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Tailoring the Code to You: NFPA 70E compliance and developing procedures that optimize electrical safety

By Derek Vigstol | Feb 15, 2024
tailor form and scissors
Safety managers across the country tell me their major concern is compliance with NFPA 70E, Standard for Electrical Safety in the Workplace.

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Safety managers across the country tell me their major concern is compliance with NFPA 70E, Standard for Electrical Safety in the Workplace. At every audit or training I provide, I hear how important compliance with NFPA 70E is. However, when asked about their written electrical safety program, many say they hand a copy of NFPA 70E to each employee and have them follow the book. And that is where the statement about compliance with NFPA 70E goes right out the window.

One of the most important sections in NFPA 70E is 105.3(A). It says the employer has the responsibility to establish, document and implement the safety-related work practices and procedures required by NFPA 70E. How does an employer do this? Section 110.3(A) requires an employer to implement and document an overall electrical safety program that directs activity appropriate to the risk associated with electrical hazards. That means if you would like to follow NFPA 70E as your electrical safety program (ESP), one of the first things required is your own program, which means written procedures.

Risk Assessment Procedures

What procedures does NFPA 70E require in an electrical safety program? An ESP’s overall goal is to direct work appropriate to the risk associated with electrical hazards. So, a procedure for determining risk is a must. 

Section 110.3(H) requires that the ESP has a risk assessment procedure. This procedure must identify electrical hazards, estimate how likely the hazard is to cause injury and the severity of such an injury, account for potential human error and direct mitigation activities in accordance with a hierarchy of risk control methods. This is the cornerstone of an ESP. 

However, this procedure is not one-size-fits-all. Sure, we can start with a template, but an employer’s risk assessment procedure must be specific to their work.

Let’s look at what makes a risk assessment procedure unique and interesting to develop. First off, the two main hazards associated with electricity are electric shock and arc flash. NFPA 70E requires a risk assessment to be performed for each hazard. Also, don’t forget about other hazards such as confined spaces, elevated locations and chemical hazards. 

The first task in the risk assessment procedure must be to identify all hazards present, including nonelectrical ones. Next, assess the likelihood of injury from identified hazards. Shock and arc flash risk assessment sections in Article 130 call out that the equipment design and condition of maintenance be considered when assessing the risk to employees. In other words, it is important that the risk assessment procedures have elements that require us to take a look at what effect the equipment has on the likelihood of an injury occurring. A new informative annex has also been added to assist in assessing the condition of maintenance, and NFPA 70B has also become a full standard now—but the maintenance conversation is for another day.

Once we determine the condition of equipment maintenance and consider the design of equipment, the risk assessment procedure must consider the worker’s task. This is now a separation between shock and arc flash. 

Electric shock risk assessment boils down to two things:

  1. Will there be exposed energized electrical conductors or circuit parts?
  2. How close to the exposed conductors or parts will the worker need to be to perform the task?

This requires using the definition of “exposed” as it applies to conductors and circuit parts and using tables in Section 130.4 to define boundaries with certain risk profiles. For example, if a 480V, three-phase panelboard is open and exposed, any worker approaching closer than 3 feet, 6 inches is exposed to a shock hazard. If they approach closer than 12 inches, there is an increased likelihood of injury from the shock hazard, and they will need to take additional measures to protect themselves, such as wearing rubber insulating gloves. The procedure will need to be written to walk through this entire thought process from start to finish, and the results of this procedure must be added to a prejob planning form such as a job site analysis.

Arc Flash Assessment

Arc flash risk assessment is slightly more complicated, as it centers around determining whether the task is likely to cause an arc flash in the first place. This includes writing a procedure for making this assessment based on the condition of equipment maintenance. The NFPA 70E table can be used as a starting point, but several routine tasks occur within a facility that Table 130.5(C) does not address. If you are performing these tasks, they should be written into the electrical safety program accordingly. 

Since this table is based on the rules and requirements in NFPA 70E, if your electrical safety program seeks to exceed this standard, you will need to modify some information. 

For instance, operation of a switch or circuit breaker is listed in Table 130.5(C) as not being likely to cause an arc flash if the equipment is in a normal operating condition. However, there are several employers that do not want to rest the decision of “no evidence of impending failure” on the shoulders of their employees, so they treat it as though operating a switch does present a likelihood of occurrence. This part of the risk assessment procedure must be written and determined based on the employer’s risk adversity level.

Once the likelihood of occurrence has been determined, write the procedure to help workers estimate the severity of injury and select the appropriate mitigation technique in accordance with the hierarchy of risk control methods. 

This part of the procedure is unique to each employer because it is based on whether an incident energy analysis has been performed. A manufacturing plant that sees the same equipment everyday can bring in an engineer to estimate incident energy values and determine arc flash boundaries. 

Electrical contractors, however, are going to experience a variety of different scenarios and must determine their procedure for making this estimate. Also, the mitigation strategies being selected in accordance with the hierarchy of risk control methods is going to be different across employers and facilities. 

For these reasons, there is no one-size-fits-all solution to this issue. After completing the risk assessment procedure, the employer must dive into developing the PPE selection process, which also is a conversation for another day.

Why It is Important  

Nearly every part of NFPA 70E will be used in writing a risk assessment procedure: from Article 100 definitions to tables in Article 130 and even incorporating the informative annexes. There are no easy buttons when it comes to developing policies out of NFPA 70E. 

This example was just one procedure that NFPA 70E requires in the ESP. We must also develop procedures for specific tasks such as racking circuit breakers or adjusting the brushes on a large DC motor. 

These policies and procedures make up the bulk of the electrical safety program and will require the most individualized development. There are also procedures to ensure that the program stays up to date and relevant, which includes auditing work to ensure it follows the electrical safety program, performing incident investigations should an incident occur and reviewing the ESP for compliance with NFPA 70E and OSHA. All these procedures will be specific to the employer based on what they do and how they do it. 

Developing policies and procedures in accordance with NFPA 70E requires a firm handle on how the document applies to your specific situation. There is a lot more to it than simply handing everyone a book and telling them to follow it. 

However, when the time and knowledge is invested in developing electrical safety policies that direct specific activities in the safest manner possible, dividends are paid in the form of fewer injuries and less time spent wondering how an industry consensus approach “square peg” fits into the “round hole” of a real-world situation. 

If my time in the electrical safety world has taught me anything, it would have to be that an ounce of prevention is worth a pound of cure any day of the week. Developing procedures that comply with NFPA 70E and OSHA and are created specifically for your day-to-day work will keep you and your employees safe from electrical hazards and headed home the same way you came to work: in one piece.

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About The Author

Vigstol is an electrical safety consultant for E-Hazard, a provider of electrical safety consulting and training services. He is also the co-host of E-Hazard’s electrical safety podcast “Plugged Into Safety.” For more information, check out www.e-hazard.com.

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