Safety Leader

There's No Easy Button for 70E: The electrical safety standard applies to all workplaces

Getty Images / AlexLMX
Getty Images / AlexLMX
Published On
Nov 15, 2022

Practical application of NFPA 70E requirements necessitates that an employer and their qualified employees have a solid understanding of all rules in their workplace’s standard. However, NFPA 70E cannot address every possible scenario involving electrical hazard exposure with a prescriptive, “how-to” approach. 

Comprehensive risk assessments are required, and they contain much more than just shock and arc flash risk. For example, qualified persons must consider the potential for human error, the application of all the risk control methods in Section 110.5(H)(3) (because in most cases, more than one method can be applied), equipment operating condition, equipment condition and maintenance, PPE required and its condition, other protective equipment, tools to be used, alerting techniques, documentation, liability concerns, other precautions in Section 130.8 and more. 

What does the code say?

There are countless types of workplaces and potential exposures. NFPA 70E is the Standard for Electrical Safety in the Workplace, and the standard applies to all workplaces. It does not apply only to electrical construction, renovation and maintenance. 

The standard user must make decisions based on their work environment, the task at hand, electrical hazards involved and much more. It is extremely important to note that the goal is safety, and we want every employee to go home at the end of the day in the same shape they arrived. OSHA is the shall, and NFPA 70E is the how. 

The following two examples of practical application illustrate that NFPA 70E does not come with an easy button; no step-by-step instructions are included and each task and associated exposure may be different. Each of these scenarios (questions) were brought up by ECs in face-to-face classes.

Replacing a switchboard

The first task is replacing a 3,000A 480/277V switchboard. The foreman inspects the low-voltage power circuit breaker (LVPCB) supplying the switchboard to determine the operating and maintenance conditions. While the device looks to be in good operating condition, the last maintenance performed was over 20 years ago. NFPA 70B and manufacturer instructions require regular maintenance of LVPCBs. The lack of maintenance presents significant hazards. Opening the LVPCB or racking it out could cause a failure that results in an arc flash incident. The result could be the complete loss of the owner’s electrical distribution system and injury or death to employees. 

The only certainty in this scenario is that the work will be performed. What should the foreman do? No easy button exits. The owner must be notified in writing (a paper trail is necessary) that the lack of maintenance could result in failure and the complete loss of the electrical distribution equipment. 

How do we address opening the LVPCB to create an electrically safe work condition (ESWC) to facilitate the switchboard replacement? Do we just have an employee wear a 40-calorie arc flash suit and hope for the best? No! We must apply all relevant hierarchy of risk control methods in Section 110.5(H)(3). 

The goal is to create an ESWC, but opening the LVPCB could result in a significant arcing event due to the lack of maintenance. We must remove the employee from the area by applying engineering controls, one of the risk control methods in 110.5(H)(3).

We can use a device to remotely open and rack out the LVPCB, which removes the employee from the arc flash boundary. The standard will not walk you through such a scenario, so a solid understanding of the requirements and a comprehensive risk assessment gets it done. 

Work in a manhole

Another common question is how to address work in a manhole that contains energized conductors. All employees working in or around confined spaces must be trained as required by applicable OSHA standards. 

Let’s assume a new manhole is installed with 400A, 208/120V feeders, pulled through and neatly racked in the manhole without splices. A gas monitor is used and no hazardous atmosphere is encountered. Is the manhole a permit-required confined space, and do the energized conductors automatically mean an electrical hazard exists? We must consider the task at hand to determine if the energized conductors represent a hazard. 

For example, if the task is to simply have an employee enter the manhole to push a fiberglass fish into a raceway and pull in a rope, there is no potential for that task to impact newly installed, neatly racked, insulated conductors (without splices). 

In this scenario, an electrical hazard does not exist. However, what if there are old lead splices, service conductors or load breaks? What if the manhole is underwater twice a day? Each scenario represents an electrical hazard. Under any of those conditions, an electrical hazard exists with every task in the manhole, and it would be considered a permit-required confined space.

About the Author

Jim Dollard

Code Columnist

Jim Dollard is the safety coordinator for IBEW Local 98 in Philadelphia. He is a member of the NEC Correlating Committee, NEC CMP-10, NEC CMP-13, NFPA 70E, NFPA 90A/B and the UL Electrical Council. He can be reached at

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