MANAGING ELECTRICAL SAFETY

By: James R. White

INTRODUCTION

Many numbers are quoted by various sources for injuries and fatalities in the workplace[1]. Most of these numbers
come from the Bureau of Labor Statistics (BLS). This information can be accessed at www.bls.gov on the Internet,
which will bring you to the Main Page. From there click on “Industries / Injuries, Illnesses and Fatalities”. From
that point there are several routes that can be followed, but the one used for this paper is under the heading, “Get
Detailed Statistics / Create Customized Tables”. This selection allows you to choose occupation, industry, fatalities,
injuries, etc. As an example, Figure 1 below shows fatalities from Contact With Current – All Industries.

FIGURE 1
Example Inquiry for Electrical Shock Fatalities
Bureau of Labor Statistics

The Bureau of Labor Statistics shows that in the year 2000 there were 256 fatalities due to contact with electric
current, Figure 1. This averages out to 0.7 fatalities per day. This may not seem all that significant on first glance,
but combine that with 3,704 lost-time injuries due to contact with electric current and we are talking significant
losses. While we’re at it, let’s add in 1,575 injuries due to electrical burns. The numbers get larger and larger.

Speaking of losses, statistics compiled by the 3rd International Conference on Electrical Injury in 1998[2], the Electric
Power Research Institute estimated the direct costs of an electrical fatality at $1.3 million dollars. Figure 2 is also
from the BLS and details injuries from electrical burns. Note that arc flash burns make up 30% of the recordable
injuries in the year 2000. Calculate the cost for trained personnel to be away from the job recovering from an
electrical accident – lost production, increases in Workman’s Compensation and insurance rates, possible OSHA
fines, legal fees; the list goes on and on. This does not take into account the pain, suffering and emotional costs,
which cannot be measured. Dr. Mary Cappelli-Schellpfeffer, in a paper presented to the 10th Annual IEEE-IAS
Workshop[3] estimated the indirect costs of a major electrical accident at 3 to 8 times that figure.

By spending a small amount of time to research this data, management can begin to determine how their company
matches up with general industry as a whole and others within the same industry. Rates per 10,000 workers are also
available on the site, which may be easier for comparison. If your company’s rates are significantly higher than
those of like industries, you probably have a management problem.

© 2003 Doble Engineering Company 1

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 FIGURE 2
Example Inquiry for Electrical Burn Injuries
Bureau of Labor Statistics

ATTITUDES TOWARDS SAFETY

That doesn’t sound fair, dumping all the blame on management. However, your company’s attitude towards safety
is probably reflected in your Lost Workday Incident Rate

The commitment has to be from the top down. If the attitude at the top is that it’s a waste of money, a big
interference with getting the job done or “That #$$*&%@ OSHA is ruining our business”, managers below will
pass that attitude to their personnel. For any program to have success management has to support it fully. In many
places in the regulations, OSHA requires that workers Shall do certain things [3]. The word “Shall” means there is no
option; it must be done. Wearing PPE is a good example. 29CFR1910.335(a)(1)(i) states, “Employees working in
areas where there are potential electrical hazards shall be provided with, and shall use, electrical protective
equipment that is appropriate for the specific parts of the body to be protected and for the work to be performed”.
Italics added for emphasis by the author.

So, Fred doesn’t like to wear his safety glasses. You catch Fred without them, even though your written safety
policy states they must be worn in certain areas. What should you do?

1st time – Counsel Fred. Try to make certain he understands the issues and hazards involved. At each step, though,
document what is said and the resulting direction / response, etc.
2nd time – Possibly give Fred a verbal warning.
3rd time – Up to your Corporate policies, but at this point Fred needs more than encouraging words.

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However, you’re an understanding person, so you don’t actively enforce the use of PPE by disciplining Fred. Fred
goes on his way and injures himself. OSHA comes in and you now have a Willful Violation situation on your hands
(up to $70,000 per violation and 6 months in jail for the decision-maker). If Fred declines Workman’s Comp and
sues, he’ll probably prevail. You have to protect workers from their ignorance or pride. Unfortunately, there are
times when my ex-DI’s words are very pertinent; “If you can’t be good at what you do, you can still be a good
example to everyone else”. Some people were born to be made the example. The presentation has a number of
examples of the aftereffects of electrical incidents.

WHAT DOES OSHA WANT FROM ME?

Quite a bit, actually. Safety is not to be a passive, reactive policy that is brought out for Show-and-Tell or after-the-
fact. Reviewing some of the major requirements [4][5]:

Employers must know what their employees do – 29CFR1910.269(a)(2)(iii) and Note - “The employer shall
determine, through regular supervision and through inspections conducted on at least an annual basis, that each
employee is complying with the safety-related work practices required by this section;” and, “Note: OSHA would
consider that tasks that are performed less often than once per year to necessitate retraining before the performance
of the work practices involved”.

Employees must be trained in their job tasks – 29CFR1910.269(a)(2) - “Employees shall be trained in and
familiar with the safety-related work practices, safety procedures, and other safety requirements in this section that
pertain to their respective job assignments. Employees shall also be trained in and familiar with any other safety
procedures (such as pole top and manhole rescue) that are not specifically addressed by this section, but that are
related to their work and are necessary for their safety”.

Qualified Employee – 29CFR1910.269(x) - “One knowledgeable in the construction and operation of the electric
power generation, transmission and distribution equipment involved, along with the associated hazards”.

There must be job briefings before the work starts – 29CFR1910.269(c) – “The employer shall ensure that the
employee in charge conducts a job briefing with the employees involved before they start each job”. .269(c)(1) goes
on to state, “Additional briefings shall be held if significant changes, which might affect the safety of the employees,
occur during the course of the work”.

Workers must wear Personal Protective Equipment (PPE) – 29CFR1910.335(a)(1)(i) - “Employees working in
areas where there are potential electrical hazards shall be provided with, and shall use, electrical protective
equipment that is appropriate for the specific parts of the body to be protected and for the work to be performed”.
Another area [29CFR1910.335(a)(iv)] states, “Employees shall wear nonconductive head protection whenever there
is a danger of head injury from electric shock or burns due to contact with exposed energized parts”. And finally
.335(a)(v), “Employees shall wear protective equipment for the eyes or face whenever there is a danger to the eyes
or face from electric arcs or flashes or from flying objects resulting from electrical explosion”.

Workers are not allowed to work if they are physically unable – NFPA standard 70E, Part II, 2-3.2.1. Alertness.
Prohibits allowing employees to work in areas containing live parts if their alertness is impaired due to illness,
fatigue or other reasons.

Never, ever, ever make someone perform a task when it’s unsafe. OSHA defines a Willful Violation as a
violation the employer intentionally and knowingly commits. I don’t care how they did it back in ’03, OSHA is
going to kick start your safety program one way or the other. See quote from my DI, above.

OTHER MANAGEMENT TATICS

Inherently Safer Technology

One area that can be used to decrease the electrical arc flash hazard is to use current limiting fuses. Current limiting
fuses decrease opening time to less than ½ cycle, which reduces the amount of arc protective equipment needed and

© 2003 Doble Engineering Company 3

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also reduces the amount of damage done to equipment. Along with current limiting fuses, current limiting circuit
breakers are also becoming more available, although at higher voltages they may have smaller interrupting ratings.

Arc resistant switchgear is on the market, although the name is somewhat misleading. “Arc resistant” implies that
the arc does not start, much in the same way that “life insurance” implies that it’s going to lengthen your life.
Instead of being arc resistant, it actually diverts that arc upwards and, often, through a duct so a worker is not
exposed to the flash and smoke created by an arc. As long as the doors are properly secured (a big IF in some
companies) arc protective clothing and equipment are not needed. Much of this equipment is found in 2.3kV to 5kV
rated gear, although some manufacturers are building 480-volt gear.

Remote operation, such as for racking circuit breakers in and out of their cubicles is becoming an option. One
circuit breaker manufacturer offers a remote device for racking breakers. It is attached to a imbecile cord that is 50
feet long. At the very least, on older systems where the doors have no provision for racking closed, extended tools
might be used to reduce the arc flash hazard. Another method is to utilize remote control switches, so the employee
is not at the switchgear when it is opened and closed.

Some circuit breakers are just not safe to rack in or out when they are energized. This causes some very real
operational issues within an organization, especially when it has been done that way for years. It must be
recognized that, in those circumstances, production or operations will have to yield to a safer method of racking,
which is to de-energize before racking. This can occur whenever the arc energy exceeds 40 cal/cm2 .

Third-Party Safety Audit

Often we are too close to the situation to see the problems. This is true for our professional lives as well as our
personal lives. We look at the same thing over and over to the point where we know what it should look like, not
what it really looks like. Try writing something and then proof-reading it yourself. It looks great; another
masterpiece! When we ask some one to go over it and they pick out numerous problems, we can’t understand why
we didn’t see them. What we needed was a new set of eyes; eyes that are fresh to the situation.

An independent audit shows good faith effort; something OSHA encourages. Yes, you could go out of business
trying to fix everything at one time, but prioritizing the issues will help weed things down. Having an audit can be
very simple - if you’re a small company. Larger companies have more issues to look at. One area that they must
consider is the legal implications. If you conduct an audit and find $20,000,000.00 worth of safety issues, which
ones get fixed first? What if you guess wrong and someone is injured by a lower priority safety issue? Get all the
players into the game from the start. Don’t go it alone, as you may find that you don’t like where you wind up.

An independent audit can identify safety hazards, point out strengths and weaknesses in your safety program,
evaluate existing practices and procedures and promote improvements in your safe work practices. One problem
with safety programs is that once they are put into place, they become static. Downsizing, changes in equipment or
personnel can cause some procedures to become outdated. If there are holes in your safety program, there’s a good
chance you won’t be able to see it, also.

Audits should look at the same areas that OSHA would want to see:

• Training records
• Procedures, such as clearances, LO/TO, work permits, switching orders, job briefing checklists
• Accident logs (OSHA 300)
• Near miss investigation reports
• Job safety analysis
• Written policies

Perform plant interviews with personnel. The need for confidentiality is crucial to getting good information on this.
No one is going to point anything out if they think that they will have to answer to management for it. Identify
strengths, weaknesses and opportunities for improvements. Identify hazards and estimate their risk. This will help
prioritize them. Lastly, designate people from each effected department or division and make them personally
responsible for any action items that need to be addressed. Schedule regular meetings to secure updates on their
progress with a final “drop dead” date for each.
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THE TO-DO LIST

1. Number one and the most important, develop a Zero Tolerance policy towards energized work. Do you work
on energized electrical equipment? Get serious about no “hot work”. Troubleshooting, infrared scans and the
like are not considered to be energized “work”, neither is operating electrical equipment in a manner in which it
was designed. However, this does not eliminate the need for conducting a electrical hazard analysis.

2. Get out in the field or plant and see what your personnel are doing. Develop checklists or other methods of
tracking who is qualified to perform what tasks. Some companies have gone so far as to conduct Job-Task-
Analysis (JTA’s). These are expensive and time-consuming, but provide a blueprint of your people’s activities.

3. Train your personnel. To be qualified to perform any task they must know the construction, operation and
hazards associated with certain types of equipment. Workers may be qualified to do certain tasks, but
unqualified to do others. It is up to supervision to know what the people can do safely.

4. Develop Safe Work Practices and Procedures. Energized Electrical Work Permits, Clearance Procedures,
Switching Orders, etc. are not called for in the regulations, but help document that the correct steps were taken.
This can be especially important if there is an accident.

5. Develop a Safety Electrical One-Line Diagram (SEOLD). This is a stripped-down version of an electrical one-
line diagram. Major devices, including nominal voltages and short-circuit currents are listed, but not wire size,
fuse sizes and ratings, or equipment that is not hazardous or involved with isolating the devices. Make certain
that all identification of devices match between the SEOLD and the names on the devices themselves. Verify
all items on the SEOLD. More information on SEOLD’s can be gleaned from “Safety Electrical One-Line
Diagrams”, IEEE CH2272-3, 1986, T. Brown, PE (deceased)[7].

6. Perform periodic safety audits. If your workers know they will be subject to random safety audits, they will try
to keep up with safe work practices and procedures. During the period of time that the former Compliance
Manager left at SUNOHIO and I was delegated the job, many of the workers became lax about their equipment
and safety requirements. Once I started performing field safety audits, word got out quickly and people paid a
lot more attention to the details that make the workplace safer.

7. Implement job briefings. If the job scope changes significantly, introducing new or different hazards than what
was first anticipated, conduct another job briefing.

8. Be very careful how you implement any Safety Awards program. OSHA has issued numerous citations when
they believe the Awards program discourages accident reporting. Even if the program is designed in good faith,
make certain it cannot be misconstrued.

9. Look into the latest technologies when replacing switchgear. Arc resistant switchgear can cost 10% to 20%
more than metal-clad, but the benefits it pays in reduced litigation and personnel exposure is more than worth
the cost.

10. Get up-to-speed on the regulations and the NFPA standard 70E. Let’s throw in the new IEEE 1584-2002, as
well. What you don’t know will kill you, and those who work under your supervision.

11. Document, document, document. Everything. If you don’t have it in writing, you never did it.

ELECTRICAL HAZARD ANALYSIS

In order to choose the proper protective equipment, the hazards must be determined by performing an Electrical
Hazard Analysis [8][9][10]. This leads to a PPE Assessment. Some of the key pieces of information needed are:

• Nominal voltage at the point of contact

• Short-circuit available current
• Maximum total clearing time of protective devices
• Expected distance from the exposed, energized conductor or equipment
© 2003 Doble Engineering Company 5
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The three hazards of electricity are shock, arc-flash burn and blast. The first two can be somewhat accounted for by
using good engineering practices, safe work procedures and PPE, but there is no available PPE for the blast hazard
in very severe arc incidents.

Shock Hazard Analysis

The NFPA 70E standard breaks the approach distances into 4 boundaries (Figure 3).

FIGURE 3
Approach Boundaries
Courtesy W. H. Salisbury and Company

The outside, dotted line is the Flash Protection Boundary. The other boundaries are Shock Approach Boundaries.
Looking at the Shock Approach Boundaries, the outside boundary is the Limited Approach Boundary. This is the
closest distance to an exposed, energized conductor that an unqualified worker can be. If the Flash Approach
Boundary is further from the exposed, energized conductor than the Limited Approach Boundary, the worker
(qualified or unqualified) must be wearing flash protective apparel. If the Limited Approach Boundary is further
from the exposed, energized conductor than the Flash Approach Boundary, unqualified workers can approach no
closer. For a qualified worker to cross the Limited Approach Boundary, he must be wearing the appropriate flash
and shock PPE. The Limited Approach Boundary (Table 2-1.3.4) is broken into two columns; Exposed Movable
Conductor (such as an overhead line) and Exposed Fixed Circuit Part (such as bus bar). Since the hazard for a fixed
part is less (it can’t swing into you) the distances are less. Note that none of the Limited Approach Boundaries
Exposed Fixed Circuit Parts (Column 3) coincide with the OSHA tables. This is because the OSHA tables address
approach distances for qualified workers working on or near overhead lines. Unqualified workers must maintain a
minimum of 10 feet from such lines.

Column 1 identifies the phase-to-phase voltage. Column 2 is the Limited Approach Distance for Exposed, Movable
Conductors. Column 3 is the Limited Approach Distance for Exposed, Fixed Circuit Parts. Note that for the
Exposed Movable Conductor column, the approach distance is 10 feet up to 72.5kV, where it begins to increase.
This roughly corresponds to 29CFR1910.333(c)(i)(A)(1) and (2), which states that for voltages 50kV to ground the
approach distance is 10 feet and to add 4 inches per kV for every 10kV additional. As an example, at 72kV (41.8kV
phase-to-ground) the approach distance would be 10 feet 4 inches by OSHA .333 and at 121 kV it would be 10 feet
8 inches. The NFPA 70E requires 10 feet 8 inches for the entire range, making it somewhat more conservative.
Since you don’t want to have your apprentice use his Stanley™ metal tape measure to accurately measure these
© 2003 Doble Engineering Company 6
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distances (you’ll lose too many apprentices that way), they are not going to be exact. OSHA does not really provide
approach distances for fixed circuit parts for unqualified workers. Generally, everyone observes the 10-foot
approach distance for unqualified persons whether it is an overhead line or fixed circuit part. The NFPA 70E does
make a distinction between overhead and fixed conductors, though, and the Limited Approach Distances are quite a
bit different between fixed parts and overhead lines. An example would be at 751V to 15kV. An Exposed Movable
Conductor would have an approach distance of 10 feet, while an Exposed Circuit Part has an approach distance of 5
feet. One quirk pointed out to me is that in the case of overhead bus you must maintain 10 feet of clearance, even
though it is fixed. The 70E Table would appear to allow closer approach distances, but that is not the case.

(All dimensions are distance from live part to employee.)

Nominal System Limited Restricted Prohibited

Voltage Range Approach Approach Approach
Phase to Phase Boundary Boundary Boundary

Exposed Exposed
Movable Fixed Circuit
Conductor Part

(1) 2) (3) (4) (5)

0 to 50 Not specified Not specified Not specified Not specified
51 to 300 10 ft 0 in. 3 ft 6 in. Avoid contact Avoid contact
301 to 750 10 ft 0 in. 3 ft 6 in. 1 ft 0 in. 0 ft 1 in.
751 to 15 kV 10 ft 0 in. 5 ft 0 in. 2 ft 2 in. 0 ft 7 in.
15.1 kV to 36 kV 10 ft 0 in. 6 ft 0 in. 2 ft 7 in. 0 ft 10 in.
36.1 kV to 46 kV 10 ft 0 in. 8 ft 0 in. 2 ft 9 in. 1 ft 5 in.
46.1 kV to 72.5 kV 10 ft 0 in. 8 ft 0 in. 3 ft 3 in. 2 ft 1 in.
72.6 kV to 121 kV 10 ft 8 in. 8 ft 0 in. 3 ft 2 in. 2 ft 8 in.
138 kV to 145 kV 11 ft 0 in. 10 ft 0 in. 3 ft 7 in. 3 ft 1 in.
161 kV to 169 kV 11 ft 8 in. 11 ft 8 in. 4 ft 0 in. 3 ft 6 in.
230 kV to 242 kV 13 ft 0 in. 13 ft 0 in. 5 ft 3 in. 4 ft 9 in.
345 kV to 362 kV 15 ft 4 in. 15 ft 4 in. 8 ft 6 in. 8 ft 0 in.
500 kV to 550 kV 19 ft 0 in. 19 ft 0 in. 11 ft 3 in. 10 ft 9 in.
765 kV to 800 kV 23 ft 9 in. 23 ft 9 in. 14 ft 11 in. 14 ft 5 in.
FIGURE 4
Table 2-1.3.4
Approach Boundaries to Live Parts for Shock Protection
From The National Fire Protection Association
Standard 70E
The next (3rd) boundary is the Restricted Approach Boundary. This boundary can only be crossed by qualified
workers wearing appropriate PPE for shock and arc protection. These distances are very similar to the OSHA
approach distances. Additionally, the qualified worker must:

• Have a documented work plan approved by management

• No part of the body can cross the Prohibited Approach Boundary
• Stay in the Restricted Space only long enough to accomplish the task

To cross the final (4th ) boundary (Prohibited Approach Boundary) the qualified worker must:

• Have specialized training for working on energized conductors or components

• Have a documented work plan that also justifies the need for working that close
• Perform a risk analysis
• Have the second and third items approved by management
• Use appropriate PPE

© 2003 Doble Engineering Company 7

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 • Ensure that no uninsulated part of his body crosses the boundary. This is to be considered the torso and
lower body.

Crossing the Prohibited Boundary is the same as making contact with the conductor or energized part. It is easy to
see why by looking at the Table in Figure 4.

Flash Protection Boundary

The Flash Protection Boundary [8][9][10] can be derived in a number of ways. THE NFPA 70E (2000 edition) provides
two calculations; the first where the short-circuit available current is known and the second for when it isn’t.

DC = [2.65 x MVA bf x t ] ½

or

DC = [53 x MVA x t] ½
Where:

DC Flash Approach Distance (just curable burn on unprotected skin)

MVA bf bolted fault MVA at point involved
MVA MVA rating of the transformer. For transformers below 0.75MVA, multiply the MVA rating by
1.25
t time of arc exposure in seconds
½
square root

On systems rated 600 volts or less, the Flash Protection Boundary is 4 feet if no calculations are done. If the short-
circuit current is available for the point of exposure, the Flash Protection Boundary can be calculated.

Note that the above equations are for systems rated 600 volts or less. For systems above 600 volts, the 70E only
states that the Flash Protection Boundary is the distance from an energized is to be kept to 1.2 ca/cm2 .

There are a number of computer programs available to calculate the Flash Protection Boundary, also. One freeware
program from Cooper-Bussmann® is available at their Safety BASICS™ site. This is an Excel-based program that
provides approach distances and some PPE recommendations. Ontario Technologies (once part of Ontario Hydro)
markets a Windows-based program called ArcPro®.

Flash Hazard Analysis

Once the Flash Protection Boundary is crossed, flash protective clothing and equipment must be worn [4][5] . OSHA
does not specify what equipment is to be worn, only that it must be adequate for the parts of the body to be
protected, the work to be performed and the hazard. The first step in complying is to calculate the incident energy
(arc energy) that would be received by the body at the working distance. To calculate the incident energy, the
nominal voltage, short circuit current available at the point of work, protective device setting and working distance
must be determined. Hand calculations can be performed or software can be used to achieve the incident energy.
FLUX.exe is a DOS-based, freeware program developed by Alan Privette, PE and is widely used. ArcPro®, a
commercial, Windows-based program was developed by Ontario Hydro Technologies and provides graphs and
tables instead of a plain numeric result. The latest tool to come onto the market is the IEEE Guide 1584-2002,
“Guide for Performing Arc-Flash Hazard Calculations”[. More about this Guide is included at the end of the
tutorial.

The incident energy will be expressed in cal/cm2 or, in the case of the IEEE Guide, j/cm2 . Current recommendations
call for exposed, unprotected skin to receive no more than 1.2 cal/cm2 incident energy[6][8][9][11] , which is
approximately equal to the heat produced by a cigarette lighter on the tip of your finger for one second. This will
produce the on-set of a second-degree burn. Be aware that incident energy calculations only take into account the
torso and the hands or other parts of the body may have a greater exposure to the incident energy.

© 2003 Doble Engineering Company 8

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 FIGURE 5
Hazard Risk Category Classifications (Partial)
From NFPA Standard 70E 2000

Once the incident energy is determined it can be compared to a clothing’s Arc Thermal Exposure
Performance Value (ATPV). The ATPV is provided by the clothing manufacturer and is a numerical rating giving
the thermal energy protection in cal/cm2 . The ATPV should be selected so that the incident energy is 1.2 cal/cm2 or
less. This amount of heat would just cause the onset of a second-degree burn. One item that deserves note is that
the new 70E would seem to indicate that 12oz/yd2 cotton or wool has a 2 cal/cm2 rating. This is not the case nor the
intent of that particular line. Cotton or wool is flammable and provides no arc flash protection. One of the concerns
in putting that into the standard was that people would view cotton or wool as having an arc rating. It really is only
allowed for HRC 0 tasks.

Often, clothing has to be layered to provide adequate protection from higher energy arcs. Some clothing may have
Breakopen Threshold Energy (EBT ) rating instead of an ATPV. The EBT is the highest incident energy, which did
not cause FR fabric breakopen and did not exceed the second-degree burn criteria. EBT is usually given when the
incident energy is too high for an ATPV rating.

The NFPA 70E standard provides three tables that simplify the selection of PPE. Figure 5 (Table 3-3.9.1 Hazard
Risk Category Classifications) for many common tasks associated with electrical work. Hazard/Risk Categories are
rated on a scale of 0 – 4, with 4 being the highest. As an example, Sheet 1, page 55 of the 70E lists “600V Class
Switchgear (with power circuit breakers or fused switches)”. Insertion or removal (racking) of CB’s from cubicles,
doors closed is a Hazard/Risk Category 2; with the doors open it is a Hazard/Risk Category 3. Moving to the next

© 2003 Doble Engineering Company 9

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table, Figure 6 [Table 3-3.9.2 Protective Clothing and Personal Protective Equipment (PPE) Matrix]
recommendations for PPE selection are given for each Hazard/Risk Category.

FIGURE 6
Protective Clothing & PPE Matrix (Partial)
From NFPA Standard 70E 2000

A Category 2 hazard would require:

• cotton t-shirt
• long pants (cotton) – not required if FR pants have an ATPV of at least an 8
• FR shirt and pants (or coverall)
• hard hat
• safety glasses or goggles
• leather gloves and safety shoes.

A Category 3 hazard would require:

• cotton t-shirt
• long pants (cotton)
• FR shirt and pants (or coverall)
• hard hat
• safety glasses or goggles
• flash hood
• hearing protection
• leather gloves and safety shoes.

Finally, Figure 7 (Table 3-3.9.3, Protective Clothing Characteristics) provides the minimum ATPV requirements for
the Hazard/Risk Categories. For a Category 2 hazard, cotton underwear plus FR shirt and pants with a minimum
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ATPV of 8 would be required. A Category 3 hazard would require cotton underwear, plus FR shirt and pants plus
FR coveralls with a minimum ATPV of 25.

FIGURE 7
Protective Clothing Characteristics (Partial)
From NFPA Standard 70E 2000

Compare the ATPV to the calculated incident energy to determine how much protection is needed, ensuring that the
minimum ATPV exceeds the incident energy.

Note that the above tables are recommendations and take a conservative approach. In some cases the actual PPE
needed would be less than that given through this process. Read all notes at the end of each table to determine
whether the Hazard/Risk Category can be reduced by one number and under what conditions the recommendations
apply.

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 FIGURE 8
NFPA 70E Compliance Guide
Courtesy DuPont Advanced Fiber Systems

One last tool that’s available is from E.I.DuPont, the makers of NOMEX®. They have a calculator wheel that will
provide the same information as the NFPA 70E Tables 3-3.9.1 through 3-3.9.3. Called the “NFPA 70E Compliance
Guide”, (Figure 8) it is based on the 2000 edition of the 70E. It is very easy to use and provides the HRC, ATPV
rating and recommends PPE for that category. I presume they will update this guide for the 2003 70E.

Acoustic (Blast) Analysis

Actually, there is no current requirement for this. That is not because the hazard does not exist, it just hasn’t been
properly quantified and studied yet. One of the real issues that the NFPA 70E Committee has been trying to come to
grips with is the fact that an electrical incident is a multi-hazard event. Whereas the shock and arc-flash hazards
have been reasonably quantified, the acoustic electrical hazard has not. As can be seen in Figure 9[14], severe
injuries can occur when the acoustic wave is greater than 5psi.

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 Pressure (psi) Type of Damage

0.5 - 1.0 Breakage of glass windows

> 1.0 Knock people down
1.0 > 2.0 Damage to corrugated panels or wood siding
2.0 - 3.0 Collapse of nonreinforced cinder block walls
5.0 - 6.0 Push over wooden telephone poles
> 5.0 Rupture ear drums
> 15.0 Lung damage
> 35.0 Threshold for fatal injuries
> 50.0 About 50% fatality rate
> 65.0 About 90% fatality rate

FIGURE 9
Effects of Acoustic Force
Engineering Analysis of Fires and Explosions

So, how much pressure is created during a fault? A paper presented by Ralph Lee to the IEEE[16] provided the
following numbers; for a 25kA, 10kV arc, the pressure developed is expected to be 160ft/lb 2 at a distance of 2 ft. At
5 feet, there is still a force of 70lb/ft 2 exerted. Another way to present this is that one Megawatt of arc energy is
equal to 1 stick of dynamite or 1/3 pound of TNT[17]. Even though we may be able to protect our employees from
the thermal effects of an arc, once the arc energy exceeds 40 cal/cm2, the acoustic effects can be more hazardous.
Personally, having my arms and/or legs blown off would ruin my day. This aspect of the electrical hazard is
currently being investigated and I’m certain that more information will be available in the next few years. At this
time, managers need to be aware that the acoustic effects do present a severe hazard and should not be discounted.

THE NFPA 70E STANDARD

The NFPA 70E standard, which was first published in 1979, was the first nationally-recognized standard for
electrical safety in the US and was the reference document used for the Electrical Safety-Related Work Practices
(ESRWP) regulation (29CFR1910.331 - .335). Although the CFR is a Federal law, the 70E is a standard, which
means it is not legally binding.

So why should we be concerned about the 70E standard? Much of it (speaking from a monetary stand point) has to
do with the fact that if there is a nationally recognized standard and we do not follow it, we are left open for
litigation if something should occur. We would be literally beat to death with it at trial. I don’t believe there is a
standard for the amount of beating you can receive for a bad decision. Whereas the OSHA regulations tell us how
we need to do to be in compliance, they don’t tell us what we need to do. The 70E provides practical solutions on
how to get there. OSHA has been citing the 70E in court as a basis for its situations and the courts have been
upholding it.

The real reason we should apply the 70E is because it contains the latest, and best, research and methods for
working on electrical systems rated 50 volts or higher. No one wants to see another person injured or killed.
However, we often make decisions based on our ignorance that can have a very negative consequence on our
employee’s lives, and on our future.

The National Fire Protection Association (NFPA) is best known for the 70 standard (National Electrical Code),
which is a consensus standard reviewed and updated every three years. The NFPA produces many additional
standards covering topics such as Aircraft Rescue and Fire Fighting, Finishing Processes and Wastewater Treatment
Plants. There are three standards that pertain directly to electrical workers and equipment:

• NFPA 70 National Electrical Code[12]

• NFPA 70B Recommended Practice for Electrical Equipment Maintenance[13]
• NFPA 70E Electrical Safety Requirements for Employee Workplaces [4]

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Overall Organization

The 2003 edition of the 70E will reorganize the entire standard. There will still be four Parts (I through IV) and
Chapters, as in the prior edition. The Chapters are now subdivided into Articles, starting with Article 100 in Chapter
1, Article 200 in Chapter 2 and so on. When discussing changes in this document, the current designation will be
used first, followed by the new designation in parenthesis. One major change that was accepted was to move Part I
to Part IV and Part II will now be Part I. This was done to put more emphasis on the electrical safety sections, as
opposed to the NEC.

Which also brings up a point from the Committee meetings. Part I was voted to be eliminated at one point. The
majority of the members felt that Part I was little more than a paraphrasing of the NEC and it was difficult to
maintain and may cause problems when compared to the NEC. The vote was later rescinded due in part that OSHA
was in the process of including it as part of their requirements.

The examples listed below use the current document organization, which is Part II as the Electrical Safety-Related
Work Practices. When the new standard is voted on it should be Part I, but you never know what can happen during
a full Committee vote.

Example:

2-1.3.1, Part II, Electrical Hazard Analysis [Article 230.1(A)(2)], which will really be Article 130.1(A)(2), but it
makes my head hurt to try to convert these numbers too many times. Just keep in mind that this is still “fluid”.

All NOTES will be changed to FPNs (Fine Print Notes).

Figure 10 is an example page from the 2003 70E preprint showing the new structure and layout. This now conforms
to the standard NFPA format.

Many of the definitions used in the 70E were reworded, so many that it is impossible to list them all in this
document. Many of the changes were to clarify or correct previous definitions that were in the standard. These
include the definitions for Prohibited Approach Boundary, Limited Approach Boundary and Electrical Hazard. The
changes primarily brought the definitions into conformance with standard NFPA formatting and language.

Construction personnel are covered by the 70E. This is not really new, as this position was affirmed during the last
revision cycle, but needs to be emphasized.

Ground-fault protection is required for all portable power tools used on the worksite. This is also not new, but
seems to be missed by a good portion of employers.

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Definitions

The term ATPV (Arc Thermal

Performance Value) is
replaced with Arc Rating.

The phrase “curable burn” is

replaced with “second-degree
burn”.

There were numerous editorial

and clarification-type changes
made throughout the standard,
most of which did not change
the intent or meaning. Some
of the more important changes
that were made are:

New definitions were added,

including; Arc Rating, Flash
Hazard Analysis, Flash
Protection Boundary, Flame
Resistant, Flash Suit and
Incident Energy.

Arc Rating. The maximum

incident energy resistance
demonstrated by a material (or
a layered system of materials)
prior to breakopen or at the
onset of a second-degree burn.
Arc rating is normally
expressed in cal/cm2 .
FPN: “Breakopen” is a
material response
evidenced by the
formation of one or more
holes in the innermost
layer of flame-resistant
material that may allow
flame to pass through the
material.

Flash Hazard Analysis. “A

Figure
study which investigating a FIGURE 10 1
Example Page NFPA 70E PrePrint
worker’s potential exposure to Example of New 70E Format
Courtesy National Fire Protection Association
arc-flash energy, conducted for Courtesy of the National Fire Protection Association
the purpose of injury
prevention and the
determination of safe work practices and the appropriate levels of PPE.”

Flash Protection Boundary. An approach limit at a distance from exposed live parts or enclosed parts if operation,
maintenance, manipulation, or testing of equipment causes a potential flash hazard, within which a person could
receive a second-degree burn if an electrical flash were to occur.

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Flame Resistant (FR). “The property of a material whereby combustion is prevented, terminated, or inhibited
following the application of a flaming or non-flaming source of ignition, with or without the subsequent removal of
the ignition source.”

Flash Suit. “A complete FR clothing and equipment system that covers the entire body, except for the hands and
feet. This includes pants, jacket, and bee-keeper type hood fitted with a face shield.”

Incident Energy. “The amount of energy impressed on a surface, a certain distance from the source, generated
during an electrical arc event. One of the units used to measure incident energy is calories per centimeter squared
(cal/cm2 ).”

Note that the IEEE is moving towards using the metric system exclusively, and the NFPA is doing the same. In the
IEEE 1584 Guide joules/cm2 is used as opposed to cal/cm2 . To convert from cal/cm2 to j/cm2 , multiply cal/cm2 by
4.184.

One of the last changes to be agreed upon was to use the metric equivalent of the cal/cm2 (j/cm2 ) followed by
cal/cm2 in parenthesis [21 j/cm2 (5 cal/cm2 )]. The rest of the standard will convert to metric values.

Although Part I contains a great deal of valuable information, it is Part II (ESRWP) that is most often referenced by
electrical supervisors and workers. This document will concentrate on the changes to Part II, Articles 230 (Working
On or Near Live Parts) and 240 (Personal and Other Protective Equipment) as well as other important information,
such as the Flash Protection Boundary and calculating incident energy from an arc flash.

Restricted Approach Boundary. “An approach limit at a distance from an exposed live part within which there is an
increased risk of shock, due to electrical flash over combined with inadvertent movement, for personnel working in
close proximity to the live part.”

Major Changes To The Standard

Multi-Employer Relationship [Article 200.3]. This section was added to clarify that hiring contracted workers does
not absolve a company from its safety responsibilities. The thrust of this section is that companies and their
contractors are to work together to ensure the safety of all employees and document it. Requirements include
determining existing hazards, PPE needs, safe work practices and emergency procedures.

2-1.1.1, Part II, Working On or Near Electrical Conductors or Circuit Parts [Article 210.1(A)(1)]. Wording has
been added to include energized work at 50 volts or less. Previously, all requirements have been focused at systems
operating at greater than 50 volts. In general, all systems operating at 50 volts or less must be placed in an
electrically safe condition if:

• There is a risk of an arc flash injury

• A high energy system could be stressed by the work being performed
• Work is done in a wet area that could cause a shock injury
• Contact time could be a dangerous factor due to position or other factors
• Protection offered by overcurrent devices could be delayed

2-1.1.2, Part II, Working On Live Parts [Article 210.1(A)(3)]. The 2000 edition was worded so that only qualified
persons could work on electrical conductors or parts that have been placed into an electrically safe condition. The
wording was changed to allow unqualified persons to work on electrically safe components if they have been de-
energized by qualified persons.

2-1, Part II, Electrical Hazard Analysis [Article 230.2]. The section in Article 210 was an overview, while Article
230.2(A)(1)(a) requires that the Shock Hazard Analysis detail voltage, boundaries and PPE required. Shock
Approach Boundaries are specified in Table 230.4 (Table 2-1.3.4).

Energized Electrical Work Permit [Article 230.3]. This is a new section. If live parts cannot be de-energized this
permit documents the steps OSHA and 70E require. An example form is in Figure 11.

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 ENERGIZED ELECTRICAL
WORK PERMIT

PART I: TO BE COMPLETED BY THE REQUESTER:

Job/Work Order Number ______________
1) Description of circuit/equipment __________________________________________________________________
______________________________________________________________________________________________
2) Description of work to be done: ___________________________________________________________________
______________________________________________________________________________________________
3) Reason(s) why the circuit/equipment cannot be de-energized or the work deferred until the next
scheduled outage: _______________________________________________________________________________
______________________________________________________________________________________________
_____________________ ______________________
Requester/Title Date
PART II: TO BE COMPLETED BY THE ELECTRICALLY QUALIFIED PERSONS DOING THE WORK

1) Detailed job description procedure to be used in performing the above described work ?
______________________________________________________________________________________________
______________________________________________________________________________________________
2) Results of the Flash Hazard Analysis:
a) Determination of the Flash Protection Boundary: ________________________________________________ ?
_________________________________________________________________________________________
b) Protective Clothing Required: _______________________________________________________________ ?
__________________________________________________________________________________________
c) Personal Protective Equipment Required: ______________________________________________________ ?
__________________________________________________________________________________________
3) Determination of Approach Boundaries to Live Parts: _________________________________________________ ?
______________________________________________________________________________________________
4) Considerations needed for Unqualified Persons: _____________________________________________________ ?
______________________________________________________________________________________________
5) Training/Preparations Needed: ___________________________________________________________________ ?
______________________________________________________________________________________________
6) Notification to affected employees on the area of the work to be performed: ________________________________ ?
______________________________________________________________________________________________
7) Do you agree the above described work can be done safely?
No (if no, return to
? Yes ? requester)

_______________________________ _______________________
Electrically Qualified Person(s) Date

_______________________________ _______________________
Electrically Qualified Person(s) Date

PART III: APPROVALS TO PERFORM THE WORK WHILE ELECTRICALLY

ENERGIZED
______________________________
Manufacturing Manager
______________________________
Safety Manager
______________________________
Maintenance/Engineering Manager
______________________________
Electrically Knowledgeable Person

______________________________ ______________________________
General Manager Date
Note: Once the work is complete, forward this form to the site Safety Department for review and retention.
FIGURE 11
Example Energized Electrical Work Permit
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 Courtesy of the National Fire Protection Association
Note that an exception to this requirement is made in 230.3(C) as follows, “Work performed on or near live parts by
qualified persons related to tasks such as testing, troubleshooting, voltage measuring, etc. shall be permitted to be
performed without an energized electrical work permit provided appropriate safe work practices and personal
protective equipment in accordance with Chapter 2 is provided and used.” This section has also been reorganized.

2-1.3.3, Part II, Arc Flash Analysis [Article 230.11(A)]. Rewords the section and includes incident energy level
limit at 1.2 cal/cm2 . 230.11(B) provides two methods of determining the Flash Protection Boundary:

• Perform an analysis specified in Annex B, B-5

• Use Table 2-1.3.3.2 (new)

TABLE 2-1.3.3.2
Alternate Method of Determining Arc Flash Boundary

Arc location System Voltage Flash Protection

relative to Boundary (feet)
equipment
Arc in air Between 200 - 1000 4
Volts
Arc in enclosure Between 200 - 1000 10
Volts
Arc in enclosure 1000 Volts and above 20

Also, wording has been added to emphasis the risk of the hands and other body parts. “Recognizing that incident
energy increases as the distance from the arc flash decreases, additional PPE shall be used for any parts of the body
that are closer than the distance at which the incident energy was determined”.

3-3.3, Part II, Head, Face, Neck and Chin Protection [Article 240.3(C)]. Reworded to include the need for
protecting the person’s neck and chin.

2-3.3.5, Part II, Body Protection [Article 240.3(E)]. Rewords the section and adds, “Non-melting, flammable
clothing, used alone, can provide protection at low incident energy levels (2 cal/cm2 , and below)”.

Electrical Hazard Analysis [Article 230.1(A)(2)]. (Was in old Section 2-1.3.2 without title). “If the live parts are
not placed in an electrically safe condition, other safety-related work practices shall be used to protect employees
who might be exposed to the electrical hazards involved. Such work practices shall protect each employee from arc
flash and from contact with live parts directly with any part of the body or indirectly through some other conductive
object. The work practices that are used shall be suitable for the conditions under which the work is to be performed
and for the voltage level of the live parts.”

2-3.5, Part II. Conductive Articles Being Worn [Article 230.4(G)]. Conductive eyeglass frames are not to be worn
where they present an electrical hazard. The general feeling was that plastic frame glasses should be worn when
working on or near exposed live parts.

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Table 3-3.9.1, Part II, Hazard Risk Category Classifications [Table 240.3(I)(1)]. Numerous modifications to this
Table (Figure 12):

• The hazard/risk category is based solely on the arc energy, not the assumed risk of the task, as the
Committee does not want to assess the amount of risk. This will be up to the individual and his supervisor.
• Clarifications for the Tasks listed
• Adds watthour meter to the equipment listed
• Adding diagnostic testing and applying safety grounds to the lists of Tasks
• The higher voltage range is changed from “1kV and above” to read “1 kV to 38kV”
• The 2* HRC is removed
• The incident energy assumptions are listed
1. LV is calculated using “arc-in-a-box” equation at a distance of 18”
2. HV is calculated using E=(793*I*kV*t)/D2 at a distance of 36”
• Note 1 is added – “Both larger and smaller available short circuit currents can result in higher available arc-
flash energies. If the available short circuit current increases without a decrease in the opening time of the
overcurrent protective device, the arc-flash energy will increase. If the available short circuit current
decreases, resulting in a longer opening time for the overcurrent protective device, arc-flash energies may
also increase.”
• Note 4 is added – “The listed fault current and upstream protective device clearing times are based on an
18-inch working distance”.
• Note 5 is added – “Hazard/Risk Category takes into account the provision of Part II, 3-3.9.4.6
(interference). During the listed diagnostic testing, there is a reduced risk of creating an arc flash incident
by using less restrictive PPE. Also, when appropriate meters and testing techniques are used, the likelihood
of an arc flash happening during diagnostic testing is low compared to working live parts, as with tools. A
job safety analysis may indicate a higher category of PPE is required”.
• Note 7 is added – “The degree of hazard and risk is too great for this task to be performed while the circuit
is energized. This task must be performed only with the equipment in an electrically safe work condition”.
• Note 8 is added – “If approved arc resistant designs or remote-operating (outside the Flash protection
Boundary) techniques are applied that permit closed door completion of the task, the HRC is 0”.
• HRC 5 was considered for inclusion in the Table, but was removed after much discussion. It was felt that
any work that is performed in close proximity to incident energies above 40 cal/cm2 should receive a full
flash hazard analysis, or better yet, only be worked de-energized. This is due to the evidence that at these
energy levels the hazard from the acoustic wave is greater than that from the heat.

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 FIGURE 12
Table 240(I)(1)
Courtesy of the National Fire Protection Association

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Table 3-3.9.2, Part II, Protective Clothing and Personal Protective Equipment (PPE) Matrix (Figure 13) [Table
240.3(I)(2)]. Changes untreated cotton to read, “Non-melting (according to ASTM F-1506-00) or untreated Natural
Fiber.” This allows using other natural fibers such as silk, rayon or wool. There were other editorial changes in the
notes, but nothing that significantly changed the meaning of any of them. HRC 5 as shown in the Table below has
been deleted by the Committee.

Protective Clothing & Protective Systems for Hazard/Risk Category

Equipment
Hazard/Risk Category Number −1 0 1 2 3 4 and 5
(Note 3)
Non-melting (according to — — — — — —
ASTM F 1506-00) or Untreated
Natural Fiber
a. T-shirt (short-sleeve) X X X X
b. Shirt (long-sleeve) X
c. Pants (long) X X X X X X
(Note 4) (Note 6)
FR Clothing (Note 1) — — — — — —
a. Long-sleeve shirt X X X X
(Note 9)
b. Pants X X X X
(Note 4) (Note 6) (Note 9)
c. Coverall X
(Note 5) (Note 7) (Note 9) (Note 5)
d. Jacket, parka, or rainwear
AN AN AN AN
FR Protective Equipment — — — — — —
a. Flash suit jacket X
(multi-layer)
b. Flash suit pants X
(multi-layer)
c. Head protection — — — — — —
1. Hard hat X X X X
2. FR hard hat liner AR AR
d. Eye protection — — — — —
1. Safety glasses X X X AL AL AL
2. Safety goggles AL AL AL
e. Face and head area protection — — — — —
1. Arc-rated face shield, X
or flash suit hood (Note 8)
2. Flash suit hood X X
3. Hearing protection AR X X
(ear canal inserts) (Note 8)
f. Hand protection — — — —
Leather gloves (Note 2) AN X X X
g. Foot protection — — — —
Leather work shoes AN X X X

FIGURE 13
Sample of Table 3-3.9.2
Courtesy of the National Fire Protection Association

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Table 3-3.9.3, Part II, Typical Protective Clothing Systems (Figure 14) [Table 240.3(I)(3)]. The reference to fabric
weight is deleted to recognize changes in technology. HRC 5 was included at one time, but was deleted.

Typical Protective Clothing Systems

Hazard Clothing Description (Typical Total Weight Required Minimum Arc Rating of
Risk number of clothing layers is given oz/yd2 PPE
Category in parentheses) cal/cm2

0 Non-melting, flammable materials 4.5 – 14 For use up to 2 cal/cm2 incident energy

(i.e., untreated cotton, wool, rayon, or exposure, but materials have no arc
silk, or blends of these materials) with rating
a fabric weight at least 4.5 oz/yd2
(1)

1 FR shirt and FR pants or FR coverall 4.5 – 12 4

(1)

2 Cotton underwear - conventional 9 – 16 8

short sleeve and brief/shorts, plus FR
shirt and FR pants (2)

3 Cotton underwear plus FR shirt and 16 – 20 25

FR pants plus FR coverall, or cotton
underwear plus two FR coveralls (3)

4 Cotton underwear plus FR shirt and 24 – 30 40

FR pants plus multi-layer flash suit
(3, or more)

5 Cotton underwear plus FR shirt and > 30 100

FR pants plus multi-layer flash suit
(3, or more)

Note: Arc Rating is defined in Part I, Section I-2 and can be either ATPV or EBT. ATPV is defined in
ASTM F 1959-99 as the incident energy on a fabric or material that results in sufficient heat transfer
through the fabric or material to cause the onset of a second-degree burn based on the Stoll curve. EBT is
defined in ASTM F 1959-99 as the average of the five highest incident energy exposure values below the
Stoll curve where the specimens do not exhibit breakopen. EBT is reported when ATPV cannot be
measured due to FR fabric breakopen.

FIGURE 14
Table 3-3.9.3
Courtesy of the National Fire Protection Association

3-3.9.4.1, Part II, Layering [240.3(K)(1)]. Nonmelting, flammable fiber garments permitted as underlayers in
conjunction with FR clothing.

3-3.9.4.3, Part II, Underlayers [240.3(K)(3)]. “Meltable fibers such as acetate, nylon, polyester, polypropylene, and
spandex shall not be permitted in fabric underlayers (underwear) next to the skin.”

Exception: An incidental amount of fabric used on non-melting fabric underwear or socks shall be
permitted.”

3-3.9.4.4, Part II, Coverage [240.3(K)(4)]. A new sentence was added, “Shirt sleeves shall be fastened at the wrists,
and shirts and jackets shall be closed at the neck.”
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3-3.9.5.1, Part II, Flash Suits [240.3(L)(1)]. The first sentence was reworded to read, “Flash suit designs shall permit
easy and rapid removal by the wearer. The entire flash suit, including the hood’s face shield, shall have an arc rating
that is suitable for the arc-flash exposure.” Adds the sentence, “When exterior air is supplied into the hood, the air
hoses and pump housing shall either be covered by FR materials or constructed of non-melting and non-flammable
materials.

3-3.9.5.2, Part II, Face Protection [240.3(L)(2)]. This section is reworded and now reads, “Face shields shall have an
arc rating suitable for the arc flash exposure. Face shields without an arc rating shall not be used. Eye protection
(safety glasses or goggles) shall always be worn under face shields or hoods:
(New) FPN 1: Face shields made with energy absorbing formulations that can provide higher levels of
protection from the radiant energy of an arc flash are available, but these are tinted and can reduce
visibility. Additional illumination of the task area may be necessary when these types of arc protective face
shields are used.

(New) FPN 2: Safety glasses and goggles provide lesser protection, but in low risk tasks they may be
justified if the task involves substantial physical work in combination with high visual requirements.”

3-3.9.5.3, Part II, Hand Protection [240.3(L)(3)]. This section has been reworded, “Leather or FR gloves shall be
worn where required for arc flash protection. Where insulating rubber gloves are used for shock protection, leather
protectors shall be worn over the rubber gloves.”
New “FPN: Insulating rubber gloves and gloves made from layers of flame resistant material provide hand
protection against the arc flash hazard. Heavy-duty leather (eg, greater than 12 oz/yd2 ) gloves provide
protection suitable up to Hazard/Risk Category 2. The leather protectors worn over insulating rubber
gloves provide additional arc-flash protection for the hands. During high arc exposures leather can shrink
and cause a decrease in protection.”

3-3.9.7, Part II, Melting [240.3(N)(1)]. Reworded, “Clothing made from flammable synthetic materials that melt at
temperatures below 3150 C (6000 F), such as acetate, nylon, polyester, polypropylene, and spandex, either alone or in
blends shall not be used.”
(New) FPN: “These materials will melt as a result of arc-flash conditions, form intimate contact with the
skin and aggravate the burn injury.”

(New) “Exception: “Fiber blends that contain materials that melt, such as acetate, nylon, polyester,
polypropylene and spandex shall be permitted if such blends in fabrics meet the requirements of ASTM
F1506, and if such blends in fabrics do not exhibit evidence of a melting and sticking hazard during arc
testing according to ASTM F1959.”

3-3.9.7.2, Part II, Flammability [240.3(N)(2)]. Reworded, “Clothing made from non-melting flammable natural
materials, such as cotton, wool, rayon and silk shall be permitted for Hazard/Risk Categories 0 and minus 1 if it is
determined by flash hazard analysis that the exposure level is 2 cal/cm2 or below, and that the fabric will not ignite
under the arc exposure hazard to which it will be exposed (using data from tests done in accordance with ASTM F
1958). See also 3-3.9.4.1 for layering requirements.”
New FPN 1: “Non-FR Cotton, polyester-cotton blends, nylon, nylon-cotton blends, silk, rayon, and wool
fabrics are flammable. These fabrics can ignite and continue to burn on the body resulting in serious burn
injuries.”

New FPN 2: “Rayon is a cellulose-based (wood pulp) synthetic fiber that is flammable, but non-melting
material.”

One thing to be noted here is that rayon is a synthetic and is specifically prohibited by 29CFR1910.269(l)(6)NOTE.
This does place the 70E in conflict with the OSHA regulation, so it would be best to exclude rayon from your list of
acceptable fabrics. Rayon, by the way, is made of wood pulp and is flammable.

Appendix B, Sample Calculation of Incident Energy and Flash Protection Boundary [Annex B]. IEEE standard
1584-2002 was included as an Annex. Wording to this Annex will remain the same as in the 2000 version of the
70E from B-1 through B-5.3. The new information will actually start with B-6. Due to copyright restrictions, that

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portion cannot be included. These new calculations will be of little use to the typical field technician, as they are
beyond what they could be expected to solve.

Annex XX (New). Job Briefing and Planning Form. A checklist to assist in documenting the requirements of a Job
Briefing. An example form is provided in the new Annex, Figure 15.

Identif
y

? What are the hazards? ? Potential for arc flash

? What voltage levels are involved? ? Unusual work conditions
? What skills are required? ? Is this a multiple-person job?
? "Foreign" voltage source present?
?
Ask

? Can the equipment be de-energized? ? Is a "standby" person required?

? Are there possible backfeeds of the ircuits to be worked on?
?
Check

? Job plans ? Safety procedures

? One lines and vendor prints ? Vendor information
? Status board ? For up-to-date information on
? Individuals familiar wit the facility? and vendor resources
?
Know

? What is the job?

? Who is in charge?
? Who else needs to know?….Communicate!
?
Think

? About the extra event…..What if? ? Use the right tools and
equipment, including PPE
? Lock - Tag - Test - Try ? Install barriers and barricades
? Test for voltage - FIRST ? What else…….?
? Install and remove grounds
?
Prepare for an emergency

? Standby person CPR trained? ? What is the exact work location?

? Telephone location? ? How is the equipment shut off
in an emergency?
? Fire alarm locations? ? Where is the emergency equipment?
? Confined space rescue available if needed? ? Is the required emergency equipment
available?
? Emergency phone numbers? ? Radio communications available?
? Extinguisher? ?
FIGURE 15
Job Briefing and Planning Form
Courtesy of the National Fire Protection Association

None of the above changes are official until the entire Committee votes on them, but chances are the ones included
in this tutorial will go through. The final edition will be published in July, 2003.
© 2003 Doble Engineering Company 24
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Legally

The CFR regulations are Federal Law. End of story. There is no option to compliance, as the large-to-massive fines
OSHA assesses will attest to. The fine points are critical to your company. When OSHA investigates an incident,
you can be certain that there will be fines recommended. Those seeking to mitigate the effects of an investigation
need to be prepared for the situation.

Have a team of representatives pre-selected. The team should consist of three people, a Management
Representative, an Employee Representative and a Recorder. According to an OSHA directive, you have up to 1
hour to assemble this team to accompany the Compliance Officer (CO) on his inspections. Have the Recorder
videotape whatever the CO videotapes and record whatever the CO records. If the Compliance Officer asks for
records, files or other documentation, you are required to provide them. However, you are not required to make
copies for him to take. Records and files are to be viewed at the site only. Approach the inspection as if you will be
going to court. Everything you say can and will be used against you.

When the CO arrives, ask for identification. Also ask him to wait while you assemble your team. He will then have
an opening conference with your team. Record everything, period. Assemble the records he requests. Remember,
you are not required to make copies. After the opening conference, the CO will inspect the facility and interview
employees. Your Representatives have a right to be there. The CO will hold a closing conference where he will
review potential violations, discuss remedial actions and abatement dates. Do not agree to abatement dates or
violations if you don’t believe they are warranted.

The next step in the process is that you will be sent a Notice of Citation from the Area Director. You have 15 days
from receipt to appeal in writing. In it will be proposed penalties for the citations, which, of course, you should not
pay at this time. You will be contacted to have an informal conference with the Area Director. Most issues can be
resolved at this point, which is where you would like it to end. If this doesn’t go anywhere, file a Notice of Contest.
This informs OSHA that you plan to go to court. During the period of time that you are appealing, everything is on
hold. Don’t agree to abatement dates or fines or even acknowledge violations. It will take about 1 ½ years to go to
trial and recent records indicate that OSHA wins about 50% of the cases that go to trial.

If you agree with the violations, you can ask OSHA to give you preferential treatment. They will reduce fines if you
show good faith effort. OSHA is not out to put you out of business, but to modify bad behavior. If you’re a small
business, or if you have not been fined in the last year, you can receive considerable reductions in the fines. In all,
you can receive up to a 95% reduction in the fines levied.

The other aspect of this scenario is that if someone is injured or killed, you will be defending yourself in court. If
you supervised the person, you could be held personally accountable for your decisions. Do not place yourself (or
your personnel) in the position of being guilty of a Willful Violation. OSHA defines this as a violation that the
employer knowingly commits, with intentional disregard or plain indifference to the employee’s welfare. Jail terms
as well as fines can be assessed on individuals as well as companies. OSHA will typically pursue the civil penalties
before the criminal ones.

As mentioned in the beginning, ignoring a nationally-recognized safety standard would be less than smart. The 70E
represents the latest and best information and policies for electrical safety at the work site and to pretend it’s not
there only increases your liability. OSHA expects companies to be pro-active in the safety area; not reactive. You
may not be cited by OSHA for violating the NFPA 70E, but it would be difficult to defend in court.

The best policy is to seek out new information, know what is going on in the industry and audit your personnel’s
safety performance on the job.

© 2003 Doble Engineering Company 25

All Rights Reserved
IEEE STANDARD 1584-2002

This Working Group released their new guide, “IEEE Guide for Performing Arc-Flash Hazard Calculations” (Figure
16) in November of 2002. Starting with Ralph Lee’s paper, “The Other Electrical Hazard, Electric Arc Blast
Burns”[15], this document goes much further than that paper in defining and quantifying the arc flash hazard. The
calculations for systems rated above 15,000 volts still uses Mr. Lee’s equations, but much has been discovered via
research about arc flash at voltages below that
value. Another paper by Doughty, Neal and
Floyd, “Predicting Incident Energy Levels to
Better Manage the Electric Arc Hazard on 600-V
Power Distribution Systems” explored the effects
of electric arcing in metal-clad switchgear, which
were determined during a series of staged tests.
These papers (and about 26 others) are used as
background for this Guide.

Two calculators and three test data spreadsheets

are included with the guide:

• The Arc-Flash Hazard Calculator

• The Bolted Fault Calculator (calculates
the short-circuit current for simple, radial systems)
• The CL Fuse Test Data (results of fuse
testing)
• The IEEE 1584 Data Set (results of actual
testing)
• The Test Results Data Base (results of
Figure 6 actual testing)
IEEE 1584 – 2002
Courtesy Institute for Electrical and Electronic Enigineer Due to the complex nature of the calculations
used to determine the incident energy of an arc,
FIGURE 16 most people will need to use the calculators.
Cover of IEEE 1584-2002 The down side of this is that the calculators are
only available (at this writing) with the Guide.
The calculators are based on:

• Three-phase voltages from 208V to 15kV, 50 and 60Hz

• Bolted fault current from 700A to 106,000A
• Grounded and ungrounded systems
• Equipment in enclosures of commonly available sizes
• Arc gaps ranging from 13mm to 152mm (0.5” to 6”)
• All results are in the metric system, where incident energy is given as joules/ cm2 and distances in mm
(0.3937 x mm = inches). (cal/ cm2 x 4.184 = j/cm2 ). (5.0 j/ cm2 = 1.2 cal/cm2 ).

Equations are included for fuses, low-voltage circuit breakers (molded-case, insulated-case and low-voltage power)
and medium-voltage switchgear. The Guide notes that the model used for the NFPA 70E is based on a number of
givens, but is reasonably accurate for the model. The calculations in IEEE 1584 are based on actual testing and are
suitable for a wider range of variables, such as voltages, currents, enclosure sizes and arc gaps. The test methods,
results analysis and variables are subject to revision as new data becomes available.

SUMMARY
© 2003 Doble Engineering Company 26
All Rights Reserved
Electrical safety is an ever-changing field that will continue to do so for many years to come. As our knowledge
increases and as new tools become available to make the work-site safer, it is our responsibility to learn and use
them. It is inherent in people’s nature to resist change, even when that change is for the better. We cannot stand by
and use the “I didn’t know” excuse, as we, as supervisors and engineers, must keep ourselves informed.

The NFPA 70E provides the best available information to safeguard our electrical personnel. Updated every three
years, it is a consensus standard that uses a common-sense approach to every day work practices. This revision, like
the revision prior, has many changes that clarifies and quantifies safe work practices in a manner that can be used at
our sites.

BIBLIOGRAPHY

1. Statistical Data From the U.S. Department of Labor, Bureau of Labor Statistics

2. 3rd International Conference on Electrical Injury, Electric Power Research Institute

3. Cost Benefits of Electrical Safety, IEEE IAS Electrical Safety Workshop, February 2003, Dr. Mary
Capelli-Shellpfeffer

4. 29CFR1910.331 - .335, Subpart S, “Electrical Safety-Related Work Practices”

5. 29CFR1910.269, Subpart R, “Electric Power Generation, Transmission and Distribution”

6. ANSI/NFPA Standard 70E, “Electrical Safety Requirements For Employee Workplaces”

7. “Safety Electrical One-Line Diagrams”, IEEE CH2272-3, 1986, T. Brown

8. ANSI/NFPA Standard 70E, “Report on Proposals”, March 2002

9. ANSI/NFPA Standard 70E, “Preprint Draft”, July 2002

10. ANSI/NFPA 70E, “Report on Comments”, December 2002

11. “Guide for Performing Arc-Flash Calculations”, IEEE 1584-2002

12. ANSI/NFPA Standard 70, “National Electrical Code”

13. ANSI/NFPA Standard 70B, “Recommended Practice for Electrical Equipment Maintenance”

14. Noon, R. 1995. “Engineering Analysis of Fires and Explosions”. CRC Press, Boca Raton, p. 191.

15. R. H. Lee. May/June 1982. “The Other Electrical Hazard – Electrical Arc Blast Burns”, IEEE Transactions
on Industry Applications, volume I-A-18, no. 3

16. R.H. Lee. July/August 1987. “Pressures Developed By Arcs”, IEEE Transactions on Industry
Applications, volume I-A-23, no. 4

17. Dr. Capelli-Schellpfeffer. December 2002 presentation to the NFPA 70E Committee.

© 2003 Doble Engineering Company 27

All Rights Reserved
BIOGRAPHY
James R. White, Director of Training
Shermco Industries

Jim is nationally recognized for technical-skills and safety training in the electrical power systems industry.
Currently the Director of Training for Shermco Industries, Jim has spent the last twenty-three years directly involved
in technical skills and safety training for electrical power system technicians, developing courses, presenting them
and managing training companies. Jim was employed by SUNOHIO, Inc. as the Electrical Field Services / Safety
Compliance Manager and his duties included quoting and managing field service projects. As Safety Compliance
Manager Jim had primary responsibility for SUNOHIO’s corporate compliance programs, conducting field safety
audits and maintaining safety records and logs. Jim is an authorized OSHA Outreach instructor, a member of the
Doble Transformer and the Asset Maintenance Management Committees, is a certified Level III technician and the
alternate NETA representative on the NFPA 70E Committee.

© 2003 Doble Engineering Company 28

All Rights Reserved