NFPA 70E was developed at the request of OSHA so they could use it as the basis for the ESRWP regulations. In 1979 the first edition of 70E came out and has had regular updates since then. Whereas the OSHA regulations must be non-prescriptive, 70E can be very specific. Where the OSHA regulations may not be clear as to their intent, 70E expands and clarifies the regulations.

As an example, in 1910.333(a) it states, “General, safety-related work practices shall be employed to prevent electric shock or other injuries resulting from either direct or indirect electrical contacts, when work is performed near or on equipment or circuits which are or may be energized. The specific safety-related work practices shall be consistent with the nature and extent of the associated electrical hazards.”

Now if you’re like me, I don’t see anything specific in that except the word “specific.”

In the NFPA 70E, Article 110 directs us to develop and implement an Electrical Safety Program, which includes performing an Electrical Hazard/Risk Evaluation before we proceed with energized electrical work.

Article 110 also requires the use of an Energized Electrical Work Permit, which ensures the Hazard/Risk Evaluation is completed and documented. In addition, Article 110 defines the skills necessary to be a qualified electrical worker. Many people skip over Articles 110 and 120 when using the 70E, jumping directly into Article 130, which covers what PPE and equipment is required to work on energized systems or equipment.

Article 120 covers how to establish an Electrically-Safe Work Condition. If we want to have a risk-free electrical maintenance environment, we need to read no further than this Article. Too often the question we ask ourselves is, “How can I work this hot and not be injured (or blow the equipment up)?”

The real question is and always should be, “How can I work this de-energized?” As long as the equipment or circuits are energized, hazards exist and there is risk involved. Deenergizing removes the hazard and the risk, providing the only certain risk free environment to carry out electrical work. This is what OSHA expects from us, and this is what the 70E directs us to do as well.

The message gets lost, in part because we have one paragraph telling us to deenergize and 50 pages talking about energized work. Many people get the impression that OSHA and the 70E are saying one thing and implying another. One thing is very clear – the first option both OSHA and the 70E want us to consider is turning it off!

In 1910.333(a)(1) OSHA states, “”Deenergized parts. Live parts to which an employee may be exposed shall be deenergized before the employee works on or near them, unless the employer can demonstrate that deenergizing introduces additional or increased hazards or is infeasible due to equipment design or operational limitations.”

There are certain circumstances when it is necessary to work on or near equipment that is in an energized state. These should be the rare exception, not the rule. The wording in the 70E (Article 130.1) is similar, although it uses the phrase “electrically safe work condition.”

If turning off power creates additional or increased hazards, which cannot be resolved, it may be safer to work the circuit energized. Testing for the absence of voltage and/or troubleshooting of electrical devices and circuits can only be done when the circuits are energized. It is infeasible to perform these tasks in a deenergized state.

OSHA uses the word infeasible in 1910.333 when it gives examples of when it is allowable to work energized, such as testing of circuits or due to equipment design or operational limitations.

This wording leads some people (mostly production managers and the like) to try to stretch the intent to cover situations that OSHA simply did not have in mind.

If you look up the word “infeasible” in the dictionary it will reflect that there is no other way to do something. The exact wording changes from reference to reference, but the meaning is clear. When discussing the possibility of shutting production down, missing quotas or rescheduling work there seems to be a sudden lack of consensus as to what “infeasible” actually means.

Don’t delude yourself. If someone is seriously injured or killed, you could be called in to account for your self-seeking definition of “infeasible.” If someone loses their life due to your decision, OSHA can recommend substantial fines and can pursue criminal charges against not only the company, but the individual responsible for the decision.

One example that occurred was when a medical facility hired a contractor to perform maintenance on an automatic transfer switch. The contractor requested that the switch be deenergized so he could work safely. The medical facility pointed to the exception in the regulation that listed “interruption of life support systems”

(1910.333(a)(1) Note 1), as the ATS fed an emergency room. The contractor proceeded with the work in an energized state, an arc occurred and he was killed. Several things came about due to this tragedy:

• The hospital found out they could turn off that source of power, as the accident destroyed the switch.

• The word “infeasible” was clarified to them by OSHA. The emergency room was not in non-stop use. Alternate power cabling fed from a generator could have been readied and connected during one of those periods when it was not in use.