When implementing electrically safe work practices in accordance with the requirements of NFPA 70E, one must apply all rules in the standard. We cannot simply jump to Article 130 and apply the requirements for work involving electrical hazards.
The 2021 revision cycle of NFPA 70E saw a significant editorial relocation of requirements in Chapter 1, Safety Related Work Practices. This created a more logical flow of rules, significantly increasing usability. Chapter 1 contains electrical safety-related work practices and procedures to address the safety of employees exposed to electrical hazards in the workplace.
Starting in the front of Article 110, General Requirements for Electrical Safety-Related Work Practices, Section 110.1 mandates that the first priority is always the elimination of electrical hazards. Section 110.3 requires that an electrically safe work condition (ESWC) be developed and maintained before performing work within the limited approach boundary or where an employee interacts with electrical equipment (without exposed energized conductors or circuit parts) in a manner that increases the likelihood of injury from an exposure to an arc flash hazard.
Section 110.4, Energized Work, provides four conditions considered justified energized work. An energized electrical work permit (EEWP) is always required when energized work is performed, due to the presence of additional hazards or increased risk in 110.4(A). In most cases, energized work performed due to the infeasibility threshold in 110.4(B) will not require an EEWP because most of these tasks are exempted from the EEWP requirements in 130.2(C).
After applying all of the rules in Article 110 and determining that energized work is justified, an EEWP is required when work is performed within the restricted approach boundary or when an employee interacts with electrical equipment (without exposed energized conductors or circuit parts) in a manner that increases the likelihood of injury from exposure to an arc flash hazard. Requirements for EEWPs are in Section 130.2.
The EEWP was developed and included in NFPA 70E for multiple reasons. It’s a checklist that helps ensure all the necessary information is obtained to properly perform a shock and arc flash risk assessment. The permit requires documentation of information needed to comply with the requirements for work involving electrical hazards in Article 130. This includes the justification for energized work, shock risk assessment, voltages and shock protection boundaries, arc flash risk assessment and the arc flash boundary, tasks to be performed, circuits and equipment involved, safe work practices employed, required PPE to protect from shock and arc flash, method(s) to restrict access to the work area, evidence of a job briefing and energized work approval.
The last item, energized work approval, requires that someone capable of authorizing energized work sign the permit before work begins. It must come from the equipment’s owner or their designee, not the EC. This makes the EEWP a useful tool for situations where equipment can be placed in an ESWC but an owner or middle/lower-level management is reluctant to do so.
When performing energized work under the “additional hazards or increased risk” justification threshold, serious potential issues exist. The equipment that the owner cannot do without for 20 minutes to an hour may be down for days or weeks if something outside of the contractor’s control creates a fault that damages the equipment. We can provide a scheduled shutdown of known duration, or the owner can gamble on an unscheduled shutdown of unknown duration. In most cases, management will not provide such approval because, in doing so, they own any failure and associated downtime along with repair costs. Creating an ESWC presents an opportunity to eliminate this risk.
It is extremely important to note that the creation of an ESWC includes energized work. The act of verifying the absence of voltage is energized work and requires a shock and arc flash risk assessment and the necessary PPE.
While an EEWP is not required for tasks listed in 130.2(C), Exemptions to Work Permit, contractors should develop similar forms for these tasks. Exempted tasks such as troubleshooting still require that qualified personnel be provided with and use appropriate safe work practices and PPE in accordance with Chapter 1.
The EC must also document all shock and arc flash risk assessments. This documentation is critical for field audits as required in 110.5(M)(2), Field Work Audit, which are required annually and are an opportunity to monitor and control the electrical safety program. Additionally, this documentation can demonstrate to future clients that the contractor is the best value for their new project.