NFPA 70E order of compliance

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realolman

Senior Member
What would be the correct and logical order of compliance with NFPA 70 E in a small to medium size industrial facility?

I am not a fan of 70E, but if they are going to do it, I would prefer that it is done correctly. I don't want to have to walk around wearing flame retardant clothing, while everyone still does everything hot, and there have not been any analyses done of the capacities of the circuits involved, and no one understanding that it means no hot work ( unless to de energize introduces additional hazards )... not no hot work unless it is convenient.

A few years ago someone put stickers on every piece of electrical apparatus in the place warning of death and destruction if NFPA 70E were not followed and PPE not used. but no one ever got any training or PPE.

Now, recently there was a suit of FR work clothes displayed in the maint shop with an attatched note inviting comments about the clothing "to be worn when doing electrical work".

Similarly, there has been introduced in years past a "hot work" permit regarding cutting and welding that contains a checklist of things for the "worker" ( not the supervisor ) to check off, that everyone knows is impossible. eg.remove all flammable material within 35 feet ( that's a 70 foot circle in an industrial facility ), wet everything down etc. ....sounds good to someone who never did anything. If anything ever happened, the worker could never have complied with the things he signed off on the permit.

In other words it looks to me like there is yet another dog and pony show in the works with this NFPA 70E.

If there was true compliance intended, in what order would what be done?
 
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ItsHot

Senior Member
Order of compliance

Order of compliance

I think the first "order of compliance" is you! You have to be responsible and accountable for your actions! Ask yourself,"do you want to go home at the end of the day"? No matter how many safety recommendations exsist, if you don't follow any of them...oh well !! I have received injuries from not doing the simpliest of things! But I see your point I Still see guys in energized equipment with no PPE!! etc., etc.! But once again, it all starts with the individual! Do you want to go home today?
 

RETRAINDAILY

Senior Member
Location
PHX, arizona
Everyone in our company attended a arc-flash class by Littelfuse.

So if anything happens the boss can say.

He was trained.and I supplied the proper equipment.
 

sii

Senior Member
Location
Nebraska
Unlike the cutting/welding policies you listed (we have them too and they are completely unrealistic), it's not a dog and pony show....it's the law. That being said, its hard-damn near impossible-to make an employer understand what they have to do without some real financial incentive to do so. They sure as heck aren't going to do it out of good will toward their employees.

It seems to me that every major safety poilcy change, at least in our plant has been the result of an insurance company policy review. Until that happens with 70E, I just don't see a company changing the way they do things.

Everyone in our company attended a arc-flash class by Littelfuse.

So if anything happens the boss can say.

He was trained.and I supplied the proper equipment.

No he cannot.
 

zog

Senior Member
Location
Charlotte, NC
What would be the correct and logical order of compliance with NFPA 70 E in a small to medium size industrial facility?

I will post a checklist for you Monday, don't have it available right now. The order things are done are just as important as how each step is done.

I am not a fan of 70E, but if they are going to do it, I would prefer that it is done correctly. I don't want to have to walk around wearing flame retardant clothing, while everyone still does everything hot, and there have not been any analyses done of the capacities of the circuits involved, and no one understanding that it means no hot work ( unless to de energize introduces additional hazards )... not no hot work unless it is convenient.

Doing it wrong can be more dangerous than not doing it at all, the whole false sense of security theory. It is obvious your plant needs to start at the top with understanding of 70E and OSHA requirements.

If there was true compliance intended, in what order would what be done?

This is more complex than you think, lots of things to consider for an industrial plant, getting an EC company in compliance is much easier. I used to teach a 32 hour class on NFPA 70E compliance, with the intended audience being plant safety managers, OSHA compliance officers, and electrical supervisors. Much more to be considered than the much more straightforward "Qualified person" training.

Step 1: Management needs to understand the requirements and how to most effectively implement them.

Step 2: An analyis of your power system must be done. That does not mean your entire plant needs an arc flash analysis, but engineering needs to know the available fault current and clearing time of the protective devices to see if the 70E tables can even be used. Using the tables without doing this not only violates the 70E, it is very dangerous.

Step 3:Mitigation, look at the most dangerous parts of the analysis. Most industrial plants will have some areas that are >40cal/cm2 which is considered dangerous and should not be worked on no matter what PPE is worn. Every mitigation project I have done for industrial plants we were able to get everything HRC 2 or less.

Step 4: PPE, lease or purchase? Daily wear or as needed? Check out my FAQ on this in this safety section.

Step 5: Develop ESWP's, EEWP's, qualification of outside contractors, enforcement plan, disipline program for non conformance, etc...(This is the hardest and most important step)

Step 6: Training. Determine who will be trained as qualified persons and who will be trained as non-qualified persons (Yep, they need training too). Classroom training is only the first step for the qualified training, see FAQ on this too. Why is training so low on this list? Can't train people without having everything above in order first. I have seen plants do the training first, big disaster. Even saw this spark a union strike at one plant.

These are just off the top of my foggy saturday mongin head so I may have missed some stuff, will post more stuff Monday.
 

zog

Senior Member
Location
Charlotte, NC
Everyone in our company attended a arc-flash class by Littelfuse.

So if anything happens the boss can say.

He was trained.and I supplied the proper equipment.

That course does not meet the 70E training requirements. It is just to sell fuses and can be very misleading too. Current limiting fuses are not the magic solution to arc flash hazards, they only are effective in certian situations.
 

puckman

Senior Member
Location
ridgewood, n.j.
zog I have a question on your step 2 in a post above . Does it violet osha rules about not being able to use 70e tables ? I have a on going argument with co. about this and could not find it in osha. THANKS.
 

zog

Senior Member
Location
Charlotte, NC
zog I have a question on your step 2 in a post above . Does it violet osha rules about not being able to use 70e tables ? I have a on going argument with co. about this and could not find it in osha. THANKS.

OSHA rarely tells you how, they just tell you what must be done. Standards like the 70E tell you how. Using the tables means you use the whole table, including the notes, which require you to know the fault current and clearing times.
 

realolman

Senior Member
I hope I have explained myself satisfactorily.

Although I don't agree with the OSHA enforcement of NFPA 70E, ( that is another thread... I understand and respect how many of you feel about that )....If it's going to be done, I want it to be done correctly.

I don't want to have to work dressed in inappropriately heavy clothing, while the NFPA70E program is just a big dog and pony show that doesn't provide any real safety. So far the compliance where I work appears to me to be shaping up to be of the the dog and pony show variety.

I don't think the management has any clue what is really involved... or worse yet, maybe they DO have a clue what is really involved, and just want to give the appearance of compliance, while putting any inconvienence involved on the employees... just like they did with the "hot work permit" business. No one with any experience and a brain in his head would look at those permits and actually think the stuff they list for you to do is realistic.

So, boy howdy, they have a hot work permit program in place, don't they. Pretty soon everyone will be walking around suffering from heat stroke, and they got stickers on all the electrical apparatus, and fuses ..... so, boy howdy again, we got us an NFPA 70 e program, don't we?

I understand that if something happens, the management will be responsible, but I don't want to have to wait until something happens.... I think that is the problem with much of this OSHA stuff. If it's supposed to be prevention, something should be done to make it prevention.

How long has NFPA70e been required to be followed? We got the same "training" an earlier poster mentioned... a couple horror films and the salemen sold a PILE of fuses. Another salesman sold them stickers which were placed everywhere. Now they appear to be in the process of replacing our uniforms.... my guess is another salesman.

Does that sound like someone who understands and is really trying to comply? I don't think so.

Like I said earlier... if you're gonna do it, do it right. How do I know what's right, and how can I enlighten others ( especially management ) what is right?
 
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Volta

Senior Member
Location
Columbus, Ohio
Maybe you know of it already, but this forum is geared specifically towards arc-flash and electrical safety. Not a cure-all, but at least another avenue to gauge applications of programs across various industries.

There is some overlapping of knowledgable members of both sites, too. If your plant hasn't researched who should be designing the overall plan yet, then Zog or someone with that experience can suggest somone, I'm sure.
 

zog

Senior Member
Location
Charlotte, NC
I don't think the management has any clue what is really involved... or worse yet, maybe they DO have a clue what is really involved, and just want to give the appearance of compliance, while putting any inconvienence involved on the employees... just like they did with the "hot work permit" business. No one with any experience and a brain in his head would look at those permits and actually think the stuff they list for you to do is realistic.
Sounds like they are just lazy, looking for the easiest fix.

How long has NFPA70e been required to be followed?
1979. I don't understand why people think this is all new.

We got the same "training" an earlier poster mentioned... a couple horror films and the salemen sold a PILE of fuses. Another salesman sold them stickers which were placed everywhere. Now they appear to be in the process of replacing our uniforms.... my guess is another salesman.

Salespeople do nothing for free, it is in thier blood.
 

wtucker

Senior Member
Location
Connecticut
First of all, the stickers are required in the NEC.

Second, it sounds to me like managment doesn't understand NFPA 70E. Instead of reading the requirements (which aren't that burdensome, when you think about it), they go out and buy 45-calorie FR clothing, including hoods, and tell everybody that's what's required for live work on 125/208.

Third, lots of folks don't understand the concept of hot work permits, either. The FM Global Hot Work Permit most companies use comes out of NFPA 51B-2003, Standard for Prevention During Welding, Cutting and other Hot Work. It does NOT require that all combustibles within 35 ft. have to be removed during ALL hot work. It points out that welding slag and sparks have been shown to scatter up to 35 ft., so combustibles within that distance need to be removed or protected when that type of work is done. Other types of hot work, like sweating pipes, don't scatter slag, so the person issuing the permit shouldn't check the box on the permit that says combustibles should be removed, etc. The person issuing the permit checks off what's actually needed for the work in question, then the supervisor is supposed to go to the work area and check to be sure that all the requirements have been met (like have a fire extinguisher handy). That's to put eyeballs on the site to double-check that everything's been done right. Going to somebody's office to have the permit signed defeats the whole purpose. So does mandating stuff that everybody knows is stupid.
 

Volta

Senior Member
Location
Columbus, Ohio
Wtucker might just mean those required by 110.16. I don't interpret that wording to require the HRC or incident energy available to be shown, but some warning is required.
 

pfalcon

Senior Member
Location
Indiana
OSHA and 70E are not a dog and pony show. Though it sounds like your plant is putting on a show of compliance.

Once they get their act together you won't be wearing overly heavy and hot PPE all over the place. The feds declared your company is responsible to provide from their pocket all of your PPE needs. That's expensive. You may end up wearing heavier PPE than your street clothes but it's really not that bad.

As to hot work permits in an industrial plant, you should only see one for tracing a problem. Fixing the problem requires lockout.

I wasn't involved in the studies but at our site the machine tool service requires 8Cal suits while the buss requires 40Cal suits. We've surveyed our entire site.
 

wawireguy

Senior Member
What's the problem with wearing PPE? You only need it when you're working live which you shouldln't be most of the time anyways. If you are working something live using PPE and there is a arc flash accident you are going to be happy you had on that PPE.
 
Regarding NFPA 70E requirements on labeling/stickers.

As required by NFPA 70 (110.16), switchboards, panel boards, industrial control panels, and motor control centers that are in other than dwelling occupancies and are likely to require examination, adjustment, servicing, or maintenance while energized shall be field marked to warn qualified workers of potential electric arc flash hazards. The marking shall be located so as to be clearly visible to qualified persons before examination, adjustment, servicing, or maintenance of the equipment. The new requirement is intended to reduce the occurrence of serious injury or death due to arcing faults to workers who work on or near energized electrical equipment. The warning label should remind a qualified worker who intends to open the equipment for analysis or work that a serious hazard exists and that the workers should follow appropriate work practices and wear appropriate PPE for the specific hazard.

The NFPA 70E (130.3(c)) states that the label must be clearly labeled with either the incident energy in cal/cm(2) or the level of PPE.

The NFPA 70E 2009 Electrical Safety in the Workplace has many changes to the regulations and it is a good idea for anyone who comes into contact with the code to review it. There have been quite a few changes regarding the definition of "qualified person", "Live work permits", and Electrical safety programs.
 
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