The 2015 changes to the NFPA 70E electrical-safety standard include new perspectives on maintenance, use of PPE, and terminology—all of which could have an impact on your operation.
By Rick Carter, Executive Editor
Electrical-safety standards turn up regularly on OSHA’s Top 10 List of “Most Frequently Cited” violations each year. On the current list, dated October 2014, electrical standards hold three of the 10 positions:
- #6 — Lockout/Tagout (1910.147)
- #8 — Electrical, Wiring Methods (1910.305)
- #10 — Electrical, General Requirements (1910.303)
Go back one or several years and you’ll see much the same lineup; only the order changes slightly (though the Fall Protection standard, 1926.501, often leads). To many, this bewildering repetition of rule breaking is akin to failing an open-book test when all questions and answers are fully provided beforehand. How does it happen?
OSHA outlines its violations online at osha.gov, but these terse reports do not address causes. Rather, they highlight the hazard violation: unexpected energization, working near live equipment without training, exposure to electrical shock hazards, and unguarded parts of live electrical equipment. These alone encompass a “who’s who” of what can go wrong in a plant when the focus on safety wavers. They also paint a disturbing picture of the poor safety condition in which plants can sometimes find themselves.
Standard rules, inconsistent adherence
“It really depends on the facility,” said Tim Rohrer, president of Exiscan LLC, a New York-based manufacturer of inspection windows for electrical equipment. “Some are right on the edge of electrically safe work practices and others are woefully behind.”
Rohrer spoke with Maintenance Technology following his presentation on the 2015 changes to the NFPA 70E Standard for Electrical Safety in the Workplace at a recent industry conference. The changes to this go-to standard (outlined in detail last month in Maintenance Technology), represent the latest industry effort to clarify electrical-safety procedures and help make industrial operations safer.
Rohrer suggested that the updating process, in which he participates, can seem like an uphill battle in some cases. “Sadly, some of those companies that are way behind might think they’re complying with 70E,” he said, “but they don’t even own a copy of the standard. In many cases they are just going off of bits and pieces they’ve picked up along the way.” This can lead to multiple electrical-safety shortcomings in key areas, such as failure to use personal protective equipment (PPE), allowing work to be done on energized equipment, and others, as OSHA’s list confirms.
Updated every three years through a four-step process that includes significant public input and review, NFPA 70E now features a greater emphasis on the role maintenance plays in the safe operating condition of electrical equipment. “Maintenance is now front and center,” said Rohrer. “It always has been, but it is more so in the latest revision; it’s referred to more often and more pointedly. For example, when a worker goes up to the equipment, they really have to bear in mind the condition and maintenance of the equipment they’ll be working on. This is pretty huge.”
NFPA 70E 2015, Article 200 states that the equipment owner is responsible for the maintenance of its electrical equipment and documentation of same. This clarification—a responsibility that might have been assumed before—is now spelled out. It reflects one goal of the changes and revisions, which is to leave less chance for either willful or accidental misinterpretation. According to Article 210.5, maintenance is now a focus because “improper maintenance of protective devices can result in increased clearing times, which thereby results in higher incident energy.”
Because of the added emphasis on the condition and maintenance of equipment, it’s Rohrer’s opinion that “if there is an accident and OSHA comes on site, and they decide a person was injured because the equipment was improperly maintained—which is stated pretty clearly in several different ways—this becomes something OSHA can start to look at.” So, whether other causes are ultimately determined to have caused an electrical accident or not, your maintenance procedures may be reviewed anyway, with deficiencies noted and, if necessary, your company fined accordingly. (For the record, OSHA does not have a direct role in creating 70E language, but does provide input through a voting member on the 70E Technical Committee.)
What kind of maintenance are we talking about? It encompasses several areas, from proper labeling and inspection procedures to testing and/or installation procedures for at least the following components:
- Circuit breakers
- Protective relays
- Substations, switchgear assemblies, panel boards, motor control centers, disconnect switches
- Transfer switches and control equipment
- Motors and generators
- Equipment in hazardous locations
- Batteries and battery rooms
- Portable electric tools and equipment
- Personal safety and protective equipment, including electrical gloves, hot sticks, and flash suits.
The safety goal
Preventing electrical accidents generally means taking the steps necessary to protect workers from shock and to prevent arc flash, the damaging explosion that can occur when high energy meets low resistance. If you’ve never seen what an arc flash looks like, several examples are available for viewing online. Watching just one can give you the best reason yet to ensure your plant’s electrical-safety program is everything it should be, which is also a goal of NFPA 70E 2015.
Interestingly, along with 70E’s added maintenance emphasis is another change that involves the use of personal protective equipment with regard to arc flash. “In the 2015 edition, arc-flash PPE is not required for normal operation of equipment if equipment is properly installed and maintained, all doors and covers are secure, and there is no evidence of impending failure,” said Daleep Mohla, principal consultant with Missouri City, TX-based DCM Electrical Consulting Services Inc.
A longtime contributor to IEEE (Institute of Electric and Electronics Engineers) Standards Association Working Groups, and considered an expert on 70E, Mohla currently specializes in 70E training.
Mohla added that “70E also made a major strategy shift in its new approach to electrical-hazard mitigation. Until the 2012 edition, mitigation was based on hazard. In 2015, mitigation is based on risk and risk assessment. It requires stakeholder evaluation and recognition of possible consequences to decide on the acceptable risk and mitigation.”
According to Rohrer, it’s important to know the difference between “hazard” and “risk.” While a hazard is considered “a source of possible injury or damage to health,” he said, the more broadly defined risk “refers to a combination of both the likelihood of injury occurrence and the severity.”
To that end Rohrer suggested that companies and employees consider the hierarchy of risk-control methods (as it appears in ANSI/AIHA Z10 and in NFPA 70E), noting that the most effective controls are featured at the top:
- Hazard elimination
- Engineering controls
- Administrative controls
In this hierarchy, the most valuable action a plant can take—hazard elimination—means de-energization of the equipment. “It’s epidemic that companies are working on energized equipment when they could be shutting down,” said Rohrer. “Whether they’re using PPE or not, the first real prime directive of 70E and any electrical-safety standard is to de-energize whenever possible.”
Electrical-safety programs at world-class operations, he said, routinely prohibit working on energized equipment unless other options don’t exist. “Companies on the leading edge of electrically safe work practices have a policy of not working live,” said Rohrer. “They simply don’t work energized. The first thing they do is de-energize. Yes, there are instances where something absolutely has to be done energized. Certain diagnostics, for example, need to be done while the gear is energized. But, aside from that, they’re de-energizing.”
To be clear, said Rohrer, even after the power to equipment is shut off, “the equipment is still considered energized until you prove it otherwise. So you still have to use your PPE and go in and do a visual inspection, apply your lockout/tagout devices, and then use your meter to prove that it has, in fact, been de-energized. Then you have to lock it out and tag it out.” But he believes that choosing to de-energize is a critical first step in assuring electrical safety.
Naturally, seeking this high level of safety can cause problems when the need to de-energize equipment or shut down lines conflicts with operations’ need to keep things running. This is where planning and scheduling becomes vital. Coordinating shutdowns not only simplifies the process of completing electrical work, it helps avoid the debate that can crop up over the need to de-energize in the first place, a situation that can lead to confusion over standards and poor safety practices.
“There is an infeasibility clause that states you can work on energized gear if it’s infeasible to do the work de-energized,” said Rohrer. “But shutting down a line so you can safely perform work is not infeasible, it’s inconvenient, and a lot of plants mistake the two. They often claim that it’s infeasible to shut down this line to do that work, when, in fact, it’s not. Infeasible means it can’t be done any other way,” Rohrer concluded.
With electrical-related hazards, violations, and injuries showing no sign of letting up, standards groups—and OSHA—are devoting more time and effort to the promotion and enforcement of electrical safety. To keep your operation safe and up to date, ensure that your maintenance team is familiar with key information sources such as osha.gov, nfpa.org, ieee.org, and cdc.gov/niosh. Also make sure that electrical contractors and outside service providers understand how 70E and other key electrical-safety rules fit in with your operation’s exact needs. MT
Best Practices For Complying With NFPA 70E
- Design inherently safe work practices
- Preventive maintenance
- Arc-flash risk assessment
- Labeling and hazard communication plan
- Design and methods review
- Accurate single-line diagrams
- Short-circuit and coordination studies
- Electrical-safety program review and development
- Arc-flash training program and PPE plan development
- Periodic reviews.
Source: Emerson Network Power, Electrical Reliability Services; Exiscan LLC, 2015.