Confused by nfpa 70e

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Confused by NFPA 70E? By John C. Klingler, P.E. Lewellyn Technology In September 1999 a majorU.S. corporation experienced an electrical accident that resulted in serious burn injuries to an electrical apprentice employee. OSHA (Occupational Safety and Health Administration) investigated the accident and issued a number of citations. The employer challenged the citations and the disagreement ended up before the Occupational Safety and Health Review Commission. As part of the citation OSHAcontended that the employer violated a federal regulation because it did not provide or require that its electricians wear appropriate flame-resistant or retardant personal protection, specifically, flame-resistant coveralls and insulated gloves. OSHA also contended that the employer violated a regulation when it did not provide or require that its electricians wear appropriate face protection. Inthe settlement the employer agreed to develop hazard analyses in accordance with the personal protective equipment provisions contained in NFPA (National Fire Protection Association) 70E. OSHA agreed that given the present state of its standards and regulations, the hazard analyses would achieve compliance with their requirements. OSHA has not adopted NFPA 70E, does not mandate 70E compliance, yetyou can be cited for non-compliance!! How is this possible? A Little Background With the passing of the Williams-Steiger Occupational Safety and Health Act of 1970 came the need for occupational safety and health regulations. Congress directed the OSHA to develop new regulations utilizing existing “national consensus standards” (see sidebar) and established Federal standards. For its electricalsafety regulations the Secretary adopted the national consensus standard NFPA 70, better known as the NEC® (National Electrical Code®). However, OSHA encountered several problems utilizing the latest editions of the NEC including:

1. The extensive legal process of adopting each new NEC® edition and the risk of
creating potential conflicts between the adopted version and the published version.2. The NEC® is only an electrical installation standard and does not address electrical
safety in the workplace.

3. The NEC® includes provisions not relevant to the workplace.


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To correct these problems and others, NFPA created a new committee to develop electrical safety standards that would serve the needsof OSHA. This committee reports through the NEC® technical committee and is called the Committee on Electrical Safety Requirements for Employee Workplaces - NFPA 70E. The first NFPA 70E standard was published in 1979, but it wasn’t until the fifth edition in 1995 that many of the current workplace safety requirements were included. The 2004 NFPA 70E is actually the seventh edition. What is NFPA70E? In NFPA’s catalog they state: “70E covers the full range of electrical safety issues from safety-related work practices to maintenance, special equipment requirements, and installation. In fact, OSHA bases its electrical safety mandates – OSHA 1910 Subpart S and OSHA 1926 Subpart K – on the comprehensive information in this important Standard.” The 2004 edition of NFPA 70E has an introduction,four chapters and thirteen annexes. Chapter 1 - Safety–Related Work Practices; is the meat of the 70E document. It covers training requirements for Qualified and Unqualified persons, which determines who is permitted to work on or near exposed energized parts. It requires an Electrical Safety Program and covers what shall be included in it. Requirements for LOTO (Lockout/Tagout) are covered as...
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