What is required to comply?
The questions that have rolled across my computer screen from customers most recently have been focused on a certain segment of industrial safety: NFPA 70E® 2018, the changes made for 2018, and the related requirements. It seems that quite often there is a concern that NFPA 70E in general is not enforced or, is not an actual safety requirement. With the release of the 2018 edition of the standard, electrical professionals and engineers responsible for ensuring compliance need to adjust to several changes to the existing safety practices they already incorporate in the workplace. Here is some basic info regarding NFPA 70E and OSHA Subchapter S. However, there are likely many more changes that need to be addressed at your facility. One of the most notable changes is the requirement of a job safety plan and risk assessment for every project.
Here is my brief interpretation of the inner workings of the relationship between OSHA and NFPA. New NFPA 70E explicitly states that the priority must be the elimination of the hazard in the workplace. To sum up the compliance requirements and enforcement by OSHA of the 29CFR 1910 Subchapter S Electrical Hazards regulations, OSHA relies on the National Fire Protection Associations 70E 2018 standards to provide the methods for meeting the Subchapter S requirements.
NFPA 70 130.5 (A) simply states: “An arc flash risk assessment shall be performed.” Yup! It is that simple, sort of…
- This section goes on to say, “In order to identify arc flash hazards and,
- Estimate the likelihood of occurrence of injury or damage to health and the potential severity of injury or damage to health and,
- Determine if additional protective measures are required, including the use of personal protective equipment (PPE).”
In short, the assessment MUST identify where a worker or equipment or the facility itself could be damaged by an electrical flash or blast, properly label that area and include on that label the protective boundaries and equipment which is required to protect a worker from exposure, that is until a complete de-energized state is confirmed.
NFPA goes on to identify via text and tables the exact parameters of the level of protection, the data on the identifying labeling, the safe working boundaries and so on.
Well, not really. The electrical blast levels are measured in Caloric Energy and 4 clearly defined levels of hazard risk are called out. The word minimum is used for the level of PPE that is required for each category. Therefore, the exact Cal rating must be clearly stated on the panel label.
The boundary areas for safe work by qualified persons are defined and must be adhered to. And, “qualified workers” are clearly defined.
There are several methods available to conduct the assessment.
- The most complete and comprehensive is to perform an Engineered Assessment where the electrical data is compiled by creating a single line diagram of the wiring within the structure, compiling all the required input from the grid supply through the end source and include the age of the equipment, conditions of the equipment and environment and the demand on that equipment.
- Then detail both the existing hazard and what might be required for abatement and remediation of that hazard.
- There are electrical safety products on the market which provide a proof of de-energization that can be added to equipment to reduce or eliminate the need for PPE and testing prior to removing a panel cover for service.
- The technology of the PPE fabrics and the materials used in face shields has improved dramatically for comfort and convenience. Voltage gloves have also improved in dexterity and tactility over the past few years.
- Documented Training for qualified workers is required to be refreshed at least within 3 years of initial training. Or if by actions, the need for re-training of a worker is evident.
- A documented audit of the assessment is required at least every 5 years or if there are changes in the electrical supply or to the system within the facility.
Failure to meet any of the NFPA 70E 2018 standards could be cited by OSHA within the regulations of their Subchapter S. For example, improper panel labeling. Blocked or unsafe conditions in front or around a panel. Lack of training for the electrical worker. Lack of PPE provided to a worker. And so on… NFPA defines how to meet OSHA standards!
2018 edition of NFPA 70E emphasizes the importance of performing a solid risk assessment that examines all aspects of the hazards to which employees are exposed and provides a valuable new tool to determine how best to mitigate the potential danger. It is imperative that the NFPA 70E standards be understood, implemented, trained on and that the assessment is complete, up-to-date and audited as required. Safety doesn’t happen by accident. The dangers of arc flash – why should you be concerned? Read our electrical arc flash brochure to learn more.
To learn more about the impacts of NFPA 70E 2018 or to discuss our arc flash assessment services contact us.
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Have you reviewed the areas in your facilities to determine how you can eliminate or reduce the arc flash hazards, even if you have appropriate PPE?