Recently, I taught a class on the application of NFPA 70E, Standard for Electrical Safety in the Workplace, and an interesting question came up. An electrician asked, “Why does NFPA 70E require skilled workers like me to fill out so much darn paperwork? How are we supposed to work when we spend all our time filling out forms?” As an electrical safety professional, this question got me excited because I knew some learning was about to take place!

I am not a member of the NFPA 70E committee, so I can’t speak for them or why they write a requirement, but I can give my understanding of the requirements. So, why is the energized electrical work permit (EEWP) even a thing? That is the question that got the hand to raise, but my answer certainly took this gentleman by surprise.

My experience

I went back to when I first started working as an electrician. I had not yet taken a class on NFPA 70E, as it was expected that apprentices didn’t work energized. NFPA 70E was not part of my trade school education, nor was it a major part of my apprenticeship curriculum. I did not get a real dose of NFPA 70E training until after I had my license. 

After taking an NFPA 70E class, I returned to work on Monday morning and my boss told me I was an energized work electrician. Meaning that, when the request came in not to shut off the power, he would send me in to work it hot. I added, “... when it was justified,” and his response was, “It is justified because the customer doesn’t want to shut it off, that is all you need to know.”

As NFPA 70E gained popularity, it was not uncommon for employers to view it as a standard on how to work energized, and they missed the part where it said to create an electrically safe work condition unless you absolutely can’t. This is why the EEWP exists, and its purpose is to prevent energized work unless it is absolutely necessary. To illustrate this, I asked my boss how often he got an EEWP signed. His response was almost never. I asked why not, to which he responded that management wouldn’t sign one because there really wasn’t anything in the plant that couldn’t be shut down.

JSP versus EEWP

To tackle the electrician’s question about paperwork, I asked what that entailed. He informed me he is required to fill out a safe work permit for everything, then a job safety plan (JSP) and then, if the job involves energized work, he needs an EEWP. The safe work permit was company-­specific and not required by NFPA 70E, so I focused just on the JSP and EEWP, which are 70E requirements.

I started going through what was required information on their EEWP. We saw that they needed to list the equipment to be worked on, the scope of work, the reason it needed to be done energized, what hazards were present, the risk assessment results, the plan for mitigating the risk and signatures from management. I asked him, what does the EEWP require that the JSP does not? He said the only difference between the two was the reason for working energized and management signatures.

Circling back to his original question, why all the paperwork? What he had realized in this little exercise is that the EEWP is not much more than a JSP, but presented to management in a way so they understand the scope of the task, why it has to be energized, how dangerous the work will be, the plan for not getting hurt or killed and, crucially, a place to authorize the work in spite of the dangers. This requires management to be sure there is no other way to do it as safely and accept responsibility for anything that happens.

Why, then, are there exceptions? When we look at the list of exceptions through this lens of why we need the EEWP, you can see that these items are always justified energized. There is no other way, so the extra level of approval isn’t necessary. Remember, the EEWP is to get us out of energized work, not just documentation. It is difficult to take voltage and current measurements with the power off, right?

By better understanding the reason behind the requirement for the EEWP, it certainly helped one skeptic change his viewpoint on filling them out. By spreading the message, we can work together on changing a culture that views NFPA 70E requirements as a hindrance instead of the protection they are meant to be.

Until next time, stay safe and remember to always test before you touch!

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