NFPA 70E Don'ts and Do's! Timely Advice!

Let's break this into two parts. Common questions and concerns that come up from the facility manager, the safety manager, even HR. John Klingler is a noted engineer and expert in this subject. Here, first the Don'ts...just in case anything might be going on now that you want to catch. Next week, we'll look at the do's.

By John Klingler, P.E. Klingler Electrical Safety, LLC
Companies across the U.S. and Canada are pursuing compliance with NFPA 70E – the Standard for Electrical Safety in the Workplace. Some of these companies will make costly mistakes; here are some Do’s and Don’ts to avoid doing the same.

• 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 the requirements of NFPA 70E, you will avoid that electrically related accident 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 which are what one would call inexpensive. So how do you know which of these ratings you need? You don’t want to buy clothing that is too light-weight exposing your employees to a hazardous injury and you don’t want to burden them with wearing too much clothing that may cause heat stress or even 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 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, reduce or eliminate as many hazards as possible, and 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 had an NFPA 70E Hazard / Risk of Category 1 or less. The most important point here is: know which equipment is not in the 75% and therefore requires the additional FR clothing and personal protective
equipment. Keep in mind 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 and are 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 tools that are practical for your facility, in some cases even
allowing 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 the insulated tools are not banging around against the non-insulated tools resulting in damage to the insulation. A worker’s life may depend on the condition of that insulated tool; take good care of the 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, and if it is necessary, complying with the permit assures every possible measure has been taken to keep the worker safe while performing the task. However, before implementing an Energized Electrical Work Permit Policy, give serious thought to how permits will be handled in the middle of the night, weekends and 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, they are protected and prepared to perform the work safely.

• Don’t implement policies 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 well-written policies; they are looking for results – a safe work place with no accidents. Facilities that have great policies, but have workers who respond, “Most of the time”, when asked if they always comply with the policies, are not achieving the level of safety needed. The 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 getting much 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 their support of NFPA 70E and its arc-flash requirements, and because manufacturers and suppliers have been aggressive in their advertising of products and services to protect against arc-flash hazards.

However, fatality statistics 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 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.