Subcontractor Electrical Safety & NFPA 70E

Electrical Safety for Subcontractors and

Subcontract Technical Representatives
NFPA
Stand 70E
Electr a rd for
i
Requi cal Safety EFCOG Electrical Safety Task Group
Emplo re m
yee W ents for
orkpl
2004 E aces
dition
Module 8
 Objective

 To provide understanding of electrical safety requirements

for the Subcontract Technical Representative and the
Subcontractor
 To facilitate communications of requirements to the
subcontractor
 To serve as an aid in assessing a subcontractors
performance

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 NFPA 70E, Standard for Electrical Safety in the Workplace

 Why is NFPA 70E a subcontractor requirement?

– DOE Order 440.1A, Worker Protection Management For DOE And Contractor
Employees Requires Implementation
– OSHA General Duty Clause requires “workplace free from recognized hazards”. OSHA
has cited General Duty Clause for failure to comply with 70E
– 10CFR 851 requires compliance with NFPA 70E
– NFPA 70E, Section 110.4 Multiemployer Relationship
• (A) Safe Work Practices. On multiemployer worksites (in all industry sectors), more
than one employer may be responsible for hazardous conditions that violate safe
work practices.
• (B) Outside Personnel (Contractors, etc.)… the on-site employer and the outside
employer(s) shall inform each other of existing hazards, personal protective
equipment/clothing requirements, safe work practice procedures… applicable to the
work to be performed.

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 Can OSHA Cite NFPA 70E?

 OSHA regulations are often described as the “Shall” and NFPA 70E
as the “How” for electrical safety in the workplace.

 OSHA commonly cites the General Duty Clause and uses NFPA 70E
as evidence of compliance

 From an OSHA Letter of Interpretation dated July 23, 2003: “Industry

consensus standards, such as NFPA 70E, can be used by employers
as guides to making the assessments and equipment selections
required by the standard. Similarly, in OSHA enforcement actions,
they can be used as evidence of whether the employer acted
reasonably.”

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 NFPA 70E, Standard for Electrical Safety in the Workplace

 How does NFPA 70E differ from the National Electric Code
(NEC)?
– NFPA 70E is intended to provide work practices to minimize the
worker from electrical energy when using or working on or near
electrical equipment and conductors
– The NEC is intended to provide a safe electrical installation so
that equipment is safe when operating normally

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 NFPA 70E, Standard for Electrical Safety in the Workplace

 What work practices does NFPA 70E require?

– Chapter 1, Safety-Related Work Practices
• Article 100, Definitions
• Article 110, General Requirements for electrical Safety-Related
Work Practices
• Article 120, Establishing an Electrically Safe Work Condition
• Article 130, Working On or Near Live Parts

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 NFPA 70E Training Requirements

Employees shall be trained to understand specific hazards

associated with electrical energy
– Trained in safety related work practices and procedural
requirements for specific job or task
– Trained to understand relationship between electrical hazards and
possible injury
– Training shall be classroom or on-the-job type or combination
– Employees working on or near energized conductors shall be
trained in release of victims from contact

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 NFPA 70E Qualified Person

A qualified person shall be trained and knowledgeable of

construction and operation of equipment or work method
and trained to recognize and avoid hazard (110.6(D)(1))
– Familiar with precautionary techniques, personal protective
equipment including arc flash, insulating and shielding materials,
insulated tools and test equipment
– Distinguish exposed energized parts from other parts
– Determine nominal voltage of live parts
– Understand safe approach distances in Table 130.2C
– Determine personal protective equipment for task

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 NFPA 70E Job Briefing

Before starting each job, employee in charge shall conduct a

job briefing with employees involved. (110.7G)
– Identify hazards
– Identify procedures to be followed
– Special precautions
– Energy source controls
– Personal protective equipment

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 Electrical Safe Work Condition

Live parts to which an employee might be exposed shall be

put into an electrically safe work condition before an
employee works on of near them unless the employee can
demonstrate work on energized components can be
justified (110.8A)
– Deenergizing introduces additional or increased hazards
(Examples include interruption of life support equipment,
deactivation of emergency alarm systems, shutdown of
hazardous location ventilation equipment)
– Deenergizing is infeasible due to equipment design or operational
limitations. (Examples include start-up or troubleshooting
diagnostics and testing)
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 Electrically Safe Work Condition

 Infeasible
– adj : not capable of being carried out or put into practice

 Inconvenient
– adj : not suited to your comfort, purpose or needs
 “Financial considerations are not an adequate reason to
work on or near energized circuits” (Std. 1584-2002 IEEE)

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 Achieving an Electrically Safe Work Condition

An Electrically Safe Condition shall be achieved by completing all the

following
 Determine all sources of electrical supply (Drawings, diagrams)
 Open disconnecting device for each source
 Visually verify all blades of disconnecting devices are fully open or
drawout-type breakers are withdrawn
 Apply lockout/tagout devices in accordance with policy
 Test each phase conductor using adequately rated voltage detector
 Ground phase conductors where possibility exists for induced or
stored energy

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 Achieving an Electrically Safe Work Condition

Electrical conductors and circuit parts that have been

disconnected but not under lockout/tagout, tested and
grounded (where appropriate) shall not be considered to be
in an electrically safe work condition
– Safe work practices shall be used in this case identical to working
on or near exposed live parts
– Applies regardless of whether equipment is temporary,
permanent or portable

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 Energized Electrical Work

If live parts are not placed in an electrically safe work

condition, work shall be considered energized electrical
work
– A written Energized Electrical Work Permit shall be required
where live parts are not placed in an electrically safe work
condition.
– Exemption: work such as testing, troubleshooting, voltage
measurement shall be permitted to be performed without an
energized electrical work permit provided appropriate safe work
practices and PPE are provided and used.

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 Elements of Energized Electrical Work Permit

 Permit shall include the following items

– Description of circuit and equipment to be worked
– Justification for performing work in energized condition
– Description of safe work practices
– Results of shock hazard and flash hazard analysis
– Shock protection boundary
– Personal protective equipment
– Means to restrict access to unqualified persons
– Evidence of job briefing
– Work approval signatures
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Working on or Near Exposed Electrical Conductors or
Circuit Parts

Perform electrical hazard analysis if live parts (50 volts or

more) can not be placed in an electrically safe work
condition
 Shock Hazard Analysis (Determine limited, restricted and
prohibited approach boundaries and shock PPE)
 Flash Hazard Analysis (Determine arc flash boundary and
PPE for personnel within this boundary)
 Use Energized Electrical Work Permit

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Shock and Arc Boundaries

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 Limits of Approach – Limited Approach
Boundary

Prohibited Restricted Limited

The closest
distance an
Energized “unqualified”
panel person can
(<750V)
approach, unless
escorted by a
“qualified” person.
3 feet 6 inches for 480V

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 Limits of Approach – Restricted Approach
Boundary

Prohibited Restricted The closest distance to

exposed live parts a
“qualified” person can
Energized approach w/out proper
part
12 inches for PPE and tools.
480 volts To cross this boundary,
the qualified person must
wear PPE and have
proper tools.

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 Limits of Approach - Shock

Prohibited
Crossed ONLY by a “qualified”
person, which when crossed by
Energized body part or object, requires the
part
same protection as if direct
1 inch for contact was made with the live
480 volts part.

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Approach Boundaries for Shock Protection

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 Limits of Approach – Flash Protection
Boundary
•The distance from exposed
Flash live parts within which a
Protection person could receive a
Boundary second degree burn if an
Prohibited Restricted Limited arc flash were to occur.
•Arc flash PPE is required
within this boundary.
Energized •Note: Distance may be less
part than or greater than the
shock protection
boundaries.

Calculated distance

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 Flash Hazard Analysis

 An arc flash hazard analysis shall be done to protect

personnel from injury by arc flash exposure
 This analysis determines the flash protection boundary and
potential thermal exposure to personnel working on or near
exposure live parts within the boundary
 Personal protective clothing and protective equipment for
workers inside the flash protection boundary are then
selected to mitigate potential thermal exposure
 Equipment may be labeled with the results of the arc flash
hazard analysis and shock protection analysis

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Typical Equipment Label

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 Personal Protective Clothing

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 Examples of PPE

Hazard Risk
Hazard Risk Hazard Risk Hazard Risk Category 4
Hazard Risk Category 3
Category 0 Category 1 Category 2

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 Alternative to Flash Hazard Analysis

 The PPE requirements of NFPA 70E, 130.7(C)(9)(a) shall

be permitted in lieu of the detailed flash hazard analysis
– Use Table 130.7(C)(9)(a) to determine hazard/risk category for
task
– Ensure the short circuit capacities and fault clearing time for task
listed in the text and notes are not exceeded
– Use Table 130.7(C)(10) to determine the PPE for the task

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 Table 130.7(C)(9)(A)

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 Table 130.7(C)(10)

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 Example Using Alternative Method

Work task involves testing for absence of voltage inside a 480

volt MCC cubicle to establish a lockout point.
– What is the Hazard/Risk Category?
– What notes apply to the task?
– Are V-rated glove and tools required?
– What PPE is required for the Qualified Worker?

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 Example Using Alternative Method

Answer
 Refer to “600 V Class Motor Control Centers” section in Table
130.7(C)(9)(A) and choose task for “work on energized parts,
including voltage testing. Hazard/Risk Category is 2*
 Notes 2 and 3 apply to this task. Confirm with Engineering that short
circuit current of 65kA and 0.03 fault clearing time not exceeded. If
short circuit current < 10 kA, hazard/risk category can be reduced by
one number
 V-rated gloves and tools are required

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 Example Using Alternative Method

Using Table 130.7(C)(10), identify PPE requirement listed

under Category 2
– T-shirt
– Long sleeve FR shirt and pants or coveralls
– Hard hat
– Safety glasses or safety goggles
– Flash suit hood and hearing protection (2* footnote to Table
130.7(C)(9)(A) requires hood for this task)
– Leather gloves over voltage rated gloves
– Leather work shoes

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 Personal Protective Equipment Care

 Clothing shall be inspected prior to use by user.

– Clothing or flash suits that are damaged shall not be used.
– Clothing that become contaminated with grease, oil or flammable liquids or
combustible materials shall not be used.

 V-rated gloves shall be inspected prior to use by user. Shall be

tested and certified every 6 months.

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 Inspecting Voltage Rated Gloves in Field

•Visual Inspection

•Inflation

•Reverse glove and repeat

•Store in appropriate glove

bag

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 Precautions Working on or Near Live Parts

 Don’t reach blindly into areas that might contain exposed

live parts
 Provide illumination in spaces to enable safe work
 Conductive articles of jewelry and clothing such as
watchbands, bracelets, necklaces shall not be worn
 Use only insulated tools rated for voltage when working
inside the Limited Approach Boundary of exposed live parts
where contact might be made

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Typical Voltage Rated Insulated Tools

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 Alerting and Barricades

 How to protect the shock and arc flash approach

boundaries from an unqualified person?
– Barrier tape
– Orange cones
– Signage
– Plastic chain
– Use an attendant to warn others approaching the area

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 NFPA 70E Compliance for Subcontractors

 Summary
– NFPA 70E is more than just “Arc Flash” requirements
– Elements provided, but entire standard may be applicable
– Chapter 1 provides Safety-Related Work Practices
– Subcontractor responsible for own personnel safety
– Communication both ways is imperative

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