In my December 2022 and January 2023 articles, I wrote about proper labeling and electrical safety in the 2023 NEC, the 2021 NFPA 70E, Standard for Electrical Safety in the Workplace, and NFPA 70B, Recommended Practice for Electrical Equipment Maintenance. The December article prompted an email from a reader asking if the safety warning label requirements would or could apply to a substation owned and operated by a municipality.

I often receive emails, text messages and phone calls from electricians, electrical contractors, electrical inspectors, electrical engineers and the general public. These contacts originate from all different types of people who read ELECTRICAL CONTRACTOR.

This speaks volumes to me about the far-reaching importance of the technical and safety information provided by the many writers contributing to the magazine. Without them (many of whom I know personally) and the people organizing and publishing this magazine, this important information would be lost in some obscure format, unavailable to those who need it or would never be published at all.

NESC or NEC?

The question I received was from a substation control and signal technician (an electrician and nonengineer) for a small municipality. He stated that he had been given different explanations over the years about why the municipal substation did not include what he thought was very necessary safety labeling and notifications as outlined and required in the NEC and NFPA 70E. 

He stated that one of the most frequent explanations was that the substation was built, maintained and operated based on the National Electrical Safety Code (NESC) as published by IEEE. He also was frequently told that the NEC did not apply to their installation.

Necessary background on this issue does certainly involve the NEC provisions in 90.2(D) involving installations not covered by the Code. Specifically, 90.2(D)(5) states, in part, that the NEC does not cover “installations under the exclusive control of an electric utility where such installations consist of service drops or service laterals, and associated metering, or are located on property owned or leased by the electric utility for the purpose of communications, metering, generation, control, transformation, transmission, energy storage, or distribution of electric energy.”

In effect, this subsection exempts a public utility from having to comply with the NEC. However, could the public utility comply with certain safety aspects of the NEC or NFPA 70E? The answer to that question is yes; they absolutely could require compliance.

Standards for safety

Certainly, a municipality or public utility could adopt whatever standards they deem necessary for safety. 

A municipality is governed by standards voted into law or adopted into their rules and regulations, so they could adopt the safety requirements in 110.16(A) of the 2023 NEC, requiring proper arc flash general warning labeling. 

They could also follow or adopt the new requirements in 110.16(B) that a permanent arc flash label be field- or factory-applied to service equipment and feeder supplied equipment rated 1,000A or more. The arc flash label could be in accordance with applicable industry practice, as provided in 130.5(H) of NFPA 70E, and include nominal system voltage, incident energy levels, arc flash boundaries, required levels of personal protective equipment and the date the label was applied.

Next, deal with the issue of qualified personnel required in the NEC, NFPA 70(E) and NFPA 70B. For example, a new Section 110.17 of the NEC covers servicing and maintenance of electrical equipment. 

It states servicing and electrical preventive maintenance must be performed by qualified persons trained in equipment service and maintenance. 

Throughout NFPA 70E, only qualified persons are permitted to work within arc flash boundaries and the shock protection limited approach and restricted approach boundaries. Sections 110.4 covering energized work, 110.5 covering safety programs and 110.6 requiring training, and other pertinent sections of NFPA 70E, would need to be employed.

A thorough knowledge of the NEC requirements, the safety methods employed in NFPA 70E, all requirements from OSHA and safety procedures required by the NESC help keep personnel safe. Installing labels based on the NEC and NFPA 70E alone would not cover the safety aspects of the electrical installation, unless the maintenance personnel are cognizant of the safety issues involved.

Header Image: shutterstock / angelh