When is a second person required when work will be performed on energized conductors and circuit parts, and what training should that person have? This is a question that arises again and again. This is presently discussed in requirements for the employer’s electrical safety program in Section 110.3. 

In Section 110.3(H)(1), required elements of a risk assessment procedure include identifying hazards, assessing risks and implementing risk control according to the hierarchy of risk control methods. A requirement for a second person does not exist; however, Informational Note No. 1 following 110.3(H)(1) informs the user that when performing the required risk assessment procedure, the employer should decide when a second person is required, and the training and equipment necessary.

Necessary requirements

There are many factors to consider. Article 130 covers requirements for work involving electrical hazards such as necessary electrical safety-related work practices, assessments, precautions and procedures when an electrically safe work condition (ESWC) cannot be established. 

The existing requirements in 130.1 that were not scope material were relocated to a new Section 130.2 , Work Involving Electrical Hazards. The existing Article 130 requirements are in new 130.2(B), and those for the energized electrical work permit (EEWP) are relocated into 130.3. The existing requirements addressing energized electrical parts not in an ESWC are relocated to 130.2(A)(1). 

A new 130.2(A)(2), Additional Person, has also been added to necessitate an additional (second) person, as follows: “If an energized electrical work permit is required in accordance with 130.3(A), at least one additional person meeting the emergency response training requirements of 110.4(C)(1) shall be present in the vicinity of, but outside of, either the limited approach boundary or arc flash boundary, whichever is greater.” 

The support for this new requirement was unanimous on the technical committee written ballot. The public input introducing this concept was broad, and it was necessary to provide qualifying criteria on when an additional person would be required. Tying this new requirement to the need for an EEWP was the most feasible path forward. 

We’re not done

Now the question is, does this revision solve the problem completely when a second person is required, and their training? It is a significant safety-driven addition to the standard—but no, this is not the complete answer. There is more work to do. 

Employers must consider the need for an additional person (and their training) for each exposure to energized conductors or circuit parts. This new requirement for a second person is limited, as it applies only when an EEWP is required in accordance with 130.3(A). This includes when work is performed within the restricted approach boundary or when an employee interacts with the equipment when conductors or circuit parts are not exposed but there is an increased likelihood of injury from an exposure to an arc flash hazard. 

In the electrical construction industry, the first priority is to always eliminate the hazard by creating an ESWC. When this is done, testing for the absence of voltage is exempted from the need for an EEWP and the requirement for an additional person will not apply. It is extremely important to understand that testing for the absence of voltage during the creation of an ESWC is considered energized work. Based on the potential exposure, it may be prudent to have a second person. Additionally, troubleshooting tasks, such as voltage testing, would be exempt from an EEWP, and an additional person would not be required. 

Another consideration is the required training for the additional person. As presently written, the additional person must  only receive emergency response training required by 110.4(C)(1), which is contact release training. While the general training requirements in Section 110.4 mandate electrical safety training for qualified persons, lockout/tagout procedure, first aid emergency response and resuscitation training, only contact release training is required for the additional person. More than one additional person may be necessary, and they may need significantly more training based on tasks performed and potential exposure. 

This new requirement is an excellent addition to the standard and will set the stage for enhancements over multiple revision cycles. NFPA 70E covers countless different workplaces; however, its extremely broad coverage makes it challenging to provide prescriptive requirements for each workplace. Employers must fully understand NFPA 70E requirements and apply them as needed, understanding that exceeding these rules is necessary in many cases. There is no “easy button.” 

There are many more employer responsibilities, including training for qualified persons as required in Section 110.4.

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