AUTHOR: Christopher Coache

A better understanding of NFPA 70E: NFPA 70E audits

New equipment is added to a facility. Knowledge gained while working through an issue drives change in safety standards. Employees with different backgrounds and from different generations have dissimilar learning styles. Electrical safety is not a static field, it is more dynamic than often believed. How do you evaluate your electrical safety program? Training, procedures and practices involving electrical safety need to be periodically reviewed to not only stay current but to be effective. NFPA 70E®, Standard for Electrical Safety in the Workplace® contains many requirements which should be your starting point for auditing an electrical safety program (ESP). The first place NFPA 70E requires an evaluation of an ESP is in 110.1(F). Controls are the company's electrical safety metrics for determining if the ESP is effective and efficient. In order to evaluate a system, you need to know where you started and how far you have come. Metrics are measurable points to determine performance. They also can be used to determine if improvements to the safety program are required and, if so, what needs to be changed. There are two common metrics used to determine the effectiveness of something: lagging metrics and leading metrics. Lagging metrics provide a reactive view of a safety program. Leading metrics are used to identify and correct contributing factors before an incident occurs. A combination of these metrics can enhance a safe work program. Next in NFPA 70E, 110.1(K) covers necessary audits. Auditing and enforcement is a critical part of any electrical safety program. It is vital that the electrical safety program — as well as the auditing and enforcement actions — be documented for the benefit of the employees and of the company. The process control points and actions (i.e., the items capable of being measured) need to be determined for there to be effective auditing. An audit of the overall ESP (110.1(K)(1)) is necessary to ensure that program principles and procedures are kept current with changing situations. Section 110.1(K)(2) addresses field audits. This involves going into the field — wherever employees are performing their required tasks and there is the potential of exposure to electrical hazards — to gather information. It is important to watch employees perform their electrical safety related tasks and ensure that they are using PPE appropriate for the task to be performed. When it has been confirmed that the ESP principles or procedures are not being followed, corrective action must be taken. The field audit should be used to confirm that all electrical hazards are addressed, and to evaluate any program and physical conditions that have changed.  Lockout/tagout programs and procedures require auditing in 110.1(K)(3). The objective of the audit is to make sure that all requirements of the procedure are properly detailed and that employees are familiar with their responsibilities. The audit should determine whether the requirements contained in the procedure are sufficient to ensure that the electrical energy is satisfactorily controlled. The audit must ensure that the lockout/tagout procedure is effective and is being properly implemented. There are several other requirements for audits and supervision in NFPA 70E. Any audit should identify and correct deficiencies in the procedure, employee training, or enforcement. Corrective actions could consist of either modification of the training program or a revision to the procedures, such as increasing the frequency of training. Audits and metrics should measure program effectiveness as well as be used for developing program improvement. Audits should evaluate incidents to determine any necessary change to the ESP. An ESP should not be developed then placed on the shelf as a job well done. Electrical safety in the workplace is not the same as it was 10 years ago. How are you protecting employees with the best ESP possible? Next time: Is there a way to increase electrical safety for workers in the future. Please Note: Any comments, suggested text changes, or technical issues related to NFPA Standards posted or raised in this communication are not submissions to the NFPA standards development process and therefore will not be considered by the technical committee(s) responsible for NFPA Standards development. To learn how to participate in the NFPA standards development process and submit proposed text for consideration by the responsible technical committee(s), please go to www.nfpa.org/submitpi for instructions.

A better understanding of NFPA 70E: Where did the 40 cal/cm2 limit go?

There must be an increase in the need to perform justified, energized work on equipment with high incident energy levels. Questions have come in regarding the restriction for incident energies above 40 cal/cm2. Many believed that NFPA 70E®, Standard for Electrical Safety in the Workplace® requirements “really” only applied above 40 cal/cm2. Others believed the standard did not cover incident energies above 40 cal/cm2. It took some time to realize what everyone was considering to be a restriction. Prior editions of NFPA 70E contained an informational note that stated when incident energy exceeded 40 cal/cm2 at the working distance, greater emphasis may be necessary with respect to de-energizing when exposed to electrical hazards. The purpose of this note was to re-emphasize the requirements of the standard. Establishing an electrically safe work condition (ESWC) was and still is required regardless of the incident energy. One problem with the informational note was that many where incorrectly interpreting it to mean that it wasn't necessary to worry about incident energies below 40 cal/cm2. These people felt that this note meant that an ESWC was not “really” necessary or required until 40 cal/cm2. Below this level it was just a suggestion to establish an ESWC. This may be why I receive so many questions about using PPE when working on energized equipment rather than establishing an ESWC. Those who Another group was interpreting the informational note to mean that NFPA 70E placed a limit on the permissible incident energy. The PPE category tables are limited to address equipment that is permitted to be worked on while wearing at least 40 cal/cm2 gear. If you have equipment that is listed on the PPE category tables but the specified parameters are not met then the equipment must be evaluated under the incident energy analysis method. There is no limit to the incident energy that can be calculated. However, finding PPE rated to protect at high energy levels may be difficult.  Misuse of the standard and specifically of the 40 cal/cm2 informational note is one reason for the removal of that informational note. Once you have a system that exceeds the threshold limits in NFPA 70E, you must minimize the hazard and risk that hazard presents to your employees. An electrically safe work condition must be established if an employee is to enter the limited approach boundary. NFPA 70E is about protecting the worker from injury but there may not be equipment available to protect from all levels of a hazard. That is one area where the hierarchy of risk controls comes into play. Although there is no limit to the amount of incident energy that may present, if energized work is justified, you are responsible for protecting your employees from whatever level of hazard exists.  For more information on 70E, read my entire 70E blog series on Xchange.  Please Note: Any comments, suggested text changes, or technical issues related to NFPA Standards posted or raised in this communication are not submissions to the NFPA standards development process and therefore will not be considered by the technical committee(s) responsible for NFPA Standards development. To learn how to participate in the NFPA standards development process and submit proposed text for consideration by the responsible technical committee(s), please go to www.nfpa.org/submitpi for instructions.

A better understanding of NFPA 70E: Lockout

Here is a pop quiz on the lockout and electrically safe work condition requirements in NFPA 70E®, Standard for Electrical Safety in the Workplace®. True or false? 1.    Lockout and tagout devices are the same thing. 2.    You may choose to use either lockout or tagout. 3.    Multiple locks indicate that a complex lockout procedure has been used. 4.    The required procedure for lockout and for tagout is the same. 5.    A written plan is required for all lockout applications. 6.    Lockout is synonymous with establishing an electrically safe work condition. 7.    Any lock can be used as a lockout device. 8.    Verification of a de-energized state must be made with a portable meter. 9.    Temporary grounding must always be used before an electrically safe work condition can exist. 10.    Electrical lockout devices must be distinct from mechanical lockout devices. 11.    A lockout program does not apply to temporary electrical equipment. 12.    Lockout procedures must be audited every 3 years. 13.    Once lockout has been applied and an electrical safe work condition established, there is no need to re-verify that condition. This was not meant to be a trick quiz. The answer to each question is false. 1.    Lockout requires a lock and tagout does not include a lock. [120.3(C) and 120.3(D)] 2.    Tagout can only be used when the isolation device cannot accept the application of a lock. [120.4(B)(11)(4)] 3.    Multiple locks may be used in a simple lockout process. [120.4(A)(4)] 4.    If tagout is used without a lockout device, an additional safety measure must be used in addition to the application of the tagout device. [120.4(B)(11)(4)] 5.    Simple lockout applications do not require a written plan however, a written plan may be developed. [120.4(A)(4)] 6.    Lockout is a single step in the process of establishing an electrically safe work condition. [120.5(6)] 7.    The lockout device must be unique and readily identifiable. [120.3(B)] 8.    Listed, permanently mounted meters are permitted. [120.5(7) Exception No.1] 9.    Temporary grounding equipment is necessary if induced or stored energy is present or if there is a possibility of energization by contact with other electrical parts. [120.5(8)] 10.    Electrical lockout devices are permitted to be similar to other lockout devices. [120.2(H)(3)] 11.    A lockout program must include temporary as well as portable equipment. [120.1(A)(3)] 12.    Lockout procedures require an annual audit. [110.1(K)(3)] 13.    Unattended job locations, including for a lunch period, require re-verification of the electrically safe work condition. [120.4(B)(6)(4)] This was refresher of some lockout basics. Sometimes details get lost or forgotten but that doesn't mean they aren't important. If you are responsible for a lockout program, this should have been easy. For more information on 70E, read my entire 70E blog series on Xchange.   Next time: How many chapters are in NFPA 70E?
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A better understanding of NFPA 70E: the ten commandments of electrical safety

It is hard to believe that this blog has entered its second year. Thank you for taking the time to read them. I hope that my comments, if they have been doing nothing else, have made you think differently about how you look at electrical safety. That what you do regardless of your position at your company does play a role in creating a safer work environment. That you consider an electrically safe work condition to be your first choice. That the simple fact of NFPA 70E®, Standard for Electrical Safety in the Workplace®, being to protect the employee from electrical injury is a major theme. Keep this in mind when trying to apply the minimum requirements. If everyone works towards that goal all employees should be returning home at the end of each day. Although electrical safety should always be a serious issue, this blog offers a humorous viewpoint. When I began my electrical safety career decades ago, I was ignorant of any electrical safety procedures. It was the Wild West. Safety was not part of the electrical engineer curriculum. Test by touch and bare hand work were commonplace. A coworker's view of your bravado was determined by your ability to handle a shock. Everyone knew of someone who had been electrocuted. Safety typically meant preventing an injury to someone using the equipment not the person working on it. NFPA 70, National Electrical Code® covered installations and NFPA 70E was just published with a chapter covering safety-related work practices. When I arrived at my first job at a research and test laboratory I was given a copy of the ten commandments of electrical safety. It was published in Orbit, the Journal of the Rutherford High Energy Laboratory, Didcot, England (31 January 1965) p.12. There are others out there but I am pretty sure that this one was the start of it all. It may have been originally written for laughs but there is some truth to what was included. These commandments contain requirements now included in NFPA 70E; lockout/tagout, electrically safe work condition, discharge of stored energy, proper test equipment and test before touch were in there decades before NFPA 70E. Enjoy. Ten Commandments of Electrical Safety I. Bewareth of the lightning that lurks in an undischarged capacitor lest it cause thee to be bounced upon thy backside in a most ungainly manner. II. Causeth thou the switch that supplies large quantities of juice to be opened and thusly tagged, so thy days may be long on this earthly vale of tears. III. Proveth to thyself that all circuits that radiateth and upon which thou worketh are grounded lest they lift thee to high-frequency potential and cause thee to radiate also. IV. Taketh care thou useth the proper method when thou taketh the measure of high-voltage circuits so that thou doth not incinerate both thee and the meter, for verily though thou hast no account number and can be easily replaced, the meter doth have one and as a consequence bringeth much woe upon the supply department.V. Tarry thee not amongst those who engage in intentional shocks for they are surely non-believers and are not long for this world. VI. Taketh care thou tampereth not with interlocks and safety devices, for this incureth the wrath of thy seniors and bringeth the fury of the safety officer down upon thy head and shoulders. VII. Worketh thee not on energized equipment, for if thou doeth, thy mates will surely be buying lunch without thee and thy space at the table will be filled by another. VIII. Verily, verily I say unto thee, never service high-voltage equipment alone, for electric cooking is a slothful process, and thou might sizzle in thy own fat for hours on end before thy Maker sees fit to end thy misery and drag thee into His fold. IX. Trifle thee not with radioactive tubes and substances lest thou commence to glow in the dark like a lightning bug. X. Commit thee to memory the works of the prophets, which are written in the instruction books, which giveth the straight info and which consoleth thee, and thou cannot make mistakes. - From Orbit, the Journal of the Rutherford High Energy Laboratory, Didcot, England (31 January 1965) p.12 For more information on 70E, read my entire 70E blog series on Xchange. Next time: Some of the statistics about your safety.
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NFPA 70E Series: A Better Understanding of NFPA 70E - Minimum arc rating, PPE category, incident energy, or site specific PPE

NFPA 70E allows you to put one of four things on the equipment label when it comes to arc-flash PPE. You can mark it with the incident energy, a PPE category, a minimum required rating or a site specific designation. Some confusion comes with the requirement's wording that the label must include at least one of these. Several NFPA 70E users ask about using both the incident energy and PPE category on a label. The first thing that enters my mind when that comment is made is that this person does not fully understand how to use NFPA 70E. That statement is made because the standard only allows one method of conducting an arc-flash risk assessment on a single piece of equipment. This would mean that either the incident energy analysis (arc-rating) or a PPE category would be used. Since PPE category is not an incident energy and an incident energy is not a PPE category, these two should never appear on a label together. Redefining a PPE category as a site specific rating could be done but then why put both on the label if they are exactly the same thing? Calculating the incident energy (arc-rating) then changing it to a site specific rating is common. A facility could use this method label all the equipment with a few PPE levels when the incident energy analysis method calculated dozens or hundreds of energy levels. It's not clear on why someone would simplify the method then make it more complex and confusing by including both. Another common method is specifying the calculated incident energy but require a minimum PPE rating above that energy level. NFPA 70E is about protecting the worker and confusing the worker when safety is at risk is a dangerous thing. If the equipment is labeled with the incident energy or minimum required arc-rating, the worker can utilize equipment with at least that rating. Equipment labeled with a PPE category provides specifics on what the worker can use. With site specific ratings, the worker is likewise provided with specific gear or rating necessary for protection. So why not include them all? Worker safety. Assume that equipment has been determined to have an incident energy of 1.1 cal/cm2, 1.5 cal/cm2, 3.5 cal/cm2, 4.7 cal/cm2 and 8.9 cal/cm2. If these were placed on the equipment labels as the minimum arc-rating necessary for PPE, anything rated higher for each piece of equipment would be acceptable. Now, assume that the facility safety system intends to use site-specific category BLUE for 4 cal/cm2 or less and ORANGE for over 4.0 cal/cm2 up to 12 cal/cm2. Three pieces are also marked BLUE and two are marked ORANGE. Now the employer also decides to require a minimum rating that is 2 cal/cm2 above the incident energy to increase the probability of successfully preventing a thermal injury. For the last one, assume that NFPA 70E is incorrectly used and the equipment is also labeled as no PPE Category, PPE Category 1, PPE Category 1, PPE Category 2 and PPE Category 3. The labels would look like: Equipment # Incident energy Required gear PPE rating PPE Category 1 1.1 cal/cm2 BLUE 3.1 cal/cm2   2 1.5 cal/cm2 BLUE 3.5 cal/cm2 1 3 3.5 cal/cm2 BLUE 5.5 cal/cm2 1 4 4.7 cal/cm2 ORANGE 6.7 cal/cm2 2 5 8.9 cal/cm2 ORANGE 10.9 cal/cm2 3                                                 Can you train your employee on how to follow all four ratings on the label? Could they comply with all four or are they following the one that results in the highest rated gear? Would you permit them to select the lowest rated gear for specific equipment? Does your package for ORANGE contain specific equipment? What happens when the worker is wearing a 1.8 cal/cm2 shirt because they did not want to put on a heavier one for Equipment #1? Which piece of equipment would you let your employee work on while wearing a 2.1 cal/cm2 shirt? Which piece of equipment specifies PPE rated for at least 25 cal/cm2? Is it confusing what to wear based on these applied labels? Maybe now you see why clearly stating the appropriate PPE, as well as using the standard correctly, is critical. The common labeling methods which include the incident energy require clear procedures so that employees understand that the specified required gear or specified minimum rating, not the incident energy, defines the only permitted PPE rating. It is often best to simplify matters to make compliance easier for the employee. Pick something for clarity. Training and enforcement will be easier. NFPA 70E is about worker safety. Why confuse the issue? Next time: Something you don't consider yourself to be the authority having jurisdiction for but you really are. For more information on 70E, read my entire 70E blog series on Xchange.
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NFPA 70E Series: Exemptions to the energized work permit

Occasionally the concept of exceptions to the energized work permit comes into question. Being a consensus standard, NFPA 70E® has four exemptions to requiring a work permit. Although a work permit “shall not be required” for the exemptions it does not state that you are forbidden from doing one (remember back to my posts on consensus standards and best practices.) An exemption to the work permit is allowed for testing, troubleshooting, and voltage measuring. The other three exemptions are for nonelectrical work being conducted outside of the restricted approach boundary. There is a saying that “if it has not been documented it did not happen.” Would I go without an energized work permit? Before covering whether I would or would not do a work permit look at the terms used in the exemption: TESTING – TROUBLESHOOTING – VOLTAGE MEASUREMENT. Everyone has the idea of what these terms mean. I have spent some time in the instrument and test field so I have my own opinion. Not one of these terms means repair. Some may disagree and consider repair as part of troubleshooting. General terms are not defined in NFPA standards. The definitions come from general sources. Just typing the words into an online dictionary here are the first definitions I saw. I hope I don't have to look up voltage measurement. Testing - the means by which the presence, quality, or genuineness of anything is determined; a means of trial. Troubleshooting – discovering the cause of trouble in mechanical equipment, power lines, etc. (A troubleshooter eliminates the trouble.) Regardless of your stance on this, this blog is discussing the need for a work permit. With or without a work permit, the qualified person has to be provided with and use appropriate safe work practices. If the task is voltage measurement, the employee must be informed of that fact. They must have the correct test instrument. They must wear the appropriate shock and arc-flash PPE. They must know the procedures for conducting voltage measurements on that specific piece of equipment. You might say that since the person is qualified an energized work permit is not necessary. The minimum requirements of the standard permit that. I, on the other hand, probably would require a work permit. Why? What procedures, test instrument, PPE, etc. were used for the task? I can tell you. Who conducted the work? I can tell you. We all know that qualified or not people do unexpected things. A loose lug was seen during a voltage measurement. It was tightened and the equipment was damaged. Was that part of the task? I can tell you. Can you tell me? Going back to “if it has not been documented it did not happen.” Justified electrical work does not mean that the task will be completed without an incident or injury. What do you do when tightening that loose lug initiates an arc-flash? The facts of what was believed to have occurred prior to an incident often get muddled up after the incident. I am not saying that I would always require a work permit. A lot you may not since you consider the work to be so menial or routine. Before you never require one under the exemptions, think about it. Next time: The conditions which permit normal operation.  
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