# Presentation: 033287

## Subcontractor Electrical Safety & NFPA 70E 

**Electrical Safety for Subcontractors and Subcontract Technical Representatives**
**EFCOG Electrical Safety Task Group**
**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 **

## 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. 

**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. **

**NFPA 70E, Standard for Electrical Safety in the Workplace**

**Notes:**
(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.). Whenever outside servicing personnel are to be engaged in activities
covered by the scope and application of this standard, 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,
and emergency/evacuation procedures applicable to the work to be performed. This coordination shall include a
meeting and documentation.

## 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.”**

## 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**

**Notes:**
NFPA 70E is all about work practices, whereas the NEC is primarily about facility installation. NFPA 70E provides for work practices that minimize exposure to electrical hazards associated with equipment or installations that are or are not covered by the NEC. The intent is for NFPA 70E to be all-inclusive where potential exposure to injury from an electrical energy source exists. The intent of NFPA 70E is to provide practices that are needed to protect both qualified and unqualified persons from exposure to hazards associated with electrical energy. 

## 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**

##  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**

**Notes:**
• Understanding the specific hazards associated with electrical energy and knowledgeable of the construction and operation of the equipment to recognize and avoid electrical hazards that might be present with respect to that equipment or work method.
• Safe-related work practices and procedure requirements as necessary to provide protection from electrical hazards.  
• Trained to identify and understand the relationship between electrical hazards and possible injury and methods of release from contact with exposed energized conductors or circuit parts.
• Describe type's) of training – classroom or on-the-job or a combination of the two.
• Degree of training determined by the risk to the employee.
• Address qualified and non-qualified worker training on and near exposed energized electrical conductors or circuit parts.

##  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**

**Notes:**
Section 110.6(D)(1) requires that a qualified person must be knowledgeable and familiar with certain aspects of executing electrical work. Note that the terms knowledgeable and familiar are synonyms for each other. To establish that an employee is knowledgeable or familiar with details of executing electrical work, employee understanding must be established in some way. Employers should establish and maintain documents that provide evidence of the qualifications of each employee. The documentation also should define the limits of each employee’s qualification.
A qualified person might understand the shock hazard and have only a passing knowledge of other electrical hazards. In that case, that person must not perform work tasks that expose him or her to the other hazards. For instance, an instrument technician who is exposed to a maximum circuit voltage of 120 volts and maximum circuit size of 30 amperes may not require arc flash training. However, if the same person performs work where an arc flash hazard exists, he or she must understand that exposure and be qualified for that task. A qualified person must be able to recognize all electrical hazards within the realm of his or her work assignment. He or she must be trained to understand and implement the procedural requirements of the employer. He or she also must be able to select and use adequate protective equipment.

##  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**

**Notes:**
A job briefing is a discussion of the work task.  The briefing must be held prior to beginning each work task associated with work on or near live parts.  As a minimum, the discussion should include the following: 

Electrical hazards associated with the work task
Procedures that must be followed when executing the task
Any special precautions that are required for the working conditions
Where and how to remove the source of energy
Emergency response and communications
Required PPE
Other work in the immediate area
Other work associated with the same electrical circuits

##  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)**

**Notes:**
The primary protective strategy must be to establish an electrically safe work condition. After this strategy is executed, all electrical energy has been removed from all conductors and circuit parts to which the worker could be exposed. After the electrically safe work condition has been established, no PPE is necessary, and unqualified workers are permitted to execute the remainder of the work.
The only exception to this requirement is if deenergizing the circuit conductors or equipment cannot be justified as described in the following list. Justification for work on or near exposed live parts must be in writing. A qualified person may perform work on or near exposed live parts under the following conditions:
• Deenergizing the conductors or equipment could result in an increased hazard. For instance,
a life support system might be dependent on the continuation of the electrical service.
• Deenergizing the conductors or equipment could require a complete shutdown of a continuous process. For instance, the design of the electrical circuit is such that a continuous processing facility must be completely shut down.

## 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)**

**Notes:**
The difference between infeasible and inconvenient is significant. In some instances, an employer treats the terms infeasible and inconvenient interchangeably. This paragraph is intended to ensure that inconvenient cannot serve to justify work on or near exposed live parts. If work is performed on or near an exposed energized electrical circuit, the employer must be able to document that the work task meets the criteria for one of the acceptable reasons for executing the work with the circuit energized.

##  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**

**Notes:**
An electrically safe work condition does not exist until all of the six steps of 120.1(1) through 120.1(6) have been completed. Until then, workers might contact an exposed live part. If an electrically safe work condition does exist, no electrical energy is in proximity of the work task(s). All danger of injury from an electrical hazard has been removed, and neither protective equipment nor special safety training is required. However, other hazards might remain.

##  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**

##  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.**

**Notes:**
The requirement for an energized electrical work permit is new in the 2004 edition of NFPA 70E. Section 130.1(A)(1) correlates with OSHA requirements to deenergize equipment and circuits except when it is infeasible to do so. Permits that cover routine work tasks to be performed by trained and qualified employees can be written to cover a long period of time. For instance, a worker might be trained and qualified to replace a fuse that involves an exposed live part. If the worker is trained to understand the electrical hazards associated with exchanging the fuse and is wearing any necessary PPE, a permit might be issued that covers, for instance, a three-month period. If the work is unusual or other than routine from any perspective, the work task must be
covered by an energized work permit. Experience shows that electrical workers tend to accept risk of exposure, believing that they are capable of managing the risk. Experience also shows that managers are less likely to accept increased risk of injury. The energized work permit is intended to ensure that the increased risk (and increased possibility of injuries) associated with exposure to an exposed live part receives adequate consideration.

## 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**

**Notes:**
When the energized work permit is executed, the items listed in 130.1(A)(2) must be considered, and the permit should provide evidence of their consideration. Note that these items evidence the fact that consideration of electrical hazards is of primary importance.

##  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**

**Notes:**
Qualified workers who are permitted to work on or near exposed energized conductors or circuit parts must select and use work practices that provide protection from shock, arc flash, and other electrical hazards. The work practices that are used must minimize any potential for injury. For instance, body position is one factor that a qualified person should recognize as an element of the analysis that could reduce exposure to electrical shock or arc flash. The hazard/risk analysis must determine whether any conductor will remain energized for the duration of the work task. The analysis must determine the shock approach boundaries and the Flash Protection Boundary.
Both a shock analysis and an arc flash analysis are required before any person is permitted to approach the exposed live part. These analyses must answer the following questions:
• Does a shock hazard exist? Will the worker be exposed to the shock hazard at any point during the work task?
• What is the degree of the hazard? What protective equipment is necessary to minimize the exposure?
• Does an arc flash hazard exist? Will the worker be exposed to a thermal hazard at any point during the work task?
• What is the degree of the arc flash hazard? What protective equipment is necessary to minimize exposure to the thermal hazard?
• Does a co-occupancy hazard exist? What measures will be taken to minimize the impact of other work?
• Will other workers be exposed to an electrical hazard because of the work task? Will the worker be exposed to any other electrical hazard while executing the work task?
• What authorization is necessary to justify executing the work task while the exposed conductor(s) is (are) energized?

##  Shock and Arc Boundaries

**Notes:**
More than one electrical hazard exists to employees working on or near live parts. Section 130.2 is intended to minimize exposure to shock and electrocution. Shock approach boundaries are identified as Limited, Restricted, and Prohibited. Crossing one of these approach boundaries increases the chance that a worker might contact an exposed live part. A person must be qualified before he or she can cross the Limited Approach Boundary. To cross the Restricted Approach Boundary, in addition to being a qualified person, the person must also wear PPE for protection from shock. The Limited Approach Boundary is intended to restrict the approach of unqualified persons. The Restricted Approach Boundary is intended to restrict the approach of qualified persons

## Limits of Approach – Limited Approach Boundary

**Energized panel (<750V)**

**Prohibited**

**Restricted**

**Limited**

**3 feet 6 inches for 480V**

- The closest distance an “unqualified” person can approach, unless escorted by a “qualified” person.

## Limits of Approach – Restricted Approach Boundary

**Energized part**

**Prohibited**

**Restricted**

- The closest distance to exposed live parts a “qualified” person can approach w/out proper PPE and tools.
- To cross this boundary, the qualified person must wear PPE and have proper tools.

**12 inches for 480 volts**

## Limits of Approach - Shock

**Energized part**

**Prohibited**

- Crossed ONLY by a “qualified” person, which when crossed by body part or object, requires the same protection as if direct contact was made with the live part.

**1 inch for 480 volts **

## Approach Boundaries for Shock Protection

**Notes:**
Section 130.2(C) defines requirements that must be observed before a qualified person can cross the Restricted Approach Boundary. This section recognizes that a tool or other object is considered to be an extension of the person’s body. If a worker is holding an object in his or her hand, the requirements of this section apply to both the worker and the object. The effect of these requirements is that the worker (or extended body part) is prevented from being exposed to any difference of potential greater than 50 volts. The purpose of columns 2 and 3 of Table 130.2(C) is to recognize that the possibility of contacting an electrical conductor that can move is greater than the possibility of contacting an electrical conductor that is fixed in place with no possibility of moving. This risk is associated with the relative position of the conductor and the worker. If that distance can vary because the conductor can move (such as a bare overhead conductor or a conductor installed on racks in a manhole), or if the distance can vary because the platform (articulating arm) on which the employee is standing can move, then column 2 applies. The Restricted Approach Boundary accounts for some inadvertent movement by the worker. In other words, a worker might move his or her hand unintentionally. The inadvertent movement adder accounts for this unintended movement.

## Limits of Approach – Flash Protection Boundary

**Energized part**

**Prohibited**

**Restricted**

**Limited**

- The distance from exposed live parts within which a person could receive a second degree burn if an arc flash were to occur.
- Arc flash PPE is required within this boundary.
- Note: **Distance may be less than or greater than the shock protection boundaries.**

**Calculated distance**

**Flash Protection Boundary**

## 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**

**Notes:**
The purpose of a flash hazard analysis is to determine if a thermal hazard exists and to select protective equipment necessary to mitigate exposure to the hazard. An arc flash analysis is a review of an electrical circuit to determine its capacity to deliver sufficient energy to cause a thermal burn from an arcing fault. The primary purpose of the analysis is to determine the distance from the potential arcing fault point that will expose a person to a second-degree burn (Flash Protection Boundary). Any body part that is closer to the potential arcing fault must be protected from the thermal effects of that fault. The analysis must determine that point. The Flash Protection Boundary can be determined by individual calculations at a specific point in a circuit or with the use of labels (or another communication method) that indicate the Flash Protection Boundary. The Flash Protection Boundary is intended to trigger the need for PPE that can protect the worker from potential thermal injury. After the Flash Protection Boundary is determined, the worker must be able to select PPE that will minimize the possibility of a second-degree burn.

##  Typical Equipment Label

## Personal Protective Clothing

**Notes:**
Table 130.7(C)(11) is intended to provide general information that could assist a worker understand the process for selecting clothing based on a hazard/risk category designation. This table describes the protective nature of clothing that meets a specific hazard/risk category. Although the table is intended for use in conjunction with Table 130.7(C)(9)(a), it can be used with other methods of determining the necessary protective clothing.

## Examples of PPE

**  **

## 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**

**Notes:**
Table 130.7(C)(9)(a) lists common work tasks and may be used to determine a hazard/risk category. A hazard/risk, including an arc flash analysis, has been performed for each common task listed in the table. The hazard/risk analysis (arc flash analysis) is based on parameters that commonly are found in industrial workplaces and are identified as notes at the bottom of the table. An arc flash analysis must be performed for fault-clearing times and short-circuit capacities that exceed the information contained in the notes. The work tasks and protective equipment identified in Table 130.7(C)(9)(a) were identified by a task group, and the protective equipment selected was based on the collective experience of the task group. The protective equipment is not necessarily based on calculations, but it is considered to be reasonable, based on the consensus judgment of the full 70E Technical Committee. The protective equipment identified in Table 130.7(C)(9)(a) considers both electrical circuit parameters and the physical attributes of the equipment and work task. 

## Table 130.7(C)(9)(A)

**Notes:**
The protective equipment identified in Table 130.7(C)(9)(a) considers both electrical circuit parameters and the physical attributes of the equipment and work task. Work tasks that are not listed in the table must be subjected to a hazard/risk analysis that considers both shock and arc flash hazards.

## Table 130.7(C)(10)

**Notes:**
The protective clothing matrix is intended to provide helpful information. FR clothing is available in many different constructions. Using FR clothing in layers is one way to achieve a higher level of protection. Table 130.7(C)(10) suggests acceptable combinations of clothing items to achieve a desired hazard/risk category. Other combinations might also be possible. Section 130.7 requires that any body part within the Flash Protection Boundary be protected from the thermal effects of an arcing fault. Defining a hazard/risk category is a viable way to translate incident energy exposure to selection of FR clothing.

##  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?**

## 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**

## 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**

## 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.**

**Notes:**
The qualified worker must inspect his or her FR clothing before wearing it. The qualified worker should be trained to understand that if any flammable substance is on the surface of the FR clothing, the rating of the FR clothing is voided. The clothing must be free from tears or rips. Maintenance instructions provided by the manufacturer must be followed to ensure that the protective characteristics of the clothing are maintained.

## Inspecting Voltage Rated Gloves in Field

**Visual Inspection**
**Inflation**
**Reverse glove and repeat**
**Store in appropriate glove bag**

## 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**

## Typical Voltage Rated Insulated Tools

## 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**

## 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**