AUTHOR: Christopher Coache

An electrician with wiring

A Better Understanding of NFPA 70E: Electrical Equipment Working Space

The National Electrical Code® (NEC)® Section 110.26 requires adequate working space for all electrical equipment. NEC Section 110.26(A) requires a clear space at least 30 inches wide and 36 inches deep if the equipment is likely to be worked on while energized. This space is necessary not only to allow workers room to perform tasks but also room to move if something goes wrong. NFPA 70E®, Standard for Electrical Safety in the Workplace®, Section 110.3 requires that all equipment be placed into an electrically safe work condition (ESWC) unless there is proper justification for the equipment to be energized. NEC 110.26(A) still applies even if equipment will be in an ESWC. The initial electrical inspection for a facility is conducted by a legislated authority having jurisdiction (AHJ).  However, as with all NFPA 70E requirements, it is the employer who assigns someone as the AHJ within the facility. That person may also be the AHJ for the NEC requirements when new equipment is installed in that facility. Floor space is at a premium so providing larger working space is a common issue. An inhouse AHJ will try to convince the official AHJ that the equipment will never be worked on while energized. The problem with that argument is that both OSHA and NFPA 70E require equipment that is not in a verified ESWC to be considered energized. As far as the NEC is concerned, energized equipment requires working space no matter which AHJ inspects the installation. The inhouse AHJ will claim that employee training, work procedures, equipment maintenance, and work practices assure that an employee will never work on the equipment energized. The inhouse AHJ may convince themselves that this is justification to use a working space smaller than NEC Section 110.26(A) when they are the sole AHJ. This argument typically fails when it is an official AHJ who must approve the proposed working space. They want to assure worker safety under any situation by providing the required space. Few official AHJs will approve a smaller working space based on conditions that are beyond their jurisdiction. They will not verify worker qualification, determine the effectiveness of the training program, check equipment maintenance records, or review work procedures and practices. Human error is a major contributor to workplace fatalities and injuries. An official AHJ will not want to sign off on an installation that will haunt them when a worker fails to follow the employer’s electrical safety program. It takes experience to protect workers while preserving valuable floor space. Electrical safety is always affected by installation, maintenance, and work practices. There is equipment not likely to be worked on while energized. There are installation methods and techniques that can minimize the amount of working space required. There is equipment that operates below the minimum shock or arc-flash hazard levels. The full working space of NEC 110.26(A) will be necessary without a holistic approach to electrical safety. Make sure your installations provide the clear space necessary to keep a worker safe. NFPA 70E and the NEC are now available in NFPA LiNK™, the association’s information delivery platform with NFPA codes and standards, supplementary content, and visual aids for building, electrical, and life safety professionals and practitioners. Learn more at nfpa.org/LiNK.

A Better Understanding of NFPA 70E: My Encounter with Electric Shock Hazards

How many times have you escaped death? That may seem like a weird question but if you are involved with the installation, repair or maintenance of electrical equipment the answer is most likely not zero. Even if you are not actively involved with these activities many of you will also not have zero as the answer if you have used electrical equipment. The near-death experience I am talking about is an electric shock. I have explained many times why you relied on luck when you survive an electric shock. I previously wrote about my first near death experience as a preteen. I was recently reminded of two other instances. The second time I survived was due to a mistake by my sister and by myself. She had decided to use an electric hedge trimmer to trim the bushes at my parents’ house during a visit. She asked me to help her with the 100-foot extension cord she had been using. I began to coil it to shorten the length as most people would do. A shock passed through my hand. She had nicked the cord enough for my hand to contact an exposed conductor. Flexible cords are involved with many electrocutions, so I count myself lucky for having survived. It was a good thing that the only contact was a single hand, and the current had no path through my body. Still over thirty years later I remember the tingle as the current run through my hand. NFPA 70E®, Standard for Electrical Safety in the Workplace® covers the use of flexible cords to prevent your workers from experiencing this or worse not surviving their encounter. The third and last time I experienced a shock was my own fault. It would not have happened if I had followed NFPA 70E. It was a stupid mistake made before I was fully aware of electrical safety rules. I purchased my second house that had a detached workshop and garage and was expanding the house to  include an attached garage. The demolition of the outbuilding was my first task. I shut off the feeder breaker to the panel in the outbuilding. I was part way through the demolition and had begun removing the electrical system. I needed power so I turned the feeder breaker back on and opened the branch circuits that I was not using. I confirmed that voltage was absent on the first branch circuit. I received a painful shock while removing some equipment. I investigated the cause after giving thanks for surviving a shock once again. I opened the panel and was surprised at the miswiring. The feeder hot leg was wired to the panel neutral bar. There was the neutral (white) wire  connected to the wrong terminal, and an equipment grounding conductor connected correctly. Of course, the voltage measurement was zero with open branch circuit breaker. I received the shock when I connected between the branch circuit neutral (actually the hot wire) and equipment grounding conductor. It was a noncompliant installation. I concluded that the previous owner had no electrical installation experience, and the building was built without a permit. If I had conducted a verification of absence of voltage as required by NFPA 70E, I would have discovered the miswiring. I know many people who act as if it is badge of courage to have survived multiple electrical shocks over their career. Everyone knows that 120 volts can kill so receiving an electric shock is not a thing to be proud of. Having never received an electrical shock is something to really be proud of. Many workers have become a fatality working on equipment that they had previously received a shock. They were just lucky that they survived the previous shocks. Test before touching under all situations. Don’t become one of the unlucky ones even when at home. Did you know that the first program in the NFPA 125th Conference Series, “Empowering Electrical Design, Installation and Safety,” is now available on demand? Get additional insights about electrical safety in the workplace and NFPA 70E through a series of engaging presentations from industry experts. Topics include a look at electrical shock injuries and the effect on both the mind and body, electrical incident data and the importance of safety training, electric shock hazards and the relationship to new technology, and how OSHA uses 70E. A special roundtable discussion also features questions and answers about staying safe on the job. Register today and earn CEU credits for participating. The program is available on demand through May 18, 2022.
Workers looking at plans

A Better Understanding of NFPA 70E: Job Safety Planning and Job Briefing

Before starting each job that involves exposure to electrical hazards, the employee in charge must complete a job safety plan and conduct a job briefing with the employees involved. That is the NFPA 70E®, Standard for Electrical Safety in the Workplace® requirement. It makes sense for the occasional need to justifiably expose an employee an electrical hazard but what about tasks that expose an employee to an electrical hazard daily? The short answer is yes; the requirement applies to those. The requirements apply just as written, the briefing and planning must be conducted before each job that exposes any employee to an electrical hazard.  What if it is a multistory printing press that has several problems every day? The answer is still yes. The primary method of protecting an employee from electrical hazards must be establishing an electrically safe work condition. Any exposure must be properly justified regardless of its nature. Documented procedures are necessary whether it is troubleshooting that exposes an employee to hazards or justified energized work that does. There is difference between troubleshooting and repair as I have pointed out many times. There are exclusions to requiring an energized work permit but that does not remove the need for a planning and briefing. How a facility’s electric safety program (ESP) is written plays a big part on how this is handled. A well written ESP should not allow any employee to decide on their own when or why they will be exposed to an electrical hazard. The ESP should not allow an employee to make up a work procedure on the fly or guess at the hazards or protective equipment (PPE) necessary to perform the task even if the task is perceived as routine. If an employee is exposed daily to an electrical hazard because of the same issue it would be better to fix the problem rather than expose them to the hazard daily. Maybe the problem cannot be fixed because of the nature of the equipment’s use, but it might be possible to use the hierarchy of risk controls to reduce the hazard or risk while performing that daily task. Either way, each day you will find a way to justify exposing the employee to the hazard. A safety procedure and energized work permit could be written for that specific repetitive task. NFPA 70E does not prohibit such a permit but there are many safety issues that should be addressed before doing so. There may be no such thing as routine when it comes to electrical safety. For example, the need to enter an enclosure because of a thermal trip does not mean that the cause of the thermal trip is the same every time. A different hazard or risk could be lurking inside and, if the employee is not prepared for it, could lead to an injury.  An energized work permit may not be required if the task is limited to troubleshooting. However, the documented procedure, proper protective equipment, planning and briefing must still be used.  All of this is true whether it is a single recurring issue or tens of recurring issues. Section 110.5(I)(1) covers the minimum requirements for the planning stage and one requirement is that it be documented.  Any task must be planned in detail for there to be an effective job briefing. If the task is being conducted for the first time, work procedures must be developed before work begins. If the planning reveals shortcomings in the established ESP or work procedure, these must be addressed before the task is performed. The planning stage is when the specific hazards associated with the specific task are identified. It should be verified that necessary equipment will be available to perform the task. The job planning section does not address the energized work permit, but the permit could be used to gather the necessary information. Section 110.5(I)(2) addresses the job briefing. This is when the employee in charge goes over the plan and discusses the energized work permit with the employee assigned to the task. The job briefing needs to be performed before the work tasks are started. However, it should not be performed so far ahead that the employees involved might forget what was covered. The briefing should include a discussion of the work procedure so that all parties fully understand the procedure. The briefing also gives employees the opportunity to express any concerns they have about the task, the procedure, their qualifications, or their safety. The employee should affirm that they will not deviate from the plan or task scope. They should also acknowledge that any deviation from the specific assigned task must be discussed before being implemented and modified in the work plan or procedure. It should be confirmed that the appropriate and necessary equipment and current procedures have been given to the employee. NFPA 70E does not require that the briefing be documented since the documented plan and work permit cover the issues discussed. As the employee in charge, I would add briefing notes to the documented plan especially if there were issues raised during the briefing. I would also have the employee sign the plan or permit as acknowledgement that the briefing was conducted. The job briefing also serves a purpose to the employee in charge and the employer. The briefing is the time to verify that the energized work permit is properly authorized or that the task is limited to troubleshooting. The employee in charge is responsible for assuring the employee is qualified not only for the task on the specific equipment but they are the right employee for the assigned task. They should assess if the employee is impaired in some manner. They may have to apply for a new work permit before the task is started based on the briefing. They need to address any issues raised by the employee before permitting them to begin the task. They will be the point of contact if the assigned task evolves into something else. There nothing prohibiting the employee in charge from being the employee assigned the task. It might seem excessive for them to establish a plan and hold a briefing for themselves. Their self-briefing allows them to verify that everything for their safety has been considered. It also gives them time to question their own qualification for the task and equipment. They should not be up to their elbows in energized equipment then realize that the work procedure has not been updated for new equipment that had recently replaced the old equipment. This is all to protect an employee from becoming an injury or fatality. An employer should know who, when, why, and where an employee may need to be rescued after an incident. Every employee should know what is expected of them before they are put at risk of an injury. Any employee assigned energized work or exposed to electrical hazards is at risk of a potential injury even if they are wearing PPE. Skipping the required planning and job briefing may seem convenient until an employee is injured. An investigator might consider that nothing was done leading up to the injury without a record of a job safety planning and briefing regardless of the employer’s documented ESP. Did you know that the first program in the NFPA 125th Conference Series, “Empowering Electrical Design, Installation and Safety,” is now available on demand? Get additional insights about electrical safety in the workplace and NFPA 70E through a series of engaging presentations from industry experts. Topics include a look at electrical shock injuries and the effect on both the mind and body, electrical incident data and the importance of safety training, electric shock hazards and the relationship to new technology, and how OSHA uses 70E. A special roundtable discussion also features questions and answers about staying safe on the job. Register today and earn CEU credits for participating. The program is available on demand through May 18, 2022.

A Better Understanding of NFPA 70E: Comparing Electrical Fatalities in Specific Occupations

Each year I have given a summary of fatalities linked to the electrical industry. The U.S. Bureau of Labor Statistics (BLS) has not yet published the fatality numbers for 2020. My blogs have occasional pointed out that electrical fatalities do not just happen to those in electrical occupations. I decided to look at fatalities specifically due to exposure to electricity in various occupations.  The average electrical exposure fatalities (2011-2019) in construction and extraction occupations (75 fatalities), Installation, maintenance, and repair occupations (34 fatalities) and building and grounds cleaning and maintenance occupations (20 fatalities) account for a majority (79%) of the 153 annual electrical exposure fatalities. However, these occupations have people working in many sub-occupations. Who are the people dying from exposure to electricity while they are at work? The following chart shows the average electrical exposure fatalities for a specific occupation from 2011 through 2019.   Source: Bureau of Labor Statistics Those who read NFPA 70E®, Standard for Electrical Safety in the Workplace®, often get hung up on the phrase working on electrical equipment as a reason not address electrical safety in their workplace. Six of these nine occupations do not work on electrical equipment. They typically interact with it and often are not actively interacting with electrical equipment when they become a fatality. Five of these are on the OSHA list of occupational categories of employees facing a higher-than-normal risk of electrical accident. Many people say that, from these nine occupations, only the electrician is required to follow NFPA 70E. Follow that logic. Electricians are the vanguards of electrical safety. Why, then, are electricians being killed by the very thing they are the most knowledgeable about? Statistically electricians are possibly exposed to potential electrical hazards more often than most occupations. However, they are also supposed to know how to prevent their death while performing their work. Based on the starting assumption, they are the only ones who have been trained to recognize electrical hazards, and in the steps necessary to avoid being killed by those hazards. Yet, electricians consistently account for nearly 22% of all electrical exposure fatalities and 37% of electrical exposure fatalities in construction occupations. Another way to look at this is that an average of about 80 electricians die every year at work and about 25 of those deaths come from exposure to electricity. Supervisors at construction sites are often responsible for the day-to-day on-site safety and enforcement. However, eight supervisors per year are electrocuted while at construction sites. These are not good track records for the leaders in electrical safety. A concerning occupation is the grounds worker. It is difficult to fathom electrical fatalities in the occupation with the use of gas and battery powered equipment. Are they hitting electrical wiring not properly protected by the installation, are they using extension cords that are damaged, or are they exposed to outdoor electrical equipment that is not properly maintained? Fifteen deaths a year due to electricity is too many for this occupation. Around 30 people a year are killed by direct contact with an overhead powerline, but I was unable to find specific occupations listed in the BLS data base. However, tree trimmers, roofers and painters are common occupations associated with this type of fatality often due to the use of a ladder, pole extension or boom. In my experience, many HVAC technicians have not taken up the belief that electrical safety applies to them which may account for their fatalities. I expect that the electrical deaths to production workers is heavily tied to lack of proper equipment maintenance. NFPA 70E is written to provide protection for these unqualified workers when exposed to electrical hazards while working. All employers must implement an  electrical safety program before these fatalities are a thing of the past. NFPA 70E is concerned with electrical safety in the workplace for all workers. Regardless of your occupation there is the potential for a fatality due to exposure to electrical hazards. Electricians as well as painters must understand this and not only learn but apply the safety protocols that NFPA 70E outlines. Want to keep track of what is happening with the National Electrical Code® (NEC®)? Subscribe to the NFPA Network to stay informed of new content. The newsletter also includes NFPA 70E information such as my blogs.

A Better Understanding of NFPA 70E: Article 320, Safety Requirements Related to Batteries and Battery Rooms

There has been a fair amount of news about battery storage systems being involved in fire and explosion incidents around the world. Do not forget that these are not the only safety issues when dealing with batteries. Battery systems pose unique electrical safety hazards. The system’s output may be able to be placed into an electrically safe work condition (ESWC), however there is essentially no way to place an operating battery or cell into an ESWC. Someone must still work on or maintain the battery system. Working on a battery should always considered energized electrical work. NFPA 70E®, Standard for Electrical Safety in the Workplace®, Chapter 3 covers special electrical equipment in the workplace and modifies the general requirements of Chapter 1. The chapter covers the additional safety-related work practices necessary to practically safeguard employees against the electrical hazards associated with the special equipment. Working around batteries can expose an employee to both electrical shock and arc flash hazards. A person’s body might react to contact with dc voltage differently than from contact with ac voltage. Batteries can also expose employees to the hazards associated with the chemical electrolyte used in batteries. Battery charging can sometimes generate flammable gases, so it is important for employees to avoid anything that could cause open flames or sparks. Employers must consider exposure to these hazards when developing safe work practices and selecting personal protective equipment (PPE). That is where Article 320, Safety Requirements Related to Batteries and Battery Rooms comes in. Its electrical safety requirements, in addition to the rest of NFPA 70E, are for the practical safeguarding of employees while working with exposed stationary storage batteries that exceed 50 volts. Article 320 reiterates that the employer must provide safety-related work practices and employee training. The employee must follow the training and work practices. It also requires that each battery room or battery enclosure be accessible only to authorized personnel. Article 320 defines authorized personnel as the person in charge of the premises, or other persons appointed or selected by the person in charge of the premises who perform certain duties associated with stationary storage batteries. All of this means that the employer must specifically understand and document an electrical safety program (ESP) for batteries. NFPA 70E, once again, does not detail who an authorized person is, how to write a procedure for the specific authorized task, what task is to be conducted and the risks to the employee performing that assigned task, or the training necessary to do any of this.  It does not need to. The employer is responsible for determining what is specifically necessary to protect an employee from the specific hazards they will be exposed to while conducting the specific task on the specific battery system. I have written many blogs on the employer’s responsibilities. It is required that, prior to any work being conducted on a battery system, a risk assessment must be performed to identify the chemical, electrical shock, and arc flash hazards and assess the risks associated with the type of tasks to be performed. The procedure for conducting an arc flash risk assessment must be specified in an employer’s ESP. The risk assessment must include the use of the hierarchy of risk controls. The risk associated with batteries could be mitigated starting with the system design. For example, a battery system could be designed to allow the battery to be partitioned into low-voltage segments before work is conducted on it. Other system design mitigation methods might include widely separating the positive and negative conductors and installing insulated covers on battery intercell connector busbars or terminals. Batteries are somewhat unique in that they present chemical hazards as well as electrical hazards. Electrolyte (chemical) hazards vary depending on the type of battery, so the risks are product-specific and activity-specific. For example, vented lead-acid (VLA) batteries allow access to liquid electrolyte, thereby potentially exposing employees to chemical hazards when performing certain tasks. By contrast, valve-regulated lead-acid (VRLA) and certain lithium batteries are designed with solid or immobilized electrolyte so that employees are only exposed to electrolyte under failure conditions. Most modern density meters expose a worker to a quantity of electrolyte too minute to be considered hazardous, if at all. Such work might not be considered handling electrolyte. However, if specific gravity readings are taken using a bulb hydrometer, the risk of exposure is higher and should be considered as handling electrolyte. The employer must have an electrical safety plan in place if a task is assigned while the battery is not under normal operating conditions. The employer must understand that the safety requirements are dependent on the electrolyte type and assigned task. There is specific training necessary for employees who will be working with batteries. Proper procedures, tools, personal protective equipment (PPE) and ventilation might be specific to a battery installation. A qualified employee trained to establish an ESWC on a motor is not qualified to deal with energized batteries. Additional training is necessary for that “qualified employee” to be qualified to enter a battery room to conduct a specific task. What they are trained for is no different than other training requirements. The employer must know, document and train the employee for the assigned task and exposed risks. It is a requirement to have all the documentation in place prior to authorized personnel entering a battery room to perform a specific work task on a battery system under normal operating conditions. However, it is likely the employee will need to enter the battery room to deal with a battery system that is not operating normally. Is it possible that there are substantially different risks for performing that same task in this case? The employer must have procedures, risk assessments, and training for this condition as well. Sending an employee who is trained only for the normal operating conditions into a battery room under thermal runaway, for example, is knowingly exposing an unqualified person to risk of injury. The employer is responsible for protecting their employees from known or recognized hazards in the workplace. NFPA 70E provides the basis and guidelines for an employer to develop an electrical safety program regardless of the type of electrical equipment. Remember this whenever an employee is required to interact with electrical equipment at your facility. Want to keep track of what is happening with the National Electrical Code® (NEC®)? Subscribe to the NFPA Network to stay informed of new content. The newsletter also includes NFPA 70E information such as my blogs.

A Better Understanding of NFPA 70E: The 2024 Edition of NFPA 70E

NFPA 70E®, Standard for Electrical Safety in the Workplace® is a safe work practice standard that is revised by the public and industry every three years. The revision cycle starts again this year. Many of you know that the main rule in electrical safety is to not work on equipment that is energized. This is what NFPA 70E and OSHA regulations require. There is seldom a need to put an employee at risk if you are honest about it. You also know that providing PPE is not a legitimate reason to put an employee at risk because things can and do go wrong even when performing the simplest task on unjustified, energized equipment. Although the rule to shut it off, lock it out and verify that it is deenergized has been around for nearly fifty years, no one has come up with something that is an as safe or safer method of protecting an employee from electrical injury. However, there are many other NFPA 70E requirements that do need to be changed with the times. NFPA does not change its standards. NFPA is a standards development organization responsible for administering NFPA 70E. In fact, to keep the process entirely independent, NFPA staff cannot submit a proposed change to a standard. This is where you come in. It is you who use the standard. And if you do, you know what issues hang you up. You know what it would take to make a requirement easier to understand, to clarify a safety issue or add a requirement to make your workplace safer. Your input could save a life by closing a safety gap that has appeared in current workplace. For those of you who knowingly do not use NFPA 70E, why is that? Do you think the requirements do not provide for your safety? Do you believe the requirements are waste of time to implement? This revision process is for you too. However, just because you believe a requirement is not worth implementing does not justify the need to remove it. Why does removing the requirement make a safer workplace? What alternative can you offer? If there is a fatality or injury reported that would have been prevented if that person did follow the requirement, you will be hard pressed to convince someone that it won’t happen again. To learn how to participate in the NFPA standards development process and submit proposed text for consideration by the responsible technical committee, please go to www.nfpa.org/submitpi for instructions. You can also submit an input by going to www.nfpa.org/70E and going to the next edition tab. When there, use the link to Submit a Public Input. You have until June 1, 2021 to submit your input for consideration during this revision cycle. Want to keep track of what is happening with the National Electrical Code® (NEC®)? Subscribe to the NFPA Network to stay informed of new content. The newsletter also includes NFPA 70E information such as my blogs.
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