- February 19, 2020
A Better Understanding of NFPA 70E: NFPA 70E Equipment Labeling
Section 130.5(H) has specific requirements for equipment labels when there are electrical hazards present. For some reason, users of NFPA 70E, Standard for Electrical Safety in the Workplace have trouble applying Exception No. 1 (compliance with a previous edition) and the requirement that the data be reviewed for accuracy within 5 years. Looking at these as two separate issues may help those who are confused on applying the rules.
The exception applies to the information on an existing label. The intent is not to require replacement of labels when electrical safety is not affected. The exception assumes that the applied label complied with a previous edition of the standard. For example, a previous edition of the standard required only an incident energy or HRC on the label. A subsequent edition required the arc-flash boundary. The current edition uses PPE categories. If nothing else has changed in the electrical system, these labels would not need to be replaced. Depending on how your facility handles electrical safety there may be reasons to change the label to the current labeling method for consistency or due to your written safety procedures. A qualified person has been trained to understand how to apply the appropriate safety procedures for any affixed, compliant label. Notice that the exception is applicable upon adoption of the current standard. It is not based on a 5-year review.
The 5-year review applies to all evaluated equipment. A review is not required to occur once every five years. It is required that a review not exceed five years. You are responsible for being aware of changes in the electrical system at your facility. It is your responsibility to conduct a review whenever a modification may change or increase the electrical hazards that an employee might be exposed to. If distribution equipment is modified the day after the labels were applied, it would be necessary to conduct a review that next day. The review may be conducted within 5 years of the last review when no known changes to the electrical system have occurred. This of course, assumes that you have conducted proper equipment maintenance, purchased the exact replacement fuse or circuit breaker for the system, and did not install auxiliary power equipment for power outages.
Another point of confusion is what is required as part of this review. The word review was chosen to be exactly that. It does not require that an entire risk analysis or re-calculation be performed within five years. You must review the systems to which the risk assessment was based on. If proper maintenance has been performed, no overcurrent devices were replaced, no new risks are present based on new equipment tasks, etc., then a note could be added in the file that the review revealed no changes in the electrical system have affected electrical safety. If equipment was not maintained, if the replacement circuit breaker specifications are different, or if the utility swapped out the facility transformer, there may be concern. A new risk assessment should be conducted to verify or change the label information.
As usual, all this is necessary to protect the employee from injury. Anything that effects their safety must be addressed in a timely manner. Hopefully, the label and risk assessment reviews are just another area where you go beyond the minimum requirements of the standard.
For more information on 70E, read my entire 70E blog series on Xchange.
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Next time: A host employer is responsible for the safety of contract employees.
Important Notice: Any opinion expressed in this column (blog, article) is the opinion of the author and does not necessarily represent the official position of NFPA or its Technical Committees. In addition, this piece is neither intended, nor should it be relied upon, to provide professional consultation or services.