Why do so many of us get wrapped around the axle? We are all committed to electrical safety. We all know that removing an electrical hazard is a good thing. But is removing the hazard the same as eliminating the hazard? Can a hazard only be permanently eliminated? If so, does this mean a hazard can only be temporarily removed but not temporarily eliminated? I might be an instigator of this confusion because I never expected it to be an issue. I do believe that a hazard that never exists should be the goal. I have often stated that “full elimination of the hazard is often not an option for installed equipment. Although elimination also can be achieved by applying other controls such as through establishing an electrically safe work condition (ESWC), these other controls introduce a potential for human error. Therefore, the initial attempt should be full elimination of the hazard.” I do not believe such a statement alters meaning of the word elimination. I was not aware that elimination has a time component for many of you. I haven’t found a definition of elimination that includes a time base. Here is the problem.
Many in the electrical safety industry consider the hierarchy of risk controls to first eliminate the electrical hazard. This is such that there is no electrical hazard at any time. I agree. NFPA 70E®, Standard for Electrical Safety in the Workplace® states that it includes installation of electrical equipment but such work is typically not conducted while energized. I believe the electrical safety of employees should be addressed at design and installation regardless whether NFPA 70E applies at that time or not. Under this belief, I have stated that full elimination of the hazard should be considered at design of the equipment as well as the design of the electrical system. I hold on to that belief since attempting it will protect future employees by making electrical installations safer. I would then consider the rest of the hierarchy for the installation to further control hazards and risks while the system design, equipment selection and installation are being considered.
For many of users of NFPA 70E, a problem comes with requirement in 105.4 that hazard elimination be the first priority. Another issue is many reference another standard where elimination only means “total elimination.” That fixed idea may not be applicable to elimination within NFPA 70E. It is typically not possible to permanently eliminate the hazard using work the practices required by NFPA 70E. Once equipment has been installed my concept of hazard elimination shifts but my definition of elimination does not. When using the hierarchy of risk controls for work practices on installed equipment, I run down the list again. Full elimination, substitution, and engineering controls are typically not possible. This brings me to the other controls (administrative, awareness, personal protective equipment (PPE). Under NFPA 70E these lead to establishing an ESWC which temporarily removes (or eliminates) electrical hazards in a specific location for a finite period of time. This leads many to believe that they have not met the goal of “elimination” of the hazard as a first priority. Many consider only full removal of the hazard as in the first context (previous paragraph) to be elimination, therefore removal of the hazard in this second context cannot also mean elimination.
I must be missing something. A sports team is eliminated from the playoffs, they are not eliminated from the league. It is a temporary thing. When a hazard is verified as not being present, it has been removed or eliminated regardless of time. There are many intricacies of requirements in a standard that you must handle on your own. NFPA 70E is no different and elimination is one of those. NFPA 70E does not mention permanent or temporary elimination of a hazard, it is simply elimination. To my knowledge I have never stated that the only elimination of a hazard is permanent elimination. I have said that the process of establishing an ESWC is not the elimination control but it results in the elimination of the hazard. There is a difference. But it is just what the standard required by eliminating the hazard through work processes. The employee will not be injured since there is no electrical hazard present where the task is being performed. You will not convince me that permanent elimination should not be considered first. However, if permanent removal of the hazard is not possible then removal of the hazard on a temporary basis is a very effective method of protecting an employee. I also do not believe that an ESWC be a default work practice without further considering ways to mitigate the hazard or risk.
I expect that much of the second draft meeting will be spent addressing the meaning of the word elimination. If full elimination or an attempt to mitigate a hazard is not addressed, many of you will ignore the hierarchy and only establish an ESWC on all equipment. On the other hand, if elimination only means an ESWC, the safety of future electrical employees will continue to be jeopardized by not mitigating the exposed hazard during the process of establishing the ESWC. Since the concern has been raised, we are getting wrapped around the axle on meaning of the word elimination. But I am not sure how many do not understand what it means and how to use it in regards to NFPA 70E. The solution may be worse than the problem it is trying to solve.
For more information on 70E, read my entire 70E blog series on Xchange
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Next time: Equipment that has electrical hazards beyond what safety equipment is designed for.
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A few weeks ago, the comprehensive First Draft Report along with the First Draft of NFPA 1, 2021 edition, was published. In the report, documentation of all first revisions, committee inputs, and responses to public inputs, are available for public review. The First Draft is the public’s first view of the current state of the document and the newly introduced changes and topics that were voted on by the Fire Code Technical Committee.
NFPA’s codes and standards must remain relevant and useful to our variety of customers who use them. One way to do this is to continue to evolve and introduce requirements for new and emerging technology into our codes and standards. NFPA 1 did just that in its First Draft by adding a chapter on Additive Manufacturing (3D printing).
Additive manufacturing is defined as ‘a process of joining materials to make objects from 3D model data, usually layer upon layer, sometimes referred to as 3D printing’. There are two types of this process that are addressed in NFPA 1. Industrial Additive Manufacturing is 3D printing operations that utilize combustible powders or metals, an inert gas supply, or a combustible dust collection system or that create a hazardous electrical classification area outside of the equipment. Nonindustrial Additive Manufacturing do not create a hazardous electrical classification area outside of the equipment and do not utilize an inert gas supple or combustible dust collection system. In general, it’s a process in which a material, such as plastic or metal, is added in layers until a fully designed item is whole and complete.
3D printing is not a completely new process, but its popularity has been growing, the technology is evolving and 3D printers are becoming more mainstream and more widely available to businesses and to the public. It is being conducted in a variety of occupancies: personal residences, healthcare, businesses and industrial operations and can produce everything from small plastic gadgets to large metal jet engine parts.
But what place does additive manufacturing have in a fire code? In the September/October 2018 edition of NFPA Journal, Angelo Verzoni cited a study published in the Environmental Science & Technology journal which found that the plastics used in smaller, desktop 3D printers (nonindustrial processes) can produce hazardous volatile organize compounds and should be used in well ventilated areas. Because most of the materials used in the process are combustible, the primary concern of larger 3D printers, likely classified as industrial additive manufacturing, is the production of combustible dust. The printing process generates dust and can produce very small particles. Some metals used in the process can burn very quickly and produce high temperatures. All of this being a concern to building owners, fire inspectors, equipment operators and occupants.
The Fire Code is addressing these issues by requiring listed equipment, safe dust collection and management processes and safe use and handing of any associated hazardous materials. Other NFPA documents such as NFPA 652 and NFPA 400 are referenced for their expertise on the relevant topics associated with the additive manufacturing process.
3D printing is an exciting technology and we are sure to see more of it in the future as the equipment advances and products that impact our day to day lives are produced by 3D printers. The Fire Code is sure to follow these advances and ensure that our customers are provided with requirements to keep their buildings, occupants and property safe from fire incidents involving this process.
To view the details of the NFPA 1 First Draft Report and new Chapter 46 visit nfpa.org/1next. We are also seeking input from the public on the recent changes made to the Code. We invite you to participate in the process by submitting comments to NFPA 1 using the link on the page above.
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After a long period of drought conditions, much of the western and central portions of the United States have been saturated by flooding in recent weeks. Today the NFPA Archives takes a look back at an incident from April 3, 1958.
It all started out innocently enough. Sixteen year-old, Ronald Gregory of Oakland, California was wading through the flood-swollen waters of a local creek bed when he was caught by surprise and swept away with the strong current. He ended up traveling a fair distance downstream before he managed to grab the trunk of a willow tree and pull himself up to a precarious position in its branches. The image above shows the final rescue that was made by the San Leandro police and fire personnel.
For more information regarding this and other moments in fire history, please feel free to reach out to the NFPA Research Library & Archives.
The NFPA Archives houses all of NFPA's publications, both current and historic.
Library staff are available to answer research questions from members and the general public.
New York State has implemented a new law requiring retailers to only sell smoke alarms that feature 10-year, non-replaceable batteries. This requirement comes in response to people removing smoke alarm batteries, or not testing and replacing them as needed.
According to a CBSNewYork/AP story, New York experiences the highest number of fire fatalities each year; the goal of the new law is to help bring those numbers down.
“If I need a battery for the remote for the TV, I’m going to take it from the smoke detector. If I need a battery for a toy for my child, I’m going to take it out of the smoke detector. If the alarm keeps going off when I’m cooking, I’m going to take the battery out, and then they don’t put it back in,” said Tom McDonough, a firefighter and board member of the Fireman’s Association of the State of New York.
McDonough fought for the ban of smoke alarms with removable batteries for years. His efforts paid off yesterday when the ban went into on Monday, April 1.
New York State’s new law reinforces the importance of working batteries in smoke alarms. When batteries are dead or removed from alarms, the consequences can be fatal:
Smoke alarms with non-removable batteries typically feature 10-year batteries so that they don’t have to be replaced for the life of the alarm. Smoke alarms should be replaced every 10 years, or when the alarm begins to chirp, signaling that it’s running low. Also, to find out how old a smoke alarm is, look at its date of manufacture on the back of the alarm. The smoke alarm should be replaced 10 years from that date (not the date of purchase or installation).
What do you think of New York State’s requirement requiring retailers to only sell smoke alarms that feature 10-year, non-replaceable batteries? We welcome your thoughts!
I still refer to the building rehabilitation chapter of NFPA 101, Life Safety Code, as the “new Chapter 43.” It’s been in the Code since the 2006 edition; that’s something like 13 years. I guess it’s not so new anymore. Nonetheless, when I teach NFPA’s three-day 2018 Life Safety Code Essentials seminar, I sometimes encounter some confusion in the class with the concepts of change of use and change of occupancy. Here’s how it works:
Chapter 4, General, mandates any rehabilitation work on an existing building must comply with Chapter 43 (see 4.6.7). One of the rehabilitation work categories is change of use or occupancy classification. It should be noted that change of use or occupancy classification does not necessarily have to involve a physical change to the building; Chapter 43 applies whether a physical change occurs or not. To understand the difference between change of use and change of occupancy classification, refer to the special definitions in Section 43.2:
188.8.131.52.5 Change of Use. A change in the purpose or level of activity within a structure that involves a change in application of the requirements of the Code.
184.108.40.206.6 Change of Occupancy Classification. The change in the occupancy classification of a structure or portion of a structure.
The key words in the ‘change of use’ definition are, “that involves a change in application of the requirements of the Code.” An example I give is converting an office in a business occupancy into a storage room. The occupancy classification has not changed; it’s still a business occupancy because storage is permitted by 220.127.116.11.3 to be considered incidental. However, general storage areas are considered to be hazardous in business occupancies per 18.104.22.168 and 22.214.171.124. This results in a change in the application of the requirements of the Code and is a change of use. Chapter 43 describes the requirements for change of use in 43.7.1. For this example, the creation of a hazardous area is covered by 126.96.36.199, which requires a new hazardous area to comply with the requirements applicable to the new use as though it were new construction. This means we would have to apply the requirements for new business occupancies in 188.8.131.52, which sends us back to Section 8.7. This requires either: 1) separation of the hazardous area from the remainder of the building by one-hour fire barriers and 45-minute doors, or 2) the installation of automatic sprinklers with a smoke partition separation and self-closing doors. Either way, some modification to the room and/or door is likely going to be required. Changes of use to other than hazardous areas might require compliance with the existing occupancy chapter requirements.
Change of occupancy is pretty straightforward: changing a building’s occupancy classification from one classification to a different classification. An example I give is when I worked in the fire marshal’s office in San Antonio (home of the 2019 NFPA Conference & Expo!) in the 1990s, we had several old office buildings on the Riverwalk that were bought by developers and converted into hotels. The former occupancy classification was business and the new classification was hotel and dormitory (this was back before Chapter 43 existed, so it’s a hypothetical application). To determine the requirements, the former and new occupancy classifications are assigned a relative hazard category classification in Table 43.7.3; these categories relate to the relative occupant risks for the various occupancies. In my example, both business occupancies and hotels and dormitories are assigned hazard category 3 (hotel and dormitory is a residential occupancy by definition). Where a change of occupancy creates other than an assembly occupancy, and the change occurs within the same hazard classification category or to a lesser hazard category, the building must meet the requirements of the applicable existing occupancy chapter for the occupancy created by the change, except that the requirements for automatic sprinklers, fire alarm systems, and hazardous areas must comply with the new occupancy chapter. For my office building-hotel example, the hotel would be required to comply with the requirements of Chapter 29 applicable to existing hotels and dormitories, except that automatic sprinklers, fire alarm systems, and hazardous areas would have to be provided/protected as required by Chapter 28 applicable to new hotels and dormitories. For other changes of occupancy, the requirements vary depending on the relative hazard categories.
Hopefully this will help you to better understand how the Life Safety Code applies to changes of use and occupancy classification and make your job a little easier. Join us at the NFPA C&E in San Antonio in June and check out some of those changes of occupancy for yourself!
Thanks, as always, for reading, and until next time, stay safe!
Got an idea for a topic for a future #101Wednesdays? Post it in the comments below – I’d love to hear your suggestions!
Did you know NFPA 101 is available to review online for free? Head over to www.nfpa.org/101 and click on “FREE ACCESS.”
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Within days of Florida Power & Light announcing plans to build the world’s largest solar-powered battery systems by 2021, NFPA has released its updated and expanded Energy Storage (ESS) and Solar Systems Safety Online Training. FEMA, underwriter of the initial training in 2015 (the world’s first), once again provided Assistance to Firefighters Grant money so that the free, self-paced training could be updated and promoted to the nation’s 1.3 million firefighters. This begs the question, “Are you prepared to respond?”
The Energy Storage and Solar Systems Safety Training, Fire Service Edition* will go a long way in Florida when that state’s proposed ESS facility eclipses the current largest system in Australia. Given the environmental, economic and sustainability virtues of solar and storage, Florida is just one of many states looking to revolutionize their electrical infrastructure with green technology. Texas, Massachusetts, Oregon, Colorado, and Hawaii have also mandated widespread energy storage system deployment.
NFPA has been attuned to the solar and ESS industries for years and offers the fire service and others a host of research and resources at nfpa.org/ess. The updated 3-hour education module entails more solar content, new technological considerations, and relevant research so that firefighters are keeping pace with the potential fire and life safety hazards that may exist with these new energy innovations.
Firefighters taking the NFPA training will receive a certificate upon successful completion and learn critical insights including basic battery and solar system function and design; various failure modes and hazards associated with ESS and solar; pre-incident planning considerations; emergency set up and disconnect details; mitigation and emergency response strategies including investigations and air monitoring; and tips on dealing with electrolyte release, overheated batteries, and fires involving alternative energy systems. The goal is to keep first responders and others safe from HAZMAT issues, thermal runaway, battery explosion and re-ignition, and off-gassing.
To help a wider swath of professionals understand, install and deal with ESS – later this year NFPA will release NFPA 855, Standard for the Installation of Station Energy Storage Systems. The Standard, which aims to establish criteria for minimizing hazards, received over 800 public comments during a recent comment phase and attracted standing-room-only crowds during two workshops in the last year.
The 2019 Safety Stand Down online interactive quiz is live. Test your knowledge of firefighter decontamination at www.nfpa.org/fireservicequiz and be automatically entered into a sweepstakes to win a limited edition challenge coin commemorating this year’s Safety Stand Down theme, “Reduce Your Exposure: It’s Everyone’s Responsibility.”
Studies indicate that firefighters are diagnosed with cancer more often than the public, and that firefighters experience more cancer-related deaths than the general population. To keep the topic of occupational exposure at the forefront, the NFPA, the International Association of Fire Chiefs (IAFC) Safety Health & Survival Section, and the National Volunteer Fire Council (NVFC) are asking all fire and emergency services personnel to promote and take the 2019 Safety Stand Down quiz. First responders are encouraged to try their hand at 13 questions related to decontamination statistics, tips and resources through June 19.
Safety Stand Down is a joint educational and awareness initiative of the IAFC, NVFC, and NFPA. This year’s event takes place June 16-22. Agencies across the country are encouraged to suspend all non-emergency activities during that time so that they can focus on decontamination techniques, training, and education. An entire week is provided to ensure that all shifts and personnel can devote the necessary time to learning best practices and discussing key concerns. Topic information, training downloads, and videos can be found at www.safetystanddown.org, the official website for the Safety Stand Down event.
A bus fire in a remote part of Kazakhstan killed over 50 people in January 2018. (Associated Press)
Last week, a bus carrying tourists to Mao Zedong's hometown in southern China burst into flames, killing more than two dozen people. The cause of the fire wasn't initially reported, but one survivor said it seemed to break out at the back of the bus and quickly overcame passengers who didn't have time to escape, the New York Times reported.
The Times said the incident exposes China's poor record of transportation safety. While government statistics claim an annual death toll of about 65,000 from transportation accidents in China, the World Health Organization estimates the real figure is closer to 250,000.
But, as I reported in the Dispatches: International section of the July/August 2018 issue of NFPA Journal, bus fires aren't all that uncommon in countries around the globe. In January 2018, a bus fire in a remote part of Kazakstan killed over 50 people. A couple of months later, 20 people died in a bus fire in Thailand. And in October of last year, children narrowly escaped death or injury when a school bus ignited in Wisconsin.
The July 2018 Journal article was prompted by a spate of bus fires in Rome, and points out that even in countries like the United States, bus fires occur with some regularity—although they're far less common than other types of fires.
"A report published in November 2016 by the U.S. Department of Transportation's Federal Motor Carrier Safety Administration, which analyzed data from 2004 to 2013, found that fires in motor coaches (defined as buses designed for long-distance passenger transportation) occurred almost daily on average, while fires in school buses occurred more than daily for a combined average of over 550 each year," the article says. "And that’s just for two types of buses." Mechanical failures are usually to blame for the blazes.
In 2005, 23 people died in a bus fire that occurred in a bus that was evacuating nursing home patients from Houston as Hurricane Rita marched toward the coast. In response to that incident, NFPA released a report that found about six bus fires occurred on average each day in the US from 1999 to 2003. More recent NFPA data suggests that figure has dropped to between four and five.
Confused about where certain topics are addressed in the latest 2019 edition of NFPA 13? You are not alone! Check out this article in PM Engineer Magazine which explains WHY NFPA 13 was reorganized and also provides an overview of who’s on first.