EC&M NFPA 70 E General Requirements
EC&M NFPA 70 E General Requirements
EC&M NFPA 70 E General Requirements
“Hazard elimination shall be the first priority in the implementation of safety-related work practices.” So begins NFPA 70E, Art. 110
in the 2021 revision. This is a very powerful statement that, in only a few words, provides the rationale behind much of what
follows.
If you had never heard of NFPA 70E, never had any safety training, and did not have safety procedures but still had this one concept
and took it seriously, how safe would you be? You would be far safer than someone who has the other three but does not internalize this
concept.
Think of a jigsaw. Twenty years ago, you had to run a portable cord to be able to use the saw to cut those dozens of drywall holes in the
commercial office space you were wiring. Without good cord management, you had a tripping hazard.
Along came battery-powered jigsaws with sufficient battery to be useful on the job. Using this tool, you eliminate that tripping hazard.
The problem now is the silica dust from the saw. So you wear a suitable fiber respirator. But it clogs up and has to be replaced often.
Plus you get dust in your eyes and all over your clothes.
Along came battery-powered jigsaws with dust collectors. Using this tool, you eliminate yet another hazard.
Why do we perform lockout/tagout (LOTO)? To eliminate a hazard. If you read through Art. 130, Work Involving Electrical Hazards,
you will find many more examples.
Now, suppose you encounter a hazard you have not seen before. Is your first priority to obtain the correct PPE? No, your first priority is
to eliminate that hazard. If you cannot immediately see how to eliminate the hazard, that does not mean you should find a way to
accommodate it. Because it is your first priority, finding a way to eliminate it is worth some extra effort.
Review the system drawings and any other documentation for that system or equipment. Ask the operators, the system engineer,
your supervisor, and anyone else who may provide some insight. If the system can’t be shut down, perhaps it can be temporarily
bypassed. Or perhaps it can be shut down later so you can work on it with several hazards eliminated.
In some cases, a hazard elimination method is identified but cannot be implemented in time for this particular job. For example,
infrared thermography is conducted on the same switchgear annually. There’s no infrared window to eliminate cover removal. That can
be scheduled for installation during the next shutdown, thereby eliminating a hazard for the next time this job is performed.
At one time, you assumed electrical conductors and circuit parts were in an electrically safe condition unless you had some reason
to suspect they weren’t. Today, you assume electrical conductors and circuit parts are not in an electrically safe condition until you
prove they are.
What is that proof? All of the requirements of Article 120 are met. Those requirements are centered on lockout/tagout. In other words,
to ensure the equipment is safe to work on, shut it down and lock it out. But there are some exceptions:
1. Shutting it down creates an even greater risk than working it energized [110.4(A)].
2. It just is not feasible to shut it down and lock it out [110.4(B)]. You can’t establish an electrically safe working condition, which
means a hazard exists.
3. Below levels of 50V, shutting it down isn’t required if specific considerations are made and it’s determined there’s no increased
exposure to electrical burns or explosion due to arcs [110.4(C)].
Some kinds of testing will require normal operation of the equipment. But when is normal operation of equipment even permitted? It is
permitted only when you have normal operating conditions, a situation that exists only when all of the following are met:
What about performing thermography on equipment that isn’t functioning properly? Clearly, that’s not normal. You can’t shut it down
before performing the thermographic scans, and you can’t perform thermography with doors and covers closed and secured.
Further, the problems might be because equipment isn’t properly installed. For example, connections were made without using a
torque wrench. Or it might not have been properly maintained because people simply tightened what they thought were loose
connections. These are exactly the issues where thermography is commonly used for identifying the hotspots created at those poor
connections.
Those are good points. These and other real-world considerations are why we have Article 130. Article 130 is about what to do when
you don’t have normal operating conditions and the equipment needs to operate or at least remain energized. The process begins with
an energized electrical permit [130.2] if either of these conditions exists:
1. Work is performed within the restricted approach boundary.
2. The employee interacts with the equipment when conductors or circuit parts are not exposed but an increased likelihood of
injury from an exposure to an arc flash hazard exists.
Article 130 is tedious and complex to apply. Always try to go the Article 120 route first. Make shut it down and lock it up your preferred
strategy.