.

 

The third changes clarifies how the standard should have always been used when justified energized work is to be conducted. It essentially is not adding new requirements but will assist in preventing the misuse of the standard. The change is that Table 130.7(C)(15)(A)(a) [that many call the task table] has become a new table applicable to both the PPE category method or the incident energy analysis method. It no longer determines whether PPE is required but whether or not there is a likelihood of an arc flash occurrence. The user conducts a risk assessment and determines the protection scheme to be employed to protect the worker using the hierarchy of controls (same as in the past editions).

 

The last big change is that the references to PPE equipment standards have been changed to informational notes. The equipment must still meet the applicable standards but the verification process has been changed to one of a conformity assessment where the PPE manufacturer should be able to provide assurance that the applicable standard has been met by one of three methods. The previous edition of the standard did not require any verification method. The three methods are; self-declaration with a Supplier’s Declaration of Conformity, self-declaration under a registered Quality  Management System and product testing by an accredited laboratory and a Supplier’s Declaration of Conformity, or a certification by an accredited independent third-party certification organization.

 

The committee's official position will be taken by ballot in early September.  If you want to keep up on the process visit the NFPA 70E web page at www.nfpa.org/70E. The next edition tab will carry all the current information throughout the process. NFPA 70E - 2017 is slated to be voted on at the association meeting in Boston, MA in June 2017.

Have you ever wondered what happens at an NFPA 70E meeting? If so, the NFPA 70E committee is coming to Salt Lake City to conduct the second stage of the 2018 edition process.  The meeting is open to the public and is scheduled to start at 8:00 am Monday July 18th. It will be held at the DoubleTree Suites by Hilton Hotel Salt Lake City Downtown. If you cannot make it to the meeting you can keep track of the next edition at www.nfpa.org/70E under the next edition tab.

 

NFPA 70E is the standard for electrical safety in the workplace. If you maintain, repair, troubleshoot or work on electrical equipment, NFPA 70E is intended to help protect you. If you are safety manager, facilities operator, or electrical contractor, NFPA 70E is there to help you determine how to protect your workers from electrical hazards.

 

NFPA 70E is the "how to" to the Occupational Health and Safety Administration's "what you are legally required to do" when it comes to protecting your workers from electrical workplace hazards.

 

The public input for this cycle included a reorganization of Articles 110 and 120, further refining the arc-flash tables to place a greater emphasis on the assessment process, and to increase the dc shock threshold to 100 Vdc. If you are in Salt Lake City stop in to see what happens with the proposed changes.

 

Picture1.png

Filter Blog

By date: By tag: