by Tim Rohrer
President, Exiscan IR WIndows

 

 
As seen in UpTime Magazine; Oct/Nov 2011

The Evolution of a Standard

Standards can be thought of as an evolution. Generally speaking any standard is a series of compromises between those who are attempting to change standard practices to reflect advancements in technology or knowledge, and those attempting to maintain some version of the status quo. A friend of mine who introduced me to the standards process, compared it to sausage making -- “a pretty ugly process to watch, but the end-product can be quite good.” 

 

NFPA 70E-2012, will be the ninth edition of the electrical safety standard since its inaugural publication in 1979. This revision cycle evaluated and weighed 500 proposals for changes to the 2009 document, and then considered over 400 comments on those proposals. The process is driven by these proposals and corresponding comments that are submitted by interested parties like you and me. So, after this new revision is published, take some time to digest it, and then fill out the Document Proposal Form in the back of the standard to propose any changes you would like to see in the next edition.

 

This document is intended to be an overview of many of the likely changes that you will see in NFPA 70E-2012. The changes noted are based on the 70E Technical Committee’s Report on Comments document from the ROC meeting in Savannah,Georgia, last September, 2010. Please keep in mind that actual changes to the standard could be different than those listed herein, depending on input received during the June 2011 Association Technical Meeting. 

 

Note: the section numbers referred to in this document are based on 70E-2009. The clauses discussed herein may be numbered differently due to additions and subtractions in the revision, and some clauses have been moved to different sections of the standard. Furthermore, the author has taken some degree of license to add emphasis with bolding and italicizing that may not be reflective of the way those passages appear in the actual standard(s).

 

Scope

Changes to the Scope [90.2(A)] clarify that the standard relates to “work practices,” while it also adds “inspection” to to the list of covered tasks (installation, operation, maintenance and demolition). The broader language “also includes safe work practices for employees performing other work activities that can expose them to electrical hazards.”

 

Electrical Safety-Related Work Practices

Using the philosophy “if it isn’t documented, it never happened,” 70E-2012 has added several requirements for documentation and record keeping. The first such requirement will be for documentation of the meetings required between host employer and contract employees [110.5(C)]. 

 

Training and Observation: 

Training documentation has included the trainees’ names, and the training dates. Employers will now be required to also record the “content of training” related to the standard [110.6(E)].  

 

The 2009 requirement for first aid and CPR training for “employees exposed to electrical hazards” [110.6(C)] will be broadened to include “those employees responsible for taking action in case of emergency.” This change was made in consideration of sites with trained first responders on-site. Training will now also include the proper use of an AED (Automatic External Defibrillator). Statistics show that when AED is properly administered within 3 minutes after the heart has stopped, survival rates are as high as 74%, versus just 5% without AED.

 

New language mirroring OSHA 29 CFR 1910.269(a)(2)(iii) has been added under the training of qualified employees [110.6(D)(1)(f)], mandating employers to  “determine through regular supervision and through inspections conducted on at least an annual basis that each employee is complying with” the standard. Additionally, retraining will now be required on at least a three-year interval [110.6(D)(3)(d)]. This change is in keeping with typical/anticipated revision cycle of the standard.

 

Electrical Safety Program

Just as an electrical safety program and procedures [110.7(E)] have been required for work performed inside the Limited Approach Boundary (LAB), this requirement has been extended to work performed within the Arc Flash Boundary (AFB) as well. Similarly, the requirement for a Hazard Identification and Risk Assessment [110.7(F)] will now be extended to work performed within the AFB as well. And in keeping with the theme, the requirement restricting testing, troubleshooting, voltage measuring, etc. to qualified persons [110.9(A)/130.4], will apply not only to work done inside the LAB, but also the AFB.

 

The term “Hazard/Risk Evaluation” has been changed to hazard identification, and risk assessment. This change was generally carried through most parts of the standard. The basic logic being that the hazard is consistent regardless of a worker’s interactions within a given application, and should therefore be identified. However, the risk of triggering an incident is higher or lower based on several factors including personnel tasks and interactions with the equipment -- therefore, the level of risk should be assessed for each given situation.

 

Job briefings [110.7(G)(1)] will now be required to include the information on the Energized Electrical Work Permit (if such permit is required). This was a logical addition -- why bother with the paperwork and documentation if the information is not going to be shared with everyone exposed to the hazards?

 

Due to the important role that audits play in any continuous improvement plan, program audits [110.7(H)] will now be required at least every three years -- previously, this interval was left up to the employer. Additional requirements for auditing field work, and for documentation of audits were also added.

 

Portable Tools and GFCI

Working with GFCI Protection Devices [110.9(C)] received a full re-write. Workers will be required to use GFCI protection not only when required by local, state and federal codes and standards, but also when the worker “is outdoors, and operating or using cord and plug connected equipment, supplied by 125V; 15-, 20-, or  30-ampere circuits.” When using equipment connected to other voltages/amperages, an “assured equipment grounding program shall be implemented.”

 

An informational note (“informational notes” have replaced “Fine Point Notes” in the latest revision) has been added [110.9(B)(3)(d)] to the section dealing with the use of portable electrical equipment in conductive locations. The hazard identification and risk assessment procedure “could also include identifying when the use of portable tools and equipment powered by sources other than 120 volts AC, such as batteries, air, hydraulics, etc. should be used to minimize the potential for injury from electrical hazards for tasks performed in conductive or wet locations.” In fact, their justification (in the ROP document) for adding the note, called the use of corded electrical tools/equipment “a last resort” in such environments.

 

Underground Electrical Lines and Equipment

A new section providing guidance on excavation has been added to the end of section 110. “Before excavation starts and where there exists reasonable possibility of contacting electrical or utility lines or equipment, the employer shall take the necessary steps to contact the appropriate owners or authorities to identify and mark the location of the electrical lines or equipment. When it has been determined that a reasonable possibility for contacting electrical lines or equipment exists, a hazard identification and risk analysis shall be performed to identify the appropriate safe work practices that shall be utilized during the excavation.”

 

LOTO

The permissible lockout/tagout (LOTO) controls [120.2(C)(2)/(D)(1)] have been changed, eliminating the “individual employee control” method. The 2012 revision will only allow simple and complex LOTO methods. 

 

Electrically Safe Work Conditions

Section 130 now starts with a general statement that “all requirements of this article shall apply whether an incident energy analysis is completed or if the tables 130.7(C)(9) and (C)(10) are utilized in lieu of incident energy analysis.” This should clarify the confusion among some table-users who would overlook the other requirements of Section 130 such as energized work permits, etc.

 

Users will also notice that “Justification for Work” [130.1] has been retitled “Electrically Safe Work Conditions.” This subtle change emphasizes that deenergization is the preferred defense against electrical hazards, as prescribed in both 70E, OSHA 1910 and virtually every electrical safety regulatory document throughout the industrialized world. Also, where the standard had previously only required a deenergized state or “electrically safe work condition” when working inside the LAB, the same requirement now exists even when “conductors are not exposed, but an increased risk of injury from arc flash exists.”

 

Energized Electrical Work Permits

EEWPs (Energized Electrical Work Permits) [130.1(B)(1)] will now be required “when working w/in LAB or AFB of exposed energized conductors or circuit parts.” This change tightens up the previous language: “when working on energized electrical conductors or circuit parts…”

 

EEWP documentation will also require additional details regarding all boundaries and PPE and other protective equipment to be used to protect workers from shock and effects of arc flash.

 

DC Approach Boundaries

The new revision will provide some much needed guidance to DC system users: approach boundaries for DC systems will now be listed in a chart similar to the AC Approach Boundaries Table [130.2(C)]. Additionally, users of the HRC Classification Table [130.7(C)(9)] for AC systems, will notice a similar table has been set up for DC systems, and will be located immediately following the AC table.

 

Arc Flash Analysis

The word “Protective” has been removed from the “Arc Flash Boundary” since there is nothing inherently “protective” about the boundary. 

 

The exemption for 240V systems [130.3] in the 2009 revision was based on IEEE/ANSI 1584. But this section has been widely misinterpreted and is also likely being clarified within the 1584 standard. This exemption will be reworded and moved to an informational note: “An arc flash hazard analysis may not be necessary for some 3-phase systems rated less than 240 volts. See IEEE 1584 for more information.” 

 

An informational note has also been moved to this section from the HRC Classification Tables [130.7(C)(9)]. The note warns that available arc flash energies may be higher than expected if current levels, or clearing times, are other than anticipated. The relocation of this statement is significant because the referenced increase in energy levels will occur regardless of whether one is using the incident energy calculation or the table methods of determining PPE (Personal Protective Equipment) and approach boundaries.

 

Users will notice a shift throughout the document from “Flame-Resistant” or “FR” to “Arc-Resistant” or “AR.” This simple change should help to protect workers from the few unscrupulous manufacturers. Unfortunately, certain manufacturers have been promoting  PPE that complies with FR standards for curtains or other irrelevant products, rather than for PPE. 

 

The definition of the arc flash boundary [130.3(A)] has been simplified, eliminating the “Four-Foot Rule” for low voltage applications. The new text will read: “The Arc Flash Boundary for systems 50V and greater, shall be the distance at which the incident energy  equals 5 J/cm² (1.2 cal/cm²).” Users of the table method, will find guidance on AFB distances imbedded into the actual tables.

 

Labeling

Labels used to require “incident energy calculations or required level of PPE.” This section has been expanded, giving workers more information to conduct their work more safely. “Electrical equipment such as switchboards, panelboards, industrial control panels, meter socket enclosures and motor control centers that are in other than dwelling units, and that are likely to require examination, adjustment, servicing or maintenance while energized shall be field marked with a label containing all the following information:”

     1. At least one of the following:

       a. available incident energy and the corresponding working distance

       b. minimum arc-rating of clothing

       c. Required level of PPE

       d. Highest Hazard/Risk Category (HRC) for the equipment

     2. Nominal system voltage

     3. Arc flash boundary

 

An exception has been provided for labels that complied with the previous requirements, and were applied prior to September, 2011. It also requires documentation of “the method of calculating and data to support the information for the label.”

 

Personal and Other Protective Equipment

A new information note has been added [130.7(A)], relocated largely from the definition for Arc Flash Hazard in the 2009 revision. The note states: “it is the collective experience of the Technical Committee on Electrical Safety in the Workplace that normal operation of enclosed electrical equipment, operating at 600 volts or less, that has been properly installed and maintained by qualified persons is not likely to expose the employee to an electrical hazard.”

 

Factors in Selection of Protective Clothing [130.7(C)(12)], removed language suggesting that PPE “will normally be used in conjunction with each other as a system…” The committee also added the following very important change: “Garments that are not arc-rated shall not be used to increase the arc rating of a garment or clothing system.” 

 

Hearing Protection [130.7(C)(#)]: Hearing protection is now required when working within the AFB. This requirement is now consistent with the 130.7(C)(10) table, which requires the use of hearing protection (inserts) for all HRC levels (2009). Recent research shows that arc blasts can exceed the 140dB OSHA limit, generating sound  levels similar to that of a gun shot, and exceeding those produced by a jet engine.

 

Face Protection [130.7(C)(13)(b)]: When inside the AFB, and anticipated exposure is 12 cal/cm² or less, employees will now be required to wear either an arc-rated balaclava with an arc rated, wrap-around style face shield (protecting face, chin, ears, forehead and neck), or an arc rated hood -- like that used in an arc-flash suit. But when anticipated incident energy exposure is greater than 12 cal/cm², then an arc-rated hood will now be required.

 

Hand Protection [130.7(C)(13)(c)]: “Heavy duty leather gloves or arc rated gloves shall be required for arc flash protection.” An information note has been added, defining heavy duty leather gloves as at least 0.03” thick, unlined or lined with non-flammable, non-melting fabric. This style of leather glove has been shown to provide 10 cal/cm² ATPV or better. Additionally, the information note regarding insulating rubber gloves [130.7(C)(13)(c)], received a makeover. Verbiage regarding layered FR material, HRC levels and shrinkage has been eliminated, leaving simply “The leather protectors worn over insulating rubber gloves provide additional arc flash protection for the hands for arc flash exposure.” Clarifying and simplifying this section is important because hands are often exposed to the highest levels of incident energy, since they are often closest to the point of arc origination, and considering the research showing how effective this “low-tech” solution has been in saving countless workers the use of their hands. 

 

The 2012 edition will also provide users with a table in Annex H, matching PPE and clothing requirements to results from an arc flash hazard analysis. This is similar to the concept of the 130.7(C)(10) table that defines the PPE and Clothing required for HRC level, which was often mis-applied in the field. This action re-affirms the committee’s stance that a facility that has performed an arc flash hazard analysis should not be using the tables associated with HRC values. Instead, those facilities should rely on the incident energy calculations and approach boundaries defined by their study -- the more thorough and accurate manner of defining hazard levels. 

 

Users of simplified, two-level PPE systems (8 cal/cm² & 40 cal/cm²) will also find new guidance in Annex H for PPE selection when working on low-voltage systems and high-voltage systems with known short-circuit clearing times.

 

HRC and PPE Related Tables

The Standards on Protective Equipment Table, and the corresponding section [130.7(C)(8)] will now follow the details regarding PPE requirement and care. Similarly, the famous HCR Classification Table [130.7(C)(9)] and the corresponding sections and tables matching PPE and HRC levels [130.7(C)(10)], and PPE Characteristics with HRC levels [130.7(C)(11)], will now be located at the end of the PPE section [130.7(C)].  The positioning of these tables will assist with the flow and usability of the section, and further limit confusion between the arc flash calculation method and HRC table method. One common mis-use of the standard has been the mixing and matching of the two methods -- they are intended to be an “either/or” proposition.

 

Some table footnotes and other critical information have been moved from the back of the HRC Classification Table [130.7(C)(9)] into the body. This change should help to highlight the characteristics of the systems to which the table applies. That information was easily overlooked in the previous revision but is critical given the standard’s direction that “for tasks not listed, or for power systems with greater than the assumed maximum short circuit current capacity or with longer than the assumed maximum fault clearing times, an arc flash hazard analysis shall be required…” Translation, if you are working on a system other than that indicated in the tables, then the HRC Classification table is not an appropriate tool.

 

Information now contained at the heading of each system class will include:

• Available short circuit current
• Maximum fault clearing time
• Working distance
• Arc Flash Boundaries

Table users who work on “Panel Boards and Other Equipment Rated >240V and up to 600V with molded case or Insulated Case Circuit Breakers” will notice three new job tasks:

• Removal of Bolted Covers… HRC 1, insulated gloves and hand tools not required
• Opening Hinged Covers… HRC 0, insulated gloves and hand tools not required
• Removal/installation of CBs or fused switches … HRC 2, and requires insulated gloves and hand tools

The committee has eliminated the HRC 2* classification [130.7(C)(10)]. Face protection has been upgraded so that HRC 2 is the same as HRC 2*. Now, performing HRC 2 tasks will require either the use of an “arc-rated arc flash suit hood, or an arc-rated face shield and arc rated balaclava.” 

 

New requirements for arc-rated hardhat liners have been added as well: “As Needed” (AN) for HRC 1 and 2; and “As Required” (AR) for HRC 3 and 4.

 

Overhead Lines

Personnel who work in the vicinity of overhead lines will sometimes mistake protective guards for insulation, and consequently put themselves and co-workers in grave danger. The standard will help to further protect such workers with the addition of the following requirement: “A qualified person shall determine if overhead electrical lines are insulated for the lines’ operating voltage” [130.5].

 

General Maintenance Requirements 

The standard will now include a statement that further underscores the importance of proper maintenance practices as a vital and ongoing safety measure. The new section [205.3] will read: “electrical equipment shall be maintained in accordance with manufacturer's instructions or industry consensus standards to reduce the risk of failure and the subsequent exposure of employees to electrical hazards.” 

 

Again, we see additional requirements added to improve record keeping and documentation: Single line diagrams [205.2] will now be required to be kept current and legible. And, the maintenance, tests and inspection of overcurrent protective devices will need to be documented. 

 

The Rest

Many additions, clarifications and changes were made to Safety Requirements to Batteries and Battery Rooms [320], and throughout the annexes: Most notable are the significant re-writes to Annex F: (newly titled) Hazard Identification & Risk Assessment; and Annex H: (newly titled) Guidance on Selection of Protective Clothing and Other Personal Protective Equipment. Both will contain considerably more direction and detail on their topics. 

 

The Future of the Electrical Safety

In the case of NFPA 70E, many of the changes through the years have been based on research presented at venues like the IEEE Electrical Safety Workshop (ESW). It is the stated mission of this conference to “change the culture of electrical safety.”

 

If you want to see the future of electrical safety and the related standards, join us in Dayton Beach in January 2012 for the next ESW. There you will see the future of electrical safety standards, practices and technology. You will also be able to meet many (if not most) of the members of the 70E committee.

 

In Conclusion
The 2012 edition of NFPA 70E is packed with too many changes to list in their entirety here. For a more in-depth look into these changes as well as the logic behind the proposals and the committee’s acceptance (or rejection) thereof, the reader should download the ROP and ROC reports from the NFPA 70E website (under the “Next Edition” tab). It is a great way to education yourself on the evolution of the standard. 

 

I was fortunate enough to attend the Report on Comments (ROC) Meeting in Savannah, where most of the final revisions were debated and voted upon. I came away with an appreciation for how thoughtful and deliberate the process is. Yes, it had its sausage-making moments; but by and large it was an impressive, regimented process that will again yield a standard that will continue to be the model for the rest of the world. 

 

 

 

About the Author:

Tim Rohrer is President of Exiscan, LLC -- Manufacturer of electrical safety products like infrared windows. He was a guest at the NFPA 70E ROC meeting that finalized most of the changes for the 2012 revision. He is very involved with several electrical safety standards committees, including CSA Z462, IEEE 1584, IEEE 1814, IEEE 1683. Mr. Rohrer is a Level 2 Thermographer who has been involved in the Maintenance and Reliability community for most of the past decade.