Full Head Protection
Bidding adieu to the 2* hazard/risk designation
NFPA Journal®, May/June 2011
As the revision process for the 2012 edition of NFPA 70E nears completion, it’s time to start phasing the term "2-star" out of our vocabulary. Actions taken by the Technical Committee on Electrical Safety in the Workplace during the Report on Proposals (ROP) phase of the revision process, and subsequently upheld during the Report on Comments (ROC) phase, will result in the elimination of the 2* hazard/risk designation in Table 130.7(C)(15)(a) and in Table 130.7(C)(16). It should be noted that NFPA’s process allows for subsequent actions at the Technical Committee Report session and appeals to the NFPA Standards Council, so the outcome of the revision process will not be final until the Council issues the standard in August 2011.
The genesis of 2* — or, as most users of the standard refer to it, "2-star" — can be traced to the first inclusion of the hazard/risk category table and the protective clothing and personal protective equipment matrix in the 2000 edition of NFPA 70E. This was the first time the task tables appeared in the standard.
In the 2000 edition, a number of entries in the task table were designated as hazard/risk category 2*. This designation was not intended to be a separate hazard/risk category, but to identify through notation (the asterisk) that the 2* tasks were Hazard/Risk Category 2 tasks that required enhanced protection for the entire head, including hearing protection, due to the exposure of the employee’s head to an arc-flash hazard while performing certain tasks. The explanation of the notation, found in the table’s legend, stated that "2* means that a double-layer switching hood and hearing protection are required for this task in addition to the other Hazard/Risk Category 2 requirements of Table 3-3.9.2 of Part II." It was not included as an apparent separate hazard/risk category in Table 220.127.116.11.
The 2009 edition departed from the format used in the 2000 and 2004 editions, and the explanation of 2* was relocated from being a note in Table 130.7(C)(9) to what seemed to be a separate hazard/risk category in Table 130.7(C)(10). While it appeared to be a separate category, this was not the intent of the revision. The relocation of the former note to the table specifying the requisite level of protective clothing and personal protective equipment was aimed at improving usability of the standard. In the 2009 edition, tasks designated with a 2* in the hazard/risk category column required the use of only an arc-rated arc flash suit hood instead of the choice of using either an arc-rated arc flash suit hood or an arc-rated face shield.
A revision to Section 130.7(C)(1) during the 2009 cycle required that all parts of the body inside the arc flash protection boundary be protected. This new provision, coupled with the requirement of Section 130.7(C)(5) for all parts of the body to be protected where the possible exposure to incident energy exceeding 1.2 cal/cm2, clearly required the entire head to be protected.
Those performing tasks designated as Hazard/Risk Category 2 in Table 130.7(C)(9) can use an arc-rated face shield that is only required to protect the face, forehead, ears, and neck, which, as was pointed out in the substantiation for the upcoming 2012 revision, is inconsistent with the requirements for full head protection.
The net result of the committee action is that the 2* designation will no longer appear in the hazard/risk tables. All Hazard/Risk Category 2 tasks will now require full head protection through the use of an arc-rated face shield and arc-rated balaclava, or an arc-rated flash suit hood.
Jeffrey Sargent is NFPA's senior electrical specilist and is staff liason for NFPA 70E.