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Four Parties Affected by NFPA 70E Updates in 2018

• Dec 01, 2017

As an industry standard, NFPA 70E outlines elements of an electrical safety program to protect workers from high-risk electrical hazards they come into contact with, day in and day out. OSHA clearly states the "what," that employers shall protect their employees from electrical hazards, and NFPA 70E frames "how."

Electrical workers face a number of hazards—arc flash hazards being one of the major ones—so NFPA 70E helps to foster safer environments for these workers. Through proper understanding and application, NFPA 70E helps to reduce the frequency and severity of such electrical hazards.

NFPA published the latest edition of NFPA 70E in September 2017. While many of the changes specifically relate to employers, there are also updates impacting employees, contactors, and manufacturers and suppliers of PPE. It is critical to understand how the changes to NFPA 70E pertain to you.

At its core, the latest update reiterates and reinforces the concept of an electrical safety program and highlights the importance of the hierarchy of risk controls. The 2018 edition continues to advocate implementation of safety-related programs and procedures and still mandates arc-rated clothing and PPE when working energized. Working de-energized is still the clearest path toward hazard elimination. Energized work is an option only when it is either infeasible or when de-energizing creates additional hazards and risks.

It is worth noting that the process of de-energizing a system is energized work. Until the absence of voltage is verified, any work done is still considered energized and, therefore, requires appropriate hazard protections, such as arc-rated PPE.

The updated NFPA 70E can be explored through the lens of parties impacted. Through analyzing party responsibility, safety engineers and managers can make informed decisions to comply with the updated standard. A thorough understanding of the changes will also help guide various elements of any electrical safety program, including creating and documenting work procedures, training employees, eliminating hazards, and implementing appropriate AR/FR PPE programs.

Employer Responsibilities
Article 105: Application of Safety-Related Work Practices and Procedures
This section clearly articulates responsibilities for both employers and the employees. For employers, the updates state that all required work practices and procedures should be established, documented, and implemented. Employers will also be required to provide safety-related training for all employees.

The new article 105.4 Priority highlights an emphasis on the hierarchy of risk controls and clearly positions hazard elimination as first priority in implementing any safety-related practices and procedures.

Article 130: Work Involving Electrical Hazards
As mentioned, an overarching theme of 2018 NFPA 70E stresses the hierarchy of risk controls. Updates reference de-energized work and, from an employer standpoint, there are a few important considerations to incorporate into energized work practices and procedures.

When de-energizing is infeasible or creates an additional hazard, working energized is an option and will require appropriate arc-rated PPE. Section 130.5 provides new information regarding an arc flash risk assessment and includes new sections and tables to determine the likelihood of occurrence and the potential injury severity from an arc flash hazard. The Table 130.5 (C) uses a yes/no format to easily discern whether there is a likelihood of occurrence of an arc flash incident when working on certain tasks and equipment. An affirmative listing in the table leads to action requiring additional protective measures, which includes PPE use.

As in previous editions, one of the following methods, but not both, shall be used for selecting arc flash PPE:

1. Incident Energy method: This method selects arc-rated clothing and PPE using Table 130.5(G): Selection of Arc Rated Clothing and other PPE.

2. Arc Flash PPE Category method: This method utilizes Table 130.5(C) and a series of tables in 130.7(C)(15) to determine arc flash PPE categories, arc flash boundary, and the minimum arc ratings needed for arc-rated clothing and PPE.

With emphasis on de-energizing and the continued use of the NFPA 70E tables for arc flash PPE selection, employers are more firmly positioned in mitigating electrical work hazards. Employers should set the tone for working completely de-energized and implement guidelines to govern both de-energized and energized work practices and procedures.

A major change in the 2018 edition of NFPA 70E is the removal of mandatory compliance language specific to PPE standards. The standard now states that PPE shall conform to applicable state, federal, and local codes and standards. It is up to the employer to determine the appropriate PPE performance standard. As there are no existing—and no forthcoming—applicable state, federal, or local codes and standards for AR/FR PPE, it is anticipated that the informational note Table 130.7 (C) (14) will continue to serve as a reference for organizations.

Contractor Responsibilities
Article 110: General Requirements for Electrical Safety-Related Work Practices
Included in the 2018 NFPA 70E update is an expanded definition of a host employer. The newly inserted informational note details host employer examples, which can include the owner, construction manager, general contractor, or employer.

Host contractors may be host employers, which means they share in the responsibility of advising, educating, and protecting contracted electrical workers in hazardous situations. If the work is done on a host employer’s work site, the designated host employer is responsible for sharing the work hazards a contractor may encounter. Proper communication among all parties involved is key.

Employee Responsibilities
Article 105: Application of Safety-Related Work Practices and Procedures
In creating employer and employee sections of NFPA 70E, this means employees have specific responsibilities to uphold. Employees are required to comply with all safety-related work practices and procedures implemented by employers. While in theory employees have been following this from the start, the updated text now explicitly states this.

Article 130: Work Involving Electrical Hazards
Employees, no matter their experience level, shall follow their employer's electrical safety program in prioritizing de-energized work, which includes complying with existing practices and procedures, attending training, and donning any PPE deemed necessary by risk assessments. While it is important that employers train employees on the definition of de-energized work, employees should note that, in accordance with their responsibility to comply with all procedures and practices, PPE must be worn during the de-energizing process.

PPE Manufacturer and Supplier Responsibilities
Article 130: Work Involving Electrical Hazards
The 2018 edition of NFPA 70E now requires PPE manufacturers and suppliers to demonstrate conformity with the standard in one of three ways:

• Self-declaration with a Supplier's Declaration of Conformity
• Self-declaration under a registered quality management system and product testing by an accredited laboratory, in addition to a Supplier's Declaration of Conformity
• Certification by an accredited, independent third-party organization

Currently, most PPE manufacturers and suppliers use the first option to demonstrate conformity. While the first option continues to be appropriate, the PPE industry will have to assess how to move forward if requested to use the other two options.

Personal Protective Equipment and the 2018 NFPA 70E
A common theme of understanding hazards and implementing appropriate steps to mitigate those hazards is present throughout NFPA 70E. The standard calls for reducing or eliminating these hazards through expanded risk assessments, clearly assigned responsibilities, and enhanced definitions and details to underscore the standard.

PPE is a final layer of defense for employees facing electrical hazards—it is meant to mitigate injuries in the event of an arc flash but should not be the only barrier for employees. Both employees and employers play a vital role in recommending and wearing PPE. While hazard elimination is the first priority in implementation, PPE still plays a crucial role.

Some electrical safety programs encourage the use of task-based PPE instead of daily AR/FR wear. While task-based wear may make sense in theory, in application, task-based poses a number of risks to employees because of the inherent risk of inconsistent PPE use. Task-based AR/FR wear requires constant risk assessment and relies on the user to make accurate judgments at all times, which is easily foiled by human error. It also is subject to employee complacency, in that an employee may become desensitized to site risks.

Everyday AR/FR apparel reduces these task-based wear issues and helps rectify the cultural issues found in task-based PPE programs. By incorporating everyday wear, employees are consistently protected throughout their day. AR/FR clothing, enabled by improved comfort and performance of innovative AR/FR fabrics, are now advancing a "want to wear" experience. Employees required to wear PPE can enjoy the functionality of non-FR garments backed by the protection of AR/FR fabrics.

By understanding the NFPA 70E updates, all affected parties can work together to become and remain compliant. Through cross-functional collaboration, further movement can be made in creating the safest possible environment for electrical workers.

This article originally appeared in the December 2017 issue of Occupational Health & Safety.