The Occupational Safety and Health Administration (OSHA) mandates that companies provide an electrically safe workplace for all personnel. To define what this means, OSHA turns to the National Fire Protection Association (NFPA) and its NFPA 70E standard.

NFPA 70E continues to evolve as new thinking on electrical safety is introduced. The latest edition, NFPA 70E 2012, has changed significantly from the 2009 edition of the standard, and to help you understand how 70E 2012 impacts your company, D.L. Steiner has prepared this summary of its most notable updates.

Audits—NFPA 70E 2012 requires that companies now conduct regular audits of their entire electrical safety program at specified time intervals.

Worker performance must now be audited at least annually to verify that qualified workers are complying with 70E standards (Article 110.2[D][1][f]).

Formal audits of the company electrical safety program must now be completed on a frequency not to exceed three years (Article 110.3[H][1]). This includes fieldwork to verify that the safety program is being followed. If it isn’t, training must be changed.

Electrical safety audits and their results must now be documented.

Electrical Safety Training—NFPA 70E 2012 contains two important new mandates related to safety training:

• A facility’s electrical workers must now undergo retraining in electrical safety at a minimum of every three years (Article 110.2[D)][3][d]).
• The documentation for electrical safety courses must now contain course content, as well as the date of the training and the names of the people who were trained (Article 110.2[E]).

Safety Practices—NFPA 70E includes procedures for managing risks associated with working near electrical energy. Some of these have changed noticeably for 70E 2012.

Previously, NFPA 70E required the electrically safe work condition (exposed conductors disconnected from power source, locked and tagged, tested for zero voltage, grounded, if necessary) whenever a worker worked within the limited approach boundary for exposed energized conductors. For 70E 2012, the electrically safe work condition is required, even if energized conductors aren’t exposed but the worker interacts with equipment in a way that increases the risk of injury due to an arc flash (Article 130.2).

Earlier NFPA 70E editions required an energized electrical work permit whenever a worker worked inside the limited approach boundary of live electrical equipment that couldn’t be placed in the electrically safe work condition. 70E 2012 requires the permit for work performed within the arc flash boundary of exposed energized electrical conductors (Article 130.2[B] [1]; Informative Annex J).

The 2009 edition of 70E contained a lockout/tagout procedure that permitted electrical workers to de-energize a circuit without applying locks or tags (Article 120.2[D][1], 2009 edition). This procedure conflicted with OSHA electrical safety standards and has been removed from 70E 2012.

Arc Flash Hazard—In previous 70E editions, arc flash hazard analysis included establishing the arc flash protection boundary and selecting the PPE (personal protective equipment) required to work safely in the presence of the arc flash hazard. Under 70E 2012, arc flash hazard analysis includes establishing the incident energy level at the working distance, plus establishing the arc flash boundary and selecting PPE (Article 130.5).

The default 4′ arc flash protection boundary of earlier 70E editions has been removed from 70E 2012. This boundary is now specified in inches for each unique situation and comes from one of two task tables: Table 130.7(C)(15)(a) for AC and Table 130.7(C)(15)(b) for DC. These tables also list the fault current, clearing time, and working distance of protective devices in the heading of each table section. This eliminates searching table endnotes to verify that a task fits within established limits.

Under 70E 2012, electrical systems of 240 Volts or less with a transformer rated 125 kVA or less are no longer exempt from the arc flash hazard analysis mandate (Article 130.5). For guidance assessing the arc flash hazard of these systems, see IEEE 1584.

Labeling—Previously, electrical equipment safety labels could include the information of either incident energy or required PPE level. NFPA 70E 2012 mandates that these labels contain more extensive safety information (Article 130.5[C])—

• At least one of the following: (1) available incident energy;(2) minimum arc rating of clothing; (3) required PPE level; (4) highest HRC (hazard risk category) for the equipment
• Date of arc flash hazard analysis
• Nominal system voltage
• Arc flash boundary

PPE—70E 2012 makes significant changes to the way PPE is used:

• The 2* Category has been deleted.
• Incident energy calculation method for selecting PPE—The balaclava (sock hood) must be worn with a face shield if the back of the head is within the arc flash protection boundary (Article 130.7[10][b][1]).
• Incident energy calculation method for selecting PPE—An arc flash hood must be used if the anticipated incident energy exposures exceeds 12 calories/cm2 (Article 130.7[10][b][2]).
• Table method for selecting PPE— The balaclava and face shield must be worn if the task table indicates Category 2 (Table 130.7[C)][16]).

New DC Information—NFPA 70E 2012 includes two new tables for assessing electrical hazards while working with DC voltages.

• Table 130.4(C)(b) lists approach boundaries for protection against shock while working with DC electrical conductors or circuit parts.
• Table 130.7(C)(15)(b) lists the arc flash hazard risk category classifications of different tasks performed on DC equipment. Previously, NFPA 70E did not cover DC equipment in any detail.

NPFA 70E 2012 is a major step forward in workplace electrical safety, but it will no doubt raise questions not addressed by the information we’ve provided. For help interpreting this new standard to ensure your company complies with its mandates, please contact D.L. Steiner.

First, understand that an electrical lockout/tagout program is not an option. Electrical lockout/tagout falls under workplace electrical safety and the overall electrical safety program mandated by OSHA and the NFPA. What’s more, NFPA 70E stipulates this program should be a documented program. Each facility should have an electrical lockout/tagout program, and this program needs to be on paper, not just in peoples’ heads. If you aren’t comfortable developing and documenting your lockout/tagout program, enlist the services of a knowledgeable professional.

Along with this, realize that an effective electrical lockout/tagout program isn’t simply your mechanical lockout/tagout program with the word electrical substituted for the word mechanical. Electrical lockout/tagout has a specific goal—the electrically safe work condition. The electrically safe work condition is a unique safety plan that must address the standards NFPA 70E has mandated:

• The conductor or circuit part has been disconnected from energized parts.
• It has been lock/tagged according to established standards.
• It has been tested to verify that voltage is absent.
• It has been properly grounded, if this is deemed necessary.

For a complete electrical lockout/tagout program, lockout/tagout procedures should be developed for each piece of equipment whose circuitry may be accessed by maintenance personnel. Naturally, the details of these procedures will vary, but all should state what the procedure is intended to accomplish. Additionally, they should specify that only a qualified electrical worker is authorized to perform the electrical lockout/tagout. Like the electrical lockout/tagout program, itself, these procedures should be documented.

Related to this is accessibility. To make proper use of the electrical lockout/tagout program and procedures, workers must have ready access to these documents. In this situation, redundancy is not a bad thing. Post or store your program/procedures in as many places as is practical so your personnel can easily find them: online, file cabinets, special notebooks, local work areas, etc. Remember, though, if you change a document in one location, make sure you also update it in all locations.

Ensure your electrical lockout/tagout program is comprehensive. Setting up a program for simple lockouts/tagouts—one worker, one piece of equipment—is not too difficult. Establishing a program that effectively addresses complex lockouts/tagouts— ones that involve multiple personnel and many forms of energy (hydraulics, steam, etc.), or ones that extend across shifts—is a different matter. Who is responsible for the entire lockout/tagout operation? How are the various types of energy coordinated during the lockout/tagout? How are shift changes handled? To be complete, your electrical lockout/tagout program should answer these and other similar questions.

An electrical lockout/tagout program must include certain tools and training to make it workable. Electrical maintenance workers should be trained in both electrical lockout/tagout and general electrical safety so they can recognize their responsibilities while on the job. They also require an adequate supply of electrical locks and tags that are for their personal use only (i.e., no “community” locks and tags). Additionally, they need access to the necessary personal protective equipment (PPE), and they need to understand when they must use the PPE (e.g., when pulling a cutout or a large breaker) and when they can remove it (e.g., after an electrical circuit has been de-energized, tested, locked, and tagged).

Finally, an electrical lockout/tagout program is not a one-time, static event. Because your electrical system and electrical safety practices continually change, your electrical lockout/ tagout program should be audited yearly to ensure it is adequate for the present state of your electrical system and that it aligns with the most recent OSHA requirements for electrical safety. Again, if you aren’t comfortable conducting this audit yourself, contact a professional.

D.L. Steiner will be happy to assist you in setting up a standards compliant electrical lockout/tagout program. Contact us today for more information.

Designing for reliability—For new construction or system updates, the dollars saved installing underrated or marginal equipment is quickly offset by maintenance and downtime. All new equipment should undergo reliability testing and verification.

Designing for safety—Too often, poor design compromises system safety, for example, a design that doesn’t permit safe maintenance on breakers without shutting down a process (typically not feasible) or a design that increases the arc flash hazard risk category. All new system designs and equipment should be evaluated for safety, especially in terms of arc flash hazard.

Designing for maintenance—All equipment, no matter how well built, eventually needs maintenance, yet the system design can make equipment inefficient—or virtually impossible— to maintain. All new system designs should be reviewed to ensure ease of equipment maintenance.

Sure, the goal of electrical systems is to distribute power. But by designing them for reliability, safety, and maintenance ease, we can ensure that they do so cost effectively—and for many years to come.

There is no doubt that wearing gloves is clumsy and makes the electrical worker’s job more difficult. It is not surprising, then, that D.L. Steiner, Inc. is often asked whether or not workers are required to wear their gloves when working on a de-energized panelboard, control panel, or PLC cabinet. The answer to this question has three parts.

Part One: an Observation to Clarify the Situation

What is being considered here is a cabinet in which the local switch has been turned to the off position in order to isolate the internal components from the feed voltage supply. This is not the same as a cabinet or panel that has been completely isolated from its power source. When a cabinet has been removed from all voltage and appropriately locked out and tested for the absense of voltage, no shock or arc-flash hazard remains. In the case of a cabinet where a local switch has merely been turned off, however, a line-side voltage is still present, even though the internal components are de-energized, having been isolated from the voltage by an integrated isolating switch. So in such a case if the internal components are free from dangerous voltage, are gloves still needed?

Part Two: Questions to Guide Action

Gloves needed inside the Restricted Approach Boundary

This question is answered with a question – two questions actually. The first involves shock protection: What is the Restricted Approach Boundary? Simply put, this is the distance (which varies with voltage) where qualified workers must restrict their approach to energized electrical conductors over 50 Volts, unless using proper personal protective equipment (PPE) and voltage-rated tools (see NFPA 70E, section 130.2[C] for an explanation). Answering this question goes a long way in determining “Are gloves still needed?”

Consider the Restricted Approach Boundary to be a protective bubble that extends around energized components. The line voltage determines the size of this protective bubble. If workers are working on components sufficiently removed from the exposed energized conductors so that hands will not be placed within the Restricted Approach Boundary, there is no requirement to wear insulating gloves. Conversely, if electrical workers’ hands will “penetrate” or are likely to penetrate the protective bubble, they definitely face a shock hazard and should be wearing insulating gloves of an appropriate voltage rating.

The simplest situation for determining to glove or not to glove is when 120/240 Volts feeds the equipment. In this case, the Restricted Approach Boundary is “avoid contact” (see NFPA 70E, Table 130.2[C] for a complete listing of boundary dimensions with their corresponding voltages). If electrical workers are careful to avoid contact with energized components, they can work on adjacent de-energized components without wearing insulating gloves.

If the feed voltage is 480 Volts, the Restricted Approach Boundary grows to one foot. Workers can work on de-energized components that are more than one foot from the energized conductor without wearing protective gloves. But if their hands will or are likely to encroach the boundary, insulating gloves of the appropriate rating must be worn.

Is that all there is to it? Not quite. So far this discussion has only considered gloves as a protection from the hazard of electrical shock. But they are also intended to protect from a second electrical hazard, namely, arc-flash. Since we know there is a Restricted Approach Boundary for electrical shock; there is also an Arc Flash Protection Boundary. This naturally leads to the next key question: What is the Arc-Flash Protection Boundary? Whenever workers enter this boundary, they have placed themselves within an area that, should an arc-flash incident occur, could result in severe and damaging burns. These burns most frequently afflict the hands, because these body parts are typically closest to the potential arc source and therefore must vulnerable to arc burns.

By definition, the Arc Flash Protection Boundary is “the distance from a prospective arc source within which a person could receive a second degree burn if and arc flash were to occur.” (NFPA 70E Art. 100). Consequently, any worker who crosses this boundary is at risk of third degree burns and death.  The NFPA 70E requires that workers wear appropriate PPE (including gloves) as a thermal barrier. Thermal hand protection may be in the form of leather gloves, arc-rated gloves, or rubber insulated gloves with leather protectors depending on the particular circumstances involved (see NFPA 70E, Table 130.7[C][10] for PPE requirements in the vicinity of arch flash hazards).

PPE must be worn within the Arc Flash Protection Boundary

This question is not easy to answer, as it is not directly related to voltage levels or any single factor, but instead involves a combination of electrical conditions. The clearest indication of this boundary occurs when an arc-flash hazard analysis has been performed on the electrical equipment in question. In such a situation, each electrical device will have an electrical hazard label identifying the Arc-Flash Protection Boundary for that device. On some pieces of equipment with very low levels of arc-flash potential energy, workers may find the Arc-Flash Protection Boundary to be small enough to permit them to work on portions of the de-energized cabinet without wearing gloves. Typically, however, the Arc-Flash Protection Boundary will be large enough that gloves are required while working on de-energized components within the cabinet.

When an arc-flash hazard analysis has not been performed, NFPA 70E stipulates a default boundary of four feet in some situations when the voltage to a device is between 50 and 600 Volts (see NFPA 70E 130.3[A][1] for the conditions that create these situations). Obviously working in a cabinet or bucket in the presence of a live feed a four-foot boundary will require workers to wear gloves to protect their hands, even when working on de-energized electrical components within that equipment.

Knowing both the Restricted Approach Boundary and the Arc-Flash Protection Boundary helps workers properly protect their hands from the dangers of shock and arc-flash. In most cases, workers will discover that this protection involves wearing either leather gloves or rubber insulating gloves with leather protectors.

Part Three: An Option to Consider

Anyone who has ever worn voltage-rated gloves, with their bulky leather protectors, realizes just how clumsy such attire can be. When a delicate touch is needed, workers are tempted to forego protective gloves and risk injury from shock or arc-flash by doing the work barehanded. This leads us to yet anotherquestion: Is there no other solution? Yes, there is!

It’s a fundamental fact: when workers’ hands, or other body parts, will be placed within a Restricted Approach Boundary or an Arc-Flash Protection Boundary, they need protection. The most typical protection is to wear gloves; however, an acceptable alternative is to place guards on the conductors so that workers cannot make accidental contact with energized components. With such guards in positions, the equipment is now touch-safe, and the need to wear protective gloves is removed. Much of the newer electrical equipment, in fact, is being manufactured with touch-safe guards already in place, making them easier to maintain and repair when these services are required.

Workers should not gamble their safety by failing to use front-line protection from the hazards of electrical shock and arc-flash. Following the guidelines presented above will help electrical workers accurately determine when glove use is essential to protect against serious hand injury.

When the 2009 edition of NFPA 70E was released, electrical safety auditing became part of the electrical industry’s best practices. Certainly, it will be one criterion OSHA will use to judge whether an employer is doing what it needs to provide a workplace that is “free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees;” [OSHA General Duty Clause]

NFPA 70E Article 100.7 (H) says: “An electrical safety program shall be audited to help ensure that the principles and procedures of the electrical safety program are being followed. The frequency of audit shall be determined by the employer, based on the complexity of the procedures and the type of work being covered. Where the audit determines that the principles and procedures of the electrical safety program are not being followed, appropriate revisions shall be made.”

Let’s take a look at some of the implications that arise from this new standard raises for American industry.—implications that must be addressed if a company wants to remain OSHA compliant..

Auditing is mandatory. The little word shall is crucial. The clearest conclusion we can draw from this paragraph is that the NFPA did not intend auditing as an optional exercise. No employer can afford to ignore a regular audit of their electrical safety program. (You do have a documented electrical safety program, don’t you?)

Audit frequency is flexible. With the exception of the need for annual auditing of the lockout/tagout procedure [(NFPA 70E article 120.3 (C) (3)] a company is free to set what it considers to be an appropriate frequency for its electrical safety audit. The frequency of audit is determined by “the complexity of the procedures and the type of work covered.” This seems to beg for a progressive auditing plan. Electrical procedures would be prioritized and scheduled for auditing according to the established priority. Lockout/tagout would be audited yearly, other procedures audited every other year or some other appropriate interval. Still other procedural audits might be triggered by programmed events, such as plant shutdown or the release of new safety standards.

The NFPA 70E itself is revised on a 3-5 year schedule. The release of a new revision of the NFPA 70E standard should automatically trigger an audit of the electrical safety program. Each company should ask itself, “Are our previously compliant procedures now out of phase with the new standard?” Remember that safety standards have no grandfather clause. Just because a procedure was compliant under the 2004 (or earlier) edition of NFPA 70E does not mean that it will remain acceptable under the newer 2009 edition. The changes to NFPA70E must be reflected in corresponding changes to an employer’s electrical safety policy.

As an example of how changes in NFPA 70E can influence your safety policy, the 2009 edition now requires electricians to wear an arc-rated faceshield when working within the flash protection boundary of HRC category 1 equipment. Companies that did  their arc flash analysis under the 2004 edition and have included a PPE list on their equipment labels would now find their category 1 labels to be inaccurate and in need of revision. A proper audit would have picked up this discrepancy and promoted compliance with the new standard.

Auditing is focused on behavior. It is important to remember that the electrical safety audit is not intended to investigate the employer’s policy on paper, but to examine whether the electricians and technicians who are doing the work are actually using the policy in practice. It is important that company auditing of its electrical safety policy investigate the controls by which the policy is monitored and enforced.

Auditing profits from independent eyes. Although the bulk of auditing can and should be accomplished in-house, there is a very real need for employers to have an independent auditor periodically examine its electrical safety program. Familiarity may breed contempt, but familiarity also breeds myopia. It is easy to overlook significant gaps in the electrical safety program by being so close to the project. Fresh unbiased eyes will see what may otherwise be overlooked. In addition, it is difficult for a person involved with the day-to-day management of operations to keep abreast of the latest in electrical safety standards and best practices. Periodically bringing in a safety professional to look over your electrical safety policy is simply an effective way to help ensure that a company remains both safe and compliant to the electrical safety standards..

Auditing is not comfortable, nor easy. Yet it is an essential part of an effective electrical safety program. After all, safety is the goal and auditing helps us do the best job we can of providing an electrically safe work place.

An unsuspecting electrician opens an electrical panel only to discover that he has let loose a lethally dangerous explosion—light flashes so bright that it permanently damages eyes, heat that is 4 times the surface of the sun incinerates clothing and flesh, molten shrapnel bores upon him with bullet-like speed, and a blast wave that throws him like a rag doll with a pressure wave of hundreds or thousands of pounds per square inch.

Approximately 2000 workers will be admitted to hospital burn units this year due to thermal burns from arc flash or arc blast accidents. These accidents will result in nearly one fatality every day. Although electrical injuries are relatively rare (1 in 494 lost time accidents are electrical in nature) they nevertheless result in a disproportionate number of fatalities as 1 in 20 industrial fatalities are as a result of electrical accidents.

Most of those killed or injured workers were unaware of and unprepared for the level of hazard they were facing. Because of the immensity of the risk, responsible employers recognize the need to facilitate electrical safety through performing arc flash hazard analysis on their electrical equipment.

It costs a bunch. I just don’t see that it is worth the cost and bother.

It has been estimated that an arc flash accident may cost the employer as much as a million dollars or more. Lost production, equipment repair or replacement, lawsuits, skyrocketing insurance premiums and OSHA fines can add up in a hurry. Arc flash hazard analysis is a form of risk management whose relatively small investment provides protection against the potentially huge costs of an arc flash accident.

My equipment is all installed according to the NEC. Doesn’t that guarantee that it is safe?

The NEC is intended to provide equipment installations that are safe from electrical hazards to workers in their normal working configuration. However, electricians and maintenance technicians by definition work on electrical equipment under abnormal circumstances—when they are broken, damaged, or in need of maintenance. These are the times that electrical arc flash accidents are most likely to occur. That is why OSHA asked the National Fire Protection Association (NFPA) to produce a standard providing for the safety of the worker exposed to electrical hazards. It is this standard, the NFPA 70E, that requires an arc flash hazard analysis before workers unknowingly expose themselves to potentially lethal hazards.

Hey, there’s no law that says I’ve got to do an arc flash study, is there?

It is true that OSHA regulations do not specifically require an arc flash hazard analysis. It is also true that the NFPA 70E is a consensus standard, not a law. However, OSHA can and does impose fines on companies that ignore the standards of the NFPA 70E. OSHA regulations require employers to provide workplaces that are “free from recognized hazards that are likely to cause death or serious physical harm to employees.”¹ More specifically OSHA requires that “Safety-related work practices shall be employed to prevent electric shock or other injuries [emphasis added] resulting from either direct or indirect electrical contacts. . . .”² OSHA tells employers WHAT to do, that is provide electrical safety, and the NFPA 70E is the handbook telling us HOW to accomplish it. Here is what the NFPA 70E has to say about arc flash hazard analysis: “An arc flash hazard analysis shall determine the Arc Flash Protection Boundary and the personal protective equipment that people within the Arc Flash Protection Boundary shall use.”³

The NFPA also calls for equipment labels that identify the level of hazard the electrical worker may be expected to encounter: “Equipment shall be field marked with a label containing the available incident energy or required level of PPE”⁴ An effective arc flash hazard analysis identifies these necessary pieces of information for electrical worker safety. It’s not an option, it’s the law!

¹29 CFR §1903.1

²29 CFR §1910.333

³NFPA 70E-2009 Article 110.8(B)(1)(b)

⁴NFPA 70E-2009 Article 110.3(C)