Comments are in for the proposed updates to the 2009 edition
With 568 proposals and 817 comments, the latest revision cycle for the NFPA 70E, “Standard for Electrical Safety in the Workplace,” — published by Quincy, Mass.-based National Fire Protection Association (NFPA) — is well underway. According to some industry experts who attended the NFPA 70E Technical Committee Report on Comments (ROC) meeting in October, proposed revisions to the 2009 edition focus on clearer and more consistent definitions of words and phrases included in the document, as well as an attempt at refining the scope and purpose of the standard. The most substantial update could be the potential deletion of Chapter 4, making it a three-part standard for the first time since before the 2000 edition.
The proposed changes in both the Report on Proposals (ROP) and in its follow-up, ROC — which together make up the Technical Committee Report (TCR) — will be presented for action at the NFPA June 2008 Association Technical Meeting to be held June 2-6 in Las Vegas. The TCR Session will provide an opportunity for each proposed new or revised code or standard to be presented to the NFPA membership for debate and consideration of motions to amend the TCR. After membership voting, the document will be forwarded to the Standards Council for action on issuance. Subject only to limited review by the NFPA Board of Directors, the decision of the Standards Council is final, and the new NFPA code or standard becomes effective 20 days after Standards Council Issuance. The revised edition of NFPA 70E is scheduled for publication in 2009 and will mark the eighth edition of the standard (See History of NFPA 70E).
Article 90 introduction
In both the ROP and ROC, there were several proposed revisions to the document's introduction — Article 90 — with particular attention paid to the standard's scope and purpose. In the ROP, proposal 70E-3 recommended creating a new section — 90.1 Purpose — by moving the text from the 2004 edition's committee scope printed on page 5 and in 90.1(A) Scope. The revised section — 90.1(A) Practical Safeguarding — was intended to summarize the committee scope, pulling from new information and reworking the first sentence of 90.2(A) of the 2004 edition. The proposed text of 90.1(B) Intention originates with text from the NEC that was revised for use in the standard. “Relocating the purpose of the standard in this manner provides clarity,” wrote James Dollard, IBEW Local 98, Philadelphia.
There were several responses to Dollard's proposed revisions to the introduction. One major potential change, ROC 70E-4, requested the deletion of the phrase “in their pursuit of gainful employment” from 90.1(A). As modified, the first sentence in the proposed change would read: “(A) Practical Safeguarding. The purpose of this standard is to provide a practical safe working area for employees relative to the hazards arising from the use of electricity.” Calling the phrase “irrelevant,” Louis A. Barrios, Shell Global Solutions, Houston, urged the 70E committee to use this opportunity with the proposed changes in proposal 70E-3 to finally remove the phrase from the standard.
Also calling for a change in wording to proposal 70E-3, the Technical Committee accepted proposal 70E-4 recommended revising the proposed 90.2(A) to include “operation and maintenance” of electrical conductors. If accepted, it would read: “(A) Covered. This standard covers the installation, operation, and maintenance of electric conductors, electric equipment, signaling and communications conductors and equipment, and race-ways. …” According to the author of the proposal, Danny Liggett, DuPont, Wilmington, Del., the revision would clarify the coverage of operations and the maintenance of electrical equipment. “The current wording implies this standard only covers the ‘installation of’ and not other aspects of interaction with electrical equipment and components,” Liggett wrote in his substantiation.
In his vote on the proposal, ASTM Committee F18 representative, Allen H. Bingham, argued that the inclusion deviates from the scope of the standard's parent document, NFPA 70, NEC. “If accepted, this is the beginning of an increase in scope for the 70E standard,” Bingham wrote.
The revisions recommended by proposal 70E-3 also encountered opposition during the Technical Committee ROC meeting, but not because proposal 70E-3's suggested changes deviate too much from the scope of the NEC. In fact, Palmer Hickman, member of both the NFPA 70E Committee on Electrical Safety in the Workplace and Technical Correlating Committee (TCC) on the National Electrical Code, as well as director of the National Joint Apprenticeship Training Program, Upper Marlboro, Md., balked at the language in the proposal's wording because of its similarity to the NEC. In comment 70E-3, Hickman advocated proposal 70E-8 in lieu of proposal 70E-3. Initially rejected by the committee but accepted in part in the ROC, proposal 70E-8 recommends that the scope in the current version of 90.1(A) and (B) should remain unchanged from the current edition. Hickman cited the inclusion of new wording taken from the NEC as the main negative aspect of proposal 70E-3. “The scope of this standard should not cover the ‘installation of’ electric conductors, electric equipment, signaling and communications conductors and equipment, and raceways,” Hickman wrote. “There is an excellent code that addresses the ‘installation of’ electric conductors, electric equipment, signaling and communications conductors and equipment, and raceways. It is NFPA 70, the National Electrical Code (NEC). There is no reason to restate the scope of an installation document such as the NEC in NFPA 70E. It is inaccurate to state that NFPA 70E covers the installation of electric conductors, electric equipment, signaling and communications conductors and equipment, and raceways. It does not.”
Revisions to NFPA 70E are often complicated by the standard's close relation to the NEC, says James R. White, the alternate NETA representative on the NFPA 70E Committee on Electrical Safety in the Workplace and training director for Shermco Industries, Dallas. “The problem that we run into sometimes is that the NEC is an ‘installation’ document, and 70E is an ‘electrical safe work practice’ document,” he explains. “We really spent a lot of time addressing the fact that even when equipment is properly engineered, installed, and maintained people can interact with it in a way that could cause failure. It's not the equipment that creates the hazard. It's when we go to do something with the equipment that could cause a hazard.”
In comment 70E-6a, the TCC reminded the Technical Committee that the scope statement is the domain of the TCC. In reference to proposal 70E-3, it advised deleting the second sentence of 90.1(A) and that 90.2(A) read as follows: “90.2 Scope. (A) Covered. This standard addresses electrical safety requirements for employee workplaces that are necessary for the practical safeguarding of employees during activities such as the installation, operation, maintenance, and demolition of electric conductors and equipment, and raceways for the following. …” In taking this action, the TCC hoped to clarify that the NFPA 70E does not apply to the installation of systems, but to the electrical safety work practices that are related to an electrical system.
Also deemed out of the scope of the standard were several proposals to exclude exemptions for railway, communication, and utility workers, such as proposal 70E-7, 8, 10, 12, 13, and 14. “We knew it was out of the scope of the document when we did it, but basically we were making a statement,” White says. “Some of us feel that if you're doing this task, you face the same type of electrical hazards that other people do.”
Accepted in principle, comment 70E-14 supported rejecting a portion of proposal 70E-7, which proposed adding provisions for utility workers. The part 70E-14 urged to accept was the exemption for those working on installations under the exclusive control of an electric utility where such installations consist of overheard transmission and distribution at more than 1,000V. According to 70E-7, this work should be exempt because it is presently done using distance from energized parts as a tool to keep persons safe. “The electric utility industry has maintained a safe work environment with qualified employees following safe work practices for many years. Currently, there are several standards that govern the safe work practices of the electric utility industry. … We feel that the introduction of yet another set of requirements would possibly conflict with those existing standards, produce confusion, create misunderstanding, and possibly affect the safety of electric utility employees,” wrote D.A. Gaddy, Southern Co. Services, Atlanta.
Other comments rejected proposal 70E-7 on the basis that the IEEE National Electric Safety Code (NESC) already covers utilities. “Duplication of coverage in the NFPA could easily result in conflicting requirements between the codes, especially during rewriting cycles,” wrote Thomas Nanney, Jackson Energy Authority, Jackson, Tenn. “Utility infrastructure construction and maintenance should only be under the requirements of the NESC.”
Article 100 definitions
Other proposals introduced to avoid confusion and misunderstanding centered around Article 100 Definitions. “The main thrust of what we were trying to do this year was to make the document more consistent in its language,” says White, who was a member of the Word and Phrase Task Group at the technical meeting.
According to White, there were several words and phrases in the current edition that don't have a written definition, such as “working on or near.” His task group aimed to be as specific as possible. “If we were talking about a shock hazard, then we talked about being ‘within a limited approach boundary,’ instead of just ‘working on or near,’” he explains. “If we were talking about an arc-flash hazard, then we talked about being ‘within a flash-protection boundary,’ and if we were talking about more than one hazard, then we just said, ‘If you're exposed to an electrical hazard.’”
In the 2004 edition, the term “energized” occurs 81 times and “live” 71 times, yet the definition of “live parts” is listed as “energized conductive components.”
“We felt that ‘live’ was slang, along with ‘hot’ and ‘dead,’” White says. “They're jargon, so we went with ‘energized.’ When someone not in the industry is reading the standard, it has to be clear to everyone — not just a select few. It's going to take us awhile to hit the goals that we want with this, but I think we're well on our way.”
Several examples of these changes can be found in comment 70E-191b.
The ROP's first proposal — 70E-1 — recommended that all definitions used throughout the document be moved into Article 100 Definitions. “Currently, definitions are scattered throughout the document,” Bobby J. Gray, Fluor Corp., Irving Texas, wrote in the proposal. “In some cases, definitions used only in a particular section are listed in Article 100, while others are listed in the section or chapter where they appear. The document needs to be consistent. Either move specific definitions to the applicable section, or move all definitions to Article 100.”
In response to the proposal, in comment 70E-1, the TCC directed it be put on hold so that the Technical Committee can address the issue in the next revision cycle. The committee agrees that “usability is improved with a definitions chapter and that the approach makes this document consistent with other NFPA documents.” The TCC also wrote that with the deletion of Chapter 4 in NFPA 70E the number of definitions is greatly reduced, making the task simpler.
In comment 70E-191a, the TCC directed the NFPA staff to review all definitions used in NFPA 70E and remove any definitions that are no longer used in the document because of the deletion of Chapter 4. In the ROP, there were two calls for deleting Chapter 4 altogether, which were rejected by the Technical Committee, as well as several requests to significantly change its wording and update the section to correlate with the 2008 NEC. The theme of the substantiations calling for the deletion of the chapter was redundancy with the NEC and a reduction in page count that would increase NFPA 70E's usability. “We felt that people were better served using the Code,” White says. “There's always been an issue in updating the Code and extracting those parts to put into the 70E.”
In its response to the recommendations for deletion, the TCC wrote in comment 70E-719, “Chapter 4 should be deleted for a number of reasons. As noted in the foreword to NFPA 70E, all of the requirements in the NEC can be related to an electrical hazard and associated with employee safety. It does not seem prudent to include a potentially subjective abbreviated version of the NEC in NFPA 70E. In conclusion, Chapter 4 has outlived its usefulness. It needs to be deleted.”
In comment 70E-722, the Technical Committee wrote, “The committee accepts the direction of the TCC to reconsider and correlate with the final action on NFPA 70-2008. By the committee action taken on comments 70E-719, 720, 721, and 721a, Chapter 4 has been deleted.”
As a result of the deletion of Chapter 4, more changes will have to be made to the introduction, specifically Article 90.3. First, all mentions of “four” chapters will have to be updated to “three,” and Chapter 4 will also have to be deleted from the list of chapters and the figure that exhibits each chapter. This is in accordance with 3.4.2 and 3.4.3 of the Regulations Governing Committee Projects.
Tables and annexes
After only minor changes to the tables in the last revision cycle, the Technical Committee decided to tackle long-standing issues with the tables in this revision cycle. “In the last cycle, we couldn't really agree on the tables,” White says. “We really had difficulty coming to consensus, and it actually delayed the release of the last 70E edition.”
In that cycle, what the committee decided to do was use the 2000 tables with very minor changes, but in the current cycle it tackled all the things it wanted to change, such as adding technology updates. The tables were then made consistent within themselves and consistent with the rest of the document.
According to White, there were 139 proposals directly related to the tables and another 98 that had an impact on the tables in some way. “That's 237 proposals just dealing with the tables, which is almost half of what was submitted,” he says.
Proposals regarding the tables were directed at calculation methods for incident energy and flash protection boundaries and determining and layering personal protective equipment (PPE). “A lot of people submitted changes for the 130.7C10 table, which is the PPE matrix,” White says. “We took what we thought was the best of the proposals and merged them. So we're going to have a hazardous category number, and then it's going to have all the PPE that you need for that hazardous category in an adjacent column, so it's not going to be all strung out. It should be a lot easier to read.”
There were several table additions too. “We added tasks related to work on utilization equipment,” White says. “There was no hazardous category or task in the table for that, so we added some. And we added arc-resistant switchgear. We recognized that if you have arc-resistant switchgear properly secured and closed, it eliminates the arc flash hazard. But if the door is open or not properly secured, it has no additional benefit. So we reselected that in the tables.”
There are numerous changes in the notes section of the document as well. For instance, the Technical Committee eliminated the -1 hazardous category. It also changed the format of the table, eliminating confusion caused by the columns.
Many of the proposals and comments in this revision cycle were in the interest of cleaning up the document. “A lot of companies use the 70E as their safety policy, so you have to be very careful how you word things,” White says. “This is an evolutionary process with this document.”
On his second cycle on the 70E Technical Committee, White argues that the disagreement within the TCR is for a larger, better end. “Not that we were contentious,” he says. “It's just that, without exception, everybody on that committee is fully committed to doing what's best for the worker. There are some pretty spirited discussions, but by the end of the day I think we've come up with a very good document.”
Sidebar: History of NFPA 70E
Currently in its eighth revision cycle, NFPA 70E, “Standard for Electrical Safety in the Workplace,” has undergone many changes since it was first published in 1979. Following is a time line of the development of — and revisions and additions to — the standard:
1979 — Three years after the Standards Council of the NFPA formed the Committee on Electrical Safety Requirements for Employee Workplaces, NFPA 70E, the first edition is published. The architects of the new standard, NFPA 70E, “Standard for Electrical Safety Requirements for Employee Workplaces,” outlined four major parts for the standard: Part I, Installation Safety Requirements; Part II, Safety-Related Work Practices; Part III, Safety-Related Maintenance Requirements; and Part IV, Safety Requirements for Special Equipment. The parts were designed to work as a whole as well as to permit their separate publication. The first edition included only Part I.
1981 — The second edition included Part I as originally published and a new Part II.
1983 — The third edition included Parts I and II as originally published and Part III.
1988 — The fourth edition was published with only minor revisions.
1995 — The fifth edition included major revisions to Part I, updating it in accordance with the 1993 edition of the NEC. Part II of this edition introduced “limits of approach” and established an “arc.”
2000 — The sixth edition included a total revision of Part I, following the 1999 NEC, and introduced Part IV. In this edition, Part II focused on establishing flash protection boundaries and the use of personal protective equipment (PPE). For the first time, it included charts to assist the user in applying appropriate protective clothing and PPE for common tasks.
2004 — The current and seventh edition included several significant revisions. These included an emphasis on safe work practices, a name change to the current title, and reformatting to comply with the NEC style manual, which gives a unique designation for each requirement. The four parts were turned into chapters and were reorganized with the safety-related work practices relocated to the front of the document to highlight the emphasis, followed by safety-related maintenance requirements, safety requirements for special equipment, and safety-related installation requirements. The chapter on safety-related work practices also was reorganized to emphasize working on live parts as the last alternative work practice. Requirements for energized electrical work permits were introduced, and several definitions were modified or added for clarity. Finally, Chapter 4 was updated to correlate with the 2002 NEC.
Sidebar: Oh! Canada
Although Canadians claim a stricter training system and regulation process — province to province — for its trade workers than what's available state to state in its neighbor to the south, some Canadian industry experts admit there has only been a limited awareness of electrical worker safety in its curriculum and out in the field. That will soon change with the adoption of Canadian Standards Association (CSA) Z462. The standard is essentially NFPA 70E-2004 adapted for Canada and revised to correlate with NFPA 70E-2009 revisions. The Canadian standard is scheduled for publication in October 2008.
“What you'll find up here is that the trades are quite regulated, but we didn't have a standard for safe work practices around electrical hazards at all,” says Terry Becker, P.Eng., C.E.M., member of the CSA Z462 Technical Committee, first pass vice chair of Z462, and CEO and owner of Electrical Safety Program Solutions (ESPS), Calgary, Canada. “We just didn't.”
Canada's provinces and territories set their own Occupational Health and Safety (OH&S) acts and regulations. In 2004, Alberta's regulation began recognizing the hazards of arc flash. “It's not that energized electrical work wasn't covered in some of these OH&S regulations,” Becker says. “It's just that they didn't uniquely identify the arc flash hazard.”
What happened to change that was the NFPA 70E arrived in Canada through a few engineering conferences. “That sort of just kicked things off,” Becker says. “All of a sudden in Canada we said, ‘Wow! We've neglected this arc flash hazard.”
CSA had just finished work on a new lockout standard, CSA Z460, “Control of Hazardous Energy - Lockout & Other Methods,” which referenced NFPA 70E. In addition, CSA was working behind the scenes with NFPA on a memorandum of understanding (MOU) to harmonize standards for North America, which was signed in December 2005. This led to Z462 becoming the first standard that will be harmonized under the agreement. It will be a national standard that is technically consistent with 70E, although structurally it will appear different through the use of the CSA style guide. There will also be an additional five annexes to add clarity to specific issues, such as arc flash and shock labeling and personal protective equipment (PPE).
“It seemed like the stars were aligning on recognizing arc flash at the same time, admitting that we hadn't really managed shock properly, uniquely recognized arc flash, and the CSA signing a historic deal with NFPA to work collaboratively on harmonizing standards,” Becker says. “It has already fundamentally started to change how energized electrical work occurs here in Canada. It's like night to day. Three years ago, if electricians had anything on they might have had rubber insulating gloves but that's it. Most of the time, they wouldn't bother to put them on.”