NFPA 70E: Standard for Electrical Safety in the Workplace® is an indispensable work in progress. For more than 35 years, NFPA 70E has delivered on its mission to create safer workplaces through improved electrical safety practices, but the standard continues to evolve.
Approximately every three years, NFPA 70E is updated to incorporate the latest in electrical safety research, risk assessments, work practices, design considerations, and personal protective equipment (PPE) in an effort to reduce the number of deaths and injuries caused by shock, arc flash, and arc blast. This voluntary how-to guide to assist in Occupational Safety and Health Administration (OSHA) compliance can play an invaluable role in helping plants mitigate their electrical hazards, protect workers, promote safety requirements, and keep their facilities up and running.
Much is learned every year. When the National Fire Protection Association (NFPA) initiated the voluntary standard at OSHA’s request in 1979, the first edition addressed only electrical installation requirements related to electrical safety. It wasn’t until the 1995 edition that arc flash hazards were addressed, and numerous workplace safety requirements have since been added.
As the safety standard evolves, so must the companies and electrical workers who use it. The 10th and latest release, NFPA 70E 2015, contains some significant differences from its 2012 predecessor. It is essential to understand these changes and why they matter in order to remain compliant with OSHA, avoid risking lives, reduce liability, and prevent unexpected and costly downtime.
Summary of NFPA 70E 2015 changes
The new edition strives to ensure a safer workplace and clarifies the responsibilities of employees and employers by making the following major changes, in addition to extensive minor adjustments:
- “Risk assessment” replaces the phrase “hazard analysis” throughout the standard as part of an effort to make users more aware of the devastating risk of failure and loss caused by shock, arc flash, and arc blast hazards. Specifically, the “risk assessment process” now is defined as including identification of shock, arc flash, and arc blast hazards; estimation of the potential severity of injury or damage to health; estimation of the likelihood of injury occurrence or damage to health; and determination of whether protective measures and PPE are required.
- Maintenance status is now an integral part of the risk assessment.
- The electrical safety program must now include maintenance on electrical equipment as a primary element.
- Clarification was made that a comprehensive risk assessment, not just an incident energy analysis, is required (see sidebar on best practices for conducting a risk assessment and incident energy analysis).
- The responsibility for proper installation and maintenance is assigned to the equipment owner or the owner’s designated representative.
- The short-circuit current and clearing time of the over-current protective device must be known for an incident energy analysis.
- Hazard/risk category (HRC) tables have been replaced with new hazard identification tables and PPE category tables. All references to HRC have been replaced with the term “arc flash PPE category.” This will force a culture change because HRC has become institutionalized terminology in the industry.
- To use the PPE category tables, the short-circuit current and clearing time of the over-current protective device must be known.
- HRC 0, the standard PPE worn every day for normal construction activities, has been eliminated; now, the qualified person must make a risk assessment based upon normal operation of equipment that meets all of the following criteria:
- The equipment is properly installed
- The equipment is properly maintained
- All equipment doors are closed and secured
- All equipment covers are in place and secured
- There is no evidence of impending failure
- Companies can develop their own PPE numbering system.
- Warning label content was modified to include:
- Incident energy at a corresponding distance or PPE category selected using 70E tables, but not both
- Site-specific level of PPE
- Labels must be updated when a hazard risk assessment review renders the label to be inaccurate
- It’s clarified that the electrical equipment owner is now responsible for the documentation, installation, and maintenance of field-installed labels.
- The requirements for construction and maintenance work were separated from outdoor work to enhance usability.
- The table update for restricted-approach boundary dimensions added clarity.
- A new requirement covers risk assessment associated with battery work.
- The prohibited-approach shock boundary was eliminated.
Why do these changes matter?
NFPA 70E provides instructions on how to comply with OSHA’s electrical safety regulations. According to OSHA, there are approximately 350 electrical-related fatalities each year. OSHA is able to cite companies for noncompliance, with the consensus standard as a reference, when an electrical accident causes a serious injury or death, even though NFPA 70E is voluntary rather than a federal regulation. Certain states and industries with more-restrictive occupational health and safety laws require NFPA 70E compliance.
NFPA makes it the responsibility of the employer to educate employees, including qualified and unqualified electrical workers, on safety standards. In fact, a plant manager can be held criminally responsible for a worker’s injury if the worker did not have proper safety training. Personnel in any industry who work on or around or who or interact with electrical equipment, AC or DC voltages of 50 volts or more, or are responsible for safety in the workplace, must receive electrical safety training according to NFPA 70E 2015.
The new standard’s risk assessment process broadens the scope of employees who must receive electrical safety education. Employers must assess generally recognized arc flash and shock hazards in the workplace and provide protection from those hazards, and all employees must be made aware of the potential hazards. Safety consulting and engineering services can be called upon to help expedite and refine safety education and compliance initiatives.
The 2015 edition also requires an arc flash risk assessment to determine whether an arc flash hazard exists. Even the process of establishing an electrically safe work condition puts the employee at risk. If an arc flash hazard exists, the employer must determine the risk to employees and the required safe work practices, arc flash boundary, and PPE. Similarly, shock risk assessments are required to determine the voltage, shock boundaries, and PPE. Employees must be trained in these new skills, and must quickly implement them. The practice of hiring an engineering firm to perform an arc flash incident energy analysis now must be followed up with a risk assessment.
All employees who are exposed to electrical hazards where the risk has not been reduced to a safe level (with no exposed energized conductors or parts of equipment and the equipment is essentially stagnant) require risk and avoidance training, according to the new standard, from electricians and operators to mechanics, janitors, office workers, or anyone who may plug into an electrical outlet. In order to train employees to identify, understand, and avoid the electrical hazards and risk of injury associated with the tasks that they are required to perform, it is recommended that a job/task analysis and task hazard analysis with shock and arc flash risk assessments be conducted for each employee. The exposure or potential exposure to electrical hazards should be recorded in the employee’s job description and their training requirements determined accordingly.
Finally, employers must document that the hazard assessments were performed and authorize energized electrical work permits as needed. Companies must be prepared to share these records if requested during an OSHA inspection.
Compliance may necessitate outside assistance
OSHA requires employers to document and implement an electrical safety program that addresses exposure to all existing hazards and those likely to exist in the workplace. The program must be published and available to all employees who might be exposed to the hazards. OSHA also has specific equipment labeling requirements.
Unfortunately, the language used by OSHA can make its electrical standards difficult to interpret and apply. Training on each new edition of the OSHA, NFPA 70E, and NEC electrical standards should be delivered by someone who has a thorough understanding of the latest requirements and how they apply to individual facilities and who can relay the complicated material in an easily understood manner. Third-party electrical safety experts can support hazard assessments, incident energy analysis, and follow-up activity speedily and in accordance with NFPA and IEEE standards.
Multiple delivery options are available for electrical safety training. Custom courses can be designed to match a company’s industry and environment, including its voltage, energy level, and circuit equipment conditions. Online and on-site training options avoid incurring personnel travel time and expenses. Fully equipped, regional training centers provide skills-based training combined with hands-on labs.
Arc flash and power system analysis studies performed by registered engineering firms identify and mitigate the hazards created by electrical equipment and systems. Folding these engineering studies into the latest industry standards enables continuous improvement of workplace safety, OSHA compliance, equipment reliability, and uptime.