Subcontractor Electrical Safety & NFPA 70E

1. NFPA 70E Standard for Electrical Safety Requirements for Employee Workplaces 2004 Edition Subcontractor Electrical Safety & NFPA 70E Electrical Safety for Subcontractors and Subcontract Technical Representatives EFCOG Electrical Safety Task Group Module 8

2. 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 EFCOG Electrical Safety Task Group

3. 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. EFCOG Electrical Safety Task Group

4. 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.” EFCOG Electrical Safety Task Group

5. 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 EFCOG Electrical Safety Task Group

6. 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 EFCOG Electrical Safety Task Group

7. 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 EFCOG Electrical Safety Task Group

8. 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 EFCOG Electrical Safety Task Group

9. 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 EFCOG Electrical Safety Task Group

10. 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) EFCOG Electrical Safety Task Group

11. 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) EFCOG Electrical Safety Task Group

12. 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 EFCOG Electrical Safety Task Group

13. 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 EFCOG Electrical Safety Task Group

14. 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. EFCOG Electrical Safety Task Group

15. 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 EFCOG Electrical Safety Task Group

16. 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 EFCOG Electrical Safety Task Group

17. Shock and Arc Boundaries EFCOG Electrical Safety Task Group

18. Limits of Approach – Limited Approach Boundary Prohibited Restricted Limited The closest distance an “unqualified” person can approach, unless escorted by a “qualified” person. Energized panel (301V to 750V) 3 feet 6 inches for 480V EFCOG Electrical Safety Task Group

19. Limits of Approach – Restricted Approach Boundary 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. Energized part 12 inches for 480 volts EFCOG Electrical Safety Task Group

20. Limits of Approach - Shock 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. Energized part 1 inch for 480 volts EFCOG Electrical Safety Task Group

21. Approach Boundaries for Shock Protection EFCOG Electrical Safety Task Group

22. Limits of Approach – Flash Protection Boundary • 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. Flash Protection Boundary Prohibited Restricted Limited Energized part Calculated distance EFCOG Electrical Safety Task Group

23. 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 EFCOG Electrical Safety Task Group

24. Typical Equipment Label EFCOG Electrical Safety Task Group

25. Personal Protective Clothing EFCOG Electrical Safety Task Group

26. Hazard Risk Category 4 Hazard Risk Category 2 Hazard Risk Category 1 Hazard Risk Category 0 Hazard Risk Category 3 Examples of PPE EFCOG Electrical Safety Task Group

27. 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 EFCOG Electrical Safety Task Group

28. Table 130.7(C)(9)(A) EFCOG Electrical Safety Task Group

29. Table 130.7(C)(10) EFCOG Electrical Safety Task Group

30. 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? EFCOG Electrical Safety Task Group

31. 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 EFCOG Electrical Safety Task Group

32. 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 EFCOG Electrical Safety Task Group

33. 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 before first use and every 6 months thereafter. EFCOG Electrical Safety Task Group

34. Inspecting Voltage Rated Gloves in Field • Visual Inspection • Inflation • Reverse glove and repeat • Store in appropriate glove bag EFCOG Electrical Safety Task Group

35. 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 EFCOG Electrical Safety Task Group

36. Typical Voltage Rated Insulated Tools EFCOG Electrical Safety Task Group

37. 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 EFCOG Electrical Safety Task Group

38. 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 EFCOG Electrical Safety Task Group