Every three years, the world has an opportunity to evaluate how we can be safer when working around electricity. NFPA 70E, Standard for Electrical Safety in the Workplace, is revisited on a triennial basis, at which time public input that has been submitted is assessed and suggested changes to the standard are considered. As the name not only implies but also clearly states, NFPA 70E is the standard on how to be safe when working on and around electricity.
Although created at the request of the United States Department of Labor - Occupational Safety and Health Administration (OSHA) as a performance-based means to fulfill OSHA’s prescriptive-based requirements, NFPA 70E has become the world’s go-to document for protecting personnel by reducing exposure to electrical hazards in the workplace. The 2021 cycle of NFPA 70E considered many valuable suggestions that were submitted by people from all over the world. During the NFPA standards development process, the “Electrical Safety in the Workplace” technical committee that oversees NFPA 70E evaluated 332 Public Inputs (resulting in 86 First Revisions) during the First Draft and 115 Public Comments (resulting in 45 Second Revisions).
Revision cycle changes can often be separated into two buckets: 1) those that impact the standard itself; and 2) those that impact the person using the standard. In some cases, the change dips into both buckets to some extent. Changes that fall more into impacting the standard itself are those that bring more clarity to a section or better alignment with other codes and standards, such as the National Electrical Code (NEC). These changes often help the end-user to better understand the book but don’t necessarily change anything regarding processes or procedures — like those that primarily impact the end-user of a standard. Although the 2021 NFPA 70E cycle saw a variety of changes, those incorporated were somewhat weighted toward those that impacted the standard itself. Some changes of note for this cycle include:
Standard impact changes
- Article 100 – General Definitions: Within Art. 100, several terms were deleted because they were not used within the context of NFPA 70E. These included definitions for Accessible (as applied to wiring methods), Accessible, Readily (Readily Accessible), and Branch Circuit. The word exposed was added to the existing definition of shock hazard to further indicate that parts must be exposed to be a hazard.
- Article 100 – Electrically Safe Work Condition: An Informational Note was added to the definition for Electrically Safe Work Condition (ESWC) that clarifies that an ESWC is not a procedure but is a state wherein all hazardous electrical conductors or circuit parts to which a worker might be exposed are maintained in a de-energized state for the purpose of temporarily eliminating electrical hazards for the period of time for which the state is maintained. Section 110.1 also saw informational Note No. 2 added that again clarifies how an ESWC is defined and expounds upon how it ties into Art. 120, which gives the requirements for establishing an ESWC.
- Article 110: Some requirements in Art. 110 have been reorganized for a more logical progression, including moving general principles of lockout/tagout (LOTO) from Sec. 120.2(A) to revised Sec. 110.2 and general principles of an electrically safe work condition and energized work requirements from Sec. 130.2 to revised Sec. 110.3. There were several PIs received stating that Sec. 130.2 should be moved to Art. 110. After review of the PIs, the committee created First Revision No.93-NFPA 70E-2018 which justified their decision with a committee statement that read: “Locating the requirement to de-energize in Art. 110 prioritizes and emphasizes the requirement: the requirement to de-energize is a requirement of an Electrical Safety Program; the requirement to de-energize should be located before lockout requirements; and Art. 130 can be focused on requirements related to work involving an electrical hazard. The voltage threshold of 50V is used to be consistent with previous actions taken during the last revision cycle.”
- Section 110.5(K): A new section was added that requires electrical safety programs to include a policy on establishing an electrically safe work condition.
- Section 110.5(L): A new section was added that clarifies the lLOTO program must be either part of the electrical safety program (ESP) or the ESP must reference the LOTO program.
- Article 130: Sections 130.1 and 130.2 have been rewritten to accommodate the relocation of information from former Sec. 130.2(A) to Sec. 110.3 and to keep the focus of Art. 130 on requirements related to work involving electrical hazards.
User impact changes
- Table 130.5(C): Revisions have been made to Table 130.5(C), which can be used to help estimate the likelihood of occurrence of an arc flash incident, including a new entry for the initial circuit breaker or switch operation and again after maintenance, as each has a higher likelihood of an arc-flash event.
- Section 350.9: Energy thresholds for electrical equipment and systems in laboratories have been revised to accurately reflect the data in the Informational Note’s resource document, and the capacitive circuit threshold has been deleted to prevent duplication and potential confusion with new Art. 360.
- Article 360 and Annex R: New Art. 360 was added to provide safety-related requirements for working with capacitors. Annex R was also added providing further information for technicians that are working with capacitors. Prior editions of NFPA 70E did not contain requirements for working with capacitors, which can be unique in their dangers due to stored energy.
There is also some crossover as to how NFPA 70E changes can impact both the standard and the user. Every change to the standard technically impacts the user even if only from a clarity aspect when reading the document. Some changes are easier to look at and understand; they really just impact the document, such as removing definitions that are not utilized within the standard. Others impact the processes and procedures employees and employers must follow to ensure safety when working with electricity.
The Informational Note that was added to the definition for an “Electrically Safe Work Condition” is a great example of having an impact in both aspects. It brings clarity within the context of the standard that an ESWC is not considered to be a procedure but goes on to state exactly what an ESWC is, which directly impacts the end-user by knowing what an ESWC entails. Depending on perspective and knowledge of NFPA 70E, an argument could likely be made that many changes impact both the standard and the end-user, whether that be an employer or employee.
Revisions to the 2021 NFPA 70E standard have made a lasting impact on electrical safety. Those changes were brought about by some valuable public contribution that was provided during the standards development process. But our work isn’t done. The 2023 NFPA 70E standards development process is already in motion with the public input stage having closed on June 1, 2021. The first draft of the 2023 NFPA 70E will be posted on March 22, 2022, at which time the public comment stage will remain open until May 31, 2022. Make your voice heard. Electrical safety is a continuing journey, not a destination. For your well-being, and of those around you, you must come along for the ride. The wheels are in motion.
Corey Hannahs is a Senior Electrical Specialist at the National Fire Protection Association (NFPA). In his current role, he serves as an electrical subject matter expert in the development of products and services that support NFPA documents and stakeholders. Corey is a third-generation electrician, holding licenses as a master electrician, contractor, inspector, and plan reviewer in the state of Michigan. Having held roles as an installer, owner, and executive previously, he has also provided electrical apprenticeship instruction for more than 15 years. Corey was twice appointed to the State of Michigan’s Electrical Administrative Board by former Governor Rick Snyder, and he received United States Special Congressional Recognition for founding the B.O.P. (Building Opportunities for People) Program, which teaches construction skills to homeless and underprivileged individuals. He can be reached at [email protected].