A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program (Part 7 – Equipment Condition)
NFPA 70E®, Standard for Electrical Safety in the Workplace® does not detail the policies and procedures that must be in an electrical safety program (ESP). However, it is not possible to comply with NFPA 70E without filling in the details. Section 110.5(C) requires that the condition of maintenance of equipment to be part of the ESP. Condition of maintenance is the state of the electrical equipment considering the manufacturers’ instructions, manufacturers’ recommendations, and applicable industry codes, standards, and recommended practices. Normal operation is permitted when the equipment is properly installed, properly maintained, used in accordance with instructions, equipment doors are closed and secured, all equipment covers are in place and secured, and there is no evidence of impending failure. Operating condition and condition of maintenance are two different things. Maintenance is only part of the operating condition. The ESP will detail what the acceptable condition of maintenance is any piece of equipment.
Equipment that is under normal operating conditions is considered to be free from exposed hazards whereas equipment that is not is rightfully considered a risk for electrical injuries. All employees should be able to determine that the equipment they are interacting with is under normal operating conditions. The condition of maintenance is often not within an equipment operator’s knowledge base. With all the variables, NFPA 70E does not specify what is acceptable or how to assess condition of maintenance. There are thousands of pieces of equipment from hundreds of manufacturers with their own maintenance requirements, used in different environments, under different loads, and subject to different types of damage throughout a facility. Determining an appropriate equipment condition is more detailed than many think. It might not be realistic to require that equipment be kept clean. Such a requirement would dictate constant, unnecessary cleaning of a motor designed to safely operate in a dust atmosphere. Equipment might have a different acceptable condition. A grease smudge on a switch might not warrant the same response as a transformer covered in debris.
Equipment that has an operator or is used every day could be evaluated by the employee using it. That employee must be trained to determine the equipment condition and know what to do if the condition is unacceptable. There are many pieces of equipment that are not often viewed by someone. An employee might be assigned to inspect that equipment. The interval might vary. For example, equipment in a loading dock might need more frequent inspection and maintenance than equipment in an electrical closet. Maintenance personnel might be solely responsible for assigning the condition of maintenance of all equipment that any employee interacts with or relies on for electrical safety. This takes an understanding of the definition of condition of maintenance and the ESPs definition of an acceptable maintenance condition.
NFPA 70E is a safe work practice standard that does not provide the details necessary for assessing the condition of maintenance of equipment. In the United States of America, equipment that is under normal operating conditions is not considered a risk for exposure to electrical hazards. The condition of equipment and an employee’s ability to recognize when it is no longer acceptable are important aspects of the ESP. The ESP policies and procedures must detail the equipment condition assessment method as well as what is an acceptable condition to advance safety in the workplace.
