Doing It The Right Way: NFPA 70E

Sad stories abound. Money can be wasted. Ensuring electrical safety in the workplace is not an option-it’s one of the most important things you’ll ever do. This noted expert offers several suggestions for effective compliance.

Companies across the U.S. and Canada are pursuing compliance with NFPA 70E–the standard for Electrical Safety in the Workplace. Sadly, some of them also are making any number of costly mistakes in the process.Here are some tips to help your organization avoid being one of them.

Don’t
♦ Don’t wait for an accident or for NFPA 70E to become a legal requirement before implementing its requirements.

NFPA 70E addresses electrical hazards, including shock and arc-flash. If you implement its requirement, you will avoid one of those electrically related accidents that causes grief, suffering, financial settlements, investigations and citations.

NFPA 70E is the most comprehensive electrical safety standard available today. There are other excellent electrical safety standards including the National Electrical Code, but NFPA 70E is the only one that addresses electrically safe work practices, electrical maintenance safety, special electrical equipment safety and electrical installation safety in one document. Serious consideration should be given to NFPA 70E not because it virtually assures compliance with OSHA’s electrical requirements, which it does, but because it addresses protection from electrical hazards for your employees and others who work in your facility

♦ Don’t purchase flame-resistant (FR) clothing needlessly.
Yes, FR clothing is probably needed for several tasks in your facility, but there are several ratings of FR clothing varying from light-weight to very heavy switching suits–none of them inexpensive. So, how do you know which of these ratings you need? You don’t want to buy clothing that is too light-weight, thus exposing your employees to a hazardous injury.Neither do you want to burden them with wearing too much clothing that may cause heat stress or, perhaps, compromise their safety by hindering visibility and movement.

Furthermore, arc-flash hazards can often be reduced or in some cases even eliminated by making changes in fuses or circuit breakers, possibly avoiding the need for heavier personal protective equipment (PPE). If you have employees that need to be protected against potential arc-flash hazards, it is always better to complete an arc-flash hazard analysis and reduce or eliminate as many hazards as possible, then decide on a reasonable PPE policy to address the remaining hazards.

A few years ago, a survey determined that 75% of the equipment-qualified personnel work on or near equipment/parts with an NFPA 70E Hazard/Risk of Category 1 or less. The most important point here is to know which equipment is not in the 75%, and, therefore, requires the additional FR clothing and PPE. Keep in mind that you do not need separate FR clothing for each Hazard/Risk Category. NFPA 70E suggests a clothing system in Annex H of the standard that may significantly simplify FR clothing requirements.

♦ Don’t purchase insulated tools that are too bulky for the tasks your employees perform.
NFPA 70E requires employees to use insulated tools when working inside the Limited Approach Boundary of exposed, energized parts where tools might make accidental contact with the energized parts.

Insulated tools are easy to find, but many tool sets are designed for big equipment that linemen work on; they’re not well suited for industrial control panels and drives.Make sure the tools you select are not too big and bulky to be used on the equipment in your plant. If you are buying multiple sets, suppliers/manufacturers may allow you to customize your tool sets by picking and choosing items that are practical for your facility. In some cases, they may even allow mixing of brands to come up with just the right set of tools for your facility.

When you buy insulated tools, invest in a separate tool pouch for the insulated tools so they don’t bang around against your non-insulated tools, causing damage to the insulation. A worker’s life may depend on the condition of that insulated tool–take good care of these tools.

♦ Don’t implement an Energized Electrical Work Permit without some serious thought.
An Energized Electrical Work Permit, as required by NFPA 70E, is an excellent means of discouraging energized work/maintenance/ repair unless absolutely necessary. If it is necessary, complying with the permit ensures that every possible measure has been taken to keep the worker safe while he/she is performing the task.

However, before implementing an Energized Electrical Work Permit Policy, seriously consider how permits will be handled in the middle of the night, on weekends and during holidays. Will the appropriate personnel be available to sign the permits when needed? Will work be delayed until the appropriate signatures are collected? Is it acceptable to fill out and sign a permit after the fact? And, what about those tasks that everyone already knows must be completed without de-energizing the equipment. . . are you going to delay the task each time until the permit is filled out and appropriate signatures are obtained?

The Energized Electrical Work Permit can be an effective tool, but you must anticipate the scenarios of how it will be applied before implementing the policy. Don’t implement an Energized Electrical Work Permit Policy just because NFPA 70E requires it–do it to reduce exposure of employees to electrical hazards and to make sure. when they are exposed, that they are protected and prepared to perform the work safely.

♦ Don’t implement policies that you are not willing to enforce.
It is a waste of time,money, and effort to develop policies that are not going to be enforced.Regulatory agencies will not be impressed by wellwritten policies; they are looking for results–a safe workplace with no accidents.

Facilities that have great policies, but also have workers who only respond,”Most of the time,” when asked if they always comply, are not achieving the level of safety needed. Facilities with the best safety results are those that have good safety policies with zero tolerance for non-compliance.

When developing a safety policy, make sure it is written such that you are willing to enforce the policy.Decide what your disciplinary policy will be for non-compliance, document the safety policy and the disciplinary policy, and communicate these policies to employees, contractors, vendors and suppliers.When disciplinary action is taken,make sure you document the action every time. This documentation is not only important to prove consistency and credibility with the workforce, but it may be extremely important in proving your regulatory compliance with the regulators following an accident.

♦ Don’t forget about shock hazards.
Today, arc-flash hazards and FR clothing are attracting significant attention. This is because knowledge of flash hazards is relatively new (most of the research has been completed since the mid 1980s); OSHA has become more outspoken in support of NFPA 70E and its arcflash requirements; and because manufacturers and suppliers have been increasingly aggressive in their advertising of products and services to protect against arc-flash hazards.

Fatality statistics, however, still show that more workers die from electrocutions than from arc-flash. It may be that more people go to the hospital with arc-flash injuries than with shock injuries, but shock is still the greater threat.

So,when purchasing PPE for electrical hazards, writing your electrical safety policies and training your workers, don’t forget about shock hazards. NFPA 70E does an excellent job of addressing shock hazards.

Do’s
♦ Do develop a training schedule.
Proof of attendance at a one-day training session on NFPA 70E is not adequate to qualify your employees to perform electrical work. Although NFPA 70E training is definitely recommended, if not required, it should only be a single component of a much broader-based training program.

Start by preparing a list of the tasks that a qualified person(s) or electrician( s) are to perform on or near exposed, energized parts. This can be accomplished more formally in a job/task analysis (JTA).

Next, complete a hazard analysis for each task, formally known as a job hazard analysis (JHA), and prepare a description of the skills and knowledge required to perform the job safely. This should include OSHA and NFPA 70E training requirements.

Now compare these requirements to the knowledge, skills and training of the person expected to perform the task(s). This comparison should identify the areas of weakness and be a guide to develop a training schedule to qualify your employee(s).

Training budgets are limited, so concentrate on the major safety deficiencies first. Try to develop a threeyear plan that will coincide with updates to the regulations and standards. Schedule a minimum of two to five days of training annually for each qualified employee.

♦ Do complete an arc-flash hazard analysis.
Facilities with employees, contractors or service personnel that perform tasks exposing them to energized components are generally better off completing an arc-flash hazard analysis as opposed to just using NFPA 70E’s fourfoot arc-flash boundary for equipment less than 600V and the PPE prescribed by the NFPA 70E tables. The NFPA 70E tables serve a vital need, providing arc-flash boundaries and PPE requirements for equipment on which a hazard analysis has not been completed. But, if the table footnotes are not properly observed, the required PPE may be inadequate to protect the worker, or, in the more likely case, the PPE requirements will exceed what is actually necessary, possibly causing heat stress, hindered visibility and restricted movement.

Based on personal experience, it would appear that a substantial percentage of the equipment operating at 480 volts and less will have an arc-flash boundary of less than twelve inches, negating the requirement for FR clothing to protect the face and torso.However, experience also has shown that it is not uncommon for industrial and large commercial facilities to have a small percentage of equipment where even the four-foot default boundary is not adequate to avoid permanent injury in the event of an arc-flash. Consequently, NFPA 70E and IEEE Standard 1584 provide formulas that are to be used under engineering supervision to determine where FR clothing is needed and where it is not.

♦ Do ask the engineers completing the arc-flash hazard analysis for recommendations on how to reduce or eliminate the hazard. An arc-flash analysis by a qualified engineer should provide more than just the results of the analysis.

The engineer should review each location having a Hazard/Risk Category 1 or greater to determine if any changes can be made to reduce or eliminate the severity of potential flash hazards. He/she also should evaluate what affect changing fuse types or breaker settings will have on the Hazard/Risk Category of the equipment. In most cases the engineer can make recommendations that, if accepted,will reduce flash hazards, resulting in a safer workplace and lower PPE cost–that’s truly a win-win.

♦ Do keep a copy of the arc-flash analysis data files.
If you use an engineering/consulting company to conduct an arc-flash hazard analysis, require that it provide an electronic copy of all the data files used in the analysis.

Within weeks or months, if not days, following the completion of the analysis, changes will be made to the facility’s electrical system,which, in turn,may require recalculating part or all of the analysis. If you have the data files, your options for updating the analysis are much greater than if your consultant owns the files.

Having the data files will generally result in a lower cost to update the flash hazard analysis. If you have the necessary resources, you may even consider purchasing the analysis software and updating the analysis yourself.

♦ Do decide on how appropriate PPE will be made available to employees before labeling equipment with PPE requirements and before training employees on those requirements.

Please, do not misunderstand–this is not to suggest that you delay informing your employees of potential electrical hazards to which they may be exposed. Rather, it is a recommendation that you not put the cart before the horse, potentially creating a situation you cannot tolerate.

The natural progression in completing hazard analyses and providing appropriate PPE should go something like this: complete the analyses; eliminate or reduce as many hazards as possible; identify where the remaining hazards are; determine the level of PPE needed; procure the PPE; label the equipment; then train your employees. The training should include:

• How to recognize and avoid hazards;
• PPE policy;
• Energized Electrical Work Permit policy;
• Lockout/tagout procedures;
• Requirements for an Electrical Safe Work Condition.

Some facilities do the right things, in the wrong order, resulting in frustration, resistance and even bitterness toward management– assuming management is only doing this to meet legal requirements, not out of a genuine concern for the safety of the employee. It is very difficult to explain why an employee should work in a cabinet that has an arc-flash warning label on the door, without having been provided the appropriate PPE required by the label. Excuses such as “the PPE is back-ordered,””the PPE has not been decided on, yet” or “the new PPE requirement has not received funding approvals, yet” do little to build an atmosphere of trust and commitment to safety.

Consider procuring a minimum amount of PPE immediately, enough to use until your analyses are complete and the appropriate levels and quantities of PPE can be procured–then proceed with labeling and training.

♦ Do label equipment with enough detail to inform the worker of the potential hazard and PPE requirements.

Labeling of equipment is an extremely important component of the Flash Hazard Analysis. Determining the arc-flash boundary and the appropriate PPE is pointless if that information is not communicated to the individuals working on or near the equipment with the hazard.

The label should be placed in a conspicuous location that will be easily seen BEFORE the equipment is opened. The label should provide the worker(s) with enough information to know at what distance PPE is called for and what level/category of PPE is required when crossing the approach/ flash boundaries.

Since 2002, the National Electrical Code® (NEC) has required labeling of panelboards and similar electrical equipment to warn of potential flash hazards. Although the current NEC language does not specify what information must be provided on the warning label, it is likely that future editions will add some requirements.At a minimum, the following information should be included on the label:

• Maximum voltage in the equipment;
• Arc-flash boundary;
• Required PPE (Hazard/Risk Category or cal/cm2).
• Do give consideration to contractors, vendors and service personnel that enter your facility and are exposed to electrical hazards.

For their safety and your company’s protection, contractors, vendors and service personnel should be required to comply with NFPA 70E when working in your facility.

Many companies send letters to all of their contractors, vendors and service providers, requiring NFPA 70E compliance when working in its facilities. The facility must make sure their equipment has been properly labeled with enough information for these non-employees to understand the potential hazards and to select appropriate PPE.

♦ Do make sure your equipment has been properly identified.

Label each disconnect (i.e. circuit breakers and switches) as to its purpose–that’s a requirement of the National Electrical Code, Section 110.22 Furthermore, remember that proper identification is required to complete lockout/tagout procedures. (But, can lockout/tagout procedures be completed if the appropriate disconnecting devices cannot be found?)

Identification is also a prerequisite of any arc-flash hazard analysis study.Whether you are conducting your own arc-flash hazard analysis or hiring it done, the required electrical data cannot be accurately collected without knowing the purpose of each disconnecting device.

Unfortunately, many facilities do not have all of their disconnects labeled, and in some plants (surprisingly), no one knows what some disconnects are used for. Leaving it to the analysis data collectors to trace out a circuit generally requires additional time, money and potential disruption of equipment operation. It is much more effective to label your disconnects BEFORE the analysis–at times that are convenient to the facility.

If you really want to enhance safety and maintenance, also consider labeling the utilization equipment (the load) with information as to the location of the respective disconnect. Proper labeling generally encourages lockout/ tagout procedures and may save valuable time in the event of an emergency.

As an example, following an electrocution of an electrician, his co-worker was interviewed to determine why the two of them had been replacing lighting ballasts while the circuit was energized. The co-worker replied that the circuit breakers were not labeled and it took too long to determine the proper breaker to de-energize. That’s why they always performed the work “hot.” Label your disconnects- it’s the law! MT

John Klingler, P.E., is a former master electrician, DOL certified electrical instructor and certified electrician in low, medium and high voltage. He’s spent 25 years in management, engineering, supervision and as an electrician, and six years as an electrical trainer. For details on his new company, e-mail: john@klinglerelectricalsafety.com