Why This Revision Came Out So Early
Every three years, the electrical safety industry is blessed with another revision to NFPA 70E®: Standard for Electrical Safety in the Workplace®¹ and it often results in a mad dash to update training programs and learn all the new rules. The new edition typically hits the market around September of the year prior to the edition year.
However, this revision cycle saw a different phenomenon. To the surprise of many in the industry, the 2024 edition of NFPA 70E was on the shelves and loaded up in NFPA LiNK® way earlier than expected. The new edition hit the market in May of this year.
The reason for this change of pace in the schedule of the NFPA 70E revision cycle was because there were no motions filed to challenge the second draft language at the annual NFPA technical session this year in Las Vegas. With there being no motions filed, the NFPA Standards Council issued the document on 04/23/2023 with an effective date of 05/13/2023.
And while it might be hard to believe that nobody felt the need to push back on the NFPA 70E committee, there is a simple explanation for this: there just weren’t that many revisions to ruffle any feathers.
Typically, there are a few revisions that will get the blood boiling of at least one or two passionate electrical safety professionals out there, but this time around, nothing seemed to pop up worth making a special trip to Vegas for.
However, that doesn’t mean that there were no revisions. The revisions that took place are simple and straightforward and don’t move the electrical safety needle all that much. Let’s look at a few of the more important changes to the 2024 edition.
Perhaps the most impactful change is the addition of a new Informative Annex S. This new Annex deals with the concept of assessing the condition of maintenance of electrical equipment during the risk assessment process.
For several editions now, it has been a requirement that the condition of maintenance be considered when performing the risk assessment process. However, there wasn’t solid guidance on how to do this from a risk assessment point of view. Keep in mind that an informative annex is not mandatory text.
Emergency Response Plan Required
Another significant change, and possibly this author’s favorite revision, is that the job safety planning process is now going to require that an emergency response plan be included in the plan. What is the plan when the job doesn’t go as planned? This might include items such as responding to injured workers but can also cover what the contingency plan might be if we find ourselves in an unexpected shutdown situation.
For instance, if work is being performed energized because de-energization presents additional hazards or increased risk, what will we do if we find ourselves suddenly without power? The answer to this question might help us find a way the work can be done in a de-energized state after all. (This is why I love this change! And I might have written one of the public inputs associated with it?)
Electrically Safe Work Condition
Next on the list of changes that affect the work in the field is the change to section 120.5, now 120.6 in the 2024 edition. This section describes the process for creating an electrically safe work condition. In particular, the change occurred in item number (7) and involves the test for absence of voltage.
Previously, the rule allowed the employer to define where it made sense to verify the circuit was de-energized but defined the process. The change states that now this absence of voltage test must take place at each point of work. With no guidance on what is meant by a “point of work,” this could mean anything from defining the circuit as a point of work to defining the individual splice/connection point as the point of work.
One thing that was made abundantly clear at the second draft meeting by the committee is that the intent was to no longer allow this test to be made at the disconnecting means upstream from the equipment being worked on, such as the device in the MCC where the LOTO equipment might be applied.
Along the lines of establishing an electrically safe work condition, we must also be aware of the fact that the committee added language into the concept of what constitutes a normal operating condition. They have added that the equipment must also be rated for the available fault current.
Although this was implied in the requirement for proper installation and use of equipment in accordance with the manufacturer’s instructions, this is an important change. Often the available fault current can change over time and what was proper at the time of installation might no longer be the case today. Add this to the list of assessments done when following the new Annex S.
Informational Note Table 130.7
Another notable change was that the committee has recognized the advent of a new type of protector for rubber insulating gloves. A new standard, ASTM F3258, has been developed that gives us guidance on how a protector can be built out of non-leather materials that meet certain performance criteria. So, Informational Note Table 130.7(C)(14) was revised to include this standard, and the word “leather” was deleted from the phrase protectors throughout NFPA 70E.
Many of the remaining revisions revolve more around the concept document re-organization. First off, one major change had to do with the fact there was a revision to the NEC Style Manual. The NEC Style Manual was revised to require that all definitions be contained within Article 100, regardless of the specific article they might apply to. This is the new reality for both the NEC and NFPA 70E going forward. So, if you referenced a definition in Chapter 3 of previous editions, look for it in Article 100 now.
Section 110.4 on energized work justification was also re-organized to become exceptions to the policy that a company must establish an electrically safe work condition whenever an employee will be working within the limited approach boundary or interacting with energized equipment in a manner that might increase the chance of injury from an arc flash, even if there are no exposed energized parts.
There were several other items that dealt with re-organization that do not affect the way work will be performed. For instance, a scope statement was added to the first section of each article and caused all the section numbers to move back one; if the article did not previously have a scope statement, 120.5 is now 120.6.
The shock approach boundary tables were also adjusted to better correspond to the tables for the minimum approach distances in OSHA 1910.269 and to include a note to adjust the distance for elevations above 3000 feet.
Another change that doesn’t have much of an impact but is worth being aware of is the clarification of energy thresholds in Chapter 3 articles to better define when these requirements must be considered.
For More Information
These are just a few of the revisions that occurred in NFPA 70E this time around. For more information on what changed and why, go check out the first draft report and second draft report at www.nfpa.org/70e and see all the public inputs and comments that spurred these revisions.
Understanding the reason for these changes might just help us better apply the rules in NFPA 70E when it comes to providing a safe workplace. Until next time, stay safe and remember to always test before you touch.