By Tim Rohrer
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 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 article offers an overview of many of the likely changes you will see in NFPA 70E-2012. The changes noted are based on the 70E Technical Committee’s Report on Comments (ROC) document from its meeting in Savannah, Georgia, in 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, or some clauses 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).
Changes to Scope 90.2(A) clarify that the standard relates to “work practices,” while it also adds “inspection” 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, added to Section 110.5(C), will be for documentation of the meetings required between host employer and contract employees.
Training and Observation
Training documentation has included the trainees’ names and the training dates. Section 110.6(E) will now require employers to also record the “content of training” related to the standard.
The 2009 requirement for first aid and CPR training for “employees exposed to electrical hazards” in Section 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 the premises. Training will also now include the proper use of an Automatic External Defibrillator (AED). Statistics show that when an AED is properly administered within three minutes after the heart has stopped, survival rates are as high as 74% versus just 5% without an AED.
New language mirroring OSHA 29 CFR 1910.269(a)(2)(iii) has been added under the training of qualified employees in NFPA Section 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, Section 110.6(D)(3) (d) will be changed to require retraining on at least a three-year interval. This change is in keeping with the typical/anticipated revision cycle of the standard.
Electrical Safety Program
Just as an electrical safety program and procedures outlined in Section 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 in Section 110.7(F) will now be extended to work performed within the AFB as well. And in keeping with the theme, the requirements in Sections 110.9(A) and 130.4 restricting testing, troubleshooting, voltage measuring, etc. to qualified persons will apply not only to work done inside the LAB, but also the AFB.
In addition, 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 in Section 110.7(G)(1) will now be required to include the information on the Energized Electrical Work Permit (if such a permit is required). This was a logical addition when you consider why paperwork and documentation was needed in the first place if the information was not being shared with everyone exposed to the hazards.
Due to the important role that audits play in any continuous improvement plan, program audits under Section 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 documentation of audits were also added.
Portable Tools and GFCI
Working with Ground Fault Circuit Interrupters (GFCI) Protection Devices received a full rewrite in Section 110.9(C). 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 information note (IN) (“INs” have replaced “fine print notes” in the latest revision) has been added to Section 110.9(B)(3)(d) 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 for adding the note - as stated in the Report on Proposals (ROP) document - called the use of corded electrical tools/equipment “a last resort” in such environments.
Underground Electrical Lines and Equipment
A new segment providing guidance on excavation has been added to the end of Section 110. It reads: “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.”
The permissible lockout/tagout (LOTO) controls in Sections 120.2(C)(2) and (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 in Sections 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” in Section 130.1 has been retitled “Electrically Safe Work Conditions.” This subtle change emphasizes that de-energization is the preferred defense against electrical hazards, as prescribed in both NFPA 70E, OSHA 1910 and virtually every electrical safety regulatory document throughout the industrialized world. Also, where the standard had previously only required a de-energized 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
Energized Electrical Work Permits (EEWPs) under Section 130.1(B)(1) will now be required “when working within 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 Personal Protective Equipment (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 direct current (DC) system users. Approach boundaries for DC systems will now be listed in a chart similar to the alternating current (AC) approach boundaries table in Section 130.2(C). Additionally, users of the HRC classification table for AC systems in Section 130.7(C)(9) 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.
In addition, the exemption for 240V systems under Section 130.3 has been reworded. In the 2009 revision, the exemption was based on IEEE/ ANSI 1584. But this section has been widely misinterpreted and is likely being clarified within the 1584 standard. The reworded exemption will be moved to an information note that reads: “An arc flash hazard analysis may not be necessary for some three-phase systems rated less than 240 volts. See IEEE 1584 for more information.”
An information note has also been moved to this section from the HRC classification tables in Section 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 and approach boundaries.
Users also 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 in Section 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.
Previously, labels required “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:
- available incident energy and the corresponding working distance
- minimum arc rating of clothing
- Required level of PPE
- Highest hazard/risk category (HRC) for the equipment
2. Nominal system voltage
3. Arc flash boundary.”
An exception has been provided for labels that comply with previous requirements and were applied prior to September 2011. However, the exception 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 to Section 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 under Section 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.”
New additions and changes were also made to these requirements:
Hearing Protection [Section 130.7(C)(number not yet assigned to this new requirement)]: Hearing protection is now required when working
within the AFB. This requirement is now consistent with the Section 130.7(C)(10) table revised in 2009, which requires the use of hearing protection (inserts) for all HRC levels. Recent research shows that arc blasts can exceed the 140dB OSHA limit, generating sound levels similar to that of a gunshot and exceeding those produced by a jet engine.
Face Protection [Section 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 [Section 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 a 10 cal/cm² arc thermal protective value (ATPV) or better. Also in this section, the information note regarding insulating rubber gloves 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. Furthermore, research shows how effective this “low-tech” solution has been in preventing countless hand injuries to workers.
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 Section 130.7(C)(10) table that defines the PPE and clothing required for HRC level, which was often misapplied in the field. This action reaffirms 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 and 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 shortcircuit 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 in Section 130.7(C)(9), the corresponding sections and tables matching PPE and HRC levels in Section 130.7(C)(10)] and PPE characteristics with HRC levels in Section 130.7(C)(11) will now be located at the end of 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 misuse of the standard has been the mixing and matching of the two methods when 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 in Section 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 thaindicated in the tables, then the HRC Classification Table is not an appropriate tool.
Information now contained in 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 panelboards and other equipment rated greater than 240 volts or up to 600 volts with molded case or insulated case circuit breakers will notice
- 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, requires insulated gloves and hand tools.
The committee has eliminated the HRC 2 classification in Section 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, with “as needed” (AN) for HRC 1 and HRC 2 and “as required” (AR) for HRC 3 and HRC 4.
Personnel who work in the vicinity of overhead lines will sometimes mistake protective guards for insulation and consequently put themselves and coworkers in grave danger. The Section 130.5 standard will help to further protect such workers with the addition of the following requirement: “A qualified person are insulated for the lines’ operating voltage.”
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 three . The new Section 205.3 will new job tasks: 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, additional requirements are added to improve record keeping and documentation. Section 205.2 requires single-line diagrams to be kept current and legible, and the maintenance, tests and inspection of overcurrent protective devices will need to be documented.
Many additions, clarifications and changes were made to Safety Requirements to Batteries and Battery Rooms in Section 320 and throughout the annexes. Most notable are the significant rewrites and new titles to Annex F, Hazard Identification & Risk Assessment, and Annex H, 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 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.” The next ESW will be held in Daytona Beach, Florida, in January 2012. There you will see the future of electrical safety and the related standards, practices and technology. You will also be able to meet many, if not most, of the members of the NFPA 70E committee.
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, download the ROP and ROC reports from the NFPA 70E website (under the “Next Edition” tab). It is a great way to educate yourself on the evolution of the standard.
I was fortunate enough to attend the 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.
Tim Rohrer is President of Exiscan LLC, manufacturer of Infrared Windows. He was a guest at the NFPA 70E ROC meeting that finalized most of the changes for the 2012 revision and is very involved with several electrical safety standards committees, including CSA Z462, IEEE 1584, IEEE 1814 and 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. visit www.Exiscan.com.