From “Recommended” to “Standard”
By now, most of us have heard about the monumental shift that occurred in the world of electrical maintenance. If this is news to you, hold on to your hats!
NFPA 70B: Recommended Practice for Electrical Equipment Maintenance has been re-issued as NFPA 70B: Standard for Electrical Equipment Maintenance. That’s right – in January of 2023, the Standard became effective, and NFPA 70B was no longer a Recommended Practice.
Many folks heard this and ran to the highest mountain top and proclaimed, “We are saved! Our prayers for maintaining electrical equipment have been answered!” Right? That is what everyone did, right? Ok, maybe this was only those of us with our noses so far into the Codes and Standards world that we had been anticipating this change.
In reality, the day after the new standard became effective was just another day in the life of the electrical industry. But concerns were coming, and questions would soon be asked.
So, let’s look at some of the more common questions that have come about since the release of the new document. Here are my Top 7 questions I have been asked about NFPA 70B.
Q1: What is the difference between a Standard and a Recommended Practice?
This was one of the first questions that came up as folks were trying to make sense of this shift. In other words, why was this such a big deal?
The NFPA Glossary of Terms, which can be downloaded at www.nfpa.org, states that NFPA 1: Fire Code® defines a recommended practice as, “A document that is similar in content and structure to a code or standard but that contains only nonmandatory provisions using the word “should” to indicate recommendations in the body of the text.”
NFPA 1 also defines a standard as the following:
An NFPA Standard, the main text of which contains only mandatory provisions using the word “shall” to indicate requirements and that is in a form generally suitable for mandatory reference by another standard or code or for adoption into law. Nonmandatory provisions are not to be considered a part of the requirements of a standard and shall be located in an appendix, annex, footnote, informational note, or other means as permitted in the NFPA Manuals of Style.
The definition then goes on to comment on the generalized use of the term Standard as it applies to the development process.
Clearly, the main difference between a recommended practice and a standard is use of mandatory language. However, it does go deeper than this. You can’t simply change the word “should” to “shall” and call it a wrap. This is something the NFPA 70B committee found out firsthand. To migrate to a standard, it meant having to redesign the intent of the document to be mandatory requirements over recommendations. This is a perfect lead-in to the next question that came about.
Q2: Does mandatory language make NFPA 70B a mandatory standard?
This is the million-dollar question right here. Does the fact that NFPA 70B became a standard as of January 16th, 2023, mean that electrical equipment owners must follow it?
So, mandatory language does not equate to mandatory compliance. Mandatory language means that the document is written in a way where it could be incorporated into law if some law-making body chose to do so, not that it is automatically mandated by OSHA or any other government body for that matter.
For some, that might come as welcome news, but before we get too excited, we need to remember that NFPA® 70E® is also a standard and we all know what happens if we don’t have an electrical safety program that at least meets the requirement in NFPA 70E. Compliance with NFPA 70B is voluntary; however, it gives organizations like OSHA a place to point to in providing solutions for mitigation of deficiencies.
Q3: Will OSHA start enforcing NFPA 70B now that it is a standard?
This was a major question at the last IEEE Electrical Safety Workshop and is also a valid concern.
First off, what we need to understand is that OSHA only enforces OSHA standards. They will not look at a document, such as NFPA 70B, and cite an employer for not following Section 9.2.1, for instance.
However, if failure to follow the manufacturer’s recommendations for electrical equipment maintenance has created an unsafe condition within the facility and has caused harm or created a hazard, the citation can be from an OSHA requirement for not providing a safe work environment, and OSHA can, and will, point to industry consensus documents as a way to prevent this from being an ongoing issue.
In other words, they won’t enforce it, but they will steer you in that direction for improvement. NFPA 70B is now an industry consensus standard for electrical equipment maintenance.
Q4: At a high level, what is the most important requirement of NFPA 70B?
This question always gets my tongue tied a little bit as I am such a “code geek” that I love going into the weeds all the way. But if I had to choose a single rule or concept that NFPA 70B requires that is the most important thing an employer can know, it would have to be Section 4.2.1.
This section is found in the General requirements chapter and states, “The equipment owner shall implement and document an overall electrical maintenance program (EMP) that directs activity appropriate to the safety and operational risks.”
For some facilities, this is no big deal. They have had one for years and follow it to the letter. But these facilities do not make up the majority. Unfortunately, one of the reasons there is such a big push in the electrical equipment maintenance world is because so few facilities did anything about maintaining their equipment, and safety suffered because of it.
If your first question about NFPA 70B is, “What does this mean for me?” I would strongly encourage you to sit down and begin to build your company’s EMP if you don’t have one yet. And if you do have one, spend the time to audit/review your EMP to ensure that it meets the recommendations of your equipment manufacturers or the requirements of NFPA 70B. This will help ensure reliability as well as lower the risk of adverse conditions in the facility that could lead to unnecessary liability in the future.
Q5: If we have nothing in place for electrical equipment maintenance, where do we start?
In addition to building your electrical equipment maintenance program, one major project will be to perform an honest and fearless inventory of your current state of affairs. This means that you are going to need to go through the facility top to bottom and assess the current condition of maintenance of electrical equipment in your facility.
This is another major requirement of NFPA 70B – to perform a condition of maintenance audit. Not only will this help to determine what condition equipment is in when you develop your maintenance interval program in accordance with Chapter 9 of NFPA 70B, but you will also need to assess things like personnel qualifications and current maintenance procedures.
Out of this exercise, you will learn where you are at so that you can compare this with where you need to be, and then develop and implement the plan to get from Point A to Point B in the straightest line possible. Without this step, the implementation of an EMP will be very piecemeal and reactive. We need to strive to be proactive here.
Q6: What training will the new edition of NFPA 70B require for workers performing maintenance?
Training requirements for personnel can be found in Section 4.3 of NFPA 70B.
The first thing you will notice is that the general requirement is personnel performing work under the EMP must be qualified for the assigned task. It goes further to state, “A qualified person responsible for conducting electrical maintenance shall be trained in the specific maintenance tasks, test methods, test equipment, PPE usage (as applicable), and hazards associated with the electrical equipment or system being serviced.”
Therefore, if your personnel will be performing IR scans, they need to be trained on how to perform IR scans and what hazards this activity might present. This may or may not include training on the requirements in NFPA 70B, but, in my opinion, the majority of training that NFPA 70B is going to require is going to be task driven.
To draw a parallel with electrical safety training, personnel will need to be trained in the requirements and work practices that they will need to know in order to perform their job duties as required and in the safest manner available. Some training can be the high-level stuff, such as when certain equipment needs to be maintained and which procedures need to be performed. But the majority of training will still be skills-based training that they were already likely undergoing.
However, just keep in mind that retraining/refresher training is required by NFPA 70B if (1) regular supervision indicates a need for more training, (2) new equipment or tasks are introduced to the employee or the task is rarely performed, or (3) if the standard changes in a way that affects previous procedures and work practices.
Q7: If we choose to follow NFPA 70B, how soon must all of this be done?
There is no set timeline for compliance with NFPA 70B. If your path forward includes implementation of the new standard into your workplace, the best time to implement these requirements was January 16th, 2023. But the second-best time is right now.
As for the question about how soon OSHA will start pointing to NFPA 70B for mitigation – who knows? It could be five years from now or it could have already happened as I sit down to write this.
The ability exists today for that to become a reality, so why wait? Start the process today by pulling together a plan to get from where you are to where you need to be. Do you know what your current EMP looks like? Do you have one? Do you have the necessary skillset to develop a program, or do you need to engage the services of a firm such as e-Hazard to help create/revise your EMP? Have you fully decided to commit to this project?
These are the questions that can be answered today at zero cost and minimal time commitment. Once you answer these, then you can start moving forward.
Don’t worry if you can’t anticipate the entire process and what that looks like. This will be common for many employers who are just finding out that the big grey box with all the cables and conduits coming out of it needed some TLC. Remember, you don’t have to see the entire staircase; just take the first step. Having a plan in place to work towards the end goal of a solid EMP will always look better than a shoulder shrug and claiming ignorance of the process.
I hope this short Q&A has helped shed some light on what this great new world that lies ahead of us might look like. As always, if you have further questions or are looking for guidance in your journey down the road NFPA 70B has paved, please do not hesitate to contact e-Hazard for help. Remember, we are all in this together, and every step in the right direction helps get another worker home safely and in one piece.
Until next time, stay safe, and always test before you touch!