AUTHOR: Christopher Coache

Conceptual design

A Better Understanding of NFPA 70E: Correctly Using the Incident Energy Analysis and Arc-Flash PPE Category Methods

The 2009 Edition of NFPA 70E®, Standard for Electrical Safety in the Workplace® clearly stated that one of the two provided methods be used for the selection of personal protective equipment (PPE) when an arc-flash hazard was present. The two methods of choice are the arc-flash PPE category method and incident energy analysis method. Although not as plainly stated before 2009, it has been required to use only one method on a piece of equipment for twenty years. Why do some NFPA 70E users ask how to combine PPE category method requirements with an incident energy analysis? A few editions ago, the public expressed concern regarding the phrase, one of the following methods shall be used. Apparently, this phrase did not fully convey that only one method could be used on a piece of equipment, or that the two methods could not be combined. So, the requirement was revised to include the statement, either, but not both methods shall be permitted to be used on the same piece of equipment. This was to clarify that one does not include both methods. I am not sure how the words one, either, and not both are being misunderstood. Also, other requirements state not to use both methods. Section 130.7(C)(15) states its requirements apply when the arc flash PPE category method is used and that it is not permitted to specify an arc flash PPE category based on the results of an incident energy analysis. Each of these were added to further clarify the misunderstanding. However, the question was asked once again last week. When shown these specific requirements prohibiting the use of both methods, their response led me to believe that an untrained or unqualified person is conducting the assessment. It is often revealed that the person has not read NFPA 70E or worse do not possess a copy. Often, a computer program has been used to calculate the incident energy and the person has been supplied with a copy of the PPE Category Table to specify PPE. Sometimes, that program automatically and incorrectly converted the incident energy into a PPE Category. These revelations should be troubling because the employer and the person assigned to do the risk assessments are putting employees at risk of injury. Make sure that you have been properly trained and fully understand the requirements when conducting assessments. It is also necessary to have access to an entire NFPA 70E to properly apply the requirements since there is more to electrical safety than an using a table. Consider that these people asking this question are not the only ones who have misapplied the requirements. Confirm that the requirements have been properly applied in your workplace. If not, correct the issue before it is too late. 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.
Rock climber

A Better Understanding of NFPA 70E: Your Risk Tolerance

NFPA 70E®, Standard for Electrical Safety in the Workplace® changed from an arc-flash hazard analysis to an arc-flash risk assessment several editions ago. Users are still having issues with the change. The most common complaint is that risk should not be a consideration when considering the electrical hazards an employee might be exposed to. Many want the standard to provide an absolute solution to what the employer should do to protect their employees. They don’t want to have to decide what to do, they want to be told what to do. They can apply the current that way if they wish. Others want guidance which is what the current edition provides. It allows for more leeway in determining the course of action to be taken for a given task on a piece of specific equipment. The hazard analysis determined the flash boundary, the incident energy at the working distance, and the personal protective equipment (PPE) necessary. The risk assessment first determines if an arc-flash hazard exists. If the hazard exists, the risk assessment then determines appropriate safety-related work practices, arc flash boundary and PPE to be used. Both methods require that the worst-case condition be labeled on the equipment to provide appropriate warning of the hazard lurking inside regardless of the assigned task. There is not much of a difference between the two except for determining if an arc flash hazard exists for a specific task. Imagine a battery system in a room with two terminals of the dc system in another room. If the conductors from the battery system are shorted together there is a potential for an arc-flash with an incident energy of 42 cal/cm2. However, that energy level only exists if the two conductors are shorted together. The positive conductors are brought into the terminal room on the left side and the negative conductors are brought in on the right. Those two covered terminals are separated by 12 feet. The first component after the terminals is an overcurrent device which lowers the incident energy to 14 cal/cm2. The entry to room is correctly labeled to require a 42 cal/cm2 arc-rated suit as the worst-case condition regardless of the task to be performed. Under the old system, at least a 42 cal/cm2 suit would have to be worn every time someone enters the room. Under the current method, when does the 42 cal/cm2 arc-flash hazard exist? The full amount of incident energy is always present in the room. The arc-flash hazard might exist if there is way to connect the two conductors. A task that involves pulling conductors around the room, using tools with a long span, or having conductive fluid present may exposure a worker to the full incident energy. Employee error while in the room may warrant concern. Under a risk assessment for the assigned task, you might determine that it is not possible for a worker to connect ahead of both overcurrent device terminals based on the assigned task. Would you let an employee enter that room wearing 14 cal/cm2 rated gear to perform the assigned task? If you believe that a risk assessment should not be part of the standard, you are not required to accept any risk. The risk assessment method allows you to decide that the worst-case incident energy always presents an arc-flash hazard regardless of the task performed on the equipment. If you can accept that a twelve-foot span cannot be bridged by the employee based on all possible factors, you might permit something different for the task. There are many things that might affect your acceptance of some risk instead of having a zero-risk tolerance. Regardless of your risk-tolerance, remember that it is the employee’s well-being that is wagered on your decision. NFPA 70E is available on 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.
Electrical symbols

A Better Understanding of NFPA 70E: Using OSHA Top 10 Violations to Identify Known Electrical Hazards

We are all creatures of habits. We do something over and over because it works for us. However, we tend to ignore a need for change even when what we do occasionally doesn’t work. There has been a substantial decrease in fatalities caused by electricity since NFPA 70E®, Standard for Electrical Safety in the Workplace® was first issued (over 600 electrocutions annually compared to 166 recently). However, the number of electrocutions over the last decade is hovering around 155 per year. So, something is broken. The National Institute for Occupational Safety and Health (NIOSH) and Occupational Safety and Health Administration (OSHA) have published reports for over forty years summarizing workplace safety issues. Each year OSHA releases its top 10 violations. Online, 1991 was the earliest located for OSHA’s top 10. The violations listed below are for those that have remedies in NFPA 70E. OSHA Most Frequent Violations Violation FISCAL YEAR RANKING 1991 2000 2006 2014 2018 2020 Head protection from impact, falling or flying objects and electrical burns 2           Ground fault protection not provided 3           Electrical path to ground missing or discontinuous 4           Appropriate PPE not used for specific operation 7           Lockout/tagout (1910.147)   5 5 6 5 6 Electrical - wiring methods, components, and equipment (1910.305)   6 7 7     Electrical - general requirements (1910.303)   7 10 10     Lifesaving equipment – eye & face protection (1926.102)         10 10   It is difficult to improve electrical safety without first properly installing the equipment. As recent as 2017, there were many citations for electrical installations that did not follow the National Electrical Code® or National Electrical Safety Code®. In some industries, such as oil and gas extraction, these citations are still in the top 10. OSHA citations are issued to a facility that has been investigated due to an injury. Improper installations might exist in other facilities until a fatality and injury investigation. There are many who consider previously installed equipment to be nearly exempt from the operating conditions or hierarchy of risk controls because NFPA 70E is not an installation or maintenance standard. However, a fatality should not be the trigger for implementing a program to address electrical safety and to identify known electrical hazards. Although not solely an electrical issue, it is disturbing that lockout/tagout has be in the middle of the pack for a quarter of a century. The basic concept is simple but proper training and application seems to be falling on deaf ears. OSHA and NFPA 70E have specific requirements for lockout and tagout as well as their use in establishing an electrically safe work condition (ESWC). OSHA 29 CFR 1910.147 covers the servicing and maintenance of machines and equipment in which the unexpected energization or startup of the machines or equipment, or release of stored energy, could harm employees. It establishes minimum performance requirements for the control of such hazardous energy. This is analogous to the lockout, tagout and establishing an ESWC requirements in NFPA 70E. The citations might also be due to employers continuing to put employees at risk rather than shutting equipment off for maintenance or repair. OSHA 29 CFR 1926.102 requires that employers ensure that affected employees use appropriate eye or face protection when exposed to eye or face hazards from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation. Although it is probable that few citations are due to exposure to electrical hazards, NFPA 70E addresses this under the required face and eye protection. A NIOSH study of 224 electrocutions determined that at least one of the following five factors was present in each fatality; (1) established safe work procedures were either not implemented or not followed, (2) adequate or required personal protective equipment was not provided or worn, 3) lockout/tagout procedures were either not implemented or not followed, (4) compliance with existing OSHA, NEC, and NESC regulations were not implemented, and (5) worker and supervisor training in electrical safety was not adequate. NFPA 70E addresses each of these. Another NIOSH study reported on 152 fatalities involved in installation, maintenance, service, or repair tasks on or near machines, equipment, processes, or systems. Factors in each of these fatalities included failure to completely de-energize, isolate, block, and/or dissipate the energy source, failure to lock out or tagout energy control devices and isolation points after de-energization, and failure to verify that the energy source was de-energized before beginning work. Lockout and tagout procedures, PPE, safe work procedures, training and establishing an ESWC are requirements in NFPA 70E. The General Duty Clause requires an employer to provide employees proper protection from known hazards. OSHA’s 2018 Top 10 violation press release concluded with the statement; ”While many of these standards are repeated each year, it provides a good place for employers to start identifying hazards in their own workplace.” How many decades does a hazard or violation need to be listed before all employers start identifying them as known hazards in their workplace. These OSHA violations, from an electrical hazard viewpoint, could be a thing of the past if NFPA 70E requirements were universally and properly implemented. The last two Top 10 violations that include electrical safety issues are low hanging fruit. Without changing our work habits to address them, they will remain on the violation tree for another quarter of a century. 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.
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.
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