NFPA 70E, the Standard for Electrical Safety in the Workplace, and NFPA 70, National Electrical Code, share the same goal of electrical safety. However, they are dynamically different because the NEC deals only with minimum installation requirements, and NFPA 70E addresses electrical safety-related work practices, safety-related maintenance requirements and other administrative controls.
Both documents are extremely well organized. The 2021 edition of NFPA 70E has been restructured, and many general requirements that were spread out over several articles have been relocated into Article 110 for clarity and usability. While many of these revisions may not initially seem important, relocating these requirements to apply generally in all situations is extremely significant.
Existing Section 105.4, “Priority,” is relocated as new Section 110.1 to emphasize that hazard elimination is always the first priority in implementing safety-related work practices. This is now the first general requirement in the standard! Article 110 is titled “General Requirements for Electrical Safety Related Work Practices.”
However, the general requirement for the implementation of safe work practices until electrical conductors and circuit parts are placed into an electrically safe work condition (ESWC) was buried in Section 120.2(A). This requirement is logically relocated as new Section 110.2 “General.” This new section also contains the general requirement that all electrical conductors and circuit parts are not to be considered in an ESWC until all of the requirements in Article 120 have been met. Existing (2018) Section 130.2 provides requirements for when an ESWC must be established and the four thresholds for situations where energized work is permitted. This requirement is relocated as two new sections in Article 110.
New Section 110.3, “ESWC,” now contains requirements for when an ESWC must be implemented and the justification thresholds in 130.2(A), “Additional Hazards or Increased Risk, Infeasibility, Equipment operating at Less Than 50 volts and Normal Operating Condition” are relocated to new Section 110.4, “Energized Work.”
All of the general requirements for the creation of an ESWC and the justification thresholds for energized work are now up front in Article 110. This reorganization has pushed the requirement for the employer’s electrical safety program (ESP) from 110.1 to 110.5. However, This does not deemphasize the importance of the written ESP in any manner.
There are two new requirements added to the overall ESP that must be implemented and documented by all employers. New 110.5(K) now requires the ESP include an ESWC policy that complies with new 110.3 that mandates when an ESWC must be established. New 110.5(L) requires that the ESP include a lockout/tagout (LOTO) program in accordance with 120.1(A) that mandates the employer establish, document and implement a LOTO program.
This section does permit the ESP to simply refer to a written LOTO program meeting the requirements of 120.1(A). All electrical contractors must have a written LOTO program that includes prescriptive procedures for employees to follow when implementing LOTO. This is required by 1910.333(b)(2)(i) in the OSHA 1910 General Industry Standard. Rest assured that while an electrical contractor may hold themselves out as construction only, they all work under both the general industry and construction requirements set forth by OSHA. Section 1910.333(b)(2)(i) requires the employer maintain a written copy of the LOTO procedures provided in 1910.333(b)(2). OSHA does permit the employer to simply copy the procedures in 1910.333(b)(2). The LOTO procedures provided by OSHA are primarily performance-based and should be supplemented with the prescriptive steps found in NFPA 70E.
By supplementing the federal regulation in 1910.333(b)(2) with the prescriptive requirements in NFPA 70E 120.5, “Process for Establishing and Verifying an Electrically Safe Work Condition,” the result is comprehensive written procedures for LOTO as mandated by OSHA. The construction requirements in 1926.417 do not require a written LOTO program. This rule mandates only that the employer render electrical equipment inoperative or incapable of being energized. The requirements of 1926.417 do not require LOTO. OSHA requirements in Subpart K Electrical do not mandate or place any emphasis whatsoever on LOTO in construction.