Revised NFPA 70E clarifies electrical safety

During the June 2008 National Fire Protection Association (NFPA) World Safety Conference and Exposition, the final content of the 70E standard began to take shape. Until then, nothing was firm because the NFPA Standards Council has the final say on 70E, as it does on any NFPA-derived documents. This structure is in place to administer the rules and regulations and to act as an appeals body for any disagreements to the codes and standards.

There were five Notices of Intent to Make a Motion (NITMAM) that were subject to a vote. One of those NITMAM’s concerned the wording of the scope of the 70E, one was in opposition to a new labeling requirement, and three concerned battery-related issues. Two of the NITMAM actions received positive votes to proceed forward for technical committee vote, which left 70E pretty much completed as written. However, as in the case of last cycle’s 70E (2004), Tentative Interim Amendments (TIA) could be added to correct real or perceived deficiencies that might arise as the document is subjected to wider scrutiny.

A TIA is used to introduce changes that affect safety or correct obvious errors. With the 578 proposals that were submitted this cycle and the 800 comments that had to be addressed, consolidating the changes was a huge task for the NFPA.

A proven track record

The 70E hasn’t always been the standard it is today, nor has it always been considered a must-have safety document. In 1976, OSHA asked the NFPA to develop a standard that OSHA could use in developing the Electrical Safe Work Practices regulation, Subpart S. The NFPA formed a consensus committee made up of representatives from a broad cross-section of industry, including IBEW, IEEE, NECA, aluminum, petrochemical, manufacturing, utilities and testing companies. The first 70E was published in 1979 and NFPA has published revised editions about every three years.

A big change in the 2000 edition caused people to take notice of 70E. The arc flash tables, which were included as 130.7(C)(9)(a), 130.7(C)(10) and 130.7(C)(11) provided, for the first time, a practical way for electrical workers to choose what OSHA terms “appropriate electrical protective equipment” [29 CFR 1910.335(a)(1)]. This eliminated much of the confusion (and foot-dragging) so prevalent when people try to comply with federal regulations, but lack solid guidance. Some people love the arc flash tables, some hate them, but since 1999, there hasn’t been one incident reported to the 70E Committee in which a worker who followed the tables was seriously injured. Personally, I think that’s a pretty good track record.

The 2002 edition of the National Electrical Code, NFPA 70, contained another significant clause. Article 110.16, which was new to the NEC, required labeling on equipment to warn qualified workers about the potential hazard of arc flash and shock. This forced the electrical contractors and their clientele to attach the labels and start implementing arc flash protection programs.

It’s pretty difficult to ignore hazards when you’re obliged to paste warning labels on equipment being installed. Suddenly, plant-floor workers were asking questions about arc flash.

Made more consistent and accessible

So, what kind of changes are found in the latest revision? For one thing, a great deal of effort went into making 70E more consistent, more understandable and simpler to use. As a member of two task groups, (Words and Phrases Task Group and the Tables Task Group), I can honestly say that the task groups spent many hours conferring after the official meeting adjourned, often until 10 p.m. or 11 p.m.

Because OSHA is using 70E as a guide for what people should be wearing and doing in the workplace (they only can enforce federal law, not a standard) and because courts have ruled that 70E is “standard industry practice,” what 70E actually says has become increasingly important. Some of the most significant changes follow.

No more jargon: This includes elimination of slang words and phrases, such as “hot,” “live” and “working on or near.” Examples of how “live” has been changed to “energized” include:

• …live energized electrical conductors or circuit parts…
• The title of Article 130 has been changed: Working On or Near Live Parts Work Involving Electrical Hazards

To make the standard more specific, which should improve clarity and make it more precise, “working on or near” will be dropped and the limits of approach will be used. There are three examples below:

• “…working on or near within the Limited Approach Boundary ….”
• “…working on or near within the Flash Protection Boundary ….”
• “110.8(A) General - Safety-related work practices shall be used to safeguard employees from injury while they are working on or near exposed to electrical hazards from electrical conductors or circuit parts that ….”

This recommended wording is much clearer and leaves little doubt about the standard’s intent. The specific hazard of concern is identified or, like in the third example, all hazards are indicated. These wording changes should eliminate ambiguity and make the intent clear to the worker. The 70E Committee, TCC and the NFPA have a common goal: to make 70E a usable safety standard, one that is as clear and concise as humanly possible. This edition of 70E moves us closer to that goal.

Article 110.6(A) added new training requirements: “Employees shall be trained to select an appropriate voltage-detector and shall demonstrate how to use a device to verify the absence of voltage, including interpreting indications provided by the device. The training shall include information that enables the employee to understand all limitations of each specific voltage-detector that might be used.”

Article 110.7(A) changed: It now requires that electrical safety programs be documented.

Chapter 4 is eliminated completely: Chapter 4 used to be Chapter 1 (it was the first chapter developed and issued as 70E), but in the 2004 cycle we decided that the emphasis of 70E was safe work practices, not the abridged version of the NEC.

This cycle, the Committee decided that if people wanted to know what the NEC said, they would need to consult the NEC. Reworking and transcribing the NEC for use in the 70E produced too many compliance problems.

Major wording changes in the tables: The wording was changed throughout the tables to reflect the effects of the Word and Phrase task group work. Again, this should make the tables clearer and more consistent. New wording, reflecting the wording in standards is used wherever appropriate. This tends to get a bit clumsy, such as using “insulated and insulating hand tools,” instead of just “insulated hand tools,” but it is necessary to provide continuity between standards.

Switchgear: New tasks involving arc-resistant switchgear are being added to Table 130.7(C)(9), and a new section pertaining to arc-resistant switchgear also is added. If the door is properly secured, no FR clothing or equipment is needed to operate or install/remove (rack) breakers. If the door is open, it would have the same level of risk as traditional switchgear.

Predictive maintenance: Infrared thermography has been added as a task applicable to many types of equipment. A reduced level of PPE could be allowed if the thermographer doesn’t remove panel covers and doesn’t break the plane of the equipment and if the work activities are nonintrusive. We also assumed the thermographer would stand as far from the equipment as possible, and no closer than the Restricted Approach Boundary. Be sure to read the notes that are included, both in and following the tables, to apply these correctly.

Some hazard/risk categories have been changed: Inserting or removing (racking) circuit breakers is now HRC 4 whether the doors are open or closed because of the high probability of the door swinging open. Add to this the venting and other openings that often are found in switchgear doors and there’s little difference between open or closed. Inserting or removing MCC buckets is now also HRC 4.

New category: Also in Table 130.7(C)(9), a new equipment category was added for “utilization equipment fed by a branch circuit of the panelboard or switchgear.” This applies to equipment such as receptacles, motors and other small devices. In the previous versions, there was no guidance for this type of electrical equipment.

Ease of use: Table 130.7(C)(10) (PPE and Clothing Matrix) was reformatted to make it easier to use. Instead of columns, each Hazard/Risk Category now is self-contained in rows. Table 1 gives and example of HRC 0 and HRC 1. 

Hazard risk table changes: Hazard/Risk Category minus 1 (HRC -1) was removed in Table 130.7(C)(10). The 70E Committee felt it could be confusing. Also, in an effort to make the Hazard/Risk Category 2* less confusing, a new row was added to accommodate it. PPE and clothing required for HRC 2* is now in one place. Then, in HRC 2* allows a balaclava hood (NOMEX sock hood) and arc-rated face shield combination to be used in place of a full flash hood.

Hazard/Risk Category 1 will now require the use of an arc-rated face shield (4 cal/cm2 minimum). The requirement for hearing protection is now required for HRC 0 and HRC 1 tasks. Some might take this as excessive, but the 70E Committee had sufficient proof that hearing loss could occur at these hazard levels, especially in an enclosed area.

Several notes associated with these tables have been changed. As always, review the notes before using the tables, because they provide the limitations of the tables.

Fine Print Note: Article 100 (Definitions) now contains a Fine Print Note (FPN) that states that an arc flash hazard might exist, even if the equipment is properly engineered, installed and maintained. This could happen during such tasks as racking breakers and inserting or removing MCC buckets. Article 130.3 adds a new FPN, stating, “Improper or inadequate maintenance can result in increased opening time of the overcurrent protective device, thus increasing the incident energy.” Article 130.3 also adds a requirement that arc flash studies be reviewed no less often than every five years or when major changes are made to the electrical system. Article 130.3(C) states, “Equipment Labeling. Equipment shall be field marked with a label containing the available incident energy or required level of PPE.” This was intended to apply to equipment identified as needing labeling as required by NEC Article 110.16.

Not that anyone actually reads Chapter 2, but some changes were made that can affect everyone’s electrical maintenance programs. As an example, Article 205.3 states, “General Maintenance Requirements: Overcurrent protective devices shall be maintained in accordance with the manufacturers' instructions or industry consensus standards.” This has been a long time in coming, but it boggles the mind to think managers often think their electrical systems don’t need maintenance to work properly (and safely). This is amplified by the FPN in 205.3, “Failure to properly maintain protective devices can have an adverse effect on the flash hazard analysis incident energy values.”

There are dozens of other changes, so you ought to purchase and study the new edition of 70E. This article only hits the major changes. Depending on your needs and the needs of your plant, other changes could have even more impact than those above.

Most importantly, be certain to review your safety program and practices continuously to be certain they meet your actual needs. An Electrical Safety Program should meet your actual needs, not just be a boilerplate document that is stuck in a book on a shelf and never used.

Jim White is the training director at Shermco Industries in Irving, Texas. Contact him at [email protected] and (972) 793-5523.