Small Things Mean a Lot

Ron Widup and James (Jim) R. WhiteColumns, NFPA 70E and NETA, Winter 2019 Columns

One of the most important details in NFPA 70E is its definitions. Many people automatically believe they already know the definition of a word or phrase. This is a mistake that can have negative consequences. The place to start is to read Chapter 1, Article 100 Definitions. Once you have a better understanding of the definitions, the rest of the standard becomes much easier to read and comprehend the intent.

For example, the definition of Electrically Safe Work Condition has seen a lot of attention over the last two revisions. Some additional controversy was created when the definition was [essentially] challenged to mean that the only way to assure compliance was that the equipment had to be replaced, rather than maintained. This caused quite a stir, so the definition was expanded and an information note was added, all intended to make the definition clearer.

In the current 2018 edition, the definition of Electrically Safe Work Condition reads:

Electrically Safe Work Condition. A state in which an electrical conductor or circuit part has been disconnected from energized parts, locked/tagged in accordance with established standards, tested to verify the absence of voltage, and, if necessary, temporarily grounded for personnel protection.

The proposed revised definition of Electrically Safe Work Condition now reads:

A state in which an electrical conductor or circuit part has been disconnected from energized parts, locked/tagged in accordance with established standards, tested to verify the absence of voltage, and if necessary, temporarily grounded for personnel protection.

Informational Note: An electrically safe work condition is not a procedure; it is a state wherein all hazardous electrical conductors or circuit parts to which a worker might be exposed are maintained in a zero energy state for the purpose of temporarily eliminating electrical hazards for the period of temporary time for which the state is maintained.

The accompanying Informational Note points out that an electrically safe work condition is not a procedure, but a state. Once it becomes an electrically safe work condition, all hazardous energy is no longer available to cause injury or death. The condition is temporary, which means it is intended to be re-energized (maybe not right away), but for a period of time for which the state is maintained. This should make the meaning of the definition clear to everyone.

Only minor editorial changes were made to a few additional definitions to ensure each definition provided in the standard is as understandable as possible. A good example is the definition of Working On (energized electrical conductors and circuit parts), which now has the proposed added text (shown as underlined) and reads:

Working On (energized electrical conductors and circuit part). Intentionally coming in contact with energized electrical conductors or circuit parts with the hands, feet, or other body parts, with tools, probes, or with test equipment, regardless of the personal protective equipment (PPE) a person is wearing. There are two categories of working on: Diagnostic (testing) is taking readings or measurements of electrical equipment, conductors, or circuit parts with approved test equipment that does not require making any physical change to the electrical equipment, conductors, or circuit parts; repair is any physical alteration of electrical equipment, conductors, or circuit parts (such as making or tightening connections, removing or replacing components, etc.).

Users of 70E are familiar with the concept of two working on conditions:

  1. Diagnostic testing using approved test equipment, which includes taking voltage readings or tasks that do not make changes to the electrical equipment, conductors, or circuit parts, and
  2. Repairs that involve making physical changes to the equipment, conductors, or circuit parts to get it to work again. The idea is to avoid intentionally coming in contact with the equipment, conductors, or circuit parts.

But remember this: Best practices teach us that if the person doing the repair task has first placed the equipment, conductors, or circuit parts in an electrically safe condition using PPE, they have removed the hazard, so there is no need to mitigate the hazard, since it isn’t there. It’s the best way to go!

The 70E standard required this in Article 110.1, which addresses general requirements for electrical safety-related work practices. There is a new first clause in 110.1 (electrical safety program) identified as Priority, which was previously located in Article 105.4 and is proposed as:

110.1 Electrical Safety Program
(A) Priority.
Hazard elimination shall be the first priority in the implementation of safety-related work practices.

Informational Note No. 1: Elimination is the risk control method listed first in the hierarchy of risk control identified in 100.5(H)(3). See Annex F for examples of hazard elimination.

Informational Note No. 2: An electrically safe work condition is a state wherein all hazardous electrical conductors or circuit parts to which a worker might be exposed are placed and maintained in a de-energized state, for the purpose of temporarily eliminating electrical hazards. See Article 120 for requirements to establish an electrically safe work condition for the period of time for which the state is maintained. See Informative Annex F for information regarding the hierarchy of risk control and hazard elimination.

This is another example where small things can make a big difference. In this section, hazard elimination is the first priority of safety-related work practices. We should always keep this in mind, as quitting time, personal issues, overtime, fatigue, and countless other items could distract us from keeping elimination as the first priority.

The second informational note also speaks to an electrically safe work condition and refers the 70E user to Informative Annex F. Informative annexes are not mandatory requirements, but contain related and very useful information that should be reviewed and incorporated into work plans and safe work practices. If you haven’t been carefully studying the informative annex material in the 70E, you really should — it’s a great resource for additional knowledge and best practices.

Conclusion

The upcoming new (2021) edition of NFPA 70E will have many changes — some very important and some just editorial.

The structure of the document, with shading that highlights any new or revised text, makes it simple to see what has changed, how it has changed, and what has been added. We recommend studying the definitions, Section 130, as well as all of Chapter 1 and Chapter 2. Add in the informative annexes, and there is quite a bit to digest. But this is not like eating distasteful food; it is more like dessert. It should be taken in, reviewed, and taken in again. Every time you do, you will likely find something new that helps us all in our quest for electrical safety perfection.

Be careful out there, and always test before touch!

Ron Widup and Jim White are NETA’s representatives to NFPA Technical Committee 70E, Electrical Safety Requirements for Employee Workplaces. Both gentlemen are employed by Shermco Industries in Dallas, Texas, a NETA Accredited Company.

Ron Widup, Shermco Industries Vice Chairman and Senior Advisor, Technical Services, has been with Shermco since 1983, and currently serves on the company’s board of directors. He is a member of Technical Committee on NFPA 70E, Electrical Safety in the Workplace; a Principal Member of National Electrical Code (NFPA 70) Code Panel 11; a Principal Member of the Technical Committee on NFPA 790, Standard for Competency of Third-Party Evaluation Bodies; a Principal Member of the Technical Committee on NFPA 791, Recommended Practice and Procedures for Unlabeled Electrical Equipment Evaluation; a member of the Technical Committee on NFPA 70B, Recommended Practice for Electrical Equipment Maintenance, and Vice Chair for IEEE Std. 3007.3, Recommended Practice for Electrical Safety in Industrial and Commercial Power Systems. Ron also serves on NETA’s board of directors and Standards Review Council. He is a NETA Certified Level 4 Senior Test Technician, a State of Texas Journeyman Electrician, an IEEE Standards Association member, an Inspector Member of the International Association of Electrical Inspectors, and an NFPA Certified Electrical Safety Compliance Professional (CESCP).

James (Jim) R. White, Vice President of Training Services, has worked for Shermco Industries since 2001. He is a NFPA Certified Electrical Safety Compliance Professional and a NETA Level 4 Senior Technician. Jim is NETA’s principal member on NFPA Technical Committee NFPA 70E®, Electrical Safety in the Workplace; NETA’s principal representative on National Electrical Code® Code-Making Panel (CMP) 13; and represents NETA on ASTM International Technical Committee F18, Electrical Protective Equipment for Workers. Jim is Shermco Industries’ principal member on NFPA Technical Committee for NFPA 70B, Recommended Practice for Electrical Equipment Maintenance and represents AWEA on the ANSI/ISEA Standard 203, Secondary Single-Use Flame Resistant Protective Clothing for Use Over Primary Flame Resistant Protective Clothing. An IEEE Senior Member, Jim was Chairman of the IEEE Electrical Safety Workshop in 2008 and is currently Vice Chair for the IEEE IAS/PCIC Safety Subcommittee.