2012 Revisions to NFPA 70E

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Electrical Construction and Maintenance

Tom Zind

By Tom Zind, Freelance Writer

Fri, 2012-08-17 16:59

Injuries to workers exposed to high voltage and related electrical hazards may never be totally eliminated, but it
wont be for any lack of trying to bolster the NFPA 70E workplace electrical safety standard. Drafters of the 2012
revisions to the standard aimed again for that lofty and worthy goal, fine-tuning and updating requirements for
oversight, documentation, procedures, and systems to protect workers. Of course, whether all thats ultimately a
good thing partly depends on how one views fate, the law of averages, and whether more is better when it comes
to rules and regulations.
But the reality is that 70E, last updated in
2009, is now a more ironclad and nuanced
safety document. Those looking to it as one
way to comply with OSHA worker safety
rules will have more standards to meet and
practices to follow, not to mention clearer
guidelines on ensuring workplace electrical
safety. Employers, workers, electrical
contractors, trainers, and, to some extent,
suppliers of electrical components and
safety products will feel the effects of this
latest round of revisions to different
degrees.
While many again reflect new knowledge
and a better understanding of risks and
hazards, the vast majority of the revisions
seem to buttress the view that safety comes
down to just keeping an eye on the ball. By
carefully developing and religiously
following formal procedures and creating
a system of checks and balances to ensure
theyre carried out parties responsible for
worker safety will be better positioned to
head off potentially deadly mishaps.
The NFPA 70E Technical Committee on
Electrical Safety in the Workplace, which developed the revisions approved by the National Fire Protection
Association (NFPA), addressed that through a number of additions and clarifications of language that spell out
employer responsibilities for making work environments as safe as possible. Lets take a look at some of the most

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significant changes and how they will affect electrical professionals.

The updated 70E now calls for worker training in new areas more often with a better paper trail confirming its
been successfully carried out. Most notably, theres a new provision that employers must verify that employees
comply with 70Es safety-related work practices on an annual basis through regular supervision or inspection,
including the new arena of field work. Before, there was no set verification schedule. New content-specific
requirements for training include the use of automatic external defibrillators and in methods of releasing
victims from exposed energized parts.
At least every three years, employers must now audit the content of their electrical safety program to ensure
compliance with 70E and provide documentation. Generally, if employees fail to demonstrate safe work
practices, they must be retrained. In any event, retraining is now required at least every three years. In addition
to keeping records of who received training and when, theres a new provision for documenting the specific
content of that training.
These and other related revisions to employer responsibilities for safety are an acknowledgement that vigilance,
knowledge, and the workforce arent static conditions. Moreover, says technical committee member
DennisNeitzel, director emeritus of AVO Training Institute, Inc., Dallas, with OSHA focused more than ever on
training and ensuring that its not just an afterthought, employers will want to make sure theyre able to
demonstrate that employees are fully trained and qualified, capable, and safety conscious when working around
electricity.
OSHA does enforce documentation, and their attitude generally is that if it hasnt been documented, it didnt
happen, he says. We didnt make these changes for that reason only; our main objective was to find a way to
make sure that these things get done through audits and retraining. The new requirements and time constraints
will mean more paperwork, time, and investment, but standards change and revisions and updates need to be
accounted for.
Along the same lines, the new standard also now calls for host employers to have a formal meeting with
contractors brought in to work on electrical equipment and systems. The aim, says Tom McCauley, president of
Consolidated Consulting Corp., an electrical engineering consulting firm headquartered in Vero Beach, Fla., is to
review workplace-specific hazards/risks and the game plan for addressing them.
The contract between the facility and the contractor can be a tricky thing where each has their own
procedures, he says. This documented meetinghelps make sure that both are on the same page on whats in the
plant and what the dangerous parts of the plant might be. Its an acknowledgement that accidents can happen
when theres not good communication.
Clearly, enhanced vigilance of this sort will come at some sort of cost to responsible parties. Whether theyre able
and willing to come into compliance on their own or seek outside assistance, employers and other service
providers will likely find themselves spending more time building a bigger margin of worker safety into their
operations. Ultimately, that amounts to a good investment, saysDarynLewellyn, president
ofLewellynTechnology, a Linton, Ind.-based electrical safety and maintenance training company thats been
ramping up staff and resources to answer calls for compliance assistance.
I think addressing points like the three-year limit on retraining and the audit of the safety program will make
people take more notice of the need to do things properly, he says. Hiring an outside consulting firm may be
necessary with the need now to look at every aspect of electrical safety from training and training

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documentation to plant and equipment walkthroughs to checking on PPE [personal protection equipment]
inventories.

While worker competence and training are vital to safety, their importance is a function of the base safety level
of the working environment. The 2012 edition of 70E adds and refines language across the standard that adds
more clarity to how workplaces can and should ensure that workers encounter the fewest conceivable risks and
hazards.
To reiterate the preferable safety advantages of working in a de-energized environment, whenever possible, a
revision at the beginning of Sec. 130.1 Electrically Safe Working Conditions clarifies the necessity of first
justifying the need for energized work. Added language here states energized conductors or circuit parts a
worker might be exposed to should be made safe prior to work beginning if the worker is within the limited
approach/arc flash boundary. The main effect of the new language, which does allow for exceptions if arc flash
risks are gauged acceptably low via a hazard identification and risk assessment procedure, is to emphasize the
need for up-front establishment of a full justification for working energized,Neitzelsays.
We put the wording in a certain order because of the need for establishing the foundation for energized
electrical work and the basis for an energized work permit, he says. This offers the best protection for workers
by giving employers every opportunity to de-energize before they even start talking about energized work. They
have to prove thats the only way to do it.
WhileNeitzelsays statistics do seem to suggest that less energized work is being done due perhaps to greater
awareness of 70E the additional clarity in the 2012 edition could prompt more workplaces to look for
opportunities to make de-energized work more feasible and commonplace.

In another bid to reiterate the importance of looking to Art.130 for guidance on ensuring a safe workplace, the
committee tweaked language that was leading to misinterpretations of the applicability and importance of the
articles specific protection requirements in different scenarios.
One of the most significant changes is that while there are two general ways to do a hazard analysis one by
doing incident energy calculations and the other by using hazard/risk category tables a lot of people think the
tables are independent of the rest of the requirements of Art. 130, says Palmer Hickman, director of code and
safety training and curriculum development for the National Joint Apprenticeship and Training Committee
(NJATC) and a member of the 70E technical committee. The tables might appear to conflict with requirements
outside the tables. New language makes clear that the tables dont operate in a vacuum and are not independent
of the rest of the requirements.
For example, guidelines in the text
of Art.130 on the use of an
arc-rated balaclava indicate theyre
required when the back of the head
is within the arc-flash boundary,
notes Hickman. Theres no such
reference to the need for such
protection for hazard/risk Category

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1 when the back of the head is

within the arc-flash boundary. Too
many folks who open up 70E and
look at the tables for guidance
wouldnt get that, he says. You
often need to look deeper than just
the tables.
Concern that greater reliance on
quick and dirty HRC table misuse
was unintentionally elevating risk
also led to changes in how
information is presented. Short
circuit current, fault clearing time,
and potential arc flash boundary
information have been moved from
table notes into the major
equipment categories.
That brings the information more
to the forefront for people to see
and hopefully pay attention
to,Neitzelsays.
In a related change, information on arc flash warning labels is now more definitive in addressing what types of
protection are needed for different types of work as well as potential exposures and how that is to be calculated.
Someone cant just go to the tables and take it at face value as to whats going to be used,Neitzelsays. You will
have to have done a short circuit analysis and protective device coordination studies to know whether you can
even use the tables. It needs to be proven and documented now to validate the chosen PPE that is stated on the
label.

Generally, PPE got a much closer look from reviewers, and that resulted in a few notable changes in language
addressing protective ratings and suitability in different exposure scenarios. In substituting references
throughout 70E to flame-resistant (FR) PPE with arc-rated, reviewers sought to clarify the important
difference between the two in the nature and level of protection. Transitioning to arc-rated terminology began
with the 2009 revisions and was carried over to the 2012 edition, which included dropping (FR) completely to
ensure employers were fully aware of the possible implications of selecting the wrong types of PPE.
Weve too often found that procurement officers tend to go with cheaper PPE that may be flame-resistant but
has no arc rating,Neitzelsays. In the 2012 revisions, we eliminated the term flame-resistant (FR) completely so
there wouldnt be any confusion. We want to ensure that workers are adequately protected with PPE made from
fabrics that protect against both incident energy and the flash-flame hazards.
The 2012 revisions also seek to increase the margin of safety afforded by PPE in some scenarios. Of particular
note, a requirement for hearing protection (ear canal inserts) within the arc flash boundary has been spelled out,
and a balaclava is now required for Category 2 tasks defined in the HRC tables, a result of the removal of the
distinct 2* category that required a balaclava as a supplement to a hard hat and face shield. Larry Ayer, vice

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president of Biz Com Electric, Cincinnati, and a technical committee member, rates that change as significant in
that its evidence of 70Es steadily greater recognition of the need for proper and adequate PPE.
The balaclava now applies in more instances, even for less hazardous tasks, he says. The committee was
concerned that Category 2 PPE requirements left the back of the head exposed. So a contractor cant just put on
a face shield in those situations. As a contractor, the way I see it is the more protection, the better.
PPE, combined with proper training, goes a long way to minimizing risk and mitigating hazards workers may
encounter, and the new 70E clearly addresses that in a more robust fashion. But arming workplaces and
workers with clear and reliable information on risks and hazards posed by working on electrical equipment is an
essential first step. The 2012 revisions seek to address this goal with not only more definitive equipment labeling
requirements but also clearer guidelines on the importance of properly maintaining and monitoring equipment
that workers routinely encounter.

Thus, a revised requirement in Art.130 spells out more clearly how switchboards,panelboards, control panels,
and like equipment must be labeled with critical information needed to gauge and mitigate potential risks and
hazards. Now, a label must include nominal system voltage and the arc flash boundary, as well as at least one of
the following: available incident energy level, minimum arc rating of clothing, required level of PPE, or highest
hazard/risk category for the equipment.
Many of the arc flash equipment labels installed today are incorrect because they include both an incident
energy level and an HRC level, which can be confusing since only one method should be used, Ayer says.
According to McCauley, the new, more definitive labeling requirement reflects the reality that accurate risk and
hazard assessment on different equipment in different settings can be challenging. Thats a problem
compounded by 70Es historic allowance of numerous calculation methods that would benefit from greater
clarity and specificity.
In the past, the practice was to put incident energy information on the label, but the reality is that can change
all the time depending on the configuration of a plants systems, he says. Something may be classified as, say,
a Category 3, but theres a range on that.
Because accurate and reliable labels depend on precise engineering assessments of equipment, which over time
can fall into disrepair that might render original calculations inaccurate, the 2012 edition codifies the
importance of maintenance.Specifically, new language in Art.205 states that to minimize the risk of failure and
exposure to hazards, electrical equipment must be maintained in accordance with manufacturers instructions
or industry consensus standards.
Committee member RonWidup, president ofShermcoIndustries, a Dallas electrical power system testing
company, says the new, pointed reference to a maintenance standard is evidence of growing recognition in the
industry that worker safety is a function of proper maintenance.
Calculation of incident energy exposure and specification of the proper PPE is premised on an engineering
analysis either IEEE 1584 or 70E guidance, and its all based on the assumption that the relay, fuse, or circuit
breaker has been installed and maintained properly,Widupsays. But if anovercurrentprotective device or panel
hasnt been tested in years, you have to ask yourself what the chance of the arc flash hazard analysis label on the
equipment being accurate is. Over the next few cycles of 70E revisions, I think were going to see more focus on
the maintenance aspect because its key to the validation of the engineering assessments designed to protect
workers.

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Zindis a freelance writer based in Lees Summit, Mo. He can be reached at tomzind@att.net.
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