Report on Comments — Copyright, NFPA NFPA 70E

Report of the Committee on Alternates

Louis A. Barrios, Jr., Shell Global Solutions, TX [U]
Electrical Safety Requirements for Employee Workplaces (Alt. to Paul S. Hamer)
Hugh R. Bundy, Sandia National Laboratories, NM [U]
Ray A. Jones, Chair (Alt. to C. Bryan Drennan)
Electrical Safety Consulting Services, Inc., NC [U] Daryld Ray Crow, DRC Consulting, WA [M]
Rep. American Chemistry Council (Alt. to Lee R. Hale)
Paul Dobrowsky, Eastman Kodak Company, NY [U]
Joseph J. Andrews, Electrical Safety Resources, Inc., SC [U] (Alt. to Joseph J. Andrews)
Rep. Institute of Electrical & Electronics Engineers, Inc. Maury C. Dunn, Dominion Virginia Power, VA [SE]
Allen H. Bingham, Bingham Consultants, GA [SE] (Alt. to Allen H. Bingham)
Rep. American Society for Testing and Materials-Committee F18 George D. Gregory, Square D Company, IA [M]
Gibeon W. Bradbury, Bradbury Technologies, Canada [SE] (Alt. to Terry Tiede)
Rep. Ontario Assn. of Certified Engineering Technicians & Technologists Palmer L. Hickman, National Joint Apprentice & Training Committee, MD
Julian R. Burns, Burns Electrical/Quality Power Solutions, Inc., NC [I M] [L]
Rep. Independent Electrical Contractors, Inc. (Alt. to Michael I. Callanan)
Michael I. Callanan, National Joint Apprentice & Training Committee, MD Michael J. Hittel, GM Worldwide Facilites Group, MI [U]
[L] (Alt. to Lynn F. Saunders)
Rep. International Brotherhood of Electrical Workers Charles J. Kelly, Edison Electric Institute, DC [U]
William R. Carney, Underwriters Laboratories Inc., IL [RT] (Alt. to Kathy Wilmer)
Darkmoon Cliffdweller, Albuquerque, NM [SE] Thomas D. Norwood, AVO International Training Institute, TX [SE]
J. F. Doering, J. F. Doering Associates, OH [SE] (Alt. to Dennis K. Neitzel)
Robert E. Downey, Allison Transmission Division, IN [U] David A. Pace, Olin Corporation, AL [U]
C. Bryan Drennan, Sandia National Laboratories, NM [U] (Alt. to Ray A. Jones)
Drake A. Drobnick, Visteon Corporation, MI [U] Vincent J. Saporita, Cooper Bussmann, MO [M]
Bobby J. Gray, Fluor Hanford/USDOE-Richland, WA [E] (Alt. to Jack Wells)
Rep. US Department of Energy Anthony A. Selk, Visteon Corporation, MI [U]
Lee R. Hale, Alcoa, Incorporated, IA [M] (Alt. to Drake A. Drobnick)
Rep. The Aluminum Association James W. Stallcup, Jr., Keller, TX [SE]
Paul S. Hamer, ChevronTexaco Corporation, CA [U] (Alt. to James G. Stallcup)
Rep. American Petroleum Institute James R. White, Shermco Industries, Inc., TX [I M]
C. E. Jackson, Jr., C. E. Jackson, Jr. Construction Consultant, MS [SE] (Alt. to Ron Widup)
Dennis K. Neitzel, AVO Training Institute, TX [SE]
David L. Potts, National Electrical Contractors Association, MD [I M] Nonvoting
Rep. National Electrical Contractors Association
Lynn F. Saunders, General Motors WFG-Utilities Services, MI [U] James R. Tomaseski, International Brotherhood of Electrical Workers, DC [L]
Keith W. Schuh, Fermilab, IL [U ] Rep. National Electrical Safety Code
James G. Stallcup, Keller, TX [SE] David M. Wallis, US Department of Labor, DC [E]
Terry Tiede, Square D Company, IA [M]
Jack Wells, Pass & Seymour/Legrand, NY [M] Staff Liaison: Kenneth G. Mastrullo
Rep. National Electrical Manufacturers Association
Ron Widup, Shermco Industries, Inc., TX [I M] Committee Scope: This Committee shall have primary responsibility for
Rep. InterNational Electrical Testing Association Inc. documents on electrical safety requirements to provide a practical safe work-
Kathy Wilmer, Duke Energy Fossil, NC [U] ing area for employees in their pursuit of gainful employment relative to the
Rep. Edison Electric Institute hazards arising from the use of electricity, as covered in the scope of NFPA 70,
National Electrical Code. This Committee shall have primary jurisdiction but
shall report to the Association through the National Electrical Code Technical
Correlating Committee.

These lists represent the membership at the time the Committees were bal-
loted on the text of this report. Since that time, changes in the membership
may have occurred. A key to classifications is found at the front of the docu-
ment.

This portion of the Technical Committee Report of the Committee on

Electrical Safety Requirements for Employee Workplaces, is presented for
adoption.

This Report on Comments was prepared by the Technical Committee on

Electrical Safety Requirements for Employee Workplaces, and documents
its action on the comments received on its Report on Proposals on NFPA 70E,
Standard for Electrical Safety Requirements for Employee Workplaces,
2000 edition, as published in the Report on Proposals for the 2003 November
Meeting.

70E-1
Report on Comments — Copyright, NFPA NFPA 70E
This Report on Comments has been submitted to letter ballot of the Technical ered to be conductive.
Committee on Electrical Safety Requirements for Employee Workplaces, Fine Print Note for Part II, 3-3.9.2:
which consists of 25 voting members. The results of the balloting, after circu- Leave the terms “may” in the text to be consistent with NEC Style Manual.
lation of any negative votes, can be found in the report. Fine Print Note for Part II, 3-3.9.3:
Leave the term “may” in the text to be consistent with NEC Style Manual.
This Report on Comments has also been submitted to letter ballot of the Fine Print Note for Part III, 8-1:
National Electrical Code Technical Correlating Committee which consists Leave the term “can” rather than “are able to” in the second to bottom line in
of 9 voting members; of whom 9 voted affirmatively. the text to be consistent with NEC Style Manual.
Fine Print Note for Part IV, 2-2.1:
Mr. Kovacik voted affirmatively stating: Leave the terms “can” and “may” in the text to be consistent with NEC Style
I wish to be recorded as voting affirmative with comment on the Ballot on the Manual.
Release of NFPA 70E-ROC. Fine Print Note No. 1 for Part IV, 2-5.1:
Fine Print Note on definition of Arc Rating: Leave the term “may” and replace “FPN 1” with “FPN No. 1ʼ in the text to be
Leave “may” in the text to be consistent with NEC and Style Manual. consistent with NEC Style Manual.
Fine Print Note on definition of Class I: Fine Print Note No. 2 for Part IV, 2-5.1:
Replace “Note 2” with “FPN and leave “may” rather than “could” in the text Leave the term “may” and replace “FPN 2” with “FPN No. 2” in the text to
to be consistent with NEC and Style Manual. be consistent with NEC Style Manual.
Fine Print Note on definition of Class I, Zone 1: Fine Print Note for Part IV, 2-5.4.7:
Replace “Note 1” with “FPN No. 1” and leave “may” rather than “could” in Replace “Note” with “FPN” and replace “can” in the text with “may” to be
the text to be consistent with NEC and Style Manual. consistent with NEC Style Manual.
Fine Print Note on definition of Class I, Zone 1: Fine Print Note Part IV, 2-6.4:
Replace “Note 2” with “FPN No.2 and leave “may” rather than “could” in the Replace “can” in the text with “may” to be consistent with NEC Style
text to be consistent with NEC and Style Manual. Manual.
Fine Print Note on definition of Class II, Division 1: Fine Print Note No. 1 for Part IV, 3-3.1
Replace “Note” with “FPN” and leave “may” in the text to be consistent with Leave the term “may” and replace “FPN 1” with “FPN No. 1” in the text to
NEC and Style Manual. be consistent with NEC Style Manual.
Fine Print Note on definition of Class II, Division 2: Fine Print Note Part I, 2-6.5.6:
Replace “Note 1” with “FPN No. 1” and leave “may” in the text to be consis- Leave the term “may” rather than replacing it with “could” to be consistent
tent with NEC and Style Manual with the NEC Style Manual.
Fine Print Note on definition of Class II, Division 2:
Replace “Note 2” with “FPN No. 2” and leave “may” in the text to be consis- Mr. Pauley voted affirmatively stating:
tent with NEC and Style Manual. I am voting affirmative on the ballot. However, I believe that the TCC
Fine Print Note for Part II, 2-2.4: should direct the 70E committee to resolve the issue of multiple calculation
Delete the text in this note and make into required text as follows: methods during the next cycle. The comments on voting from some commit-
2-2.4.1.Objects that are not insulated for the voltage involved shall be consid- tee members point out the issue of having multiple “answers” to the arc flash
energy analysis is inappropriate in a standard.

70E-2
Report on Comments — Copyright, NFPA
________________________________________________________________
70E-1 Log #2 Final Action: Accept
( Entire Document )
________________________________________________________________
Submitter: National Electrical Code Technical Correlating Committee
Comment on Proposal No:70E-13
Recommendation: The Technical Correlating Committee directs the
committee to do a complete review of the document and address the issue of
NOTES contained in the text. The Technical Correlating Committee directs the
committee to convert these NOTES to Fine Print Notes (FPN) in accordance
with the NEC Style Manual. It should be specifically noted that FPNs are
not permitted to contain requirements, provide recommendations or provide
interpretations. The Technical Correlating Committee notes that there are
numerous instances where the committee will need to consider revising the
requirement in order to accomplish the objective presently stated in a NOTE.
Examples of NOTES containing requirements can be found in Proposals
70E-45 (Log #99) and 70E-55 (Log #112). Examples of NOTES with
recommendations can be found in Proposals 70E-49 (Log #104) and 70E-124
(Log #72). These are limited examples and the committee should thoroughly
review the entire document and make appropriate revisions.
Substantiation: The document is being reformatted from the NFPA Manual of
Style to the NEC Style Manual. All notes should be modified for consistency
with the NEC Style Manual.
Committee Meeting Action: Accept
The Technical committee has reviewed the Fine Print notes and have
modified the text for those FPNʼs as follows:
1-1.1(2) FPN: For additional information concerning such installations
concerning such installations in an industrial or multi-building complex, see
ANSI C2-1997 2002, National Electrical Safety Code.
Revise text as follows:
FPN: For additional information concerning such installations concerning such
installations in an industrial or multi-building complex, see ANSI C2-1997
2002, National Electrical Safety Code.
Substantiation:
The committee removed redundant text from the Fine Print Note.
Fine Print Note for the definition of Arc Rating.
NOTE: “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.
Revise text as follows:
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 would
allow flame to pass through the material.
Substantiation:
The committee modified the text to comply with the NEC Style Manual.
Fine Print Note #2 for the definition of Class I Locations
NOTE 2: In some Division 1 locations, ignitible concentrations of flammable
gases or vapors may be present continuously or for long periods of time.
Examples include the following:
Revise text as follows:
NOTE 2: In some Division 1 locations, ignitible concentrations of flammable
gases or vapors may could be present continuously or for long periods of time.
Examples include the following:
Substantiation:
The committee modified the text to comply with the NEC Style Manual.
Fine Print Note #1 for the definition of (2) Class I, Zone 1
NOTE 1: Normal operation is considered the situation when plant equipment
is operating within its design parameters. Minor releases of flammable material
may be part of normal operations. Minor releases include the releases from
mechanical packings on pumps. Failures that involve repair or shutdown (such
as the breakdown of pump seals and flange gaskets, and spillage caused by
accidents) are not considered normal operation.
Revise text as follows:
NOTE 1: Normal operation is considered the situation when plant equipment
is operating within its design parameters. Minor releases of flammable material
may could be part of normal operations. Minor releases include the releases
from mechanical packings on pumps. Failures that involve repair or shutdown
(such as the breakdown of pump seals and flange gaskets, and spillage caused
by accidents) are not considered normal operation.
70E-3
NFPA 70E
Substantiation:
The committee modified the text to comply with the NEC Style Manual.
Fine Print Note #2 for the definition of (2) Class I, Zone 1
NOTE 2: This classification usually includes locations where volatile
flammable liquids or liquefied flammable gases are transferred from one
container to another. In areas in the vicinity of spraying and painting operations
where flammable solvents are used; adequately ventilated drying rooms or
compartments for evaporation of flammable solvents; adequately ventilated
locations containing fat and oil extraction equipment using volatile flammable
solvents; portions of cleaning and dyeing plants where volatile flammable
liquids are used; adequately ventilated gas generator rooms and other portions
of gas manufacturing plants where flammable gas may escape; inadequately
ventilated pump rooms for flammable gas or for volatile flammable liquids; the
interiors of refrigerators or freezers in which volatile flammable materials are
stored in the open, lightly stoppered, or in easily ruptured containers; and other
locations where ignitible concentrations of flammable vapors or gases are likely
to occur in the course of normal operation but not classified Zone 0.
Revise text as follows:
NOTE 2: This classification usually includes locations where volatile
flammable liquids or liquefied flammable gases are transferred from one
container to another. In areas in the vicinity of spraying and painting
operations where flammable solvents are used; adequately ventilated drying
rooms or compartments for evaporation of flammable solvents; adequately
ventilated locations containing fat and oil extraction equipment using volatile
flammable solvents; portions of cleaning and dyeing plants where volatile
flammable liquids are used; adequately ventilated gas generator rooms and
other portions of gas manufacturing plants where flammable gas may could
escape; inadequately ventilated pump rooms for flammable gas or for volatile
flammable liquids; the interiors of refrigerators or freezers in which volatile
flammable materials are stored in the open, lightly stoppered, or in easily
ruptured containers; and other locations where ignitible concentrations of
flammable vapors or gases are likely to occur in the course of normal operation
but not classified Zone 0.
Substantiation:
The committee modified the text to comply with the NEC Style Manual.
Fine Print Note for the definition of Class II, Division 1.
NOTE: Combustible dusts that are electrically nonconductive include dusts
produced in the handling and processing of grain and grain products, pulverized
sugar and cocoa, dried egg and milk powders, pulverized spices, starch and
pasts, potato and wood-flour, oil meal from beans and seed, dried hay, and
other organic materials that may produce combustible dusts when processed
or handled. Only Group E dusts are considered to be electrically conductive
for classification purposes . Dusts containing magnesium or aluminum are
particularly hazardous, and the use of extreme precaution is necessary to avoid
ignition and exposion.
Revise text as follows:
NOTE: Combustible dusts that are electrically nonconductive include dusts
produced in the handling and processing of grain and grain products, pulverized
sugar and cocoa, dried egg and milk powders, pulverized spices, starch and
pastse, potato and wood-flour, oil meal from beans and seed, dried hay, and
other organic materials that may could produce combustible dusts when
processed or handled. Only Group E dusts are considered to be electrically
conductive for classification purposes. Dusts containing magnesium or
aluminum are particularly hazardous, and the use of extreme precaution is
necessary to avoid ignition and explosion.
Substantiation:
The committee modified the text to comply with the NEC Style Manual.
Fine Print Note #1 for the definition of Class II, Division 2.
NOTE 1: The quantity of combustible dust that may be present and the
adequacy of dust removal systems are factors that merit consideration in
determining the classification and may result in an unclassified area.
Revise text as follows:
NOTE 1: The quantity of combustible dust that may be present and the
adequacy of dust removal systems are factors that merit consideration in
determining the classification and may could result in an unclassified area.
Substantiation:
The committee modified the text to comply with the NEC Style Manual.
Fine Print Note #1 for the definition of Class II, Division 2.
NOTE 2: Where products such as seed are handled in manner that produces low
quantities of dust, the amount of dust deposited may not warrant classification.
[ROP 70E-15]
Report on Comments — Copyright, NFPA
Revise text as follows:
NOTE 2: Where products such as seed are handled in manner that produces
low quantities of dust, the amount of dust deposited may could not warrant
classification. [ROP 70E-15]
Substantiation:
The committee modified the text to comply with the NEC Style Manual.
Fine Print Note for Part II, 2-1.1.1
NOTE 1: Example of increased or additional hazards include, but not limited
to, interruption of life support equipment, deactivation of emergency alarm
systems, shutdown of hazardous location ventilation equipment.
Revise text as follows:
NOTE 1: Example of increased or additional hazards include, but are not
limited to, interruption of life support equipment, deactivation of emergency
alarm systems, and shutdown of hazardous location ventilation equipment.
Substantiation:
The committee modified the text to comply with the NEC Style Manual.
Fine Print Note #2 for Part II, 2-1.1.1
NOTE 2: Examples of work that that may be performed on or near exposed
energized electrical conductors or circuit parts because of infeasibility due to
equipment design or operational limitations include performing diagnostics and
testing (e.g., start-up or troubleshooting) of electrical circuits that can only be
performed with the circuit energized and work on circuits that form an integral
part of a continuous process that would otherwise need to be completely shut
down in order to permit work on one circuit or piece of equipment.
Revise text as follows:
NOTE 2: Examples of work that that may might be performed on or near
exposed energized electrical conductors or circuit parts because of infeasibility
due to equipment design or operational limitations include performing
diagnostics and testing (e.g., start-up or troubleshooting) of electrical circuits
that can only be performed with the circuit energized and work on circuits
that form an integral part of a continuous process that would otherwise need
to be completely shut down in order to permit work on one circuit or piece of
equipment.
Substantiation:
The committee modified the text to comply with the NEC Style Manual.
Fine Print Note for Part II, 5-1.1.1
NOTE: An example of direct exposure is the qualified electrician who is to
work on the motor starter control, or power circuits, or the motor. An example
of indirect exposure is the person who is to work on the coupling between the
motor and compressor.
Revise text as follows:
NOTE: An example of direct exposure is the qualified electrician who is to
work on the motor starter control, or power circuits, or the motor. An example
of indirect exposure is the person who is to work on the coupling between the
motor and compressor.
Substantiation:
The committee modified the text to comply with the NEC Style Manual.
Fine Print Note for Part II, 2-2.4
NOTE: Objects that are not insulated for the voltage involved shall be
considered to be conductive.
Revise text as follows:
NOTE: Objects that are not insulated for the voltage involved shall should be
considered to be conductive.
Substantiation:
The committee modified the text to comply with the NEC Style Manual.
Fine Print Note for Part II, 3-3.9.2
NOTE 2: The PPE requirements of this section are intended to protect a person
from arc-flash and shock hazards. While some situations may result in burns to
the skin, even with the protection described in Table 3-3.9.2, burn injury should
be reduced and survivable. Due to the explosive effect of some arc events,
physical trauma injuries may occur. The PPE requirements of this section do not
provide protection against physical trauma other than exposure to the thermal
effects of an arc flash.
Revise text as follows:
NOTE 2: The PPE requirements of this section are intended to protect a person
from arc-flash and shock hazards. While some situations may could result in
70E-4
NFPA 70E
burns to the skin, even with the protection described in Table 3-3.9.2, burn
injury should be reduced and survivable. Due to the explosive effect of some arc
events, physical trauma injuries may could occur. The PPE requirements of this
section do not provide protection against physical trauma other than exposure to
the thermal effects of an arc flash.
Substantiation:
The committee modified the text to comply with the NEC Style Manual.
Fine Print Note for Part II, 3-3.9.3
NOTE: The arc rating for a particular clothing system may be obtained from
the FR clothing manufacturer.
Revise text as follows:
NOTE: The arc rating for a particular clothing system may could be obtained
from the FR clothing manufacturer.
Substantiation:
The committee modified the text to comply with the NEC Style Manual.
Fine Print Note #1 for Part II, 3-3.9.7.2
NOTE 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.
Revise text as follows:
NOTE 1: Non-FR Cotton, polyester-cotton blends, nylon, nylon-cotton blends,
silk, rayon, and wool fabrics are flammable. These fabrics can could ignite and
continue to burn on the body resulting in serious burn injuries.
Substantiation:
The committee modified the text to comply with the NEC Style Manual.
Fine Print Note for Part III, 8-1
FPN: These locations require special types of equipment and installation that
will ensure safe performance under conditions of proper use and maintenance.
It is important that inspection authorities and users exercise more than ordinary
care with regard to installation and maintenance. The maintenance requirements
for specific equipment and materials covered elsewhere in Part III are applicable
to hazardous (classified) locations. Also, other maintenance is required to ensure
that the form of construction and of installation that make the equipment and
materials suitable for the particular location are not nullified. The maintenance
required for specific hazardous (classified) locations requires that the
classification of the specific location be known. Also, the design principles and
equipment characteristics, for example, use of positive pressure ventilation,
explosionproof, nonincendive, intrinsically safe, and purged and pressurized
equipment, that were applied in the installation to meet the requirements of the
area classification must also be known. With this information, the employer and
the inspection authority can determine whether the installation as maintained
has retained the condition necessary for a safe workplace.
Revise text as follows:
FPN: These locations require special types of equipment and installation that
will ensure safe performance under conditions of proper use and maintenance.
It is important that inspection authorities and users exercise more than ordinary
care with regard to installation and maintenance. The maintenance requirements
for specific equipment and materials covered elsewhere in Part III are applicable
to hazardous (classified) locations. Also, other maintenance is required to ensure
that the form of construction and of installation that make the equipment and
materials suitable for the particular location are not nullified. The maintenance
required for specific hazardous (classified) locations requires that the
classification of the specific location be known. Also, the design principles and
equipment characteristics, for example, use of positive pressure ventilation,
explosionproof, nonincendive, intrinsically safe, and purged and pressurized
equipment, that were applied in the installation to meet the requirements of the
area classification must also be known. With this information, the employer and
the inspection authority can are able to determine whether the installation as
maintained has retained the condition necessary for a safe workplace.
Substantiation:
The committee modified the text to comply with the NEC Style Manual.
Fine Print Note for Part IV, 1-3
FPN: Additional chapters may be developed in the future by the NFPA 70E
Technical Committee for other types of special equipment.
Revise text as follows:
FPN: Additional chapters may might be developed in the future by the NFPA
70E Technical Committee for other types of special equipment.
Substantiation:
The committee modified the text to comply with the NEC Style Manual.
Report on Comments — Copyright, NFPA
Fine Print Note for Part IV, 2-2.1
FPN: Electrolytic cells can exhibit characteristics similar to an electrical
storage battery, and thus a hazardous voltage may exist after the power supply is series. The voltage of a series connection of cells is the voltage of a single
disconnected from the cell line.
Revise text as follows:
FPN: Electrolytic cells can could exhibit characteristics similar to an electrical rated capacity of such a battery is the sum of the capacities of a group of cells
storage battery, and thus a hazardous voltage may could exist after the power
supply is disconnected from the cell line.
Substantiation:
The committee modified the text to comply with the NEC Style Manual.
Fine Print Note #1 for Part IV, 2-5.1
FPN 1: Exposed energized surfaces may not establish a hazardous condition.
A hazardous electrical condition is related to current flow through the body
causing shock and flash burns and arc blasts. Shock is a function of many
factors, including resistance through the body, through skin, of return paths, of
paths in parallel with the body, and the system voltages. Arc flash burns and arc
blasts are a function of the current available at the point involved and the time
of arc exposure.
Revise text as follows:
FPN 1: Exposed energized surfaces may might not establish a hazardous
condition. A hazardous electrical condition is related to current flow through the
body causing shock and flash burns and arc blasts. Shock is a function of many
factors, including resistance through the body, through skin, of return paths, of
paths in parallel with the body, and the system voltages. Arc flash burns and arc
blasts are a function of the current available at the point involved and the time
of arc exposure.
Substantiation:
The committee modified the text to comply with the NEC Style Manual.
Fine Print Note #2 for Part IV, 2-5.1
FPN 2: A cell line or group of cell lines operated as a unit for the production of (for example: dirt and acid touching the battery rack), it is creatinges a short-
a particular metal, gas, or chemical compound may differ from other cell lines
producing the same product because of variations in the particular raw materials with an alarm to indicate the presence of a ground-fault.
used, output capacity, use of proprietary methods or process practices, or other
modifying factors. Detailed standard electrical safety-related work practice
requirements may become overly restrictive without accomplishing the stated
purpose of Part II of this standard.
Revise text as follows:
FPN 2: A cell line or group of cell lines operated as a unit for the production
of a particular metal, gas, or chemical compound may might differ from other
cell lines producing the same product because of variations in the particular
raw materials used, output capacity, use of proprietary methods or process
practices, or other modifying factors. Detailed standard electrical safety-related hydrogen evolution rate for other types of batteries (e.g., lead calcium and
work practice requirements may could become overly restrictive without
accomplishing the stated purpose of Part II of this standard.
Substantiation:
The committee modified the text to comply with the NEC Style Manual.
Fine Print Note for Part IV, 2-5.4.7
NOTE: Tools and other devices of magnetic material can be difficult to handle
in energized cells areas due to the strong dc magnetic fields.
Revise text as follows:
NOTE: Tools and other devices of magnetic material can could be difficult to
handle in energized cells areas due to the strong dc magnetic fields.
Substantiation:
The committee modified the text to comply with the NEC Style Manual.
Fine Print Note for Part IV, 2-6.4
FPN: Test equipment that is not suitable for use in such magnetic fields can
result in an incorrect response. When such test equipment is removed from the
cell line working zone, its performance can return to normal, giving the false
impression that the results were correct.
Revise text as follows:
FPN: Test equipment that is not suitable for use in such magnetic fields can
could result in an incorrect response. When such test equipment is removed
from the cell line working zone, its performance can might return to normal,
giving the false impression that the results were correct.
Substantiation:
The committee modified the text to comply with the NEC Style Manual.
70E-5
NFPA 70E
Fine Print Note for Part IV, 3-3.1
FPN 1: Batteries usually consist of a number of identical cells connected in
cell multiplied by the number of cells. If cells of sufficiently large capacity
are available, than two or more series-connected strings of equal numbers of
cells may be connected in parallel to achieve the desired rated capacity. The
comprising a single cell from each of the parallel branches.
Revise text as follows:
FPN 1: Batteries usually consist of a number of identical cells connected in
series. The voltage of a series connection of cells is the voltage of a single cell
multiplied by the number of cells. If cells of sufficiently large capacity are
available, than two or more series-connected strings of equal numbers of cells
may could be connected in parallel to achieve the desired rated capacity. The
rated capacity of such a battery is the sum of the capacities of a group of cells
comprising a single cell from each of the parallel branches.
Substantiation:
The committee modified the text to comply with the NEC Style Manual.
Fine Print Note for Part IV, 3-3.6
FPN: Work on such a system should be carried out with the battery isolated
from the battery charger. If an intentional ground is placed at one end of the
battery, an increased shock hazard existed between the opposite end of battery
and ground. Also, if another ground would develop within the system (for
example: dirt and acid touching the battery rack) it is creating a short-circuit
which could cause a fire. An ungrounded dc system should be equipped with an
alarm to indicate the presence of a ground-fault.
Revise text as follows:
FPN: Work on such a system should be carried out with the battery isolated
from the battery charger. If an intentional ground is placed at one end of the
battery, an increased shock hazard would existed between the opposite end of
battery and ground. Also, if another ground would develops within the system
circuit, which could cause a fire. An ungrounded dc system should be equipped
Substantiation:
The committee modified the text to comply with the NEC Style Manual.
Fine Print Note for Part IV, 3-3.4.3.2 (3)
FPN: Ventilation rates should be based on the maximum hydrogen evolution
rate for the applicable batteries. The maximum hydrogen evolution rate for lead
antimony batteries should be considered as 0.000269 cubic feet per minute per
charging ampere per cell at 25oC, with the maximum charging current available
from the battery charger applied into a fully charged battery. The maximum
nickel cadmium), should be obtained for the condition when the maximum
charging current available from the battery charger is applied into a fully
charged battery.
Revise text as follows:
FPN: Ventilation rates should be based on the maximum hydrogen evolution
rate for the applicable batteries. The maximum hydrogen evolution rate for lead
antimony batteries should be considered as 0.000269 cubic feet per minute per
charging ampere per cell at 25oC, with the maximum charging current available
from the battery charger applied into a fully charged battery. The maximum
hydrogen evolution rate for other types of batteries (e.g., lead calcium and
nickel cadmium, should be obtained for the condition when the maximum
charging current available from the battey charger is applied into a fully charged
battery.
Substantiation: The TCC has requested that this note be deleted because it
contains requirements. NFPA staff will clarify where the requirements is in the
FPN.
Fine Print Note #1 for Part IV, 3-3.5.1.4
FPN 1: The battery room floor should be of concrete construction. The floor
should be graded so any spillage of electrolyte will drain to an area where
the electrolyte can be neutralized before disposal (The battery manufacturer
should be consulted on the appropriate floor grading so as to reduce connection
alignment problems).
Revise text as follows:
FPN 1: The battery room floor should be of concrete construction. The floor
should be graded so any spillage of electrolyte will drain to an area where the
electrolyte can could be neutralized before disposal (The battery manufacturer
should be consulted on the appropriate floor grading so as to reduce connection
alignment problems).
Report on Comments — Copyright, NFPA
Substantiation:
The committee modified the text to comply with the NEC Style Manual.
Fine Print Note for Part I, 2-6.5.6
FPN: Where extensive metal in or on buildings may become energized and
is subject to personal contact, adequate bonding and grounding will provide
additional safety. [ROP 70E-24]
Revise text as follows:
FPN: Where extensive metal in or on buildings may could become energized
and is subject to personal contact, adequate bonding and grounding will provide
additional safety. [ROP 70E-24]
Substantiation:
The committee modified the text to comply with the NEC Style Manual.
Fine Print Note for Annex B-7-5
FPN: These equations may be used to determine if selected PPE is
adequate to prevent thermal injury at a specified distance in event of an arc
flash.
Revise text as follows:
FPN: These equations may could be used to determine if selected PPE is
adequate to prevent thermal injury at a specified distance in event of an arc
flash.
Substantiation:
The committee modified the text to comply with the NEC Style Manual.
Fine Print Note for Annex B-7-5
FPN 2: For tasks that expose workers to incident energy exceeding 40 cal/cm2,
Hazard/Risk Category 5 PPE may be required. See Table 3-3.9.1, 3-3.9.2, and
3-3.9.3.
[ROP 70E-149]
Revise text as follows:
FPN 2: For tasks that expose workers to incident energy exceeding 40 cal/cm2,
Hazard/Risk Category 5 PPE may should be required. See Table 3-3.9.1, 3-
3.9.2, and 3-3.9.3.
[ROP 70E-149]
Substantiation:
Fine Print Note #2 was not accepted because it is not consistent with the
requirements of the document.
Committee Statement: The committee has revieved and made modified to
the text of the FPNʼs as required the FPNʼs to comply with NEC Style manual.
Modification are in include file FPN for 70E in committee action. In FPN I-
1.1.(2) change the date for Ansi National Electrical Safety Code 1997 to 2002.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: The committee proposals for 70E do not address the needs
of the construction industry, are too complex for the construction industry,
and would cause an unnecessary economic hardship to contractors and
subcontractors who attempt to comply with NFPA 70E. Suitable electrical
safety related work practices, less complex than those in committee proposals
for NFPA 70E, can provide protection for construction workers against
electrical hazards. Construction should be specifically excluded from the scope
and contents of NFPA 70E, and a separate standard should be prepared for the
construction industry.
The committee proposals for NFPA 70E are acceptable for auto
manufacturing, refinery, petrochemical, and similar type large industrial
complexes with thousands of employees and multiple plant locations. Large
corporations have the financial resources and often hire electrical engineers
who specialize in electrical safety and related areas on a full time basis.
________________________________________________________________
70E-2 Log #113 Final Action: Reject
( Entire Document )
________________________________________________________________
Submitter: David Soffrin, American Petroleum Institute
Comment on Proposal No:N/A
Recommendation: The ROP Preprint has numerous typographical and
transcription errors. ROP public comments directly on the content of the
Preprint should be ignored to avoid confusion and inefficiency during the
December 2002 ROC meeting. The Technical Committee should act only on
public comments to the specific content of ROP Proposal Recommendations,
Substantiations, Committee Meeting Actions, Committee Statements, negative
or abstention vote explanations or affirmative comments.
The renumbering of the document makes catching the Preprint errors
extremely difficult. Correct all of the errors by meticulously going through
a prepublication draft that includes all accepted proposals (and the accepted
70E-6
NFPA 70E
comments on the ROP) before issuing NFPA 70E-2003. Multiple reviews
of a post-ROC (prepublication) draft by NFPA staff and a task group of the
Technical Committee members will be necessary to ensure the accuracy of the
document.
Substantiation: Spot checks made by API members during the ROP review
revealed many inaccuracies in the Preprint. The specific ROP proposals and
subsequent TC and TCC actions should govern, by NFPA procedure.
Committee Meeting Action: Reject
Committee Statement: The commentors recommendation offers no specific
proposed text that the committee can address and therefore is in violation of
NFPA Regulations Section 4-4.5.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
_______________________________________________________________
70E-2a Log #CC1 Final Action: Accept
( Entire Document )
________________________________________________________________
Submitter: Technical Committee on Electrical Safety Requirements for
Employee Workplaces
Comment on Proposal No:70E-161
Recommendation: The Committee directs NFPA Staff to review the entire
document and ensure that the units of measurement comply with the NEC
Style Manual. The Committee further directs that wherever the unit of joules in
j/cm2 are expressed, the units in calories (cal/cm2) follow immediately after in
parentheses.
Substantiation:During the ROP cycle, Proposal 70E-161 that would have
provided for the metrification of NFPA 70E, failed to pass ballot and was
reported as “reject” because less than 2/3 of those voting had voted in the
affirmative. This action is necessary to direct NFPA staff to complete the
necessary metrification of the standard. The use of soft conversion is directed
where joules and calories are considered because the committee believes that a
hard conversion could have a negative impact on safety.
Committee Meeting Action: Accept
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-3 Log #1 Final Action: Reject
( Parts 1, 2, 3 and 4 )
________________________________________________________________
Submitter: Alvin Havens, U.S. Gypsum
Comment on Proposal No:70E-163
Recommendation: I support the proposal to relocate Part 1 to the Appendix
and renumber Parts 2, 3 and 4 to Parts 1, 2, 3.
Substantiation: I concur with the Proposal authorʼs substantiation.
Committee Meeting Action: Reject
Committee Statement: Part 1 should remain a mandatory part of the
document and will provide the foundation for compliant installations. See
Committee Action on 70E-4 (Log #17).
Number Eligible to Vote: 25
Ballot Results: Affirmative: 23 Negative: 1
Vote Not Returned: 1 CLIFFDWELLER
Explanation of Negative:
POTTS: If the entire NEC applies, then a reference to the code is only
necessary. Otherwise, by including some references to the code the message is
that only those requirements found in Part I of the standard are applicable. The
pro/con is that other sections of the NEC could not legitimately be cited even
under OSHAʼs general duty clause. Relocation of Part I to the back of the main
document does allow for more emphasis on the more important work practices
as the opening information, but does not address this stated issue.
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-4 Log #17 Final Action: Accept in Principle
( Parts 1, 2, 3 and 4 )
________________________________________________________________
Submitter: Ray A. Jones, Electrical Safety Consulting Services, Inc. / Rep.
ACC
Comment on Proposal No:70E-163
Recommendation: The committee action should have been “accept.”
Substantiation: When opening the standard, the reader should first see the
standardʼs most significant contribution, i.e., work practices. In the case of
NFPA 70E, the potential impact of Part II requirements is at least 100% greater
than Part I.
Report on Comments — Copyright, NFPA
In order to provide a basis for 29 CFR 1910 Subpart S, Part I requirements
should remain an enforceable part of NFPA 70E, but should be relocated to
a position that supports the standardʼs most significant contribution in lieu of
making the standard more complex. Keeping Part I requirements within the
body of the standard provides an acceptable basis for regulatory purposes.
The preamble to 29 CFR 1910 Subpart S supports the fact that Part II of the
current standard is much more important in preventing workplace injuries
when compared to Part I. If Part II is more important, we should not bury
the information in the middle of the standard. The information should be
moved to the front where a user is immediately exposed to the most significant
contribution.
The work practices contained in Part II have the potential to eliminate 67
percent of all electrical fatalities if adequately implemented. Of course, in
addition to eliminating fatalities, implementing adequate work practices (Part
II) would eliminate 2/3 of the injuries as well.
No requirement exists in part I that is not also required by the National
Electrical Code. For NFPA 70E to begin by restating already existing
requirements increases the complexity of the standard.
Several sources of data support the concept that failures in work practices
represent the major source of injuries.
The underlying cause of electrical injury in unsafe work performance. [1] In
fact, unsafe work performance accounts for about 75% of all electrocutions. [2]
Most electrical accidents would occur even with 100 Percent compliance with
Part I of NFPA 70E. Note that these requirements are essentially mirrored in
29 CFR 1910 Subpart S. In fact, 67% of all electrical accidents are the result
of inadequate work practices. [3]
References
[1] Federal Register/vol. 55, No. 151/August 6, 1990 — page 31984, second
paragraph of “C. Nature of Electrical Accidents”
[2] Federal Register/vol. 55, No. 151/August 6, 1990, last paragraph of “E.
Need for Final Regulation”
[3] Federal Register/vol. 55, No. 151/August 6, 1990 — Page 31987, last
sentence in the first paragraph
Committee Meeting Action: Accept in Principle
Section 1-1.3 of the introduction read as follows:
“I-1.3This standard is divided into the following four parts and two
appendixes: Part I, Safety-Related Work Practices. Part II, Safety-Related
Maintenance Requirements. Part III, Safety Requirements for Special
Equipment. Part IV, Installation Safety Requirements. Appendix A, Tables,
Notes, and Charts [Reserved]Appendix B, Referenced Publications”
The committee directs that NFPA insert the first paragraph I-2.1 which reads
as follows:
“I-2.1 General. Definitions apply whereever the terms are used throughout
the standard.”
Committee Statement: The committee modified Section I-1.3 for clarity. The
committee directs NFPA staff to review all references and make corrections
to reflect reorganization of document. It is the intent of the committee that the
final reorganization of the document is to comply with the NEC style manual
that the definitions become a mandatory part of the document.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
POTTS: Agree with commenter that emphasis should be placed on work
practices rather than repeating NEC requirements.
________________________________________________________________
70E-5 Log #134 Final Action: Reject
( Intro, 1-2 )
________________________________________________________________
Submitter: J. F. Doering Akron, OH
Comment on Proposal No:70E-2
Recommendation: As both 70E-2 and 70E-8 were rejected, no further action
is requested, but it would be appropriate for the Chairman to:
1) Determine OSHAʼs needs with regard to 1926 Subpart K.
2) If OSHA feels the proposed 70E can essential be used for their proposed
rulemaking, no further action is needed, but if a more concise document is
desired, a task group of committee members with construction experience
should submit a document for the next edition that would be suitable for
29 CFR 1926 Subpart K. As OSHA has essentially adopted 70E Part I, the
emphasis would be the remaining parts.
Substantiation: At this point, I believe the committee needs some direction
from OSHA on how well the present document meets their need for a revised
29 CFR 1926 Subpart K. Quoting from the original Foreword to NFPA 70E,
“This committee was formed to assist OSHA in preparing electrical safety
standards that would serve OSHAʼs needs.........”. Another consideration is to
determine the position or emphasis on a construction standard by the OSHAʼs
Advisory Committee on Construction Safety & Health. I understand they play
a key role in supporting actions connected to construction standards. Further,
the construction standards are tied to Section 107 of the Contract Work Hours
and Safety Standards, commonly known as the Construction Safety Act.
While these later two thoughts donʼt have much to do with “the physics of
electricity,” they may play a role in the promulgation of construction standards.
70E-7
NFPA 70E
OSHA has bounced back and forth on the use of “specification standards”
(design standards impose detailed requirements on employers) and
“performance standards” (describe the result to be reached, but permit the
employer flexibility in determining the means for achieving that result). In
general, performance standards result in a more concise and flexible document.
The 70E Committeeʼs task was not to write standards in a form for direct
adoption by industry, but one suitable for OSHA rule making. It appears that
the position of the Committee is that OSHA should adopt the 70E document in
its entirety as 29 CFR 1910 Subpart S and 29 CFR 1926 Subpart K. If OSHA
agrees, our work is done. If not we have addition work, such as adding another
part to 70E. It also appears that if OSHA proceeds with rule making, based on
the proposed 70E Edition, the construction industry will oppose many of the
items, as demonstrated by their negative votes.
It was interesting to note in the NFPA September 27, 2002, news release, that
what appears to be a “grassroots” action by NECA, OSHA, and IBEW. They
have an “agreement” to put into practice the safety measures specified in NFPA
70E. Quoting the release, “These new rules–much more specific than the
existing federal regulations–will now apply to the 2,500 unionized electrical
workers in the Columbus area.” Other than recognizing “good practice,” Iʼm
not sure of the significance of this action with respect to OSHA citations. This
does appear to be an example of OSHAʼs “performance” standard versus 70Eʼs
“specification” standard.
Committee Meeting Action: Reject
Committee Statement: The commentors recommendation offers no specific
proposed text that the committee can address and therefore is in violation of
NFPA Regulations Section 4-4.5.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 23 Negative: 1
Vote Not Returned: 1 CLIFFDWELLER
Explanation of Negative:
POTTS: Agree with commenter in that construction conditions needs to be
addressed in the standard. This must be done before any consideration is given
to potential and partial usage as an OSHA regulatory requirement.
Comment on Affirmative:
DOERING: As the 70E Committee has consistently opposed the concept
of a separate Part for construction, I wonʼt vote negative, but I am concerned
what OSHA will do when they revise 1926 Subpart K. The 70E Committeeʼs
function is to work with OSHA, and to provide them with a document they
can use to create their proposed rules for construction. Iʼm afraid the 70E
Committee will be unhappy when OSHA revises 1926 Subpart K, as the OSHA
staff will have to “pick and choose” those items applicable to construction. I
remember a number of years ago at a meeting, sitting on a platform with 70E
committee members and the OSHA staff. We were taking OSHA to task for
changing some of the provisions of our 70E document when they were going
through 1910 Subpart S rule making.
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-6 Log #7 Final Action: Accept
( Intro ,1-2 Definitions (GOT) )
________________________________________________________________
Submitter: National Electrical Code Technical Correlating Committee
Comment on Proposal No:70E-3
Recommendation: The Technical Correlating Committee directs the
committee to review this proposal as well as action on other proposals (e.g.,
70E-15) to clarify the Committee Action and determine if the appropriate
definitions are included in the document. The Technical Correlating
Committee agrees with the comments that it is the objective to maintain
definitions in 70E that are consistent with those in the NEC. The Technical
Correlating Committee notes that “preferred” definitions from the NFPA
Glossary are not “required” definitions, but are provided to determine if the
document language can support the use of the preferred definition.
Substantiation: Adoption of Preferred definitions will assist the user by
providing consistent meaning of defined terms throughout the National Fire
Codes.
Committee Meeting Action: Accept
The committee accepted the following definitions from the glossary of terms
to be added as replacements for existing definitions in the 2000 edition of 70E.
“Automatic. (secondary) NFPA 70E, 2000 ed.
Self-acting, operating by its own mechanism when actuated by some
impersonal influence, as, for example, a change in current strength, pressure,
temperature, or mechanical configuration.
Building. (secondary) NFPA 70E, 2000 ed.
A structure that stands alone or that is cut off from adjoining structures by fire
walls with all openings therein protected by approved fire doors.
Enclosure. (secondary) NFPA 70E, 2000 ed.
The case or housing of apparatus, or the fence or walls surrounding an
installation to prevent personnel from accidentally contacting energized parts,
or to protect the equipment from physical damage.
Equipment. (secondary) NFPA 70E, 2000 ed.
A general term including material, fittings, devices, appliances, luminaires
(fixtures), apparatus, and the like used as a part of, or in connection with, an
electrical installation.
Report on Comments — Copyright, NFPA NFPA 70E
Exposed. (as applied to live parts.) (secondary) NFPA 70E, 2000 ed. Also due to the “live part” definition change, the following definition changes
Capable of being inadvertently touched or approached nearer than a safe are required, as also stated in my Affirmative comment to Proposal 70E-15.
distance by a person. It is applied to parts that are not suitably guarded, Working Near (exposed live parts). an activity inside a limited approach
isolated, or insulated. boundary.
Exposed (as applied to wiring methods.) (preferred) NFPA 70, 1999 ed. Working On (exposed live parts). coming in contact with exposed live
On or attached to the surface or behind panels designed to allow access. parts with the hands, feet, or other body parts, with tools, probes, or with
Fuse. (secondary) NFPA 70E, 2000 ed. test equipment, regardless of the personal protective equipment the person is
An overcurrent protective device with a circuit-opening fusible part that is wearing.
heated and severed by the passage of overcurrent through it. See also the Affirmative comments of Mr. Andrews and Mr. Saunders as
Note: A fuse comprises all the parts that form a unit capable of performing the published in the ROP for Proposal 70E-7.
prescribed functions. It may or may not be the complete device necessary to JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
connect it into an electrical circuit. #2).
Health Care Facilities. (preferred) NFPA 99, 1999 ed.
Buildings or portions of buildings in which medical, dental, psychiatric,
nursing, obstetrical, or surgical care are provided. Health care facilities include, ________________________________________________________________
but are not limited to, hospitals, nursing homes, limited care facilities, clinics, 70E-8 Log #45 Final Action: Accept
medical and dental offices, and ambulatory care centers, whether permanent or ( Intro, 1-2.1, Authorized Person )
movable. ________________________________________________________________
Heating Equipment. (secondary) NFPA 70E, 2000 ed. Submitter: Danny Liggett Newark, DE
For the purposes of Part I, Chapter 4, the term includes any equipment Comment on Proposal No:70E-5
used for heating purposes whose heat is generated by induction or dielectric Recommendation: This proposal should remain rejected.
methods. Substantiation: I support the panelʼs action on this proposal. There is not
Voltage, Nominal. (secondary) NFPA 70E, 2000 ed. a need for a separate classification for someone who needs to work “near”
A nominal value assigned to a circuit or system for the purpose of exposed live parts. The hazards remain the same however you classify the
conveniently designating its voltage class (as 120/240 volts, 480Y/277 volts, person. The skills and the knowledge of the person are paramount. The
600 volts). The actual voltage at which a circuit operates can vary from the requirements in the proposed definition are not enough to protect the person.
nominal within a range that permits satisfactory operation of equipment.” Committee Meeting Action: Accept
Committee Statement: The committee has reviewed the definitions and have Number Eligible to Vote: 25
addressed them. See Comments 70E-7 (Log #18) and 70E-15 (Log #19). Ballot Results: Affirmative: 24
Number Eligible to Vote: 25 Vote Not Returned: 1 CLIFFDWELLER
Ballot Results: Affirmative: 24 Comment on Affirmative:
Vote Not Returned: 1 CLIFFDWELLER JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
Comment on Affirmative: #2).
DOERING: The expression “(secondary)” and “(preferred)” should be
dropped from the definitions. Did the 70E Committee decide only to have _______________________________________________________________
only one “exposed” definition? NFPA 70E, 2000 Edition has three “exposed” 70E-9 Log #92 Final Action: Accept
definitions. ( Intro, 1-2.1, Class 1, Div 1 )
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log ________________________________________________________________
#2). Submitter: C. Bryan Drennan, Sandia National Laboratories
Comment on Proposal No:70E-15
Recommendation: In the definition for Class 1, Division 1 there is note 2
________________________________________________________________ under (10). Change Example to Examples.
70E-7 Log #18 Final Action: Accept Substantiation: There are five examples cited. The text was modified to be
( Intro, 1-2.1 Askarel ) grammatically correct.
________________________________________________________________ Committee Meeting Action: Accept
Submitter: Ray A. Jones, Electrical Safety Consulting Services, Inc. / Rep. Number Eligible to Vote: 25
ACC Ballot Results: Affirmative: 24
Comment on Proposal No:70E-15 Vote Not Returned: 1 CLIFFDWELLER
Recommendation: The Committee Action should have been accept-in-part. Comment on Affirmative:
Definitions for the following words/phrases should not have been accepted. JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
Askarel; cable tray system; center pivot irrigation machine; collector rings; #2).
isolated power system; permanently installed decorative fountains; permanently
installed swimming, wading and therapeutic pools; portable X-ray; power ________________________________________________________________
outlet, remote control circuit, sealable equipment, storable swimming or 70E-10 Log #124 Final Action: Accept
wading pool; general-use snap switch; general-use switch; transportable x-ray; ( Intro, 1-2.1 Energized )
oil cutout; and oil switch. ________________________________________________________________
Substantiation: These words/phrases are not used within the body of the Submitter: Paul Dobrowsky Holley, NY
standard. Including definitions for these words does not improve the standard. Comment on Proposal No:70E-6
Instead, the definitions add complexity to an already complex document. Recommendation: Continue to accept the proposal.
Committee Meeting Action: Accept Substantiation: In response to the committee comments, Part 1 already has
Number Eligible to Vote: 25 differences from the NEC. Additionally, the concepts addressed by Chapter
Ballot Results: Affirmative: 24 2 (new) are different than the installation provisions contained in the NEC.
Vote Not Returned: 1 CLIFFDWELLER When equipment is disconnected from the “source of supply”, the existing
Comment on Affirmative: definition would consider it to be deenergized, yet a voltage could be present
HAMER: Acceptance of the 2002 NEC definition change for “live parts,” as due to inductance or capacitive coupling.
included in Proposal 70E-15, has completely changed the context of the use of The term energized is also used in a broader sense when describing the
this term from what was intended in the 2000 Edition of NFPA 70E. condition (state) of equipment (e.g., “on” or “off”) even though the internal live
The old definition of “live parts” in the 2000 Edition of NFPA 70E is: parts may not be exposed.
Live Parts. Electric conductors, buses terminals, or components that are Committee Meeting Action: Accept
uninsulated or exposed and a shock hazard exists. Number Eligible to Vote: 25
The new definition, as accepted in Proposals 70E-7 and 70E-15: Ballot Results: Affirmative: 22 Negative: 2
Live Parts. Energized conductive components. Vote Not Returned: 1 CLIFFDWELLER
Literally interpreted, the new definition of “live parts” includes the guarded or Explanation of Negative:
insulated (energized) conductive parts of metal-clad switchgear and insulated DOERING: I accept Hamerʼs reason for a negative vote.
cable. HAMER: The 2002 NEC definition for “energized” should be used with the
The word “exposed” has a certain meaning when used with “live parts.” following suggested FPN. The additional wording accepted by this proposal
Again, from the accepted (and existing 2000 Edition) definition: and comment is awkward. See Mr. Wellsʼ explanation of negative for Proposal
Exposed. (as applied to live parts.) Capable of being inadvertently touched or 70E-6.
approached nearer than a safe distance by a person. It is applied to parts that Energized. Electrically connected to a source of voltage. (This is the
are not suitably guarded, isolated, or insulated. definition from the 2002 NEC).
There are numerous places in the text where “live parts” must be changed to FPN: “Electrically connected” can include mechanical, magnetic, capacitive
“exposed live parts” (or similar phrasing) in the next edition of NFPA 70E to and other types of connection or coupling. (Suggested new FPN).
make the requirements in the standard unambiguous and equivalent to the 2000 Comment on Affirmative:
Editionʼs meaning. There are at least 50 places in the document, not covered JACKSON: See my Affirmative with Comment on Comment 70E-1
by other Comments, where this still needs to be done. (Log #2).
70E-8
Report on Comments — Copyright, NFPA
_______________________________________________________________
70E-11 Log #85 Final Action: Accept in Principle
( Intro, 1-2.1, Flash Hazard Analysis )
________________________________________________________________
Submitter: Joseph J. Andrews, Electrical Safety Resources, Inc.
Comment on Proposal No:70E-4
Recommendation: Add the following definition:
Flash Hazard Analysis. A method to determine the risk of second degree
burn or other personal injury as a result of exposure to incident energy from an
electrical arc flash.”
Substantiation: The term “Flash Hazard Analysis” is used at least seven
times in the Standard. A definition would be helpful to readers so that they can
understand the intention of the term.
Committee Meeting Action: Accept in Principle
Add the following definition:
“Flash Hazard Analysis. A study investigating a workerʼs potential exposure
to arc-flash energy, conducted for the purpose of injury prevention and the
determination of safe work practices and the appropriate levels of PPE.”
Committee Statement: This definition communicates meaning without
including requirements and is consistent with the recommendation of Proposal
70E-4.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
POTTS: Agree particularly that all references to “second degree burn”
should be removed form the standard. It implies that the risk of second-degree
burns and 100 percent prevention of second-degree burns will be achieved
by compliance with this standard. It is unlikely that elements and provisions
of the standard will achieve this “aim” as currently written, especially, since
supporting research is still evolving and field-testing has been minimal.
Current wording of second-degree burn means that an employer must correct
for situations of potential risk of a single, small blister on any part of exposed
skin.
________________________________________________________________
70E-12 Log #64 Final Action: Reject
( Intro, 1-2.1, Flash Hazard Analysis, Incident Energy, Flash Protection
Boundary, )
________________________________________________________________
Submitter: Robert E. Downey, Allison Transmission
Comment on Proposal No:70E-4
Recommendation: Where cal/cm2 is indicated as units for ATV, include after
it (J/cm2).
Also, word search document and make same revision at other locations.
Substantiation: Although metric units are not the units found on clothing in
the marketplace, this additional data will allow the metric units to also become
recognized.
Committee Meeting Action: Reject
Committee Statement: Offering the SI units in these specific locations is not
consistent with the style manual throughout the document.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-13 Log #81 Final Action: Hold
( Intro, 1-2.1, Flash Protection Boundary )
________________________________________________________________
Submitter: J. F. Doering Akron, OH
Comment on Proposal No:70E-4
Recommendation: Reject the proposed definition for “Flash Protection
Boundary.”
As proposed in the ROP “Flash Protection Boundary”: An approach limit at a
distance from exposed live parts within which a person could receive a second
degree burn if an electric arc flash were to occur.
Continue to use the existing concept in 70E-2000 Edition to define the “Flash
Protection Boundary”: An approach limit at a distance from exposed live parts
within which a person could receive a curable burn if an electric arc flash were
to occur.
The replacement of “curable” with “second-degree” is proposed by 70E-139
(Log #66) and 70E-140 (Log #64). There maybe others. 70E-139 and 70E-
140 uses the same criteria limit (i.e., skin temperature remains less than 80
degrees C or (176° F).
Substantiation: The time-temperature relationship of human skin tolerance
to thermal burns as Lee discusses in his IEEE May/June 1982 Industry
Applications Transactions, he concludes that the temperature rise of skin
must be limited to 46 degrees centigrade for a curable burn in 0.1 second. A
70E-9
NFPA 70E
temperature rise of skin of 62 degrees centigrade for 0.1 second results in total
destruction of the tissue. There is a grey zone between the two temperature
rises. In the Doughty, Epperly, Jones, in the January/February 1992 IEEE
Industry Applications transactions, they expand on Leeʼs conclusions as
follows:
The amount of radiant heat in kilowatts required to produce the limited
curable burn temperature rise can be estimated by analyzing a square inch
of skin with thickness of 0.003 inch. The basal or dermal layer is located
approximately 0.00? inch (not legible on copy of paper) beneath the skin
surface. The specific heat of skin assumed to be essentially equal to that
of water. The skin coefficient of absorption is assigned the value of 1.0,
representing dark or dirty skin. A time interval of 0.1 second was consistence
with Leeʼs analysis. The calculated power to raise the skin temperature 46
degrees centigrade in 0.1 second was determined to be 0.095 kW/in2. This
value shows reasonable agreement with the heat flux level of 4.9 cal/cm2-s or
0.13 kW/in2, determined by extending by extending the 1979 Artz curve to 0.1
second. The calculated result is very conservative as the thermal conductivity
of the epidermis was neglected.
O.095 kW/in2 or 3.58 cal/cm2 for an exposure time of 0.1 second is very
reasonable as the value to define the “Flash Hazard Boundary”, rather than the
1.2 cal/cm2 value that seems to have crept into the 70E calculations.
I have to agree with Pottʼs “negative comment” that “one blister” should
not determine the “Flash Hazard Boundary.” Based on further study, my
“comment on affirmative” in the ROP would be more appropriate to support a
negative.
Committee Meeting Action: Hold
Committee Statement: The comment introduces the concept of a curable
burn that was not in proposal 70E-4 and is therefore has not had adequate
public review.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 23 Negative: 1
Vote Not Returned: 1 CLIFFDWELLER
Explanation of Negative:
DOERING: Apparently the 70E Committee, in Proposal 70E-140 (Log
#64), to define the Flash Protective Boundary, agreed to accept changing from
“just curable burn” to “second degree burn,” defining a second degree burn
as when the skin temperature remains less than 80°C (176°F). Ralph Lee had
concluded, for a 0.1 second (6 cycles) duration, skin temperature above 96°C
represented total destruction of the tissue, and that below 80°C tissue can be
cured, with a gray zone between.
The 70E Committee statement reads, “The (J. F. Doering) comment
introduces the concept of a curable burn that was not in Proposal 70E-4 and
therefore has not had adequate public review.” In my opinion, the concept of
“curable burn” does not need to be introduced by Proposal 70E-4, as it is the
term of choice in the 2000 Edition of 70E. Further, my comment to Proposal
70E-4 had public review as it was published in the ROP.
Iʼm afraid anything I say at this point will not change the committeeʼs action.
I am left with some questions. One, are we willing to accept first degree
burns, but not second. Or are we willing to accept second degree burns but
not third? I felt that receiving a second degree burn as a trigger to define the
Flash Protection Boundary seems unnecessarily restrictive. A second degree
burn means the skin blisters and the epidermis will have to regenerate. Studies
do indicate chance of survival is effected if the second and third degree burns
covers 25 percent of the body, but if incident energy barely reaches third
degree level, I would not expect large areas to be burned.
Two personal events have given me insight to the difference between second
and third degree burns. While in the Army, our captain thought we would
enjoy a day at the beach. With no sun screen or shade, I received a severe
sun burn (second degree burns) over a large area, and was hospitalized for
three days. I lost some soldiering time, but had no lasting effects. A year
later, while working as a substation helper I contacted a 23,000 volt circuit
and received second and third degree burns over a large area, and spent three
months in the hospital receiving skin graphs, etc. The lasting effects have been
minimal, other than lots of scars. If we are to use skin damage as defining
the Flash Protection Boundary, should be protecting at the 80°C level. The
question remains as what is the incident energy value that produces the 80°C
skin temperature for typical electric arcs.
Leeʼs work as well as Stoll and Artz indicated that human tissue tolerance for
the 0.1 second burn, that they classified as “curable burn”, was 4.9 cal/cm2.
The Doughty, Epperly, Jones paper in January 1992, developed a value of 3.58
cal/cm2, a value they considered very conservative. In the Neal, Bingham,
Doughty July 1997 paper, they state that a “curable burn” is comparable to
the blister or second-degree burn discussed by Stoll and Chianta. They also
concluded that an absorbed heat energy of 1.2 cal/cm2 for one second of
exposure will produce a second degree burn. They note that the absorbed
energy is generally approximately 90 percent of the incident energy. Privette
in 1992-3, did work with depilated rats and found that a second degree burn
(destruction of the epidermis) ranged between 1.2 and 3.2 cal/cm2, but in the
later paper narrowed the range to 1.2 and 1.6 cal/cm2 for arc with a duration
less than 0.1 second. Other authors have pointed out that many factors can
influence the onset of burn injury in human tissue, including variable thickness
of the epidermis, water content in the skin, and the amount of water on the skin
surface due to perspiration or other sources.
This negative points out that, 1.2 cal/cm2 as a value to define the Flash
Protection Boundary, is based on fuzzy data, much of which is testing with
Report on Comments — Copyright, NFPA
rats as humans are not interested in volunteering for such testing. As the
seriousness of a burn is a function of the area burned, and the bulk of the
worker is covered by clothes, it would seem appropriate to base the Flash
Protection Boundary on commonly worn 5.2 opsy Twill, Blue Cotton Shirt
material and use a value of 4.6 cal/cm2. Clothing can be tested under most
any condition, and a test procedure is available that permits replication of
results. This trigger value combined with a requirement such as required by
OSHAʼs 1910.269(1)(6)(iii), which reads, “The employer shall ensure that
each employee who is exposed to the hazards of flames or electric arcs does
not wear clothing that, when exposed to flames or electric arcs, could increase
the extent of injury that would be sustained by the employee,” would protect
the employee for incident energy below 4.6 cal/cm2. Paragraph 3-3.5 Body
Protection contains this requirement.
The committee members should vote negative on Comment 70E-13, and leave
the definition with curable burn. In Comment 70E-74, we will introduce the
4.6 cal/cm2 level.
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
_______________________________________________________________
70E-14 Log #22 Final Action: Hold
( Intro, 1-2.1, Flash Protection Boundary )
________________________________________________________________
Submitter: Paul S. Case, Fluor Hanford, Inc.
Comment on Proposal No:70E-4
Recommendation: Add text so definition of Flash Protection Boundary will
read:
“Flash Protection Boundary. An approach limit at a distance from exposed
live parts or enclosed live parts if operation, manipulation, or testing of
equipment creates a potential flash hazard within which a person could receive
a second degree burn if an electrical arc flash were to occur.”
Substantiation: The additional text is necessary to correlate the new
definition of Flash Protection Boundary with text in the heading of Column
1 in Table 3-3.9.1 that reads, in part, “(Assumes... and Work Is Done Within
the Flash Protection Boundary)” Table 3-3.9.1 includes tasks that would not
be performed within the FPB as now defined, for example, operating circuit
breakers and switches with covers on, which do not involve “exposed live
parts.”
Alternate solution would be my comment on Proposal 70E-98 (Log #45).
Committee Meeting Action: Hold
Committee Statement: The comment introduces new material that has not
had public review.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-15 Log #19 Final Action: Accept
( Intro, 1-2.1, General Use Snap Switch )
________________________________________________________________
Submitter: Ray A. Jones, Electrical Safety Consulting Services, Inc.
Comment on Proposal No:70E-3
Recommendation: The committee Action should have been accept in
principle-in-part.
The term “General use snap switch” is not used in the document and should
not be defined. Neither definition for “Qualified Person” meets the need for
NFPA 70E. The definition from the 2000 edition of 70E should be used. The
definition of the term “enclosure” should not be changed.
Substantiation: The term “general use snap switchʼ is not used in the
document. Including a definition for this term unnecessarily increases
complexity of the document. The term “qualified person” as defined in 70E-
2000, served as the basis to establish several requirements within part II of the
document. If the definition is changed, several requirements will be incorrect.
The term “enclosure” as defined in 70E-2000 more nearly meets the need for
NFPA 70E.
Committee Meeting Action: Accept
Committee Statement: The definition “General Use Snap Switch” shall be
deleted. The definition for “Qualified Person” and “Enclosure” shall not be
modified by Proposal 70E-3.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
70E-10
NFPA 70E
________________________________________________________________
70E-16 Log #112 Final Action: Accept in Principle
( Intro, 1-2.1, Prohibited Approach Boundary )
________________________________________________________________
Submitter: David Soffrin, American Petroleum Institute
Comment on Proposal No:70E-3a
Recommendation: As indicated in the affirmative comment by Mr. Hamer,
change the definition for “restricted approach boundary” as follows:
Restricted Approach Boundary. A shock protection boundary to be crossed
by only qualified persons (at a distance from a live part) which, due to its
proximity to a shock hazard, requires the use of shock protection techniques
and equipment when crossed. An approach limit at a distance from an exposed
live part within which there is an increased risk of shock, due to electrical
flashover and inadvertent movement, for personnel working in close proximity
to the live part.
Substantiation: The committee accepted a definition change to remove
requirements from “Prohibited Approach Boundary” per the NEC Manual of
Style, but did not act to remove requirements from the definition of “Restricted
Approach Boundary.” This definition should also be changed to remove
requirements.
Committee Meeting Action: Accept in Principle
Revise the definition for “restricted approach boundary” as follows:
“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 arc over combined with inadvertent movement, for personnel
working in close proximity to the live part.”
Committee Statement: The term “arc over” is more technically correct. The
term “combined with” more accurately reflect the intent of the committee.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-17 Log #84 Final Action: Reject
( Intro, 1-2.1, Restricted Approach Boundary )
________________________________________________________________
Submitter: Joseph J. Andrews, Electrical Safety Resources, Inc.
Comment on Proposal No:70E-3b
Recommendation: Completely revise the definition of “Restricted Approach
Boundary” to read:
Restricted Approach Boundary. An approach limit, at a distance from
an exposed live part, within which the risk of shock is great enough that
appropriate personal protective equipment is needed.
Substantiation: The Committee accepted revised definitions of “Limited
Approach Boundary” and “Prohibited Approach Boundary” in order to remove
requirements from the current definitions. In order to be consistent, similar
revision is needed for the term “Restricted Approach Boundary”.
Committee Meeting Action: Reject
Committee Statement: The committee prefers the wording described in the
Panel Action in Comment 70E-16 (Log #112).
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-18 Log #111 Final Action: Accept in Principle
( Intro, 1-2.1, Restricted Approach Boundary )
________________________________________________________________
Submitter: David Soffrin, American Petroleum Institute
Comment on Proposal No:70E-3b
Recommendation: Revise as follows:
As indicated in the affirmative comment by Mr. Hamer, change the definition
for “restricted approach boundary” as follows:
Restricted Approach Boundary. A shock protection boundary to be crossed
by only qualified persons(at a distance from a live part) which, due to its
proximity to a shock hazard, requires the use of shock protection techniques
and equipment when crossed. 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 and inadvertent movement, for personnel working in close proximity to
the live part.
Substantiation: The committee adopted a definition change to remove
requirements from “Limited Approach Boundary”, per the NEC Manual of
Style, but did not act to remove requirements from the definition of “Restricted
Approach Boundary”. This definition should also be changed to remove
requirements.
Report on Comments — Copyright, NFPA
Committee Meeting Action: Accept in Principle
Committee Statement: See Panel Action on Comment 70E-16 (Log #112).
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-19 Log #41 Final Action: Reject
( Intro, 1-2, Working on Live Parts )
________________________________________________________________
Submitter: Edward G. Jacobson Los Alamos, NM
Comment on Proposal No:70E-12
Recommendation: The Committee Statement, “In addition, testing involves
[sic] contact with live parts is just as dangerous as using any other tool” is
simply not true. If NFPA 70E does not recognize that energized work that
consists of moving rated probes, connected to a rated measuring instrument,
from point to point in well-maintained equipment is fundamentally different
from physically moving energized components, it loses credibility with persons
who daily work with electrical/electronic equipment. Thirty experienced
electrical workers, consisting of journeyman electricians who work on common
120/208/480V industrial equipment, and electronic technicians, engineers,
and physicists who daily deal with various combinations of high voltage, high
current, and high stored energy, each said that measuring voltages on stationary
components is much less hazardous than moving energized components.
Several added that not only is measurement activity less hazardous, but the
potential for harm to personnel and equipment is less. Inadvertent connections
or disconnection of less-than-50-volt control wiring can compromise personnel
safety interlocking and machine protection interlocking, resulting in heavy
damage, just as can an arc flash occurring at a higher voltage.
The requirements for PPE should be different for the two types of energized
work. Test instrument standards ensure the safety of bare-hand operation of
voltage probes, used within the transient voltage withstand category of the
probes and instrument. To arbitrarily require the use of insulating gloves when
making voltage measurements forces an unnecessary compromise of the barrier
provided by dry skin, particularly in dry climates where ambient temperatures
(and perspiration containment) can be high. If energized components are
physically arranged or in such a poor state of repair that it is hazardous
to manipulate a voltage probe with bare hands, it is unlikely the situation
is improved if gloves are worn. If exposed energized metallic parts are so
arranged that an arc flash could be initiated when using a voltage probe, the
measurement should not be made, regardless of the PPE worn.
As noted in both the Substantiation and the Explanation of Negative for
proposal 70E-98, movement of energized components presents hazards that
must be minimized to the extent possible and some work should simply not be
done energized. Making voltage measurements on stationary parts is not the
same as moving energized parts relative to each other in normal operations or
moving energized parts with or without the use of tools.
The preprint for NFPA 70E 2003 both does and does not recognize a
difference. Movement of an energized part requires a written energized
electrical work permit that contains a minimum of eleven entries (220.3 (A),
(B)). (C) allows diagnostic and testing activity without a written permit but
requires use of essentially the same PPE.
With so many rules to follow, it will probably not be possible to work without
violating some. Any organization that uses 70E as other than a reference will
likely find that both employees and employer will be found in violation of
some provision(s) whenever an undesired event occurs whether the violation(s)
contributed to the event or not. Perhaps working in such an environment
increases electrical worker safety, but more likely it does not.
Substantiation: None given.
Committee Meeting Action: Reject
Committee Statement: The commentors recommendation offers no specific
proposed text that the committee can address and therefore is in violation of
NFPA Regulations Section 4-4.5.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-20 Log #125 Final Action: Reject
( Intro, 1-2.1, Working on (Live Parts) )
________________________________________________________________
Submitter: Paul Dobrowsky Holley, NY
Comment on Proposal No:70E-12
Recommendation: Accept the proposal.
Substantiation: NFPA 70E appropriately requires that equipment to be placed
in an electrically safe working condition. To do so a qualified person must
verify the absence of voltage, using test instruments. This action is considered
“working on” by the definition. Provide a distinction, either as part of a single
70E-11
NFPA 70E
term or possibly as two separate terms, e.g.:
1. Working On, (Live Parts), Testing
2. Working On, (Live Parts), repair or Installation.
This will support the concept of verifying the absence of voltage, but will
help discourage actual “actions” on live parts.
Committee Meeting Action: Reject
Committee Statement: The modification suggested by the original proposal
is not appropriate within a definition. The Committee reaffirms its position
that the need for PPE should be based upon a hazard/risk analysis. The
substantiation submitted with the Comment does not provide technical
substantiation with regards to the need for a distinction between various levels
of “working on” equipment or conductors.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 23 Negative: 1
Vote Not Returned: 1 CLIFFDWELLER
Explanation of Negative:
DOWNEY: See my comment to original Proposal 70E-12.
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-21 Log #5 Final Action: Accept
( Part 1, Chapter 1 )
________________________________________________________________
Submitter: National Electrical Code Technical Correlating Committee
Comment on Proposal No:70E-15
Recommendation: The Technical Correlating Committee directs the
committee to clarify the text and location of the FPN mentioned in the
Committee Statement since the Committee Action does not indicate the
addition.
Substantiation: No substantion was provided.
Committee Meeting Action: Accept
Committee Statement: See Committee Action and Statement on Comment
70E-1 (Log #2).
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-22 Log #77 Final Action: Reject
( Part 1, 1-1.1 )
________________________________________________________________
Submitter: Michael I. Callanan, IBEW
Comment on Proposal No:70E-14
Recommendation: The Committee should accept the proposal.
Substantiation: The Committee has not provided any substantiation as to the
need for Part 1. To state that it helps meet the original intent as stated in the
Forward is beside the point. Part 1 Installation Safety Requirements are merely
an abbreviated part of the National Electrical Code. It is clear that while 70E
met a need for OSHA at one time, that need no longer exists. The strength of
the 70E Standard lies in the Safety-Related Work Practices provisions. There
was some concern expressed at the ROP meeting about the need to address
existing installations. IF it is felt that that provision is needed, the original
proposal can be revised to include appropriate language that clarifies the scope.
Committee Meeting Action: Reject
Committee Statement: The Committee reaffirms its position that Part I is
useful for the application of NFPA 70E. Some cities, municipalities and local
jurisdictions rely on Part I for Installation Standards that more closely are
related to the direct safety of employees. In addition, there is hope that the
Occupational Safety and Health Administration may utilize the newly revised
Part I for help updating some of their electrical standards. See Comment 70E-
4 (Log #17) that relocated Part I to the end of the standard. This should result
in an increased emphasis being placed upon the safety-related work practices
portion of the standard.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 23 Negative: 1
Vote Not Returned: 1 CLIFFDWELLER
Explanation of Negative:
TIEDE: Part I from the 2000 Edition, and its replacement in the in the
2003 edition, consist of requirements that are extracted and, in many cases,
paraphrased from the original requirements in the NEC for reprinting in
NFPA 70E. This section has been growing. As it grows, it will eventually
incorporate most of the requirements in the NEC. Continuing to provide these
extractions seems unnecessary since the parent document exists in readily
available form and at a reasonable price. Duplicating the requirements, but
in slightly different words, seems to be a formula for conflict and error. This
section should be replaced with an appropriate reference to the NEC.
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
Report on Comments — Copyright, NFPA
_______________________________________________________________
70E-23 Log #8 Final Action: Reject
( Part 1, 1-1.1 )
________________________________________________________________
Submitter: Ray A. Jones, Electrical Safety Consulting Services, Inc. / Rep.
ACC
Comment on Proposal No:70E-14
Recommendation: The committee action should have been “Accept.”
Substantiation: The argument posed by Callanan is powerful. All provisions
of the NEC apply to installation safety when the equipment is operating
normally. I agree with Callananʼs argument that including selected NEC
requirements within the body of NFPA 70E does little to improve safety
associated with work practices or maintenance practices. Instead, including a
significant volume of text that is nothing more than extracted from the NEC
increases the confusion factor and is not associated with the primary scope of
the NFPA 70E.
The committee statement suggests that the committee is bound by the content
of the foreword. However, it is noted that the foreword provides a historical
record of the committee on Electrical Safety Requirements for Employee
Workplaces and has no bearing on the content of the standard.
The content and organization of the standard is the responsibility of the
committee as stated in the scope assigned by the Standards Council. The
committee scope reads in part “... shall have primary jurisdiction...”
Committee Meeting Action: Reject
Committee Statement: See Committee Action and Statement on Comment
70E-22 (Log #77).
Number Eligible to Vote: 25
Ballot Results: Affirmative: 23 Negative: 1
Vote Not Returned: 1 CLIFFDWELLER
Explanation of Negative:
TIEDE: See my Explanation of Negative Vote on Comment 70E-22
(Log #77).
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-24 Log #133 Final Action: Reject
( Part 1, 1-1.1 )
________________________________________________________________
Submitter: Edward G. Jacobson Los Alamos, NM
Comment on Proposal No:70E-14
Recommendation: Delete NFPA 70, except to reference it, just as the
submitter suggests. If historical background is desired, add a paragraph or two
of fine print note.
Substantiation: The title of 70E is Standard for Electrical Safety
Requirements for Employee Workplaces. Workplace safety is optimized when
equipment and its installation and maintenance meets high standards. NFPA
70 is intended to ensure that electrical components are suitable and installed
properly. Assuming that is the first ingredient of an electrically safe work
place, if any of NFPA 70 is important, it is all important.
Committee Meeting Action: Reject
Committee Statement: The Committee reaffirms its position that Part I is
useful for the application of NFPA 70E. Some cities, municipalities and local
jurisdictions rely on Part I for Installation Standards that more closely are
related to the direct safety of employees. In addition, there is hope that the
Occupational Safety and Health Administration may utilize the newly revised
Part I for help updating some of their electrical standards. See Comment 70E-
4 (Log #17) that relocated Part I to the end of the standard. This should result
in an increased emphasis being placed upon the safety-related work practices
portion of the standard.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 23 Negative: 1
Vote Not Returned: 1 CLIFFDWELLER
Explanation of Negative:
TIEDE: See my Explanation of Negative Vote on Comment 70E-22
(Log #77).
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-25 Log #88 Final Action: Reject
( Part 1, 1-1.1.1 )
________________________________________________________________
Submitter: Danny Liggett Newark, DE
Comment on Proposal No:70E-14
Recommendation: This proposal should be Accepted.
Substantiation: I agree with the comments made by those who voted
Negative. The NEC should not be paraphrased. Each cycle more and more
of the NEC is added to Part 1. The value of 70E is in the other Parts, not Part
1. Having part 1 dilutes the attention of the panel from the issues of electrical
safe work practices. Pulling only selected sections out of the NEC can lead
70E-12
NFPA 70E
to taking things out of context. Article 250 in the NEC is one of the larger
Articles of the NEC and in 70E it has been reduced to less than 2 pages. This
is paraphrasing. Having an intermixing between the NEC and 70E does an
injustice to both. The 70E committee should be governed by the scope of
Part V of the A Guide for Officers of Technical Committees and Technical
Correlating Committees of the NFPA International not by the “Foreword”.
Committee Meeting Action: Reject
Committee Statement: The Committee reaffirms its position that Part I is
useful for the application of NFPA 70E. Some cities, municipalities and local
jurisdictions rely on Part I for Installation Standards that more closely are
related to the direct safety of employees. In addition, there is hope that the
Occupational Safety and Health Administration may utilize the newly revised
Part I for help updating some of their electrical standards. See Comment 70E-
4 (Log #17) that relocated Part I to the end of the standard. This should result
in an increased emphasis being placed upon the safety-related work practices
portion of the standard.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 23 Negative: 1
Vote Not Returned: 1 CLIFFDWELLER
Explanation of Negative:
TIEDE: See my Explanation of Negative Vote on Comment 70E-22
(Log #77).
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-26 Log #89 Final Action: Accept in Principle
( Part 1, 1-1.3 )
________________________________________________________________
Submitter: Danny Liggett Newark, DE
Comment on Proposal No:70E-15
Recommendation: Delete from I-1.3 the following: Part V, Safety
Requirements for Construction.
Substantiation: Proposal 70E-15 was accepted by the committee action in
the ROP but in the preprint of 70E the accepted proposal was not completely
included. One of the items accepted, but left out, was the inclusion of “Part
V, Safety Requirements for Construction”. There should not be a separate
section for construction. The Committee Statement on Proposal 70E-2 stated
that 70E applies to construction. I applaud this statement. The comment of
Mr. Nietzel in his substantiation of 70E-2 concerning the physics of electricity
is very true. Electricity does not care what industry you are in. In September
of 2002 the Bureau of Labor Statistics issued a report of finding from fatalities
for the year 2001. Construction worker deaths by electrocution have risen
to the late 90ʼs level. Part of this can be contributed to the perception that
OSHA has two sets of rules for electrical safety, one for general industry and
one for construction. The common reply from construction folks when told
of the rules they be following is “that doesnʼt apply to construction”. Having
worked in construction for over 20 years, I have an understanding of the work
activities involved in construction. Most of the construction work is done in a
de-energized condition. The concepts of establishing an electrically safe work
condition contained in 70E can easily be put in place in construction. Where
the problem lies is when there is exposure to electrical hazards. Because of the
perception that construction needs different rules fewer precautions are taken
to protect workers. In reviewing the number of electrocutions in construction
over the last 10 years the trend has not decreased. Generally industry
electrocutions for the same time frame have dropped by 40%. We need one set
of electrical safety rules for all to follow. This reduces confusion. It provides
a better work environment for not only electricians but for all workers exposed
to electrical hazards.
Committee Meeting Action: Accept in Principle
In I-1.3 delete “five” and replace with “four”.
Committee Statement: The panel does not believe that a need for separate
section for construction since the hazards associated with electrical work are
the same for any industry segment. See committee action and statement on
Comment 70E-4 (Log #17) which meets the intent of the submitter.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 22 Negative: 2
Vote Not Returned: 1 CLIFFDWELLER
Explanation of Negative:
DOERING: Unitl there is a specific set of regulatins for construciton the
committee is not meeting their “charter”.
POTTS: Agree with commenter that there should be special considerations
for construction operating conditions. To ignore the operational risks
associated with construction is also to ignore the unique corrective actions of
this transient industry. This has particular relevance in that as a general rule,
contractors are more likely to be assigned more hazardous work than what
may be performed willingly by a fixed facilityʼs workforce. As it relates to
NFPA 70E, this means work performed in an “energized state”. It should be
remembered that this work is conducted by a temporary employer; under less-
known conditions; by a universally-trained, transitory workforce; and often
without the needed participation of the client. If the choice is not to address
the different risks posed by construction work, then contractors, as informed
Report on Comments — Copyright, NFPA
practitioners, will tend to view NFPA 70E as a general reference document
instead of an applicable standard.
Consider: If all is equal, why is the work contacted rather than performed by
the fixed facilityʼs workforce? Is it because, the work is more hazardous? Are
in-plant personnel less qualified than contractor personnel? Do contractors
better understand construction operations and conditions? Are the risks just
perceived as being too great?
Respectfully, there requires a realization that the risks faced by construction
and maintenance contractors differ from those of general industry even though
the electrical-related hazards and most exposures are similar. Again, it is
more likely that maintenance work on energized systems will be contracted
to construction employers rather than performed in-house. This will cause
an increased level of activation of the NFPA 70E standard by customers for
application by the construction sector.
Furthermore, a study by NIOSH of fatalities for a 12-year period found
that in the construction industry excluding power line work, one third of
the electrocutions were attributed to electricians, while the rest were among
laborers, painters, and other construction craft personnel. Many of these other-
than-electrician incidents involved the use of ladders, scaffolds, and cranes.
These construction conditions are not addressed in the current standard. Even
more, temporary power usage and check out/start up issues are only minimally
approached.
Therefore, all construction considerations and electrical exposures not just
those associated with direct electrical work should be given primary attention
in development of a standard.
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
_______________________________________________________________
70E-27 Log #27 Final Action: Accept
( Part 1, 1-8.1.1.1 )
________________________________________________________________
Submitter: Kathy Wilmer, Duke Power Co. / Rep. Edison Electric Institute
Comment on Proposal No:70E-16
Recommendation: Do not add “operating at 50 volts or more” to Part 1, 1-
8.1.1.1.
Substantiation: Edison Electric Institute opposes the committee action.
Adding “operating at 50V or more” to Part 1, 1-8.1.1.1 creates a conflict with
Table 1-8.1.1 which lists “0 to 150 V”. Any change to the text should be
accompanied by a change to the table. However, changing Table 1-8.1.1 to “50
to 150V” will create a conflict with both the NEC, Table 110.26(A)(1) and with
OSHA 1910.302, Table S-1. This proposal should be rejected.
Committee Meeting Action: Accept
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-28 Log #93 Final Action: Accept
( Part 1, 1-9 )
________________________________________________________________
Submitter: C. Bryan Drennan, Sandia National Laboratories
Comment on Proposal No:70E-45
Recommendation: In Part 1, 1-9 Revise text to read as follows:
“1-9 Identification of Disconnecting Means. Each disconnecting means shall
be legibly marked to indicate its purpose unless located and arranged so the
purpose is evident. The marking shall be of sufficient durability to withstand
the environment involved.
Where circuit breakers or fuses are applied in compliance with the series
combination ratings marked on the equipment by the manufacturer, the
equipment enclosure(s) shall be legibly marked in the field to indicate the
equipment has been applied with a series combination rating. The additional
series combination interrupting rating shall be marked on the end use
equipment, such as switchboards and panelboards. The marking shall be readily
visible and state the following:
CAUTION –SERIES COMBINATION SYSTEM RATED __ AMPERES.
IDENTIFIED REPLACEMENT COMPONENTS REQUIRED
FPN: The additional series combination interrupting rating shall be marked on
the end use equipment, such as switchboards and panelboards.
Substantiation: The existing note contains mandatory language. The sentence
is relocated to the body of the document to comply with the Manual of Style.
Committee Meeting Action: Accept
Committee Statement: The committee believes that the submitter was
referencing Proposal 70E-15.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
70E-13
NFPA 70E
________________________________________________________________
70E-29 Log #28 Final Action: Accept
( Part 1, 2-2.4.2.2 )
________________________________________________________________
Submitter: Kathy Wilmer, Duke Power Co. / Rep. Edison Electric Institute
Comment on Proposal No:70E-25
Recommendation: Do not add requirement for GFCI testing.
Substantiation: Edison Electric Institute opposes the committee action.
Adding a specific requirement related to testing GFCIʼs per manufacturerʼs
instructions is unnecessary as 1-3.2 in Part 1 already requires that “Listed
or labeled equipment shall be installed and used in accordance with any
instructions included in the listing or labeling.”
Committee Meeting Action: Accept
Number Eligible to Vote: 25
Ballot Results: Affirmative: 23 Negative: 1
Vote Not Returned: 1 CLIFFDWELLER
Explanation of Negative:
TIEDE: A recent NEMA survey indicated that GFCIs are not being tested
and replaced when they cease to function. Each reminder to test will help to
assure protection is as expected.
Comment on Affirmative:
CALLANAN: I am not certain that 2-2.4.2.2 is where the proposed
requirement for GFCI testing per the manufacturers instructions should be
placed. However, assuring that a GFCI device will operate to protect personnel
is a crucial link in the safety chain. Having language in 2-2.4 to further
assure compliance with this important requirement would certainly serve as an
important reminder and enhance worker safety.
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-30 Log #20 Final Action: Accept in Principle
( Part 1, 4-3.1.(2) )
________________________________________________________________
Submitter: Edward A. Donoghue, Edward A. Donoghue Associates, Inc. /
Rep. National Elevator Industry Inc.
Comment on Proposal No:70E-36
Recommendation: Revise text to read as follows:
(2) Machine room/machinery space Machine room or control room/machinery
space for or control spacing space lighting and receptacle(s).
Substantiation: To make consistent with terminology in NFPA 70.
Committee Meeting Action: Accept in Principle
Revise the second paragraph of 4-3.1 to read as follows:
“The disconnecting means for the main power supply conductors shall not
disconnect the following required branch circuits:”
The committee accepts the submitters recommendation.
Committee Statement: The committee accepts the editorial change as
submitted by the comment and has made editorial changes to the sentence
structure.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-31 Log #94 Final Action: Accept in Principle
( Part 1, 5-4.1 )
________________________________________________________________
Submitter: C. Bryan Drennan, Sandia National Laboratories
Comment on Proposal No:70E-15
Recommendation: In Part 1, Section 5-4.1 revise the note as follows:
Note: For the requirements for electrical and electronic equipment and
wiring for all voltages in Class I, Division 1 or Division 2; Class II, Division
1 or Division 2; and Class III, Division 1 or Division 2 hazardous (classified)
locations where fire or explosion hazards may exist due to flammable gases or
vapors, flammable liquids, or combustible dusts or fibers. This information is
in Chapter 5 of NFPA 70, National Electrical Code.
Substantiation: This information was extracted from NFPA-70, National
Electrical Code. This text will direct the user to the source document for
additional information.
Committee Meeting Action: Accept in Principle
Revise the Note following 5-4.1 to read as follows:
“FPN: Requirements for electrical and electronic equipment and wiring for all
voltages in Class I, Division 1 or Division 2; Class II, Division 1 or Division
2; and Class III, Division 1 or Division 2 hazardous (classified) locations
where fire or explosion hazards may exist due to flammable gases or vapors,
flammable liquids, or combustible dusts or fibers, are contained in Articles 500
through 504 of NFPA 70-2002, National Electrical Code. Revise the second
paragraph of 4-3.1 to read as follows:
“The disconnecting means for the main power supply conductors shall not
disconnect the following required branch circuits:”
Report on Comments — Copyright, NFPA
The committee accepts the submitters recommendation.
Committee Statement: The committee believes the submitter is referencing
to Proposal 70E-42. The committee has made grammatical corrections to the
language.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-32 Log #83 Final Action: Accept in Principle
( Part 2 )
________________________________________________________________
Submitter: Joseph J. Andrews, Electrical Safety Resources, Inc.
Comment on Proposal No:70E-137
Recommendation: The reorganization of Part II, per this Proposal, contains a
significant number of changes that need to be addressed by the 70E Committee.
Suggestions are on how to handle the changes are also included.
NOTE: The prefix “PS” is used in this Comment to refer to the new Section
Numbers per the Proposal.
PROPOSAL CHAPTER 1
PS 1-4 This section has been significantly revised due to the nature of the
proposal and contains words that do not appear in the existing text. Also,
there are only three chapters not four in this proposal. These words need to be
reviewed because text from other proposals have now been included in Chapter
1. Chapter 1 would now also include other general safety related work practice
requirements.
PROPOSAL CHAPTER 2
Proposal Chapter 2 has a new title. The Task Group recommends that this title
be “Working On Deenergized Parts”. There are also several sections and para-
graphs that do not belong in Chapter 2 as stated in 1-4 Organization, which
states: “provisions for establishing a safe work condition so that work can be
performed safely on deenergized parts.” The sections and paragraphs are as
follows:
PS 2-2, PS 2-2.1, PS 2-2.1.3, PS 2-2.1.4, PS 2-2.1.5, PS 2-2.1.6, PS 2-2.1.6.1,
PS 2-2.1.6.2, PS 2-2.1.7, PS 2-2.3, PS 2-2.3.1, PS 2-2.3.2, PS 2-2.3.3. PS 2-
2.3.4 contains some deenergized work and some energized. PS 2-3 applies to
both energized and deenergized work.
PS 2-1 is now a stand-alone title. The Task Group recommends that the original
text be returned to this location. (Relocated by this proposal to PS 3-1.1.)
PS 2-1.1 is a new section title. The Task Group recommends that the text of
this section be placed under “General”.
PS 2-1.2 is a new section title. The Task Group does not think that the title
“Qualifed Workers” is appropriate for the associated text. . The word “not”
belongs between “have” and “been” in the text.
PS 2-1.3 is a new section title and a text change. In the first sentence, reference
to the procedures of a section (old section 2-1.2) was changed to reference all
of Chapter 2.
PS 2-2 (from 2-3.1.5) has a new title and new text. The text in the second sen-
tence is new.
PS 2-2.1 is a new section title.
PS 2-2.1.1 contains an incorrect reference to PS 2-5 for lockout/tagout proce-
dures. The reference should be to PS 2-6.
PS 2-2.1.2 now has title of old section 2-1.3.5 combined with text of 2-1.3.5.1
PS 2-2.1.4 This Section is missing paragraph 2-3.4.1 of the original text. It
has been relocated to a new Section, paragraph PS 3-2.1.3.4.1. The title
“Illumination” has been duplicated at PS 3-2.1.3.4.
Section number PS 2-2.1.5 appears twice. The second one should be 2-2.1.6.
PS 2-2.2 is a new section title.
PS 2-2.2.1 The word “done” in the original text has been replaced by the words
“performed according to Section 3-2.2”. The Task Team disagrees with the new
statement. PS 3-2.2 does not tell you how to perform a Flash Hazard Analysis.
PS 2-2.3 is a new section title.
PS 2-4 is a new text section not found in the existing standard. The first
70E-14
NFPA 70E
sentence is new wording. The rest is copied from existing sections 2-
1.1.3(a),(b),(c) which are already part of PS 2-1.3
PS 2-5 is new text (section) not found in the current standard. The first sentence
is new wording. The rest is copied from existing section 2-1.1.3(e) and sections
3-4.10.1, 3-4.10.2, and 4-1.1. PS 2-1.3, already contains the words from existing
section 2-1-1.3(e).
PS 2-6 Title and sentence is new text not found in the existing standard.
PS 2-6.8.1 Text needs a section number correction. It currently states: “The
procedure shall require planning, including 2-6.8.1.1 through 2-6.8.1.14 of Part
II.” The second reference should be 2-6.8.2.14.
PS 2-7 Title is new and is not in the existing standard. It also gives the
impression that it is more inclusive than the words “Temporary Protective
Grounding” that is part of the title of PS 2-7.1. The text is from existing section
2-1.1.3(f). But, the text is duplicated from PS 2-1.3(f).
PROPOSAL CHAPTER 3
Many of the duplications mentioned below belong in PS Chapter 3 instead of
PS Chapter 2. Some of them apply to both deenergized and energized work.
The ones that apply to both deenergized and energized work probably should
go into Chapter 1.
Proposal Chapter 3 has a new title.
PS 3-1.2.1 The references mentioned do not cover all of the requirements
contained in existing text 2-1.3.1. In addition, the references should be written
so that the sentence flows more clearly.
PS 3-2 Duplicates title of PS 2-2. There is no PS 3-2 on page 271 of ROP it is
mislabeled it says 2-2 which is a typo.
PS 3-2.1 Duplicates title of PS 2-2.1. There is no PS 3-2.1 on page 271 of ROP
it is mislabeled it says 2-2.1 which is a typo.
PS 3-2.1.2 Duplicates title of PS 2-2.1.2. Paragraph PS 3-2.1.2 does not belong
in the proposed location. Should be included with paragraph 2-2.1.2 and
numbered as 2-2.1.3 as it is in the existing standard paragraph under the title of
“2-1.3.5 Unqualified Persons”.
PS Table 3-2.1.2 This should be named Table 3-2.1.1. The last line of the Table
contains typographical errors on the last line. They should be eliminated. Some
footnotes are missing. The following foot notes should be added. However, the
reference to “2-1.3.5” needs to be corrected to read 2-2.1.2 and 3-2.1.2.
1
Notes:
For SI units: 1 in. = 25.4 mm; 1 ft = 0.3048 m.
2
For flash protection boundary, see 2-1.3.3.2.
3
1. See definitions in the Introduction and text in 2-1.3.5 and Appendix A of
Part II for elaboration.
PS 3-2.1.3.3 is a duplication of PS 2-2.1.3.
PS 3-2.1.3.4 This title is a duplicate of PS 2-2.1.4
PS 3-2.1.3.4.2 This section is a duplication of PS 2-2.1.4.
PS 3-2.1.3.5 This section is a duplicate of PS 2-2.1.5
PS 3-2.1.3.6 This title is a Duplicate of PS 2-2.1.6
PS 3-2.1.3.6.1 This section is a Duplicate of PS 2-2.1.6.1
PS 3-2.1.3.6.2 This section is a Duplicate of 2-2.1.6.2
PS 3-2.1.3.7 Section 3-2.1.2 referenced in the NOTE is wrong. It should be
3-1.2.
PS 3-2.1.3.12 This section is a duplicate of PS 2-2.1.7
PS 3-2.2 Title is new Text and also duplicates PS 2-2. There is no PS 3-2.2 on
pg 273 of ROP it is mislabeled it says 2-2.2 Arc Flash Hazard which is a typo.
PS 3-2.2.1 This section is a duplicate of 2-2.2.1
PS 3-2.2.3 needs to add the following formula from section 2-1.3.3.1 of the
original text.
Dc = [ 2.65 x MVA bf x t ] 1/2
Or
Dc = [53 x MVA x t ] 1/2
Report on Comments — Copyright, NFPA
PS 3-2.1 This section is a Duplication of PS 2-2.3
PS 3-2.3 ROP page 273 says 2-2.3, Other Hazards. It should read 3-2.3.
PS 3-2.3.1 This section is a Duplication of PS 2-2.3.1
PS 3-2.3.2 This section is a Duplication of PS 2-2.3.2
PS 3-2.3.3 This section is a Duplication of PS 2-2.3.3
PS 3-2.3.4 This section is a Duplication of PS 2-2.3.4
PS 3-2.3.4.1 This section is a Duplication of PS 2-2.3.4.1
PS 3-2.3.4.2 This title is a Duplication of PS 2-2.3.4.2
PS 3-2.3.4.2.1 This section is a Duplication of PS 2-2.3.4.2.1
PS 3-2.3.4.2.2 This section is a Duplication of PS 2-2.3.4.2.2
PS 3-2.3.4.2.3 This section is a Duplication of PS 2-2.3.4.2.3
PS 3-2.3.4.3 This title is a Duplication of PS 2-2.3.4.3
PS 3-2.3.4.3.1 This section is a Duplication of PS 2-2.3.4.3.1
PS 3-2.3.4.3.2 This section is a Duplication of PS 2-2.3.4.3.2
PS 3-2.3.4.3.3 This section is a Duplication of PS 2-2.3.4.3.3
PS 3-2.3.4.4 This section is a Duplication of PS 2-2.3.4.4
PS 3-2.3.4.5 This title is a Duplication of PS 2-2.3.4.5
PS 3-2.3.4.5.1 This section is a Duplication of PS 2-2.3.4.5.1
PS 3-2.3.4.5.2 This section is a Duplication of PS 2-2.3.4.5.2
PS 3-2.3.4.5.3 This section is a Duplication of PS 2-2.3.4.5.3
PS 3-3 This section is a duplication of PS 2-3. ROP page 274 says 2-3, Job
Briefing. It should say 3-3.
PS 3-4 This is a new title that did not exist in 70E-2000. ROP page 274 says
2-4 Safe Operating Procedures. It should say 3-4.
PS 3-4.1.1.5 This section is a duplication of PS 2-2.
PS 3-4.5.3 is out of order appearing after PS 3-4.6.2.2 on page 33 of Log #6
or page 275 of the ROP. It appears to be a cut and past error. PS 3-5.7 almost
duplicates this section except that it refers to PS 3-5 instead of PS 3-4.
PS 3-4.6 is a combination of existing sections. The title and first sentence come
from existing section 4-1. The second sentence comes from existing section
3-4.10.1, and the third sentence comes from existing section 3-4.10.2. However,
the second sentence is a duplicate of PS 2-5(b), and the third sentence is a
duplicate of PS 2-5(c).
PS 3-4.6.1 This section is a duplication of PS 2-5(d).
PS 3-4.6.2.2 This section is a duplication of PS 2-4.1.
PS 3-5 This section has a new title not in the original standard. The title is also
duplicated later in PS 3-5.2 The word “General” from existing Section 3-1 is
eliminated. The text comes from existing Section 3-1. The note should refer to
Sections 3-5.2 through 3-5.7 in order to cover all personal and other protective
equipment.
PS 3-5.1 References in the NOTES will now send you to PS 3-5.7 that only
sends you someplace else. In order to be completely correct the NOTES should
reference:
Section 3-5.2.9.6 for Care and Maintenance of FR Clothing and FR Flash Suits.
Table 3-5.2.8 for Standards on Protective Equipment.
Table 3-5.7 for Standards on Other Protective Equipment.
PS 3-5.2 The title of this section comes from existing Section 3-3. However, it
also appears above in PS 3-5
PS 3-5.2.1 This section should probably be moved up three places.
PS 3-5.2.9.1 The last reference in the text should refer to PS 3-2.2 not PS 3-2.
PS 3-5.7 This is almost a duplication of PS 3-4.5.3 with the exception that it
refers to PS 3-5 instead of PS 3-4.
70E-15
NFPA 70E
PS Table 3-5.2.8 The superscript “vii1”, after the word “Apparel” in the
SUBJECT Column, should be taken out. This Table is also missing the follow-
ing foot notes.
ASTM - American Society for Testing and Materials
ANSI - American National Standards Institute
PS Table 3-5.2.9.1 There are extraneous numbers and superscripts in the
last line of this Table. They appear to be typographical errors and should be
removed.
PS Table 3-5.2.2 This Table number should be changed to Table 3-5.2.9.2.
There are extraneous numbers and superscripts in the last line of this Table.
They appear to be typographical errors and should be removed. The Table
number references in the Legend need to be corrected. Note 1 should refer to
Table 3-9.2.5.3. Note 3should refer to Table 3-5.2.9.1.
PS Table 3-5.2.9.3 There are extraneous numbers and superscripts in the
last line of this Table. They appear to be typographical errors and should be
removed.
PS Table 3-5.7 There are extraneous numbers and superscripts in the last
line of this Table. They appear to be typographical errors and should be
removed.
PS 3-6.5.1 The number of the Table mentioned in the first sentence of this
section should be corrected to read “Table 3-2.1.2”
At the very end of the Proposal, there is an accumulation of NOTES. These
NOTES belong under several different Tables in the text. There are also
extraneous superscripts throughout these NOTES. They appear to be
typographical errors and should be removed.
Notes:
4
For SI units: 1 in. = 25.4 mm; 1 ft = 0.3048 m.
5
For flash protection boundary, see 2-1.3.3.2.
6
1. See definitions in the Introduction and text in 2-1.3.5 and
Appendix A of Part II for elaboration.
This first group of notes belong under PS Table 3-2.1.2
7
Notes:
For SI units: 1 in. = 25.4 mm; 1 ft = 0.3048 m.
8
For flash protection boundary, see 2-1.3.3.2.
9
1. See definitions in the Introduction and text in 2-1.3.5 and
Appendix A of Part II for elaboration.
This second group of notes are a duplicate of the first group and can be
deleted.
ANSI – American National Standards Institute
10
ASTM – American Society for Testing and Materials
This third group of notes belong under PS Table 3-5.2.8
11
Legend:
12
V-rated Gloves are gloves rated and tested for the maximum line-
to-line voltage upon which work will be done.
13
V-rated Tools are tools rated and tested for the maximum line-to-
line voltage upon which work will be done.
14
2* means that a double-layer switching hood and hearing protection
are required for this task in addition to the other Hazard/Risk Category 2
requirements of Table 3-3.9.2 of Part II.
15
Y = yes (required)
16
N = no (not required)
Notes:
17
1. 25 kA short circuit current available, 0.03 second (2 cycle) fault
clearing time.
18
2. 65 kA short circuit current available, 0.03 second (2 cycle) fault
clearing time.
19
3. For < 10 kA short circuit current available, the Hazard/Risk
Category required may be reduced by one Number.
20
4. 65 kA short circuit current available, 0.33 second (20 cycle) fault
clearing time.
21
5. 65 kA short circuit current available, up to 1.0 second (60 cycle)
fault clearing time.
22
6. For < 25 kA short circuit current available, the Hazard/Risk
Category required may be reduced by one Number.
This fourth group of notes are belong under PS Table 3-5.2.9.1 and are
already shown there.
23
Legend:
24AN = As needed
This fifth group of notes belong under PS Table 3-5.2.9.2 and are
already shown there.
Report on Comments — Copyright, NFPA
*ATPV is defined in the ASTM P S58 standard arc test method
25
for flame resistant (FR) fabrics as the incident energy that would just
cause the onset of a second degree burn (1.2 cal/cm2). E
BT is reported
according to ASTM P S58 and is defined as the highest incident energy
which did not cause FR fabric breakopen and did not exceed the second-
degree burn criteria. EBT is reported when ATPV cannot be measured
due to FR fabric breakopen.
This sixth group of notes belong under PS Table 3-5.2.9.3 and are
already shown there.
26 ASTM - American Society for Testing and Materials
27 ANSI - American National Standards Institute
This last group of notes belong under PS Table 3-5.7 and are already
shown there.
Substantiation: This Comment is submitted by the Part II Reorganization
Task Group, assigned by the Chair of NFPA 70E, to review Proposal 70E-
137. The 70E Committee Accepted-in-Principle Proposal 70E-137 with
the understanding that the scope of the proposal was only to effect the
reorganization of Part II. As was its intention, the Proposal did incorporate
all of the existing sections from Part II of NFPA 70E-2000. Section
numbers, Table numbers, and locations of text were necessarily changed due
to the nature of the proposal. However, there are a significant number of
changes that need to be addressed by the 70E Committee. In this Comment,
the Task Group has supplied many suggestions relative to the changes.
These are highlighted in the attachment. There was not enough time to
create a suggestion for every item by the Comment submission due date.
The Task Group plans to have recommendations completed for all of them
by the Committee meeting date in December.
Committee Meeting Action: Accept in Principle
Reorganize 70E Part II according to the following outline.
(The italicized numbers in the outline indicate where the text was located in
the 70E-2000 version.)
Chapter 1 (former title of Chapter 2) General Requirements for Electrical
Work Practices
1-1 Scope.
1-2 Purpose.
1-3 Responsibility.
1-3.1 Multi-Employer relationship
1-3.1.1 Outside personnel (contractors, etc.).
1-4 Organization. Part II of this standard is divided into three chapters.
Chapter 1 provides general requirements regarding
the preparation for, and conduct of, work per-
formed on or near electrical components regard-
less of whether such components are energized or
not. Chapter 2 emphasizes working deenergized
and describes the work practices used to deen-
ergize electrical components to put them into an
electrically safe work condition before attempting
work on or near them. Chapter 3 provides require-
ments for working on or near electrical compo-
nents that have not been placed into an electrically
safe work condition. (Revised text to reflect ROC
70E-32 )
1-5 Training Requirements.
1-5.1 Safety Training.
1-5.2 Type of Training.
1-5.3 Emergency Procedures.
1-5.4 Employee Training.
1-5.4.1 Qualified Persons.
1-5.4.2 Unqualified Persons.
1-5.4.2.1
1-6 (2-3) Electrical Safety Program.
1-6.1 (2-3.1) General.
1-6.1.1 (2-3.1.1) Awareness and Self Discipline.
1-6.1.2 (2-3.1.2) Electrical Safety Program Principles.
1-6.1.3 (2-3.1.3) Electrical Safety Program Controls.
1-6.1.4 (2-3.1.4) Electrical Safety Program Procedures.
1-6.1.5 (2-3.1.5) Hazard/Risk Evaluation Procedure
1-6.1.6 (2-3.1.6) Job Briefing
1-7 (2-1) Working On or Near Electrical Conductors or Circuit Parts
1-7.1. (2-1.1) General
1-7.1.1 (2-1.1.1 abbreviated) “Live parts to which an employee might be
exposed shall be put into an electrically safe work
condition before an employee works on or near
them, unless work on energized components can
be justified according to Section 3-1”. (Revised
text)
1-7.1.2 (2-1.1.2)
1-7.2 (2-1.3) Working On or Near Exposed Electrical Conductors
70E-16
NFPA 70E
or Circuit Parts that Are or Might Become
Energized.
1-7.2.1 (2-1.3.1) Electrical Hazard Analysis If the live
parts operating at 50 volts or more are not placed in an electrically
safe work condition, other safety-related work practices shall be
used to protect employees who might be exposed to the electrical
hazards involved.
1-7.2.1.1 (2-1.3.2) Shock Hazard Analysis A Shock Hazard Analysis
shall determine the voltage to which personnel will be exposed, boundary
requirements, and the personal protective equipment necessary in order to
minimize the possibility of electrical shock to personnel.
FPN: See 3-2 of Part 1 for the requirements of conducting a Shock Hazard
Analysis.[Proposal 70E-55 and Comment 70E-47]
1-7.2.1.2 Flash Hazard Analysis. A Flash
Hazard Analysis shall be done in order to protect
personnel from the possibility of being injured by an arc
flash. The analysis shall determine the flash protection
boundary and the personal protective equipment that
people within the flash protection boundary shall use.
FPN: See 3-4 of Part 1 for the requirements
of conducting a Flash Hazard Analysis.
1-7.2.2 Energized Electrical Work Permit 2-1.3.6.1 If live parts
are not placed in an electrically safe work condition (i.e., for the reasons of
increased or additional hazards or infeasibility per Section 2-1.1.1), work to be
performed shall be considered energized electrical work and shall be performed
by written permit only.
FPN: See 3-1.1.1 of Part 1 for the requirements of an Energized Electrical
Work Permit.
1-7.2.3 (2-1.3.5) Unqualified Persons
1-7.2.3.1 (2-1.3.5.1)
1-7.2.4 (2-3.11) Safety Interlocks
1-8 Use of Equipment
1-8.1 (3-4.10) Test Instruments and Equipment.
1-8.1.1 (3-4.10.1)
1-8.1.2 (3-4.10.2)
1-8.1.3 (4-1.1) Visual Inspection
1-8.2 (4-3) Portable Electric Equipment.
1-8.2.1 (4-3.1) Handling.
1-8.2.2 (4-3.2) Grounding-type Equipment.
1-8.2.2.1 (4-3.2.1)
1-8.2.2.2 (4-3.2.2)
1-8.2.2.3 (4-3.2.3)
1-8.2.3 (4-3.3) Visual Inspection of Portable Cord- and
Plug-Connected Equipment and Flexible Cord Sets.
1-8.2.3.1 (4-3.3.1) Frequency of Inspection.
1-8.2.3.2 (4-3.3.2) Defective Equipment.
1-8.2.3.3 (4-3.3.3) Proper Mating.
1-8.2.4 (4-3.4) Conductive Work Locations.
1-8.2.5 (4-3.5) Connecting Attachment Plugs.
1-8.2.5.1 (4-3.5.1)
1-8.2.5.2 (4-3.5.2)
1-8.2.5.3 (4-3.5.3)
1-7.6 (2-3.11) Safety Interlocks
1-8.3 (2-3.14) Overcurrent Protection Modification.
Chapter 2 - Establishing an Electrically Safe Work Condition
2-1 (2-1.1.3) Process of Achieving An Electrically Safe Work Condition
(New Title)
2-2 (2-1.2) Working On or Near Deenergized Electrical Conductors or
Circuit Parts That Have Lockout/Tagout Devices Applied
Report on Comments — Copyright, NFPA NFPA 70E
2-3 (former title of Chapter 5) Lockout/Tagout Practices and Devices 2-3.4.1.3 (5-4.1.3) Person In Charge.
2-3.1 (5-1) General. 2-3.4.1.4 (5-4.1.4) Individual Qualified
2-3.1.1 (5-1.1) Principles of Lockout/Tagout Employee Control.
Execution. 2-3.4.1.5 (5-4.1.5) Simple Lockout/Tagout.
2-3.1.1.1 (5-1.1.1) 2-3.4.1.6 (5-4.1.6) Complex Lockout/Tagout.
2-3.1.1.2 (5-1.1.2) 2-3.4.2 (5-4.2) Elements of Control.
2-3.1.1.3 (5-1.1.3) 2-3.4.2 (5-4.2.1) Deenergizing Equipment
2-3.1.1.4 (5-1.1.4) (Shutdown).

2-3.1.1.5 (5-1.1.5) 2-3.4.2 (5-4.2.2) Stored Energy.

2-3.1.1.6 (5-1.1.6) 2-3.4.2 (5-4.2.3) Disconnecting Means.

2-3.1.1.7 (5-1.1.7) 2-3.4.2 (5-4.2.4) Responsibility.

2-3.1.2 (5-1.2) Responsibility. 2-3.4.2 (5-4.2.5) Verification.

2-3.1.2.1 (5-1.2.1) Audit. 2-3.4.2 (5-4.2.6) Testing.

2-3.1.3 (5-1.3) Hazardous Electrical Energy Control 2-3.4.2 (5-4.2.7) Grounding.

Procedures. 2-3.4.2 (5-4.2.8) Shift Change.
2-3.1.3.1 (5-1.3.1) Individual Qualified 2-3.4.2 (5-4.2.9) Coordination.
Employee Control Procedure.
2-3.4.2 (5-4.2.10) Accountability for
2-3.1.3.2 (5-1.3.2) Simple Lockout/Tagout Personnel.
Procedure.
2-3.4.2 (5-4.2.11) Lockout/Tagout
2-3.1.3.3 (5-1.3.3) Complex Lockout/Tagout Application.
Procedure.
2-3.4.2 (5-4.2.12) Removal of Lockout/
2-3.1.4 (5-1.4) Coordination. Tagout Devices.
2-3.1.4.1 (5-1.4.1) 2-3.4.2 (5-4.2.13) Release for Return to
2-3.1.4.2 (5-1.4.2) Service.

2-3.1.4.3 (5-1.4.3) 2-3.4.2 (5-4.2.14) Temporary Release for

Testing/Positioning.
2-3.1.4.4 (5-1.4.4)
2-4 (3-4.2) Temporary Protective Grounding Equipment.
2-3.2 (5-2) Training and Retraining.
2-4.1 (3-4.2.1)
2-3.3 (5-3) Equipment.
2-4.2 (3-4.2.2)
2-3.3.1 (5-3.1) Lock/Tag Application.
2-4.3 (3-4.2.3)
2-3.3.2 (5-3.2) Lockout/Tagout Device.
2-4.4 (3-4.2.4)
2-3.3.3 (5-3.3) Lockout Device.
2-3.3.3 (5-3.3.1)
Chapter 3 Working On or Near Live Parts
2-3.3.3 (5-3.3.2) 3-1 (2-1.1.1) Justification For Work (New Title)
2-3.3.3 (5-3.3.3) 3-1.1 Energized Electrical Work Permit
3-2 (2-1.3.4) Approach Boundaries To Live Parts
2-3.3.3 (5-3.3.4) 3-2.1 (2-1.3.2.1) Shock protection boundaries
3-2.2 (2-1.3.2.2 ) Approach to live parts
2-3.3.3 (5-3.3.5) Table 3-2.2 (Table 2-1.3.4)
3-2.3 (2-1.3.5.1) Approach by unqualified persons
2-3.3.3 (5-3.3.6) 3-2.3.1 (2-1.3.5.2)Working at or close to the limited
approach boundary
2-3.3.3 (5-3.3.7) 3-2.3.2 (2-1.3.5.3) Entering the limited approach
boundary
2-3.3.4 (5-3.4) Tagout Device. 3-3 (2-1.3.5) Unqualified Persons
3-3.1 (2-1.3.5.2)
2-3.3.4.1 (5-3.4.1)
3-4 (2-1.3.3) Flash Hazard Analysis
2-3.3.4.2 (5-3.4.2) 3-4.1 (2-1.3.3.1) General
3-4.2 (2-1.3.3.2) Flash Protection Boundary
2-3.3.4.3 (5-3.4.3) 3-4.3 (2-1.3.3.3) Protective Clothing and Personal Protective
Equipment for Application with a Flash
2-3.3.4.4 (5-3.4.4) Hazard Analysis.
3-5 (4-1) Test Instruments and Equipment Use.
2-3.3.5 (5-3.5) Electrical Circuit Interlocks. 3-6 (2-2) Work On or Near Uninsulated Overhead Lines.
3-6.1 (2-2.1) Uninsulated and Energized.
2-3.3.6 (5-3.6) Control Devices. 3-6.2 (2-2.2) Deenergizing or Guarding.
3.6.3 (2-2.3) Employer and Employee Responsibility.
2-3.4 (5-4) Procedures. 3-6.4 (2-2.4) Approach Distances for Unqualified Persons.
2-3.4.1 (5-4.1) Planning. 3-6.5 (2-2.5) Vehicular and Mechanical Equipment.
3-6.5.1 (2-2.5.1)
2-3.4.1.1 (5-4.1.1) Locating Sources. 3-6.5.2 (2-2.5.2)
3-6.5.3 (2-2.5.3)
2-3.4.1.2 (5-4.1.2) Exposed Persons.
70E-17
Report on Comments — Copyright, NFPA NFPA 70E
3-7 Other Precautions For Personnel Activities (New Title) 3-8.3.9.4.4 (3-3.9.4.4) Coverage.
3-7.1 (2-3.2) Alertness 3-8.3.9.4.5 (3-3.9.4.5) Fit.
3-7.1.1 (2-3.2.1)
3-7.1.2 (2-3.2.2) 3-8.3.9.4.6 (3-3.9.4.6)
3-7.2 (2-3.3) Blind Reaching. Interference.
3-7.3 (2-3.4) Illumination
3-7.3.1 (2-3.4.1) 3-8.3.9.5 (3-3.9.5) Arc Flash Protective
3-7.3.2 (2-3.4.2) Equipment.
3-7.4 (2-3.5) Conductive Articles Being Worn.
3-7.5 (2-3.6) Conductive Materials, Tools, and Equipment Being 3-8.3.9.5.1 (3-3.9.5.1) Flash Suits.
Handled.
3-7.5.1 (2-3.6.1) 3-8.3.9.5.2 (3-3.9.5.2) Face
3-7.5.2 (2-3.6.2) Protection.
3-7.6 (2-3.10) Confined or Enclosed Work Spaces. 3-8.3.9.5.3 (3-3.9.5.3) Hand
Protection.
3-7.7 (2-3.12) Housekeeping Duties.
3-8.3.9.5.4 (3-3.9.5.4) Foot
3-7.8 (2-3.13) Occasional Use of Flammable Materials. Protection.
3-7.9 (2-3.15) Anticipating Failure. 3-8.3.9.6 (3-3.9.6) Care and Maintenance of
4-2 Energizing and Deenergizing Electrical Power Circuits. FR Clothing and FR Flash Suits.

3-7.10 (4-2.1) Routine Opening and Closing of Circuits. 3-8.3.9.6.1 (3-3.9.6.1) Inspection.

3-7.11 (4-2.2) Reclosing Circuits after Protective Device 3-8.3.9.6.2 (3-3.9.6.2)

Operation. Manufacturerʼs Instructions.

3-7.12 (4-3.5) Connecting Attachment Plugs. 3-8.3.9.7 (3-3.9.7) Clothing Material

Characteristics.
3-7.12.1 (4-3.5.1)
3-8.3.9.7.1 (3-3.9.7.1) Melting.
3-7.12.2 (4-3.5.2)
3-8.3.9.7.2 (3-3.9.7.2)
3-7.12.3 (4-3.5.3) Flammability.
3-8.3.9.8 (3-3.9.8) Clothing Not Permitted.

3-8 (former title of Chapter 3) Personal and Other Protective Equipment 3-8.3.10 (3-3.9.6) Care and Maintenance of FR
3-8.1 (3-1) General. Clothing and FR Flash Suits.

3-8.2 (3-2) Care of Equipment. 3-8.3.10.1 (3-3.9.6.1) Inspection.

3-8.3 (3-3) Personal Protective Equipment. 3-8.3.10.2 (3-3.9.6.2) Manufacturerʼs

Instructions
3-8.3.1 (3-3.1) General.
3-8.4 (3-4) Other Protective Equipment
3-8.3.2 (3-3.2) Movement and Visibility.
3-8.3.3 (3-3.3) Head, Face, Neck, and Chin Protection.
3-8.4.1 (2-3.7) Insulated Tools and Equipment.
3-8.3.4 (3-3.4) Eye Protection.
3-4.1 Insulated Tools.
3-8.3.5 (3-3.5) Body Protection.
3-8.4.1.1 (3-4.1.1) Requirements
3-8.3.6 (3-3.6) Hand and Arm Protection. Qualifications for Insulated Tools. [ROP 70E-122]

3-8.3.7 (3-3.7) Foot and Leg Protection. 3-8.4.1.1.1 (3-4.1.1.1)

3-8.3.8 (3-3.8) Standards for Personal Protective 3-8.4.1.1.2 (3-4.1.1.2)

Equipment.
3-8.4.2 (2-3.7.1)
3-8.3.9 (3-3.9) Selection of Personal Protective
Equipment. 3-8.4.3 (2-3.7.2)

3-8.3.9.1 (3-3.9.1) Personal Protective

Equipment Required for Various Tasks. 3-8.4.4 (3-4.1.2) Fiberglass-Reinforced Plastic Rods.
3-8.3.9.2 (3-3.9.2) Protective Clothing and 3-8.4.5 (2-3.9) Portable Ladders.
Personal
Protective 3-8.4.5.1 (3-4.3) Nonconductive Ladders.
Equipment
Matrix. 3-8.4.6 (2-3.8) Protective Shields
3-8.3.9.3 (3-3.9.3) Protective Clothing 3-8.4.7 (3-4.4) Rubber Insulating Equipment.
Characteristics.
3-8.4.8 (3-4.5) Voltage Rated Plastic Guard
3-8.3.9.4 (3-3.9.4) Factors in Selection of Equipment.
Protective Clothing.
3-8.4.9 (3-4.6) Physical or Mechanical Barriers.
3-8.3.9.4.1 (3-3.9.4.1) Layering.
3-8.5 Alerting Techniques
3-8.3.9.4.2 (3-3.9.4.2) Outer
Layers. 3-8.5.1 (3-4.7) Safety Signs and Tags.

3-8.3.9.4.3 (3-3.9.4.3) 3-8.5.2 (3-4.8) Barricades.

Underlayers.
3-8.5.3 (3-4.9) Alternate Alerting Techniques —

70E-18
Report on Comments — Copyright, NFPA
Attendants.
3-8.6 (3-4.11) Standards for Other Protective Equipment.
Committee Statement: The committee agrees that it is desirable to reorganize
Part 2 in a way that emphasizes work in an electrically safe work condition.
However, the committee prefers to use the language adopted in the committee
action.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
HAMER: As an additional comment, a cross-reference Annex will be
necessary for locating 2000 Edition paragraphs in the new sections and in the
new document numbering format.
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-33 Log #78 Final Action: Accept in Part
( Part 2, 1-3 )
________________________________________________________________
Submitter: Michael I. Callanan, IBEW
Comment on Proposal No:70E-44
Recommendation: The Committee should accept the proposal in principal
and accept only parts 1-3, 1-3.1, 1.3.1.1, 1-3.1.2, 1-3.1.3, and 1-3.3. Do not
accept proposed parts 1-3.2 and 1-3.4.
Substantiation: The concept of establishing better guidelines for
multiemployer worksites is a good one. However section 1-3.2 takes the
authority away from the electrical contractor and the electrician from
determining when and where energized work may be performed. In addition,
1-3.4 is an inappropriate provision. Part 1, which is derived from the NEC
provisions of Article 527 and OSHA prohibited temporary electrical power
and lighting to extend past the period of construction. Section 1-3.4 as written
would essentially permit temporary wiring to remain in place provided it is
subject to regular inspection.
Committee Meeting Action: Accept in Part
The Committee accept the parts 1-3, 1-3.1, and 1-3.1.1. Do not accept
proposed parts 1-3.1.2, 1-3.1.3, and 1-3.3.
Committee Statement: The committee agrees with the substantiation in 70E-
37 with respect to deleting 1-3.1.2 , 1-3.1.3, and 1-3.3. See Committee Action
and Statement on Comment 70E-37 (Log #29).
Number Eligible to Vote: 25
Ballot Results: Affirmative: 22 Negative: 2
Vote Not Returned: 1 CLIFFDWELLER
Explanation of Negative:
CALLANAN: See my Explanation of Negative Vote on Comment 70E-37
(Log #29).
POTTS: All sections of the original proposal Part 2 1-3 to the committee
on Log #78 are integral to the successful communication and coordination of
safe electrical work practices between the host employer, contractors and their
employees.
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-34 Log #9 Final Action: Reject
( Part 2, 1-3 )
________________________________________________________________
Submitter: Ray A. Jones, Electrical Safety Consulting Services, Inc. / Rep.
ACC
Comment on Proposal No:70E-44
Recommendation: The committee action is to accept in principle is correct,
however, proposed paragraph 1-3.2 should be revised to read as follows:
1-3.2 Determination and monitoring of work on live systems. Working
together, the onsite employer or its designee, the outside employer and the
worker(s) shall decide whether electrical contraction/maintenance work on
lines and system is to be performed in an energized or de-energized manner.
The host employer or designee will review plans for and monitor any
contracted work to assure it is conducted in accordance with this standard.
Substantiation: The current language does not consider the worker who will
or may be exposed to the electrical hazard. Incidents and injuries occur when
the opinion of the worker is not considered. If the worker does not agree that
the work can be performed safely, the work should not be performed.
For example, in a recent incident a contractor employee was assigned to add
a new conductor to an existing circuit breaker, increasing the capacity of the
load conductors. The on-site employer determined that the work could be
performed safely with the CB primary conductors energized. The contractor
employee who knew that an additional cover had to be removed was not
consulted. The incident occurred when the cover was being replaced. It is
unlikely that the incident would have occurred had the scope of the work been
completely understood.
70E-19
NFPA 70E
Committee Meeting Action: Reject
Committee Statement: The Committee has decided to delete Section 1-3.2
from the original proposal. The basis of this decision is that NFPA 70E already
clearly dictates in Part 2, Section 2-1.1.1, the conditions under which work
may be performed on or near energized equipment or conductors. When such a
decision is made it is required that the employer demonstrate the need to work
in an energized condition. The employer may consult the on-site employer but
the responsibility for any decision to work on or near energized conductors
falls with the employer.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
POTTS: Agree with the commenter that absence of customer (on-site
employer, host employer, client, etc.) communication with the contractor does
increase risks to contractor employees. NFPA 70E needs to adequately address
these operating conditions. It should be very apparent in the standard that a
close and cooperative relationship between the host employer and contractor
must be maintained to avoid the direct hazards and the underlying causes of
risks of which many are contractually related.
________________________________________________________________
70E-35 Log #10 Final Action: Reject
( Part 2, 1-3 )
________________________________________________________________
Submitter: Ray A. Jones, Electrical Safety Consulting Services, Inc. / Rep.
ACC
Comment on Proposal No:70E-44
Recommendation: Add a new sentence at the end of the committee modified
proposal for section 1-3.2. The suggested new sentence is to read as follows:
1-3.2 ... The host employer or designee will review plans for and monitor any
contracted work to assure it is conducted in accordance with this standard.
Substantiation: As offered by Mr. Neitzel, Proposal 70E-44, Log 72
contained the suggested sentence. The proposed requirement was deleted
without justification in the committee statement.
Committee Meeting Action: Reject
Committee Statement: See Committee Action and Statement on Comment
70E-34 (Log #9).
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
_______________________________________________________________
70E-36 Log #107 Final Action: Reject
( Part 2, 1-3 )
________________________________________________________________
Submitter: David Soffrin, American Petroleum Institute
Comment on Proposal No:70E-44
Recommendation: Do not accept the wording as proposed in the Affirmative
Comment by Mr.Neitzel. Retain and revise the “Committee Meeting Action”
wording of 1-3.1.2 to as follows:
1-3.1.2 The outside employer shall ensure that his or her employees
understand and comply with restrictions and prohibitions of the on-site
employerʼs safety program, where the on-site employer has a documented
safety program in effect. Where the on-site employer has no safety program
established, the on-site employer shall ensure that his or her employees
understand and comply with restrictions and prohibitions of the outside
employerʼs safety program.
Substantiation: From APIʼs perspective, Mr. Neitzel has 1-3.1.2 backwards
in his affirmative comment (also note that his comment has numerous
mistranscriptions, missed strikethroughs, etc.). In industrial establishments,
such as most petrochemical operating facilities, the contractor (“outside
employer”) must become familiar with the facilitiesʼ (“on-site employerʼs)
safety program - not vice versa. The OSHA 1910.147 wording assumes
the on-site location has no established safety program. The correct
interpretation, from a large industrial userʼs point of view, is reflected in the
Committee Meeting Action. The proposed additional wording allows for both
circumstances - with and without an established safety program at the on-site
employerʼs site.
Committee Meeting Action: Reject
Committee Statement: See Committee Action and Statement on Comment
70E-37 (Log # 29).
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
Report on Comments — Copyright, NFPA
_______________________________________________________________
70E-37 Log #29 Final Action: Accept
( Part 2, 1-3 )
________________________________________________________________
Submitter: Kathy Wilmer, Duke Power Co. / Rep. Edison Electric Institute
Comment on Proposal No:70E-44
Recommendation: From the proposal, retain 1-3.1.1 and delete 1-3.1.2 and 1-
3.1.3. Also delete 1-3.2, 1-3.3, and 1-3.4.
Substantiation: Edison Electric Institute opposes the committee action.
Regulating the relationship between on-site employers and outside contractors
is outside the scope of this standard. This proposal has very specific
requirements related to communication, coordination and documentation
between the on-site employer and outside contractors which differ substantially
from OSHAʼs current multi-employer policy. For instance, the proposal
requires outside employers to train personnel to on-site work practices. Many
on-site employers hire outside employers for their expertise and skill related to
the task. They may expect outside employers to come to the site fully trained
and ready to start work. Adding an arbitrary requirement to re-train outside
employers to on-site work practices will be unnecessary in many cases and
will add cost and time to projects. OSHAʼs current multi-employer policy
covers this subject adequately. The committee should consider retaining only
1-3.1.1 which generically requires communication and coordination between
on-site employers and outside contractors but does not specify the details of
that relationship.
Committee Meeting Action: Accept
Committee Statement: The committee notes that Sections 1-3 and 1-3.1.1
will remain.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 22 Negative: 2
Vote Not Returned: 1 CLIFFDWELLER
Explanation of Negative:
CALLANAN: I agree that the action taken in accepting Proposal 70E-
44 was too broad and the original proposal contained provisions that went
beyond the scope of this standard and the relationship between the employer
and their subcontractors. However, the action taken by this committee on
this comment moves too far in the other direction. I disagree that Sections
1-3.1.2 and 1-3.1.3 should have been deleted. These two provisions complete
the requirement established in the accepted Section 1-3.1.1. This language is
similar to that utilized by OSHA in some of their safety standards and should
have remained as part of NFPA 70E requirements.
POTTS: Deletion of the requirements for improved customer and contractor
interaction does not enhance the safety of employees.
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
______________________________________________________________
70E-38 Log #44 Final Action: Reject
( Part 2, 1-3.2 )
________________________________________________________________
Submitter: Danny Liggett Newark, DE
Comment on Proposal No:70E-44
Recommendation: 1-3.2 Determination and monitoring of work on live
systems. The onsite employer or its designee and the outside employer shall
jointly decide whether work performed electrical contractor or maintenance
work on lines and systems by the outside contractor is to be performed in
an energized or de-energized manner. The host employer or designee will
review plans for and monitor any contracted work to assure it is conducted in
accordance with this standard.
Substantiation: The wording the proposal as accepted assumes the onsite
employer will always have greater knowledge of the best way to work
on these systems. Although the onsite employer may have greater of the
operation of the system, the onsite employer may not have always known the
safest way to perform the work. Leaving the decision solely up to the onsite
employer may be in contradiction to the outside employers responsibility to
OSHA requirements. Requiring a joint decision allows both employers to
meet their OSHA requirements. Adding the second sentence back in places
a responsibility on the onsite employer to assure other employers on site are
meeting the requirements of this standard. I disagree with the abstention of
Mr. Jackson. The physics of electricity does not change with the type of work
being done. Exposure to electrical hazards must be controlled regardless of
what the company prefers to call the activity. The line between “construction”
and “maintenance” is so blurred is it difficult to distinguish between the two.
By having separate standards for construction and other industries only leads to
confusion for the electricians. We need one set of rules.
Committee Meeting Action: Reject
Committee Statement: See Committee Action and Statement on Comment
70E-34 (Log #9).
Number Eligible to Vote: 25
Ballot Results: Affirmative: 23 Negative: 1
Vote Not Returned: 1 CLIFFDWELLER
70E-20
NFPA 70E
Explanation of Negative:
POTTS: Agree with commenter that this level of cooperation would increase
the safety on on-site and contract employees.
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-39 Log #42 Final Action: Reject
( Part 2, 1-5.4 )
________________________________________________________________
Submitter: Stephen D. Thorne, BBWI-Idaho National Engineering and
Environmental Lab
Comment on Proposal No:70E-46
Recommendation: Add new text to Chapter 2, Paragraph 200.1 Scope to read:
Chapter II covers electrical safety-related work practices and procedures
for employees who work on or near exposed energized electrical conductors
or circuit parts in workplaces that are included in the scope of this standard.
Included are installations of electric conductors and equipment that have been
found to not conform with the electrical installation requirements of Chapter
1. Conditions of nonconformance may include improper design, installation
or modification, inadequate maintenance, system degradation, manufacturing
defect or adverse environmental condition.
Substantiation: A greater context is needed for interpreting the requirements
of Part II as it applies to exposed live parts in workplaces that are included
in the scope of the standard. Revising the scope to include conditions of
nonconformance, clarifies the intent of the standard and enhances the process
for ensuring the installation meets the intent of Chapter 1.
Background.
Chapter 2, 200.1 Scope. is intended to cover electrical safety-related work
practices and procedures for employees who work on or near “exposed”
energized electrical conductors or circuit parts in workplaces that are included
in the scope of this standard. It is applied to parts that are not suitably guarded,
isolated, or insulated.
Direction for determining whether energized electrical conductors or circuit
parts meets the definition of “exposed”, (i.e., not suitably guarded, isolated,
or insulated) is delineated in NFPA 70E, Chapter 100.1. It states: “The
requirements contained in Chapter 1 shall be based on the provisions of NFPA
70, National Electrical Code. Where installations of electric conductors and
equipment have been found to conform with the safety requirements of the
National Electrical Code in use at the time of installation by governmental
bodies or agencies having legal jurisdiction for enforcement of the National
Electrical Code, this conformance shall be prima facie evidence that such
installations were adequately designed and installed.
Therefore, Chapter 2 applies when:
• Employees work on or near exposed energized equipment, OR
• Employees work on or near electric conductors and equipment, which have
been found to not conform to the safety requirements of the NEC.
The proposed change is consistent with supportive statements cited in
NFPA 70E regarding safety training: Chapter 2, 200.5(A) Safety Training.
“The training requirements in this section apply to employees who face a
risk of electrical shock that is not reduced to a safe level by the installation
requirements of Chapter 1”
The proposed change is supported by the accident history. A case history for
shock or burn injury resulting from breaker operation under 480 volts does
not exist. There are instances recorded in NIOSH and OSHA in which injury
has occurred from breaker operation in the voltage range of 480 volts and
above. The root cause of these incidents has not been adequately identified in
the reports and indicates a deficiency in the investigation/reporting process.
However, experts consider these occurrences to be related to nonconforming
equipment. That is, these incidents are considered to be the result of one of the
following factors:
• Improper design and installation, e.g., breaker fault duty rating is less than
available fault current
• Modifications that do not conform to the NEC
• Inadequate maintenance
• Degraded systems
• Manufacturing defects
• Adverse environmental conditions
Including conditions of nonconformance as a part of the criteria for
determining the scope of Chapter 2, will enhance the hazard analysis process,
generally increase awareness of this issue and provide a higher level of
electrical safety for the employeeʼs workplace.
Committee Meeting Action: Reject
Committee Statement: The comment does not address material contained
in Proposal 70E-46 and is therefore new material. This comment does not
address Part 2, 1-5.4.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
Report on Comments — Copyright, NFPA
_______________________________________________________________
70E-40 Log #95 Final Action: Accept
( Part 2, 1-5.4.1 )
________________________________________________________________
Submitter: C. Bryan Drennan, Sandia National Laboratories
Comment on Proposal No:70E-45
Recommendation: Revise Part II, Section 1-5.4.1 to read as follows:
200.6 Training Requirements.
(A) Safety Training. The training requirements contained in this section shall
apply to employees who face a risk of electrical hazard that is not reduced
to a safe level by the electrical installation requirements of Chapter 1. Such
employees shall be trained to understand the specific hazards associated with
electrical energy. They shall be trained in safety-related work practices and
procedural requirements as necessary to provide protection from the electrical
hazards associated with their respective job or task assignments. Employees
shall be trained to identify and understand the relationship between electrical
hazards and possible injury.
(B) Type of Training. The training required by this section shall be classroom
or on-the-job type, or a combination of the two. The degree of training
provided shall be determined by the risk to the employee.
(C) Emergency Procedures. Employees working on or near exposed
energized electrical conductors or circuit parts shall be trained in methods of
release of victims from contact with exposed energized conductors or circuit
parts. They shall be regularly instructed in methods of first aid and emergency
procedures, such as approved methods of resuscitation, if their duties warrant
such training.
(D) Employee Training.
(1) Qualified Persons. A qualified person shall be trained and knowledgeable
of the construction and operation of equipment or a specific work method, and
be trained to recognize and avoid the electrical hazards that might be present
with respect to that equipment or work method. Such persons shall also be
familiar with the proper use of special precautionary techniques, personal
protective equipment, insulating and shielding materials, and insulated tools
and test equipment. A person can be considered qualified with respect to
certain equipment and methods but still be unqualified for others. An employee
who is undergoing on-the-job training and who, in the course of such training,
has demonstrated an ability to perform duties safely at his or her level of
training and who is under the direct supervision of a qualified person shall be
considered to be a qualified person for the performance of those duties.
Such persons permitted to work within limited approach of exposed live parts
operating at 50 volts or more shall, at a minimum, be additionally trained in all
of the following:
(1) The skills and techniques necessary to distinguish exposed energized parts
from other parts of electric equipment
(2) The skills and techniques necessary to determine the nominal voltage of
exposed live parts
(3) The approach distances specified in Table 220.2(A)(1) and the
corresponding voltages to which the qualified person will be exposed
(4) The decision-making process necessary to determine the degree and extent
of the hazard
and the personal protective equipment and job planning necessary to perform
the task safely
FPN: An employee who is undergoing on-the-job training and who, in
the course of such training, has demonstrated an ability to perform duties
safely at his or her level of training and who is under the direct supervision
of a qualified person shall be considered to be a qualified person for the
performance of those duties.
Substantiation: The existing note contains mandatory language. The sentence
is relocated to the body of the document to comply with the Manual of Style.
Committee Meeting Action: Accept
Committee Statement: The committee directs NFPA staff to make corrections
to the numbering in this comment.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-41 Log #65 Final Action: Accept in Principle
( Part 2, 1-5.4.1 )
________________________________________________________________
Submitter: Robert E. Downey, Allison Transmission
Comment on Proposal No:70E-45
Recommendation: Change, “... personal protective equipment, insulating ...”
to “... personal protective equipment, including arc-flash, insulating ...”.
Substantiation: A qualified person should be aware and be protected from
arc-flash hazards as well as shock hazards. The proposed definition did not
specifically refer to this hazard.
Committee Meeting Action: Accept in Principle
In Part 2 1-5.4.1 Change, “... personal protective equipment, insulating ...” to
“... personal protective equipment, including arc-flash protective equipment,
insulating ...”.
70E-21
NFPA 70E
Committee Statement: The committee notes that this action modifies the
action taken on Comment 70E-40. Including arc flash protective equipment is
necessary to expand on personal protective equipment requirements.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-42 Log #79 Final Action: Accept
( Part 2, 2-1 )
________________________________________________________________
Submitter: Michael I. Callanan, IBEW
Comment on Proposal No:70E-47a
Recommendation: The Committee should reject this proposal.
Substantiation: As stated in my negative vote, this proposal removes the
standard that exists in both OSHA and the existing 70E-2000 (2-1.1.1) for
energized work at less than 50 volts to ground. The revised text provides a
laundry list to situations that may warrant de-energizing electrical parts that
operate at less than 50 volts to ground. I believe the better approach is to keep
the performance oriented text that limits energized work on these parts only
where “there will be no increased exposure to electrical burns or to explosion
due to electrical arcs.” Clearly, more work needs to be done to ascertain
when and where systems and parts that operate at less than 50 volts to ground
provide the potential for risk to the employee. The existing text provides the
greatest degree of protection at this time.
Committee Meeting Action: Accept
Number Eligible to Vote: 25
Ballot Results: Affirmative: 23 Negative: 1
Vote Not Returned: 1 CLIFFDWELLER
Explanation of Negative:
DOERING: 70E-2000 defined Live Parts as Electric conductors, buses,
terminals, or components that are uninsulated or exposed and a shock hazard
exists. 70E-2003 will define Live Parts as energized conductive components.
The committee agreed that the 70E-2000 definition (left-handily) excluded
live parts less than 50 volts unless a shock hazard existed. To maintain the
same requirement in 70E-2003, 41 change proposes were offered, to add after
“live parts” operating at 50 volts or more. A small task group put together
70E-47a, so that the 41 changes would not be necessary in 70E-2003, nor
would we have to worry about adding “operating at 50 volts or more” in future
editions. 70E-47a was designed to cover all live parts operating at less then 50
volts. The committee approved the concept, but also forgetting that part of the
concept to avoid adding the words “operating at 50 volts or more,” went ahead
and adopted most of the 41 proposals.
At the ROC, having forgot the objective of 70E-47a, the committee voted to
reject the proposal, based on the assertion the best approach was to keep the
present 2-1.1.1 performance language, “Energized parts that operate at less
than 50 volts to ground are not required to be deenergized if there will be no
increased exposure to electrical burns or explosion due to electric arcs.”
It is obvious that 70E-47a provides more protection than the existing
provision as it requires the live part to be put in an electrical safe work
condition if the employee is exposed to electrical burns, high energy systems,
wet environment where an electric shock. hazard exists, dangerous contact
times, or overcurrent devices may be delayed. Specific references are made to
Part IV, where such low voltage systems are covered.
The committee members should vote negative on Comment 70E-42.
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-43 Log #26 Final Action: Hold
( Part 2, 2-1.1 )
________________________________________________________________
Submitter: Paul S. Case, Fluor Hanford, Inc.
Comment on Proposal No:70E-47a
Recommendation: Add text to first sentence as shown so paragraph will read:
2-1.1 General. Safety-related work practices shall be used to safeguard
employees from injury while they are working on or near exposed electric
conductors or circuit parts that are or could become energized, or while
operating, manipulating, or testing electrical equipment that could expose
employees to hazards whether or not live parts are exposed. The specific
safety-related work practices shall be consistent with the nature and extent of
the associated electric hazard.
Substantiation: Safety-related work practices are required when working
with electrical equipment even if live parts are not exposed. Operating circuit
breakers and switches with covers on are activities included in Table 3-3.9.1,
but that is contradictory to the scope of Part II in 2-1.1 (exposed conductors or
circuit parts) and to the definition of Flash Protection Boundary, which is based
on exposed live parts. Table 3-3.9.1, in assigning the hazard/risk category, also
assumes that work is being performed within the flash protection boundary,
Report on Comments — Copyright, NFPA
which, by definition, would not include operating circuit breakers and switches
with covers on. One example of such hazards is shown in the following
excerpt from NFPA Journal, September/October 2002, firewatch section.
Although work was not being performed at the time of the explosion, itʼs easy
to see that a hazard existed and someone operating a circuit breaker would
have been exposed to a very serious hazard even though such work would not
have involved exposed live parts.
“Electrical equipment fire starts fire in furniture shop.
Illinois
An undetermined failure and subsequent explosion in the buildingʼs electrical
service equipment resulted in the ignition of nearby furniture padding,
wooden tables, and furniture under repair in the workroom of a furniture
store. Fortunately, sprinklers in the area of origin controlled the flames while
firefighters completed extinguishment with a hose line after the electrical
equipment was deenergized.
The one-story store had concrete-block walls and a poured-concrete floor.
Steel trusses supported the metal deck roof, which was covered by a rubber
membrane. The buildingʼs wet-pipe sprinkler system and smoke alarms were
connected to a municipal fire alarm system measuring 300 square ft (28 square
meters), the store was open at the time of the fire.
The fire broke out in the buildingʼs repair section, which measured 12 ft (4
meters) by 20 ft (6 meters) and was open on two sides. Chain link fencing
formed two walls, and concrete block walls formed the remaining sides. Also
in the area were the three-phase service panels that provided electrical power
to the building. Numerous combustible materials associated with furniture
repair, including flammable liquids were also present. At 8 p.m., heat from
an explosion in the electrical panels ignited nearby furniture padding, and the
resulting fire spread to wood work tables and ladders. The explosion deformed
the locked doors of the electrical panels. Four sprinklers activated, and the fire
department received the water flow and smoke detector alarms. Investigators
determined that two of the three outdoor pole-mounted fuses installed on the
line side of the service that supplied the building opened, however, the cause of
the failure within the service equipment is undetermined.
The sprinklers held the fire in check, limiting flame damage to 15 ft (4
meters) surrounding the area of origin. The building, valued at $300,000,
sustained no damage. However, its contents, valued at $200,000 sustained an
estimated loss of $75,000. One fire fighter was injured.”
Committee Meeting Action: Hold
Committee Statement: The comment introduces new material that has not
had public review.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-44 Log #51 Final Action: Reject
( Part 2, 2-1.1.1 )
________________________________________________________________
Submitter: Louis A. Barrios, Jr., Shell Global Solutions
Comment on Proposal No:70E-47a
Recommendation: Modify committee-accepted text as follows:
Exposed electrical conductors or circuit parts that operate at less than 50V to
ground are required to be put into an electrically safe work condition if one or
more of the following exist:
Substantiation: Editorial comment so that this statement is parallel to the one
in 2-1.1.2.
Committee Meeting Action: Reject
Committee Statement: See Committee Action on Comment 70E-42 (Log
#79) which deleted the text reference in the comment.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-45 Log #48 Final Action: Reject
( Part 2, 2-1.1.2 )
________________________________________________________________
Submitter: Danny Liggett Newark, DE
Comment on Proposal No:70E-47a
Recommendation: Delete the last sentence of 2-1.1.2 as follows:
Energized parts that operate at less than 50 volts to ground are not required
to be energized if there will be increased exposure to electrical burns or to
explosion due to electric arcs.
Substantiation: This sentence is incorrect and is not required. 2-1.1.1 covers
the requirements of less than 50 volts. The sentence in question only requires
circuits to be de-energized when there is a electric arc hazard. Section 2-1.1.1
requires the circuit to be placed in an electrically safe work condition and has
70E-22
NFPA 70E
more parameters as to when action on less than 50 volt circuits is required.
There is a significant difference between de-energizing circuits and placing
circuits is an electrically safe work condition. This leads to a contradictions and
confusion as to the intent of the panel.
Committee Meeting Action: Reject
Committee Statement: That sentence was incorrect in the ROP and the
committee desires to retain the wording in the 2000 edition of 70E. See
Committee action on 70E-42 (Log #79) that restored the original language.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-46 Log #50 Final Action: Reject
( Part 2, 2-1.1.2 )
________________________________________________________________
Submitter: Louis A. Barrios, Jr., Shell Global Solutions
Comment on Proposal No:70E-47a
Recommendation: Remove the last sentence in Part II, 2-1.1.2.
Energized parts that operate at less than 50 volts to ground are not required
to be energized if there will be increased exposure to electrical burns or to
explosion due to electric areas.
Substantiation: Per Mr. Doeringʼs Affirmative Comment, the statement is not
correct because “energized” should read “deenergized”, and “exposure” should
read “no exposure”, and this sentence is no longer needed since the committee
added requirements for deenergizing exposed electrical conductors operating at
50V and below in 2-1.1.1.
Committee Meeting Action: Reject
Committee Statement: See Committee Action and Statement on Comment
70E-45 (Log #48).
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-47 Log #106 Final Action: Accept in Principle
( Part 2, 2-1.3 )
________________________________________________________________
Submitter: David Soffrin, American Petroleum Institute
Comment on Proposal No:70E-55
Recommendation: The first sentence of Section 2-1.3 should begin with
“Prior to working on exposed electrical conductors and circuit parts,... “ to
retain the defined term “working on” in the text. The definition for Dc in
2-1.3.3.1 should read: “Dc = distance in feet from an arc source for a second-
degree burn” to be consistent with the action on 70E-140 (Log #64). Note that
the action on proposal 70E-58 supercedes some of this proposalʼs accepted text
(2-1.3.3, 2-1.3.3.1, and 2-1.3.3.2).
Delete the following phrase from the NOTE after 2-1.3.2.1 to remove a
requirement: “...and the greater distance shall be utlilized to trigger the need for
personal protective equipment.” End the sentence immediately after “Limited
Approach Boundary.”
Substantiation: Need to retain the defined term “working on” in the text for
clarity. Adopt the definition of Dc, from 70E-140 instead of that stated in the
proposal. Requirements need to be removed from a note, according to the
NFPA Manual of Style.
Committee Meeting Action: Accept in Principle
Revise the first sentence of Section 2-1.3 in Proposal 70E-55 by replacing the
words “ When work is to be done on exposed electrical conductors and circuit
parts” with “Prior to working on or near exposed electrical conductors and
circuit parts”
Revise the definition for Dc in Proposal 70E-55 to read as follows:
“Dc = distance in feet from an arc source for a second-degree burn”
Delete the following phrase from the NOTE in Proposal 70E-55 after 2-
1.3.2.1 “...and the greater distance shall be utlilized to trigger the need for
personal protective equipment.”
At the end of 2-1.3.3 of Part 2 in Proposal 70E-55 revise the last sentenece to
read as follows:
“The analysis shall determine the flash protection boundary and the personal
protective equipment that people within the flash protection boundary shall
use.”
Revise the existing note in 2-1.3.3.2 of Part 2 of Proposal 70E-55 to read as
follows:
“Note: For information on estimating the incident energy see Appendix B of
Part II.”
The committee accepts the editorial revisions suggested in Comment 70E-47.
Report on Comments — Copyright, NFPA
Committee Statement: The final text will reflect the wording in Proposal
70E-55 with these modifications.
The substantiation had a typographical error. The recommendation
should remain the same. The final bolded statement of the commentorʼs
substantiation had a typograpical error and should read: This comment is not
oriiginal material; its reference/source is as follows: Explanations given in
the “negative” “affirmative comment” vote (Hamerʼs) in the ROP and the
API Interdepartmental Advisory group. The recommendation of the comment
should remain the same.”
The commitee also revised the note found in 2-1.3.3.2 to provide a reference
to Appendix B. This action was necessary to correlate with Comment 70E-51.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 23 Negative: 1
Vote Not Returned: 1 CLIFFDWELLER
Explanation of Negative:
DOERING: Iʼm opposed to adding another specific “analysis.” There are
currently the following analysis required by 70E:
1. Determine that the facility to be worked on has been installed and still
meets 70E Part I.
2. Determine if the worker is qualified to do the particular job.
3. Determine if there are increase or additional hazards if the facility is
deenergized.
4. If the plan is to put the facility in an “electrically safe work condition,” six
requirements are to be met.
5. A “flash hazard analysis” shall be made.
6. The employer shall implement an overall electrical safety program, that
includes:
a. Awareness and Self Discipline
b. Electrical Safety Program Principles
c. Electrical Safety Program Controls
d. Electrical Safety Program Procedures
e. Hazard/Risk Evaluation Procedure
f. Job Briefing
I believe the requirement for a shock hazard analysis is more than covered by
existing requirements.
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
_______________________________________________________________
70E-48 Log #63 Final Action: Reject
( Part 2, 2-1.3.3 )
________________________________________________________________
Submitter: Robert E. Downey, Allison Transmission
Comment on Proposal No:70E-58
Recommendation: In paragraph 2-1.3.3.1, we recommend that items A, B
and C and Table 2-1.3.3.2 be removed, and the sentence at the end of the first
paragraph should read: “The Flash Protection Boundary shall be permitted to
be determined by utilizing the methods illustrated in Appendix C or Appendix
D.”
We recommend that a bibliographical reference be made in Appendix C.5 to
IEEE P1584.
Substantiation: This allows a “legal” reference to IEEE P1584 in an
appropriate location in the document. Also, we could determine no basis for
the table and the values it contains.
Committee Meeting Action: Reject
Committee Statement: The committee action on Comment 70E-51 deleted
the text referred by this comment. See committee action and statement on
Comment 70E-51.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 23 Negative: 1
Vote Not Returned: 1 CLIFFDWELLER
Explanation of Negative:
HAMER: By rejecting this Comment, the Table 2-1.3.3.2 from Proposal
70E-58 disappears from the proposed document. The first two rows of the
proposed Table are based on the “arc in open air” and “arc in a cubic box”
calculations of Appendix B-5 of Part II for a 50 kA, 0.1 second fault, and
the third row is based on the “Lee” equation from 2-1.3.3.2 of Part II for a
bolted fault of 50 kA at 15 kV for 0.1 second. The Committee Action should
have been Accept in Part, rejecting the second sentence of the Commentʼs
Substantiation, and retaining the content of proposed Table 2-1.3.3.2.
The text that will prevail as a result of this commentʼs rejection is shown in
the Committee Meeting Action on Comment 70E-47 (on Proposal 70E-55).
This text still establishes a Flash Protection Boundary of 4.0 ft based upon
the product of clearing times of 6 cycles (0.1 second) and available bolted
fault current of 50 kA or any combination not exceeding 300 kA cycles (5000
ampere seconds). This is clearly at variance with Appendix B-5.2 (arc in a
cubic box) which indicates 111 in. (~10 ft) for a 1.2 cal/cm2 Flash Protection
Boundary threshold for a 50 kA, 0.1 second duration fault.
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-23
NFPA 70E
70E-49 Log #25 Final Action: Reject
( Part 2, 2-1.3.3 )
________________________________________________________________
Submitter: Paul S. Case, Fluor Hanford, Inc.
Comment on Proposal No:70E-58
Recommendation: Delete text referring to incident energy levels other than
1.2 cal/cm2 as shown:
2-1.3.3.1 Flash Protection Boundary. The Flash Protection Boundary is at
a distance where the incident energy level equals 1.2 cal/cm2. For situations
where fault clearing time is 0.1 second (or faster), the flash protection
boundary is the distance at which the incident energy level equals 1.5 cal/
cm2. The Flash Protection Boundary shall be permitted to be permitted to be
determined by using one of the following methods:
Substantiation: People who need to be involved in performing flash hazard
analyses are already finding it difficult to sort through information, data,
methods of calculation, etc. Using multiple incident energy levels only adds
to the difficulty and does not appreciable affect the outcome of a flash hazard
analysis for low incident energy levels. Using 1.2 cal/cm2 as the threshold for
the Flash Protection Boundary provides a necessary safety cushion.
Committee Meeting Action: Reject
Committee Statement: The committee action on Comment 70E-51 deleted
the text referred by this comment. See committee action and statement on
Comment 70E-51.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-50 Log #43 Final Action: Reject
( Part 2, 2-1.3.3 )
________________________________________________________________
Submitter: Michael LaRoche Metheun, MA
Comment on Proposal No:70E-58
Recommendation: The committee should have accepted this proposal in
Part. The committee should have rejected the text in 2-1.3.3, 2-1.3.3.1, and 2-
1.3.3.2. The committee should accept new Table 2-1.3.3.2.
Substantiation: The committee should accept new Table 2-1.3.3.2. The
committee statement verifies that the table was added based on test experience.
Utilizing several different methods available today verifies that the distances in
this table provides safety for the user of the document.
The submitter did not provide a technical substantiation for the revisions to
2-1.3.3. The submitter did not provide a technical substantiation to modify
2-1.3.3.1. The existing text provides an acceptable method for calculating the
flash protection boundary. The existing note in 2-1.3.3.3 of the 2000 edition
refers the reader to the appendix for possible arc flash boundary solutions. It
is commonly known that there are several arc flash programs available today.
To write a requirement in the body of the document that permits only one of
these programs to be utilized does not seem proper. The user of the document
should use the formulas in the 2000 edition, use the annex as a guide, use one
of several arc flash programs available today, or use the default table that can
be verified through the users calculations. The IEEE P1584-2002 standard has
just been released and has not had adequate public review and track record to
be a requirement of this document.
Committee Meeting Action: Reject
Committee Statement: The committee action on Comment 70E-51 deleted
the text referred by this comment. See committee action and statement on
Comment 70E-51.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 23 Negative: 1
Vote Not Returned: 1 CLIFFDWELLER
Explanation of Negative:
HAMER: By rejecting this Comment, the Table 2-1.3.3.2 from Proposal
70E-58 disappears from the proposed document. The Committee Action
should have been Accept, retaining the content of proposed Table 2-1.3.3.2.
The text that will prevail as a result of this commentʼs rejection is shown in
the Committee Meeting Action on Comment 70E-47 (on Proposal 70E-55).
This text still establishes a Flash Protection Boundary of 4.0 ft based upon
the product of clearing times of 6 cycles (0.1 second) and available bolted
fault current of 50 kA or any combination not exceeding 300 kA cycles (5000
ampere seconds). This is clearly at variance with Appendix B-5.2 (arc in a
cubic box) which indicates 111 in. (~ 10 ft) for a 1.2 cal/cm2 Flash Protection
Boundary threshold for a 50 kA, 0.1 second duration fault.
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
Report on Comments — Copyright, NFPA
________________________________________________________________
70E-51 Log #53 Final Action: Reject
( Part 2, 2-1.3.3 )
________________________________________________________________
Submitter: Craig M. Wellman , Newark, DE
Comment on Proposal No:70E-58
Recommendation: Continue acceptance of Proposal 70E-58 as stated in the
ROP.
Substantiation: This comment is a response to some of the negative
comments in voting in the ROP.
1. IEEE 1584 has been peer reviewed by the 46 members of the P1584
Working Group and by the 48 members of the P1584 Ballot Group, a largely
different group. Five members or alternate members of the NFPA 70E
committee are members of the P1584 WG and ten members of the IEEE Power
Engineering Society are members of the P1584 WG. The guide was approved
by the IEEE SA board on Sept. 12, 2002. It has since been made available
for sale. IEEE has made downloadable copies available at no charge to all
members of the 70E Committee for study.
2. IEEE 1584 includes a discussion of its methods of calculating incident
energy and of other available methods.
3. One of the current calculation methods for flash protection boundary could
be retained. It would fit best in Appendix B. See my comment on Proposal
70E-157a.
Committee Meeting Action: Reject
Committee Statement: Proposal 70E-58 is based on data that was collected
from several different test locations and conditions. No information is provided
to enable the committee to verify the accuracy of the reverse calculation
process that was reportedly used to generate equations.
Information about instruments that were used to take measurements is not
reported. No calibration information is available for review by the committee.
Using the equations provided in IEEE Std. 1584 to back calculate data that
was used in the reverse calculation process does not correlate to the data
that was reported as measured quantities. The inability to achieve correlation
between these data points is disconcerting.
The committee is unable to verify that equations contained in IEEE Std. 1584
tell the complete story.
However, since IEEE Std. 1584 is a published consensus standard, the
technical committee elects to include the IEEE 1584 process as one method in
Appendix B. See comment 70E-132.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 22 Negative: 2
Vote Not Returned: 1 CLIFFDWELLER
Explanation of Negative:
ANDREWS: IEEE Standards Coordinating Committee No. 18, which
provides Direct Votes for the IEEE Representatives to the NFPA 70E
committee, objects to the negative implications relative to IEEE Standard 1584
in the committee Statement associated with Comment 70E-51. The following
responses are provided regarding the 70E Committeeʼs concerns.
The 70E Committee Statement says, “Proposal 70E-58 is based on data that
as collected from several different test locations and conditions.”
Response: Specialists in the field of test design and analysis strongly
recommend conducting tests in different laboratories to reduce the impact of
errors in testing that may occur at a single location.
The Statement says, “ No information is provided to enable the Committee to
verify the accuracy of the reverse calculation process that was reportedly used
to generate equations.”
Response: IEEE Standard 1584-2002 includes the test data in its auxiliary
files. This data is provided in spreadsheet format so that any interested
qualified statistician can easily copy the files into an analysis program and
duplicate the process used to generate the equations.
The Statement says, “Information about instruments that were used to take
measurements is not reported: No calibration information is available for
review by the Committee.”
Response: Modern laboratories do not include this information in their
test reports. The laboratories used met the requirements of UL and ASTM
Standards and invite compliance inspection by certification bodies.
As stated in Clause 8.1 of IEEE Standard 1584, several test programs that
provided data used in this Standard were documented in IEEE papers that
discussed the test setup in detail. Clause 8.2 states that the test method
ASTM F-1959-99, is the basis for the incident energy testing described in
this Standard. This clause further states, “It is intended by ASTM to enable
determination of the incident energy that clothing material can withstand...
The test methodology works equally well to determine the incident energy to
which a worker would be exposed in case of an arc in a specified electrical
installation. The results of the two types of tests are complimentary”, i.e.
much of the uncertainty over the accuracy of the test program is canceled by
applying the same test method and the same types of instruments to find both
the arc energy generated by a given application and the effect of arc energy
on garments. The Standard goes on to discuss the test instruments and setup
in some detail. The ASTM standard provides additional information. If
the Committee is not satisfied with the ASTM standard provides additional
information. If the Committee is not satisfied with the ASTM standardʼs
requirement, it should address those issues in the sections of NFPA 70E
addressing garment test standards.
The Statement says, “Using the equations provided in IEEE Standard 1584
70E-24
NFPA 70E
to back calculate data that was used in the reverse calculation process does not
correlate to the data that was reported as measured quantities. The inability to
achieve correlation between these data points if disconcerting.”
Response: First, the Committee fails to recognize that there is a lot of
variation in arc behavior. Arcs wander around and this causes variation in
incident energy. Clause 9.11.3 of the Standard discusses the correlation issue
and introduces a calculation factor to enable users to select the degree of
overprotection vs. underprotection appropriate for their applications. A table
shows how accurately the calculations for low voltage test points would protect
employees.
Second, IEEE Standard 1584 recognizes that correlation of the data is not as
good as everyone would like and intends to conduct further tests and update the
Standard in a second edition. The current edition of the Standard is not perfect,
but its empirically derived state of the art model is currently the best available
technology.
The Statement says, “The Committee is unable to verify that equations
contained in IEEE Standard 1584 tell the complete story.”
Response: It is not clear as to what the committee means by saying that they
are unable to verify that equations tell “the complete story”. NFPA Technical
Committees do not usually conduct studies to verify that equations or practices
in other standards tell the complete story. To our knowledge, there was no
Committee task group assigned to perform such verification relative to IEEE
Standard 1584.
One option considered and rejected by the IEEE 1584 Working Group was
to provide simpler conservative equations that recommend higher levels of
PPE. Instead it opted to provide as much accuracy as feasible, recognizing that
requiring more protection than needed can also create hazards for employees.
This increased the complexity of the equations. By using tools such as the
calculator provided with IEEE Standard 1584, or system analysis programs, the
complexity of the equations is reduced to a manageable level.
The Statement says, “However, since IEEE Standard 1584 is a published
consensus standard, the Technical Committee elects to include the IEEE 1584
process as one method in Appendix B.”
Response: It is prudent, and within the domain, of NFPA 70E to include
other methods of determining the arc-flash hazard and allowing users to apply
those methods.
In conclusion, IEEE Standard 1584 enables an arc flash hazard analysis on a
level of accuracy and breadth that has not been available before. The Standard
provides improved ability to comply with the NFPA 70E requirement that an
arc-flash hazard analysis be performed. As a result of the publication of IEEE
Standard 1584, there has been a surge in the efforts to conduct arc-flash hazard
analyses, as NFPA 70E requires.
TIEDE: As the Committee Statement clarifies, IEEE 1584 is a published
consensus standard that has been through public and peer review. It is a
comprehensive update of and improvement beyond information formerly
available on the topic of arc flash calculations. The output is based on many
test points and includes test points from earlier work on which earlier equations
were based. It is the best information available to the industry at this time. Its
acceptance would permit improvement of related information in NFPA 70E.
Comment on Affirmative:
BINGHAM: We support the action of the committee on Comment 70E-
51. However the Committee Statement for this item is negative regarding
the IEEE 1584 standard. Since we are including reference to IEEE 1584
within the NFPA 70E Appendix as one of several methods of hazard analysis
which can be used, it is inconsistent and a potential source of confusion to
provide this negative critique of IEEE 1584 within a Committee Statement. In
addition, since there was not a NFPA 70E task group established to conduct
an analysis of the validity of IEEE 1584 along with all of the other hazard
analysis approaches, it is inappropriate to single out potential issues with IEEE.
The Committee Statement very powerfully questions the use of IEEE 1584,
yet 1584 is referenced in the Appendix. If the committee feels this strong
regarding the usage of 1584, then why place a reference in the Appendix. Just
because it is an IEEE standard is not sufficient justification for inclusion.
DOERING: I support Binghamʼs comment.
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
JONES: The American Chemistry Council Electrical Codes and Standards
Task Group accepts the Committee Action but not the Committee Statement.
SAUNDERS: We support the Committee Action but make the following
comments with regard to the Committee comments supporting the action;
The 70E Committee Statement says, “Proposal 70E-58 is based on data that
was collected from several different test locations and conditions.”
Comment: Specialists in the field of test design and analysis strongly
recommend conducting tests in different laboratories to reduce the impact of
errors in testing that may occur at a single location.
The Statement says, “No information is provided to enable the Committee to
verify the accuracy of the reverse calculation process that was reportedly used
to generate equations.”
Comment: IEEE Standard 1584-2002 includes the test data in its auxiliary
files. This data is provided in spreadsheet format so that any interested
qualified statistician can easily copy the files into an analysis program and
duplicate the process used to generate the equations.
The Statement says, “Information about instruments that were used to take
measurements is not reported. No calibration information is available for
review by the Committee.”
Report on Comments — Copyright, NFPA
Comment: Modern laboratories do not include this information in their
test reports. The laboratories used met the requirements of UL and ASTM
Standards and invite compliance inspection by certification bodies.
As stated in clause 8.1 of IEEE Standard 1584, several test programs that
provided data used in this Standard were documented in IEEE papers that
discussed the test setup in detail. Clause 8.2 states that the test method,
ASTM F-1959-99, is the basis for the incident energy testing described in
this Standard. This clause further states, “It is intended by ASTM to enable
determination of the incident energy that clothing material can withstand...
The test methodology works equally well to determine the incident energy to
which a worker would be exposed in case of an arc in a specified electrical
installation. The results of the two types of tests are complimentary”, i.e.
much of the uncertainty over the accuracy of the test program is canceled by
applying the same test method and the same types of instruments to find both
the arc energy generated by a given application and the effect of arc energy on
garments.
The Standard goes on to discuss the test instruments and setup in some detail.
The ASTM standard provides additional information. If the Committee is not
satisfied with the ASTM standardʼs requirements, it should address those issues
in the sections of NFPA 70E addressing garment test standards.
The Statements says, “Using the equations provided in IEEE Standard 1584
to back calculate data that was used in the reverse calculation process does not
correlate to the data that was reported as measured quantities. The inability to
achieve correlation between these data points is disconcerting.”
Comment: First, the Committee fails to recognize that there is a lot of
variation in arc behavior. Arcs wander around and this causes variation in
incident energy. Clause 9.11.3 of the Standard discusses the correlation issue
and introduces a calculation factor to enable users to select the degree of
overprotection vs. underprotection appropriate for their applications. A table
shows how accurately the calculations for low voltage test points would protect
employees.
Second, IEEE Standard 1584 recognizes that correlation of the data is not as
good as everyone would like and intends to conduct further tests and update the
Standard in a second edition. The current edition of the Standard is not perfect,
but its empirically derived state of the art model is currently the best available
technology.
The Statement says, “The Committee is unable to verify that equations
contained in IEEE Std. 1584 tell the complete story.”
Comment: It is not clear as to what the Committee means by saying that they
are unable to verify that equations tell “the complete story.” NFPA technical
committees do not usually conduct studies to verify that equations or practices
in other standards tell the complete story. To our knowledge, there was no
Committee task group assigned to perform such verification relative to IEEE
Standard 1584.
One option considered and rejected by the IEEE 1584 Working Group was
to provide simpler conservative equations that recommend higher levels of
PPE. Instead it opted to provide as much accuracy as feasible, recognizing that
requiring more protection than needed can also create hazards for employees.
This increased the complexity of the equations. By using tools such as the
calculator provided with IEEE Standard 1584, or system analysis programs, the
complexity of the equations is reduced to a manageable level.
The Statement says, “However, since IEEE Std. 1584 is a published
consensus standard, the technical committee elects to include the IEEE 1584
process as one method in Appendix B.”
Comment: It is prudent, and within the domain, of NFPA 70E to include
other methods of determining arc-flash hazard and allowing users to apply
those methods.
In conclusion, IEEE Standard 1584 enables an arc flash hazard analysis on a
level of accuracy and breadth that has not been available before. The Standard
provides improved ability to comply with the NFPA 70E requirement that
an arc-flash analysis be performed. As a result of the publication of IEEE
Standard 1584, there has been a surge in the efforts to conduct arc-flash hazard
analyses, as NFPA 70E requires.
________________________________________________________________
70E-52 Log #87 Final Action: Reject
( Part 2, 2-1.3.3 )
________________________________________________________________
Submitter: Richard Piotrowski Wexford, PA
Comment on Proposal No:70E-58
Recommendation: Revise text as follows:
2-1.3.3 Flash Hazard Analysis. A flash hazard analysis shall be done
performed before a person approaches any exposed electrical conductor or
circuit part that has not been placed in an electrically safe work condition. The
Flash Hazard Analysis shall determine the flash protection boundary and the
personal protection equipment that people within the arc flash boundary must
use.
Note: For example methods of performing a flash hazard analysis, see
Appendix B-5.
2-1.3.3.1 Flash Protection Boundary. The flash protection boundary is the
distance at which where the incident energy level equals 1.2 cal/cm2. For
situations where the fault clearing time is 0.1 second (or faster), the flash
protection boundary is the distance at which the incident energy equals 1.5
cal/cm2. The flash protection boundary shall be permitted to be determined by
70E-25
NFPA 70E
using one of the following methods:
A. perform an analysis as described in IEEE standard 1584-2002 “Arc Flash
hazard Calculations.”
B. Perform an analysis as described in Appendix B of Part II
C. Apply table 2-1.3.3.2
Continue with the remainder of 2-1.3.3.1 unchanged.
2-1.3.3.2 Protective Clothing and Personal Protective equipment for
Application with a Flash Hazard Analysis. Where it has been determined
that work will be performed within the Flash Protection Boundary by 2-
1.3.3.1 of part II, the flash hazard analysis shall determine, and the employer
shall document, the incident energy exposure of the worker (in calories per
square centimeter). The incident energy exposure shall be based on the
working distance of the employeeʼs face and chest areas from a prospective
perspective arc source for the specific task to be performed. The incident
energy exposure shall be permitted to be determined by performing an analysis
and applying one of the methods described in IEEE standard 1584-2002 “Arc
Flash Hazard Calculations” or one of the methods in Appendix B-5 of Part II.
As an alternative to performing a detailed incident energy analysis, the PPE
requirements of 3-3.9 shall be permitted to be used in lieu o the detained flash
hazard analysis approach described in 2-1.3.3.1 of Part II. Flame Resistant
(FR) Clothing and Personal Protective Equipment (PPE) shall be used by the
employee based upon the incident energy exposure associated with the specific
task and shall meet the requirement of 3-3.8.
Note: For information on estimating the incident energy exposure on 600 volt
systems, see Appendix B-5 of Part II.
Substantiation: NFPA 70E should require an arc-flash analysis to be
performed as an integral part of the overall hazard/risk analysis without placing
restrictions on the process of performing the arc-flash analysis. Although arc-
flash injury is widely recognized and the need for minimize exposure to the
hazard, complete understanding of the mechanisms of arc-flash injury is not yet
available. The language accepted by the committee seems to limit available
choices about how to perform the analysis.
Committee Meeting Action: Reject
Committee Statement: The committee action on Comment 70E-51 deleted
the text referred by this comment. See committee action and statement on
Comment 70E-51.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-53 Log #122 Final Action: Accept in Principle
( Part 2, 2-1.3.3. )
________________________________________________________________
Submitter: Mary Capelli-Schellpfeffer, CapShell, Inc.
Comment on Proposal No:70E-58
Recommendation: I recommend deletion of references to IEEE Standard
1584.
Substantiation: 1. The suggested retail price of IEEE Standard 1584 as
of 9.27.02 was $595, or about 20 times more than NFPA 70E, making the
standard inaccessible financially.
2. The IEEE Standard 1584 calculations are based on data from staged
tests in high voltage labs. There has been no field testing of the lab results to
establish how closely they “fit” industrial conditions.
3. The IEEE Standard 1584 calculations performance (i.e., accuracy,
reliability, predictive power, consistency) have never been field tested.
Committee Meeting Action: Accept in Principle
Committee Statement: See committee action and statement on Comment
70E-51 which meets the intent of the submitter.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 23 Negative: 1
Vote Not Returned: 1 CLIFFDWELLER
Explanation of Negative:
HAMER: I do not agree with the basic premise of the Commentʼs
substantiation or with the Committee Statement. IEEE Std 1584-2002 was
developed by a consensus process and contains the best available methods for
arc flash calculation. The standard will improve as the amount of test data
increases and the standard is revised.
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
Report on Comments — Copyright, NFPA
________________________________________________________________
70E-54 Log #99 Final Action: Accept in Principle
( Part 2, 2-1.3.3.2 )
________________________________________________________________
Submitter: Allen H. Bingham, Bingham Consultants
Comment on Proposal No:70E-58
Recommendation: Revise text as follows:
2-1.3.3.2 Protective clothing and Personal Protective Equipment for
Application with a Flash Hazard Analysis. Where it has been determined that
work will be performed within the Flash Protection Boundary by 2-1.3.3.1
of Part II, the flash hazard analysis shall determine, and the employer shall
document, the incident and energy exposure of the worker (in calories per
square centimeter). This incident energy exposure level shall be based on the
working distance of the employeeʼs face and chest areas from a prospective
arc source for the specific task to be performed. The incident energy exposure
shall be permitted to be determined by performing an analysis and applying
one of the methods described in IEEE standard 1584-2002 “Arc Flash Hazard
Calculations” or one of the methods in Appendix C or Appendix D B-5 of Part
II. As an alternative to performing a detailed incident energy analysis, the PPE
requirements of 3-3.9 shall be permitted to be used in lieu of the detailed flash
hazard analysis approach described in 2-1.3.3.1 of Part II. Flame Resistant
(FR) Clothing and Personal Protective Equipment (PPE) shall be used by the
employee based upon the incident energy exposure associated with the specific
task and shall meet the requirements of 3-3.8.
Substantiation: Remove the reference to IEEE P1584 and place a
bibliographical reference in Appendix C and Appendix D for IEEE P1584.
Committee Meeting Action: Accept in Principle
Committee Statement: See committee action and statement on Comment
70E-51 which meets the intent of the submitter.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-55 Log #33 Final Action: Reject
( Part 2, 2-1.3.3.2 )
________________________________________________________________
Submitter: Edwin Scherry, PC&E
Comment on Proposal No:70E-58
Recommendation: Flash Boundary:
I have been working with an industrial plant electrical distribution system
with both medium and low voltage switchgear with power circuit breakers.
The low voltage system, below 600V, has fault current levels above 30kA and
the breakers do NOT have instantaneous trip settings but have trip and clear
time settings of the order of 0.35-sec. This combination yields 10,500A-sec,
well above the 5,000A-sec suggested limit for use of a 4-ft flash boundary.
It appears that the equation in Section 2-1.3.3.2: Dc = SQRT(2.65 x MVAbf x
t) provides results for an arc in air, and should be labeled as such. Using the
equation with the 1.25 multiplier, for transformers below 750KVA, results in
a flash boundary distance of 42-inches, less than 4-ft. How should the flash
boundary be calculated for arc in a box?
In comparing this result with access to a PRELIMINARY copy of the arc flash
calculator for IEEE-P1584 yielded a flash boundary result about twice the
NFPA-70E-2000 calculated value.
Also is there an equation for calculating the flash boundary for medium
voltage arc in a box?
Incident Energy:
In calculating the Incident Energy using arc in a box equation of NFPA-70E-
2000 from Appendix B Section B-5.2 with the same data as above yields 20.4
cal/cm2. In addition this equation also yields higher results when the fault
level is lowered when the breaker operating time increases. As example: the
same low voltage breaker above with a 22kA fault would take about twice as
long, 0.7-sec, to trip the circuit. However, although there is less current the
incident energy calculates to 29.5-cal/cm2, roughlt 1.5 times that previously
calculated.
Another example: If we add instantaneous to the above breaker at about 0.08-
sec and 30kA would yield 4.7cal/cm2 and an arc flash boundary of 20-inches.
Is there a set of circumstances that should be considered as most reasonable
in preparing a analysis of flash boundary and incident energy? Is the bolted
fault level and the breaker trip time either at the bolted fault or just below the
instantaneous set point most appropriate?
Is ther an available fault level where it is believed that the incident energy
would be below the 1.2cal/cm2 rating?
Again the PRELIMINARY IEEE-P1584 calculator yields a result of about
10cal/cm2 for 30kA at 0.35-sec.
Is there an equation for calculating the incident energy for medium voltage
devices?
Substantiation: I am interested in the methods providing results which agree
with each other, at least in principle. I am concerned because IEEE P1584 is
to be issued 10/2002 and preliminary comparisons between NFPA 70E and
IEEE P1584 have yielded significantly different flash boundary and incident
70E-26
NFPA 70E
energy values. Does the committee believe that one of the methods is better?
It is agreed that all methods provide results which indicate the need for the use
of appropriate PPE. However, is it not better to provide personnel with PPE
which is not as restrictive and thus allows for better movement, comfort, and
visibility?
Committee Meeting Action: Reject
Committee Statement: The commenters recommendation offers no specific
proposed text that the committee can address and therefore is in violation of
NFPA Regulations Section 4-4.5.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-56 Log #121 Final Action: Accept in Principle
( Part 2, 2-1.3.3.3 )
________________________________________________________________
Submitter: Mary Capelli-Schellpfeffer, CapShell, Inc.
Comment on Proposal No:70E-59
Recommendation: I strongly concur with the submitterʼs revised text. I
disagree with the Committee Action taken.
Substantiation: The committee too narrowly focuses on the Flash Protection
Boundary and use of PPE to prevent burns. “What parts of the body will
be within the flash Protection Boundary” can serve to initiate or ignite an
electrical arc flash. When breaching the boundary, a body part shortens the
space across which dielectric breakdown thru air may occur. Inclusion of
the submitterʼs revised text would increase recognition of the means of flash
prevention thru preserving spatial cushions.
Committee Meeting Action: Accept in Principle
Add the following words which amends the existing text to read as follows:
“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.”
Committee Statement: The revised text addresses the submitters intent. In
Section 2-1.3.3.3 this sentence will become the next to last sentence of the
existing 2000 edition of 70E.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 18 Negative: 6
Vote Not Returned: 1 CLIFFDWELLER
Explanation of Negative:
BINGHAM: The Committee Action should be hold. Adding the requirement
contained in the revised verbiage (“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).
The requirement to “wear additional PPE on parts of the body that are closer
than the distance at which the incident energy was determined” is vague.
During an arc exposure, the incident energy that strikes perpendicular to the
body is absorbed the most.
It is not known at this time what type of PPE will be required or even if PPE
is available for the exposure. This needs to be researched; until then we should
look at accident reports where workers were wearing the same amount of
PPE on both the torso and the arms and determine if the arms received greater
degree of burns.
Employers will not know how much additional PPE is required or that would
be protective. Getting employers to do flash hazard analysis at one distance
(the distance to the torso) will be a challenge. Determining how much
additional PPE is required for body parts such as hands that could be inside
that distance will be even more difficult. Flash hazard analysis is complicated
enough. We should allow employers to calculate the incident energy at one
distance and provide PPE for that exposure.
DOERING: The comments supporting the other negative votes convinced
me to change my vote.
HAMER: The Committee Meeting Action should be a “Fine Print Note”
rather than being stated as a requirement, since the added wording does not
define how much additional PPE is required and only provides information.
Suggest that such a note be added as follows (legislative text modifying the
Committee Meeting Action wording), placed after 2-1.3.3.3:
FPN: Recognizing that incident energy increases as the distance from the
arc flash decreases, additional PPE shall be used could be needed for any parts
of the body that are closer than the distance at which the incident energy was
determined.
POTTS: This is somewhat new material introduced into the standard
development cycle without adequate public review. Relevant documentation
needs to be submitted for study by committee before accepting or rejecting the
position. Moreover, significant new compliance requirements are introduced
here without revealing justification for inclusion. This issue should have been
placed on hold until the next standard review cycle.
Report on Comments — Copyright, NFPA
TIEDE: Although the wording change propose by the committee is in the
right direction for safety of the employee, implementation of it has not been
thought through. It does not appear to be enforceable. This change will
cause confusion that may result in unsafe practices. Handware does not exist
with a rating that will allow conformance to this new requirement, to our
understanding. Also, Part II, Table 3-3.9.1, does not address body parts closer
than the anticipated “working distance”. The wording could be interpreted to
mean that those who apply the table do not have to comply. As written, the
new wording does not clarify what degree of PPE satisfies it. A FPN clarifying
that body parts closer than the “working distance” are not protected against
third-degree burn would perhaps be more useful until a well thought through
set of rules can be established. We must all keep in mind that no one has been
burned when working on equipment that has been properly de-energized.
WILMER: EEI opposes the Committee Action. The Committee Action
should be to reject the comment which would eliminate the new requirement
that “additional PPE shall be used for any parts of the body that are closer than
the distance at which the incident energy was determined”. This requirement
is vague. Employers will not know how much additional PPE is required or is
protective. Getting employers to do flash hazard analysis at one distance (the
distance to the torso) will be a challenge. Determining how much additional
PPE is required for body parts such as hands that could be inside that distance
will be even more difficult. Flash hazard analysis is complicated enough. We
should allow employers to calculate the incident energy at one distance and
provide PPE for that exposure.
Comment on Affirmative:
CALLANAN: I agree with the action by the committee on this comment.
Clearly, parts of the body closer to the source of an arc flash than the distance
at which incident energy was determined should require additional protection.
This is crucial language to aid users of this standard in providing adequate
protection for workers exposed to the hazards associated with working on or
near energized electrical equipment.
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-57 Log #11 Final Action: Accept
( Part 2, 2-1.3.5 )
________________________________________________________________
Submitter: Ray A. Jones, Electrical Safety Consulting Services, Inc. / Rep.
ACC
Comment on Proposal No:70E-62
Recommendation: The committee action should have been “accept.”
Substantiation: The committee statement indicates that requirements have
been removed from the definition but does not reintroduce the requirements in
another place in the text. The need for the requirements remains and should be
inserted into the document as suggested by the proposal.
Committee Meeting Action: Accept
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-58 Log #105 Final Action: Accept
( Part 2, 2-1.3.5 )
________________________________________________________________
Submitter: David Soffrin, American Petroleum Institute
Comment on Proposal No:70E-62
Recommendation: Accept this proposal.
Substantiation: The reason given for rejection in the Committee Statement
does not address the substantiation of this proposal. By the action on Proposal
70E-3b, there is no longer a requirement in the definition of “limited approach
boundary” that covers unqualified persons. This proposed new section is
needed.
Committee Meeting Action: Accept
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-59 Log #47 Final Action: Accept
( Part 2, 2-1.3.5 )
________________________________________________________________
Submitter: Danny Liggett Newark, DE
Comment on Proposal No:70E-62
Recommendation: This proposal should be accepted as proposed.
70E-27
NFPA 70E
Substantiation: The Committee Statement is correct that the requirements
of an unqualified person entering the Limited Approach Boundary was in the
definitions in 70E-2000. Acceptance of proposal 70E-3b has now removed
this requirement. Acceptance of this proposal is necessary to maintain the
requirement as stated in the 70E-2000.
Committee Meeting Action: Accept
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-60 Log #52 Final Action: Reject
( Part 2, 2-1.3.5.1 )
________________________________________________________________
Submitter: Louis A. Barrios, Jr., Shell Global Solutions
Comment on Proposal No:70E-3b
Recommendation: Modify the existing text as follows:
Unqualified persons shall not be permitted to enter spaces that are required
under 1-8.2 of Section I-9 of Part I to be accessible to qualified employees
only the Limited Approach Boundary unless escorted by a qualified person or,
unless the electric conductors and equipment involved are in an electrically
safe work condition.
Substantiation: The committeeʼs acceptance of the new definition of
Limited Approach Boundary in proposal 70E-3b removed the requirement
that unqualified persons are not to cross the Limited Approach Boundary
unless escorted by a qualified person. This comment inserts the requirement
where it should be, in the body of the text. In the 2000 version of NFPA
70E, it was very clear that the Limited Approach Boundary was the point at
which qualified persons could continue working but unqualified persons had
to stop. The committeeʼs attempt to remove mandatory language from the
Limited, Restricted, and Prohibited Approach Boundary definitions have left
these definitions ambiguous. Even though this comment does not correct
the ambiguity of the definition, it reestablishes within the text the very clear
requirements that were once in the definition.
Committee Meeting Action: Reject
Committee Statement: The comment does not address text from Proposal
70E-3b. See Committee Action on Comments 70E-57 (Log #11), 70E-58 (Log
#105), and 70E-59 (Log #47) which accepts Proposal 70E-62.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-61 Log #24 Final Action: Reject
( Part 2, 2-1.3.6 )
________________________________________________________________
Submitter: Paul S. Case, Fluor Hanford, Inc.
Comment on Proposal No:70E-63
Recommendation: Modify proposed text as shown:
“2-1.3.6 energized Electrical Work Permit Authorization
2-1.3.6.1 If live parts are not placed in an electrically safe work condition
(i.e., for the reasons of increased or additional hazards or infeasibility per
Section 2-1.1.1), work to be performed shall be considered energized electrical
work and shall be performed by with written permit authorization only.
2-1.3.6.2 The Written authorization for energized electrical work permit shall
include, but not be limited to the following items:
a) A description of the circuit and equipment to be worked on and their
location
b) Justification for why the work must be performed in an energized
condition (2-1.1.1)
c) A description of the safe work practices to be employed (2-1.3..1)
d) Results of the Shock Hazard Analysis (2-1.3.2)
e) Determination of Shock Protection Boundaries (2-1.3.2.1 and Table 2-
1.3.4)
f) Results of the Flash Hazard Analysis (2-1.3.3)
g) The Flash Protection Boundary (2-1.3.3.1)
h) the necessary personal protective equipment to safely perform the assigned
task (2-1.3.3.2, 3-3.9 and Table 3-3.9.1)
i) means employed to restrict the access of unqualified persons from the area
(2-13.5.1)
j) Evidence of completion of a Job briefing, including a discussion of any job
specific hazards (2-3.1.6)
kc Energized Work Approval (Authorizing or responsible management,
safety officer, or owner, etc.) signature(s).
2-1.3.6.3 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 written authorization for energized
Report on Comments — Copyright, NFPA
electrical work permit provided appropriate safe work practices and personal
protective equipment in accordance with Part II is provided and used.
Note: For an example of an acceptable Energized Electrical Work Permit,
See Annex G of Part II.”
Substantiation: Many businesses may have effective means of controlling
energized work other than “permits.” We have used an energized electrical
work permit for more than eight years, but are now eliminating the requirement
for it. We already have a mature work control system that effectively
controls what, how, who, and where work is performed. That is sufficient for
management to provide written justification and authorization before releasing
work on or near live parts. Adding a new requirement for a “permit” would be
redundant and a step backwards for us.
Written authorization for energized work should be limited to a description
and location of the work, Justification for why the circuit or equipment cannot
be shut down, and a signature of responsible plant management accepting
responsibility for authorizing energized work. The other information listed is
already required as part of the hazard analyses (shock and flash hazard). We
use an electronic tool (Automated Job Hazard Analysis) to identify hazards
and determine safe work practices, PPE, etc. Adding that same information
on another form is unnecessary and would be overly burdensome to many
companies without adding any additional safety benefit for workers.
Committee Meeting Action: Reject
Committee Statement: The use of the word “authorization” in lieu of
“permit” does not add clarity or usefulness to this requirement. Regardless of
what an employer calls it, the provision established a basis for determining
when, where and under what condition energized work may be performed. The
Committee reaffirms its position that the list of items to be included on the
permit is not all inclusive but does contain those items that are already required
to comply with other provisions in NFPA 70E. It is not the intent of the
Committee, nor this provision to provide a specific permit form or format. That
is best left to the employer. There is nothing to preclude the use of electronic
forms or software as described in the substantiation to generate the permit.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-62 Log #30 Final Action: Reject
( Part 2, 2-1.3.6 )
________________________________________________________________
Submitter: Kathy Wilmer, Duke Power Co. / Rep. Edison Electric Institute
Comment on Proposal No:70E-63
Recommendation: Delete new paragraph 2-1.3.6.
Substantiation: Edison Electric Institute opposes the proposal to add a new
requirement for a detailed written permit for all energized work. The work
permit contains a long list of specific items that must be reviewed and checked
off prior to work. Management signature is required for all energized work.
This permit adds an unnecessary burden to employers who choose to work
on energized systems. Performing the items listed on the permit is already
required by the standard. Employers can ensure that those requirements are
achieved by a variety of means – procedures, work orders, pre-job briefings,
etc. The requirement for a specific, detailed written permit is burdensome and
unnecessary.
Committee Meeting Action: Reject
Committee Statement: The Committee reaffirms their acceptance of the
substantiation submitted with the original proposal position that stated the use
of a energized work permit “discourages or eliminates the need for performing
work while energized,or ensures all existing requirements are met prior to the
work being done,meeting the objective of protectingemployees from exposure
to electrical hazards is significantly improved. See Committee Action and
Statement on Comment 70E-61 (Log #24).
Number Eligible to Vote: 25
Ballot Results: Affirmative: 21 Negative: 3
Vote Not Returned: 1 CLIFFDWELLER
Explanation of Negative:
BINGHAM: The committee meeting action should have been accept.
The committeeʼs desire to use a written energized work permit to eliminate
energized work will not achieve the desired affect. Simply state that work is
not to be performed energized. The addition of this requirement to the standard
will not eliminate energized work and will not be performed. The addition of a
permit will create a paper work nightmare.
DOERING: Qualified electrical workers and their immediate supervisors
should be able to decide how to do a job. The introduction of a “Energized
Electrical Work Permit” appears to be an effort to make it so onerous to do
a job energized, based on the belief that such work presents an unacceptable
hazard, that every job will be done deenergized. Certainly companies that do
not have qualified electrical personnel may wish to institute such a procedure,
but it should not be a requirement. It is interesting to note that the committee
excludes testing, troubleshooting, voltage measuring, etc., from the need for a
“Energized Electrical Work Permit.” This falls under the category of “whose
ox is being gored.” They want their workers to do testing, etc., so they donʼt
70E-28
NFPA 70E
require a permit as a road block, but they donʼt want them to do energized
work, so they establish a permit road block. This is not to say that many, if not
most, jobs involving “inside wiring” are amenable to being worked energized
as there is not adequate clearances between phase to phase or phase to ground.
The committee members should vote negative on Comment 70E-62.
WILMER: EEI opposes the Committee Action. The Committee Action
should be to accept the comment which would delete new paragraph 2-1.3.6.
A new requirement for a detailed written permit for all energized work is a
burden to employers. Performing the items listed on the permit is already
required by the standard. Employers can ensure that those requirements are
achieved by a variety of means - procedures, work orders, pre-job briefings,
etc. This proposal arbitrarily requires a written permit even if employers have
other satisfactory means of ensuring that the requirements of the standard are
being met. This requirement is an unnecessary burden on employers.
Comment on Affirmative:
CALLANAN: I agree with the action by the committee on this comment
and the Panel Statement supporting the action. I do not feel that a permit
system “adds an unnecessary burden employers who chose to work on
energized systems” or “is burdensome and unnecessary” as suggested in
the substantiation. I do agree that the stated use of a energized work permit
“discourages or eliminates the need for performing work while energized, or
ensures all existing requirements are met prior to work being done...” as noted
in the Committee Statement.
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-63 Log #46 Final Action: Reject
( Part 2, 2-1.3.6 )
________________________________________________________________
Submitter: Danny Liggett Newark, DE
Comment on Proposal No:70E-63
Recommendation: Revise 2-1.3.6 as follows:
2-1.3.6.1 If live parts are not placed in an electrically safe work condition (i.e.
for the reasons of increased or additional hazards or infeasibility per Section
2.1.1.1). work to be Work performed inside the Restricted Approach Boundary
shall be considered energized electrical work and shall be performed by written
permit only.
Substantiation: I agree with the intent of this proposal but it may not be the
correct approach at this time. Transitioning from “no permitting” to permitting
every exposure may create an environment where people just go through the
motions of filling out the form versus trying to meet the intent of this section.
By concentrating on the tasks where the greater hazards existing may bring
more credibility to the process.
Committee Meeting Action: Reject
Committee Statement: The Comment would unduly restrict the need for a
written permit to work “inside the Restricted Approach Boundary” only. In
doing so, it limits the application, and thus the benefits, of the permit system
for those workers who are still working within the limited approach boundary
and may at risk. Section 2-1.3.6.3 provides the necessary relief from the permit
for tasks such as testing and troubleshooting provided the necessary safe work
practices and PPE are in place. The application of an energized work permit
applies to work on or near exposed energized electrical conductors or circuit
parts.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 23 Negative: 1
Vote Not Returned: 1 CLIFFDWELLER
Explanation of Negative:
POTTS: Agree with commenter that acceptance, training in, and usage of
permits would increase if initial focus was placed on high-risk exposures.
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-64 Log #54 Final Action: Reject
( Part 2, 2-1.3.6 )
________________________________________________________________
Submitter: Robert E. Downey, Allison Transmission
Comment on Proposal No:70E-63
Recommendation: The committeeʼs action on this proposal in regards to 2-
1.3.6.3 implies acceptance of the fact that troubleshooting is a different class
of work than other “hot” work. This idea was defeated by the committee in
Proposal 70E- . I agree that troubleshooting is/can be a less risky form of hot
work and can imply the need for less stringent PPE than other hot work.
Substantiation: Work PPE should be based on the degree of the risk that
exists. Too conservative can be as bad as too liberal of protection.
Committee Meeting Action: Reject
Report on Comments — Copyright, NFPA
Committee Statement: The commentors recommendation offers no specific
proposed text that the committee can address and therefore is in violation of
NFPA Regulations Section 4-4.5.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-65 Log #120 Final Action: Accept
( Part 2, 2-1.3.6 )
________________________________________________________________
Submitter: Mary Capelli-Schellpfeffer, CapShell, Inc.
Comment on Proposal No:70E-63
Recommendation: I strongly concur with the submitterʼs proposed text and
the Committee Action taken.
Substantiation: Energized electrical installations are hazardous. Electricity is
toxic to humans and can be characterized by a threshold limit, lethal dose (LD
50/100), permissible exposure limit (PEL), short term exposure limit (TLV-
STEL), flammable limit (explosive), flash point, and ignition temperature. In
addition, where current flows, energy transfer is possible. A permit to work
energized is a strategy that recognizes these features using an approach already
accepted in LO/TO and process management.
Committee Meeting Action: Accept
Number Eligible to Vote: 25
Ballot Results: Affirmative: 23 Negative: 1
Vote Not Returned: 1 CLIFFDWELLER
Explanation of Negative:
DOERING: See my negative comment on 70E-62 (Log #30), (70E-63).\
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-66 Log #12 Final Action: Accept in Principle
( Part 2, 2-3.4.2 )
________________________________________________________________
Submitter: Ray A. Jones, Electrical Safety Consulting Services, Inc. / Rep.
ACC
Comment on Proposal No:70E-72
Recommendation: The committee action should have been “accept in
principle.” The word “where” should be inserted as follows:
“...operating at 50 volts or more or where an electrical hazard exists.”
Substantiation: As written, the requirement is confusing. Adding the word
“where” makes a significant difference in understanding.
Committee Meeting Action: Accept in Principle
The Committee Action should have been “accept in principle.” The word
“where” should be inserted as follows:
“...operating at 50 volts or more, or where an electrical hazard exists.”
Committee Statement: The committee made grammatical correction to the
text.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-67 Log #90 Final Action: Reject
( Part 2, 2-3.5 )
________________________________________________________________
Submitter: Danny Liggett Newark, DE
Comment on Proposal No:70E-74
Recommendation: Revise text as follows:
2-3.5 Conductive Articles Being Worn. Conductive articles of jewelry and
clothing (such as watchbands, bracelets, rings, key chains, necklaces, metalized
aprons, cloth with conductive thread, metal headgear, or unrestrained metal
frame glasses) shall not be worn where they present an electrical contact hazard
with exposed live parts.
Substantiation: I agree with the committeeʼs intent on removing jewelry but
not on the metal frame glasses. The submitter has stated a problem inherent
with all safety and prescription glasses, plastic or metal frame. With this in
mind, the issue is not the glasses but the placement of the personʼs head. If
a person has placed their head in a position where contact with the glasses is
probable the glasses are not the problem, body positioning is. Issues of this
nature should be covered in the hazard analysis and appropriate action taken.
Restricting every electrician to only plastic frame glasses is not the answer to
the problem. Planning and utilizing the appropriate safe work practice is the
right approach.
70E-29
NFPA 70E
Committee Meeting Action: Reject
Committee Statement: The Committee reaffirms its position that the use of
plastic frame glasses is required where they present an electrical contact hazard
with live parts. The restraint of the metal frame glasses may alleviate a concern
from falling into energized parts but it does not remove the concern of metal in
direct contact with the skin in locations where electrical exposure is possible.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 23 Negative: 1
Vote Not Returned: 1 CLIFFDWELLER
Explanation of Negative:
DOERING: I support Mr. Liggettʼs substantiation. A worker wearing a hard
hat would very likely make contact with the hat before the glasses. Requiring
all plastic glasses will unnecessarily limit the glass selection to the person
wearing prescription glasses full time. Very few glasses come with all plastic
temples. The important thing is that they meet the ANSI Standard z87.1.
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-68 Log #104 Final Action: Accept
( Part 2, 2-3.6.2 )
________________________________________________________________
Submitter: David Soffrin, American Petroleum Institute
Comment on Proposal No:70E-76
Recommendation: The action should be “Accept in Principle.”
Do not add the phrase “...operating at 50 volts or more” to the existing
wording. Add “exposed” before “live parts.”
Substantiation: The proposal should be “Accepted in Principle” because the
table referred to in 2-3.6.2 (Table 2-1.3.4) does not specify any requirements
for voltages less than 50 volts. The “in principle” is justified because
“exposed” should be added before “live parts” in the proposal to reflect the
defnition change for “live parts.”
Committee Meeting Action: Accept
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-69 Log #103 Final Action: Accept
( Part 2, 2-3.7 )
________________________________________________________________
Submitter: David Soffrin, American Petroleum Institute
Comment on Proposal No:70E-77
Recommendation: The action should be “Accept in Principle.”
Do not add the phrase “... operating at 50 volts or more” to the existing
wording of the text and the NOTE. Add “exposed” before “live parts” in the
text and in the NOTE.
Substantiation: The proposal should be “Accepted in Principle” because the
term “limited approach boundary” referred to in 2-3.7 (see Table 2-1.3.4) does
not specify any boundaries for voltages less than 50 volts. The “in principle” is
justified because “exposed” should be added before “live parts” in the proposed
version of the text and Note to reflect the definition change for “live parts.”
Committee Meeting Action: Accept
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-70 Log #110 Final Action: Reject
( Part 1, 2-6.3.7.1 and 2.6.3.7.2 )
________________________________________________________________
Submitter: David Soffrin, American Petroleum Institute
Comment on Proposal No:70E-24
Recommendation: Revise as follows:
API supports the affirmative comment by Mr. Hamer. Delete the two
paragraphs, as worded in the proposal, and replace with:
“2-6.3.7 Portable and Vehicle-Mounted Generators. The frames of portable or
vehicle-mounted generators shall be grounded.
Substantiation: Grounding portable or vehicle-mounted generators according
to the present wording can result in a shock hazard. For example, the neutrals
on most 240/120 volt, single-phase, portable generators are bonded directly to
the metal frame of the generator. An incident could occur with cord-and-plug
connected equipment connected to the generator output. The “hot” conductor
could become connected or faulted to “plant” ground (either through cord
Report on Comments — Copyright, NFPA
abuse, or a tool dropped water). The output circuit breaker of the generator
would not trip and provide no ground-fault-protection, since no current would
flow. During this situation, the entire frame of the generator would be raised to
a potential of 120 volts with respect to ground (since the frame is not required
to be grounded). This would represent a shock hazard to a person who came
along and touched anything bonded to the generatorʼs frame (since the person
would create a path through the body between the frame to ground). Only if
a GFCI were applied to the generatorʼs receptacle (as required in 210.8 of the
2002 NEC) would any personnel protection be provided, but the person would
still be shocked. GFCI protection is not required if the generator receptacle is
other than 125 volt, single-phase, 15-, 20-, and 30- ampere (see 527.6(B) of
the 2002 NEC) - the “assured equipment grounding conductor program” is an
option, but this would not provide protection from the shock hazard described
above. For example, this would be the case for a 480 volt, three-phase portable
or vehicle-mounted generator.
This situation could be eliminated by always assuring that the frame of a
portable or vehicle-mounted generator is required to be grounded (usually to
nearby structural steel or a local ground grid).
Sections 250.34(A) (portable generators) and 250.34(B) (vehicle-mounted
generators) of the 2002 NEC should both be replaced by the proposed wording.
API will be submitting such a proposal for the 2005 NEC. In the meantime,
the change should be incorporated in NFPA 70E to avoid a safety hazard.
Committee Meeting Action: Reject
Committee Statement: The requirement in Section 2-6.3.7 comes directly
from Article 250 of the NEC. The proposed new last sentence does not provide
any direction as to how to accomplish the grounding nor does it provide
applications for grounding portable and vehicle-mounted generators.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 23 Negative: 1
Vote Not Returned: 1 CLIFFDWELLER
Explanation of Negative:
HAMER: I do not agree that the Committee Meeting Action should be
“reject.” The TCC should monitor the action of NEC CMP 5 on the API
proposal on NEC Section 250.24 (A) and (B). A safety hazard exists if the text
of 2-6.3.7 remains as is.
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-71 Log #62 Final Action: Accept
( Part 2, 3-3.5 )
________________________________________________________________
Submitter: Robert E. Downey, Allison Transmission
Comment on Proposal No:70E-91
Recommendation: The TCC made a note regarding this proposal which we
believe was reconciled by the Committeeʼs action on Proposal 70E-58.
Substantiation: Information for the Committee.
Committee Meeting Action: Accept
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-72 Log #3 Final Action: Accept
( Part 2, 3-3.5 )
________________________________________________________________
Submitter: National Electrical Code Technical Correlating Committee
Comment on Proposal No:70E-91
Recommendation: The Technical Correlating Committee directs the
committee to consider the comments contained in Ms. Wilmerʼs affirmative
comment on vote and address the issue of conflicting requirements.
Substantiation: No technical substantation is provided
Committee Meeting Action: Accept
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-73 Log #36 Final Action: Reject
( Part 2, 3-3.5 )
________________________________________________________________
Submitter: Kevin J. Lippert, Eaton/Cutler-Hammer
Comment on Proposal No:70E-91
Recommendation: The proposed new Exception: “For incident-energy
exposures 2 cal/cm2, and below, employees may wear non-melting clothing
described in Hazard/Risk Category 0 in Table 220.6(B)(9)(C).” should not be
added. Neither should the last sentence of the FPN “Non-melting, flammable
70E-30
NFPA 70E
clothing, used alone, can provide protection at low incident energy levels (2
cal/cm2, and below).”
Substantiation: This change qualifies “flammable materials” for use up to 2
cal/cm2. This essentially permits a 2 cal/cm2 arc rating, which is contradictory
to the proposed statement from 70E-104 that these “materials have no arc
rating.” In the substation to 70E-104, the same submitter acknowledges that arc
ignition is possible at 2 cal/cm2 and below. Knowing this, it would not seem
prudent for this Standard to specify their use for that application. This portion
of the proposed new information should not be accepted.
Committee Meeting Action: Reject
Committee Statement: See Committee Action and Statement on Comment
70E-74 (Log #23). The fabrics desribed have been indicated in IEEE paper
PCIC 97-35 as providing sufficient protection under the conditions indicated in
the text.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 23 Negative: 1
Vote Not Returned: 1 CLIFFDWELLER
Explanation of Negative:
CALLANAN: I am concerned that the substantiation of the submitter stating
that “this change qualifies “flammable materials” for use up to 2 cal/cm2” and
that “the ...submitter acknowledges that arc ignition is possible at 2 cal/cm2
and below” has gone unchallenged.
Therefore, I must agree with the submitter of this comment that “it would not
seem prudent for this standard to specify their use for that application”.
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-74 Log #23 Final Action: Accept in Principle
in Part
( Part 2, 3-3.5 )
________________________________________________________________
Submitter: Paul S. Case, Fluor Hanford, Inc.
Comment on Proposal No:70E-91
Recommendation: Delete text referring to incident energy levels other than
1.2 cal/cm2 as shown:
“Body Protection. Employees shall wear FR clothing wherever there is
possible exposure to an electric arc flash above the threshold incident energy
level for a second-degree burn (1.2 cal/cm2 for fault clearing times exceeding
0.1 second, or 1.5 cal/cm2 for fault clearing times 0.1 second or faster.)
Exception: For incident energy exposures 2 cal/cm2, and below, employees
may wear non-melting clothing described in Hazard/Risk Category 0 in Table
3-3.9.3.
Note: Such clothing can be provided as shirt and trousers, or as coveralls,
or as a combination of jacket and trousers, or, for increased protection, as
coveralls with jacket and trousers. Various weight fabrics are available.
Generally, the higher degree of protection is provided by heavier weight fabrics
and by layering combinations of one or more layers of FR clothing. In some
cases one or more layers of FR clothing are worn over flammable, non-melting
clothing. Non-melting, flammable clothing, used alone, can provide protection
at low incident energy levels (2 cal/cm2, and below)”
Substantiation: People who need to be involved in performing flash hazard
analyses are already finding it difficult to sort through information, data,
method of calculation, etc. Using multiple incident energy levels only adds
to the difficulty and does not appreciably affect the outcome for protective
clothing at low incident energy levels. Using 1.2 cal/cm2 as the threshold for
requiring FR clothing provides a necessary safety cushion considering the
unpredictability of electric arc flash, the multiple variables that are involved,
and that the arc rating of FR clothing is generally based on a 50 percent chance
of ignition at the rated incident energy level.
Committee Meeting Action: Accept in Principle in Part
Delete text referring to incident energy levels other than 1.2 cal/cm2 as shown:
“Body Protection. Employees shall wear FR clothing wherever there is
possible exposure to an electric arc flash above the threshold incident energy
level for a second-degree burn (1.2 cal/cm2 for fault clearing times exceeding
0.1 second, or 1.5 cal/cm2 for fault clearing times 0.1 second or faster.)
Exception: For incident energy exposures 2 cal/cm2, and below, employees
may wear non-melting clothing described in Hazard/Risk Category 0 in Table
3-3.9.3.
Note: Such clothing could be provided as shirt and trousers, or as coveralls,
or as a combination of jacket and trousers, or, for increased protection, as
coveralls with jacket and trousers. Various weight fabrics are available.
Generally, the higher degree of protection is provided by heavier weight
fabrics and by layering combinations of one or more layers of FR clothing. In
some cases one or more layers of FR clothing are worn over flammable, non-
melting clothing. Non-melting, flammable clothing, used alone, could provide
protection at low incident energy levels (2 cal/cm2, and below).”
Committee Statement: The committee believes that eliminating fault clearing
times is necessary to avoid conflicts. The committee believes the last sentence
in the note and the exception is valuable information and should not be deleted.
The committee believes the commentors substantiation contains information
that is in error. The committee modified the text in the note to comply with the
NEC Style manual.
Report on Comments — Copyright, NFPA
Number Eligible to Vote: 25
Ballot Results: Affirmative: 22 Negative: 2
Vote Not Returned: 1 CLIFFDWELLER
Explanation of Negative:
DOERING: See my negative comment on 70E-13 (Log #81). The
committeeʼs action would more properly read as follows:
Body Protection. Employees shall wear FR clothing whenever there is
possible exposure to an electric arc flash about the threshold incident energy
level of 4.6 cal/cm2 for non-melting clothing, for a second degree burn (1.2
cal/cm2.)
Exception: For incident energy exposures 4.6 cal/cm2 2 cal/cm2, and below,
employees may wear non-melting clothing described in Hazard/Risk category
0 in Table 3-3.9.3.
FPN: Such clothing can be provided as shirts and trousers, or as coveralls,
or as a combination of jacket and trousers, or, for increased protection, as
coveralls with jacket and trousers. Various weight fabrics are available.
Generally, the higher degree of protection is provided by heavier weight fabrics
and by layering combinations of one or more layers of FR clothing. In some
cases one or more layers of FR clothing are worn over flammable, non-melting
clothing. Non-melting, flammable clothing, used alone, can provide protection
at low incident energy levels 4.6 cal/cm2, and below. 2 cal/cm2 and below).
The committee in their statement supporting their action on 70E-107,
referenced fabric information from IEEE Paper PCIC 97-35. This paper also
provides information on cotton fabric ignitability from tests determined per the
ASTM Provisional Arc Text Method PS57. For the lightest cotton material, 5.2
opsy Twill, Blue, Shirt Material, they published the following:
For 1 percent probability of ignition the mean was 5.0 cal/cm2, and the lower
95 percent confidence level for a given set of data points was 3.0 cal/cm2.
For 10 percent probability of ignition the mean was 5.7 cal/cm2, and the
lower 95 percent confidence level for a given set of data points was 4.6 cal/
cm2.
4.6 cal/cm2 has been used by OSHA in a prerelease document as the ignition
threshold for cotton based on IEEE Paper No. PCIC-97-35. This same value
was used in a paper published in IEEE Transactions on Power Delivery, Vol 16,
No. 3. July 2001, Estimating the Ignition hazard of 100 Percent Cotton Worn
by Transmission and Distribution Line Workers. Both of these papers have
been peer reviewed.
The committee members should vote negative on Comment 70E-74, and
support the use of 4.6 cal/cm2 as the trigger for requiring FR clothing, and for
determining the base flash Protection Boundary.
POTTS: Statement includes references to responsibilities related to second-
degree burn. See previous response on Comment 70E-11.
Comment on Affirmative:
CALLANAN: I agree that the Committee Action deleting the 1.5 cal/
cm2 level of FR clothing meets the goals of the submitter and committee
in that it both enhances worker safety as well increases usability. I do not
necessarily agree with the portion of the Panel Statement where it is stated
that “eliminating fault clearing times is necessary to avoid conflicts.” To
the contrary, I believe that fault clearing times are crucial components in
determining necessary personal protection.
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-75 Log #119 Final Action: Accept
( Part 2, 3-3.5 )
________________________________________________________________
Submitter: Mary Capelli-Schellpfeffer, CapShell, Inc.
Comment on Proposal No:70E-91
Recommendation: I endorse the Committee Action on Proposal 70E-91.
Substantiation: The “whenʼs” and “whereʼs” of FR clothing are well
established. FR clothing use is warranted whenever and whereever ignition
sources would or could expose a worker to combustion of their apparel. How
much FR clothing (i.e., layers or amounts of protection) to recommend for
use is changing as the technology of engineered natural and synthetic fibers
advances. Just as NFPA 471, 10.1-10.7 outlines medical considerations, NFPA
70E may need to do so as well.
Committee Meeting Action: Accept
Number Eligible to Vote: 25
Ballot Results: Affirmative: 23 Negative: 1
Vote Not Returned: 1 CLIFFDWELLER
Explanation of Negative:
DOERING: I disagree with the Committee Action on Proposal 70E-91. See
my negative comment on Comment 70E-74 (Log #23).
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
70E-31
NFPA 70E
________________________________________________________________
70E-76 Log #130 Final Action: Accept in Principle
( Part 2, Table 3-3.8 )
________________________________________________________________
Submitter: Thomas E. Neal, Neal Associates Ltd.
Comment on Proposal No:70E-96
Recommendation: For the entry in Part 2, Table 3-3.8 regarding:
ASTM F1506-00 change to F1505-02 and for ASTM F1891-01 change to
F1891-02a.
Substantiation: During the NFPA 70E revision process, more recent editions
have been issued for ASTM F1506 and F1891. The change in the issue date
references these more recent ASTM editions.
Committee Meeting Action: Accept in Principle
For the entry in Part 2, Table 3-3.8 regarding:
“ASTM F1506-00” change to “ASTM F1506-02a” and for “ASTM F1891-
01” change to “ASTM F1891-02a”.
Committee Statement: The committee made modifications to the text to
reflect the correct reference.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-77 Log #80 Final Action: Accept
( Part 2, Table 3-3.9.1 )
________________________________________________________________
Submitter: Michael I. Callanan, IBEW
Comment on Proposal No:70E-98
Recommendation: The Committee should reject this proposal.
Substantiation: As stated in my negative vote, this proposal and the several
related companion proposals highlights a dangerous trend towards “bigger
and better PPE.” I believe the effort is misguided because it fails to address
the many other serious hazards and risks that a worker may be exposed to
when they perform work at these energy levels. Even if the PPE is suitably
rated for the available incident energy levels that may be available, the PPE is
not designed nor intended to provide adequate protection beyond the thermal
effects of the arc or blast. As data becomes available, I believe Tables 3-3.9.1
and 3-3.9.2 should be modified and adapted to indicate when certain tasks
simply cannot be worked in an energized condition. This will result in greater
worker safety.
Committee Meeting Action: Accept
Committee Statement: The committee understands by this action Table 3-
3.9.1 will appear as it shows in the 2000 edition of 70E.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 23 Abstain: 1
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
DOERING: Proposal 70E-98 included the results of a risk/hazard
evaluation, considering probability, for typical tasks, but the committee was not
willing to accept the result of the analysis as it reduced the risk category using
standard risk analysis procedures. While I disagree with this logic, I agree
with Committee Action, as it essentially continues to use the 2000 Edition
table, which will allow for more study of the concept of recognizing reduced
probability as part of the risk/hazard analysis.
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
TIEDE: Accepting this comment is appropriate since it allows the standard
to move ahead. However, this action ignores the technical reality that there
are installations at which the incident energy is above values associated with
Hazard Category 4. Table 3-3.9.1 does not acknowledge that fact as it appears.
Workers should be made aware of the potentially higher value installations.
Also, as the commentor mentions, there may be certain tasks that should not be
done with equipment energized, especially when very high incident energy is
available.
Explanatin of Abstention:
HAMER: The table of Proposal 70E-98 could have been modified to
eliminate the new Hazard/ Risk Category 5 (100 cal/cm2) - the subject of this
Comment - by action on other Comments. Retaining the 2000 Edition of Table
3-3.9.1 will require an immediate Tentative Interim Amendment, because there
are a number of entries that exist in the present table that may not protect a
worker adequately. I plan to submit TIAs related to this point.
Report on Comments — Copyright, NFPA
________________________________________________________________
70E-78 Log #68 Final Action: Reject
( Part 2, Table 3-3.9.1 )
________________________________________________________________
TCC Action NOTE: Since the ballot on this Comment did not confirm the
Committee Action, the Comment is being rejected.
Submitter: Paul S. Hamer, Chevron Texaco Energy Research and
Technology Company
Comment on Proposal No:70E-98
Recommendation: Revise the table as follows as shown on the following
pages.
These revisions are proposed due to the newly-issued IEEE Std 1584-2002,
IEEE Guide for Performing Arc-Flash Hazard Calculations, which the latest
information available for calculating arc-flash energy.
Substantiation: When the proposal was submitted, the only equations
available were those from the existing NFPA 70E-2000, Appendix B-5, and
those originating from the Lee equations. The equations from B-5 introduce
serious errors when applied outside the applicable range of 16 to 50 kA, which
was done for the original proposal. As part of this substantiation, see the
attached modified “Appendix G” table from 70E-151 and the corresponding
IEEE Std 1584 calculation spreadsheet. Following is a summary of the
principal changes:
• Panelboards rated 240 V and below – All HRCs become “0” due to lower
calculated energies using IEEE 1584
• Panelboards or Switchboards rated >240 V and up to 600 V – Maximum
current reduced to 24 kA to stay within HRC 2.
• 600 V Class Motor Control Centers (MCCs) and Busways – Allowable
fault levels revised to correspond to the upper limits of HRC 4 and 5 with
common upstream 600 V clearing times of 0.33, 0.2, and 0.1 second.
• 600 V Class Switchgear – Allowable fault levels revised to correspond to
the upper limits of HRC 4 and 5 with common 600 V CB clearing times of 0.5,
0.33, 0.2, and 0.1 second
• Other 600 V Class (277 V through 600 V, nominal) Equipment – One
HRC level changed. Allowable fault levels revised to correspond to the upper
limits of HRC 4 with common 600 V CB clearing times of 0.5, 0.33, 0.2, and
0.1 second.
• NEMA E2 (fused contactor) Motor Starters – Three HRC levels changed.
Allowable fault levels changed to 14 kA correspond to the upper limits of HRC
2.
• Metal Clad Switchgear – One proposed HRC change, but more background
levels given in the modified “Appendix G”
• Other Equipment 1 kV to 38 kV – Three HRC levels adjusted due to
calculation refinements, but more background guidance given in the modified
“Appendix G”
The word “exposed” should also be added before “live parts” in all places
where it appears in the proposed table to reflect the definition change for “live
parts.” Other minor wording changes are required to accomplish this.
Committee Meeting Action: Reject
Committee Statement: IEEE Std. 1584-02 represents only one method to
calculate incident energy. The committee recognizes that there are other
methods to calculate incident energy, and concludes that comment 70E-78
expresses a preference for IEEE 1584 that may not yet be fully warranted
based on the level of field experience with the standard.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 23 Abstain: 1
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
CALLANAN: I agree with the action by the committee to reject this
comment. Clearly it new information. The submitter of this comment
substantiates this in the recommendation for this comment. Here it is stated
that “These revisions are proposed due to newly issued IEEE Std 1584-
2002...”. The substantiation continues by stating that “When the proposal
was submitted, the only equations available were those from existing NFPA
70E-2000, Appendix B-5, and those originating from the Lee equations.”
The Committee recognized this and took the correct action in rejecting this
comment. I also agree with the panel statement rejecting this comment in
that it addresses crucial issues as to why the committee took the correct action
in rejecting this comment. The worst case scenario was not built into the
proposed table in this comment. The 70E Committee has not determined
that one method of calculation is the “preferred” or “more correct” method,
but rather that there are alternative calculation methods. Having a table not
build on worst case scenario values of recognized calculations does not seem
responsible. The submitter and committee spent a great deal of time and effort
with the original proposal and this comment at both ROC meetings.
70E-32
NFPA 70E
Clearly, the committee was unable to reach a solid consensus on how the table
should appear and what should be included. I strongly believe that the most
prudent action at this time is to revert back to Table 3-3.9.1 as it appears in the
NFPA 70E-2000 as the committee voted to do in its action on this comment.
I understand that there are some concerns with the table as it appears in the
NFPA 70E-2000 and believe those can best be addressed by a TIA if they are
deemed to be emergency in nature.
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
Explanatin of Abstention:
HAMER: Rejecting this Comment and retaining the 2000 Edition of Table
3-3.9.1 will require an immediate Tentative Interim Amendment, because there
are a number of entries that exist in the present table that may not protect a
worker adequately. I plan to submit TIAs related to this point. See also my
abstention comment on Comment 70E-77.
________________________________________________________________
70E-79 Log #91 Final Action: Reject
( Part 2, Table 3-3.9.1, Note 7 )
________________________________________________________________
Submitter: Danny Liggett Newark, DE
Comment on Proposal No:70E-98
Recommendation: Revise Note 7 as follows:
7. These tasks are very hazardous. A job safety analysis is required to
with strong justification justify that for this task be done with the equipment
energized. These tasks shall be done by permit only. (See Part 2, 2-1.3.6)
Substantiation: I agree with Mr. Callananʼs comments concerning the degree
of hazard associated with HRC 5 tasks. Unless an Arc Flash analysis is done
there is a great deal of unknown associated with these tasks. The panel should
be driving employers to performing the arc flash analysis. Limiting the higher
hazard tasks will help do this.
Committee Meeting Action: Reject
Committee Statement: See Committee Statement on Comment 70E-77.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
CALLANAN: I agree with the Committee Action not to delete Note 2 as
recommended by the submitter of this comment,m and to delete the reference
to HRC 5. I believe there is information contained in this note that provides
insight to the user of this document regarding the intention of the PPE
requirements of this section. However, I feel that submitter of this comment
alerts us to some significant issues that need to be addressed. Unfortunately
the proposed words to make this note more technically correct and create a
better understanding of the intention and limitations of the PPE requirements of
this section is not provided in the recommendation.
DOERING: By action of Comment 70E-77, these two comments were
rejected, but not because the proposals were faulty, but for other reasons.
Quoting from Binghamʼs negative, “I agree that there needs to be an upper
incident energy exposure limit for a worker. Should the limit be 30, 60, 90,
or 120 ca;/cm2? 70E requires the user to perform a hazard assessment to
determine the magnitude of the incident energy exposure. It places no limit
on that exposure. However as an alternate, Table 3-3.9.1 may be used if the
workplace exposure conditions are within the limits stated in the table. The
modification of Note 7 states that you cannot do the task while the circuit is
energized. This places the two requirements for the same set of conditions,
which is wrong.”
More on this when we discuss Table 3-3.9.3, in conjunction with Proposal
70E-104.
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
Report on Comments — Copyright, NFPA NFPA 70E

Table 3-3.9.1 Hazard Risk Category Classifications

Task (Assumes Equipment Is Energized, and Work Hazard/ Risk V-rated V-rated
Is Done Within the Flash Protection Boundary) Category Gloves Tools

Panelboards rated 240 V and below – Notes 1 and 3 — — —

Operate circuit breaker (CB) or fused switch with covers on 0 N N

Operate CB or fused switch with covers off 0 N N

Work on exposed live parts, including voltage testing 10 Y* Y

Remove/install CBs or fused switches 10 Y Y

Remove bolted covers (to expose uncover exposed live parts) 10 N N

Open hinged covers (to expose uncover exposed live parts) 0 N N

Work on exposed live parts of utilization equipment fed directly by a branch circuit 10 Y* Y
of the panelboard

Panelboards or Switchboards rated >240 V and up to 600 V (with molded case — — —

or insulated case circuit breakers or fused switches) — Notes 1 and 3 (Except
as indicated)

Operate CB or fused switch with covers on 0 N N

Operate CB or fused switch with covers off 1 N N

Work on exposed live parts, including voltage testing (maximum of 36 24 kA for 2 Y Y

0.1 sec, main bus exposure)

Work on exposed live parts of utilization equipment fed directly by a branch circuit 1 Y Y
of the panelboard or switchboard

600 V Class Motor Control Centers (MCCs) and Busways – Notes 2 (except as — — —
indicated) and 3

Operate CB or fused switch or starter with enclosure doors closed 0 N N

Read a panel meter while operating a meter switch 0 N N

Operate CB or fused switch or starter with enclosure doors open 2 N N

Diagnostic testing, including voltage testing -- Note 5 2 Y Y

Work on exposed live parts within starters on the load side of the starter or on the 2 Y Y
load side of a busway switchʼs short circuit protective device. Includes voltage
testing -- Note 5

Work on exposed live parts on the main MCC bus (maximum of 42 36 kA for 0.33 4 Y Y
sec, 52 60 kA for 0.2 sec, or 65 120 kA for 0.1 sec) -- Note 4

Work on exposed live parts on the main MCC bus (maximum of 62 92 kA for 0.33 5 Y Y
sec, 76 150 kA for 0.2 sec, or 102 200 kA for 0.1 sec) -- Note 4 Note 7

70E-33
Report on Comments — Copyright, NFPA NFPA 70E

Table 3-3.9.1 Hazard Risk Category Classification (continued)

Work on control circuits while working near exposed live parts 120 V or below 0 Y* Y

Work on control circuits while working near exposed live parts >120 V 2 Y Y

Insert or remove individual starter “buckets” from MCC, or plug-in devices from 4 Y N
busway (maximum of 42 36 kA for 0.33 sec, 52 60 kA for 0.2 sec, or 65 120 kA
for 0.1 sec) -- Note 4

Insert or remove individual starter “buckets” from MCC, or plug-in devices from 5 Y N
busway (maximum of 62 92 kA for 0.33 sec, 76 150 kA for 0.2 sec, or 102 200 kA Note 7
for 0.1 sec) -- Note 4

Apply safety grounds, after voltage test 2 Y N

Remove bolted covers (to expose uncover exposed live parts) 4 N N

Open hinged covers (to expose uncover exposed live parts) 2 N N

Work on exposed live parts of utilization equipment fed directly by a branch circuit 2 Y Y
of the MCC or busway

600 V Class Switchgear (with power circuit breakers or fused switches) — — —

— Note 6

Operate CB or fused switch with enclosure doors closed 0 N N

Read a panel meter while operating a meter switch 0 N N

Operate CB with enclosure doors open 2 N N

Operate fused switch with enclosure doors open 5 N N

Note 7

Work on exposed live parts, (maximum of 35 26 kA for 0.5 sec, 42 40 kA for 0.33 4 Y Y
sec, 52 67 kA for 0.2 sec, or 65 135 kA for 0.1 sec) -- Note 4

Work on exposed live parts, (maximum of 68 kA for 0.5 sec, 62 104 kA for 0.33 5 Y Y
sec, 76 175 kA for 0.2 sec, or 102 200 kA for 0.1 sec) -- Note 4 (Note 6 does not Note 7
apply)

Diagnostic testing, including voltage testing -- Note 5 2 Y Y

Work on control circuits while working near exposed live parts 120 V or below 0 Y* Y

Work on control circuits while working near exposed live parts >120 V-- Note 5 2 Y Y

70E-34
Report on Comments — Copyright, NFPA NFPA 70E

Table 3-3.9.1 Hazard Risk Category Classifications (continued)

Insert or remove (rack) CBs from cubicles, doors open or closed (maximum of 35 4 N N
26 kA for 0.5 sec, 42 40 kA for 0.33 sec, 52 67 kA for 0.2 sec, or 65 135 kA for 0.1
sec) -- Note 4

Insert or remove (rack) CBs from cubicles, doors open or closed (maximum of 68 5 N N
kA for 0.5 sec, 62 104 kA for 0.33 sec, 76 175 kA for 0.2 sec, or 102 200 kA for
0.1 sec) -- Note 4 (Note 6 does not apply)

Apply safety grounds, after voltage test 2 Y N

Remove bolted covers (to expose uncover exposed live parts) 4 N N

Open hinged covers (to expose uncover exposed live parts) 2 N N

Work on exposed live parts of utilization equipment fed directly by a feeder circuit 2 Y Y
of the switchgear with instantaneous fault protection

Other 600 V Class (277 V through 600 V, nominal) Equipment — — —

Lighting or small power transformers (600 V, maximum) — — —

-- Remove bolted covers (to expose uncover exposed live parts) 32 N N

-- Open hinged covers (to expose uncover exposed live parts) 1 N N

-- Work on exposed live parts (maximum short circuit at primary 4 Y Y

voltage of 35 24 kA for 0.5 sec, 42 36 kA for 0.33 sec, 52 60 kA for 0.2
sec, or 65 120 kA for 0.1 sec) -- Note 4

-- Diagnostic testing, including voltage testing -- Note 5 2 Y Y

-- Apply safety grounds, after voltage test 2 Y N

Insert or remove revenue meters (kW-hour, at primary voltage and current) 2 Y N

Insert or remove revenue meters (kW-hour, at primary voltage and current) -- 1 Y N

Applicable to 240 volt, single-phase services

Remove or install auxiliary gutter or wireway cover, with no exposure hazard of 1 N N

exposed live parts

Remove or install miscellaneous equipment cover, with no exposure hazard of 1 N N

exposed live parts

Work on exposed live parts, including voltage testing (maximum of 35 24 kA for 4 Y Y

0.5 sec, 42 36 kA for 0.33 sec, 52 60 kA for 0.2 sec, or 65 120 kA for 0.1 sec) -
- Note 4

Diagnostic testing, including voltage testing -- Note 5 2 Y Y

70E-35
Report on Comments — Copyright, NFPA NFPA 70E

Table 3-3.9.1 Hazard Risk Category Classifications (continued)

Apply safety grounds, after voltage test 2 Y N

NEMA E2 (fused contactor) Motor Starters, 2.3 kV through 7.2 kV — — —

Operate contactor with enclosure doors closed 0 N N

Read a panel meter while operating a meter switch 0 N N

Operate contactor with enclosure doors open 2 N N

Diagnostic testing, including voltage testing 2 Y Y

Work on exposed live parts 3 Y Y

Work on control circuits while working near exposed live parts 120 V or below 0 Y* Y

Work on control circuits while working near exposed live parts >120 V 3 Y Y

Insert or remove (rack) starters from cubicles, doors open or closed --maximum 54 N N
upstream fault and clearing time 55 kA for 0.35 sec Note 8

Insert or remove (rack) starters from cubicles, doors open or closed -- maximum 42 N N
upstream fault and clearing time 25 14 kA for 0.35 sec Note 8

Apply safety grounds, after voltage test 2 Y N

Remove bolted covers (to expose uncover exposed live parts) 4 to 5 N N

Note 7

Open hinged covers (to expose uncover exposed live parts) 2 N N

Work on exposed live parts of utilization equipment (e.g., motor or transformer) 1 Y Y

fed directly from the starter

Metal Clad Switchgear, 1 kV to 38 kV — — —

Operate CB or fused switch with enclosure doors closed 2 N N

Note 8
Read a panel meter while operating a meter switch 0 N N

Operate CB or fused switch with enclosure doors open 4 to 5 N N

Note 7

Work on energized exposed live parts, including voltage testing -- Note 5 4 to 5 Y Y

Work on control circuits while working near exposed live parts 120 V or below 0 Y* Y

Work on control circuits while working near exposed live parts >120 V 4 to 5 Y Y
Note 7

Insert or remove (rack) CBs from cubicles, doors open or closed 5 N N

Note 8

70E-36
Report on Comments — Copyright, NFPA NFPA 70E

Table 3-3.9.1 Hazard Risk Category Classifications (continued)

Apply safety grounds, after voltage test 2 Y N

Remove of bolted covers (to expose uncover exposed live parts) 4 to 5 N N

Note 7

Open hinged covers (to expose uncover exposed live parts) 2 N N

Open voltage transformer or control power transformer compartments 5 N N

Work on exposed live parts of utilization equipment (e.g., motor or transformer) 42 Y Y

fed directly from a feeder circuit breaker -- up to and including 15 kV Class
equipment

Other Equipment 1 kV to 38 kV — — —

Metal enclosed load interrupter switches, fused or unfused — — —

-- Operate switch, doors closed 2 N N

Note 8

--Work on energized exposed live parts, including voltage testing 4 3 to 5 Y Y

-- Remove bolted covers - up to and including 15 kV Class equipment 4 to 5 3 N N

(to expose uncover exposed live bare, energized parts) Note 7

-- Open hinged covers (to expose uncover exposed live bare, energized 3 N N
parts)

Operate outdoor disconnect switch (hookstick operated) 3 Y Y

Operate outdoor disconnect switch operation (gang-operated, from grade) 2 Y N

Examine insulated cable, in manhole or other confined space 4 Y N

Note 7

Examine insulated cable, in open area 2 Y N

Legend:
V-rated Gloves are gloves rated and tested for the maximum line-to-line voltage upon which work will be done.
V-rated Tools are tools rated and tested for the maximum line-to-line voltage upon which work will be done.

Y* See Part II, 3-3.6 for required use of rubber insulating gloves
Y = yes (required)
N = no (not required)
Notes:
1. 42 kA short circuit current available, 0.03 second (2 cycle) fault clearing time.
2. 65 kA short circuit current available, 0.03 second (2 cycle) fault clearing time.
3. For < 10 kA short circuit current available, the Hazard/Risk Category required may be reduced by one
Number.
4. The listed fault current and upstream protective device clearing times are based on an 18-inch working distance
5. Hazard/Risk Category takes into account the provision of Part II, 3-3.9.4.6 (interference). During the listed diagnostic
testing, there is 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 on exposed live parts, as with tools. A job safety analysis may indicate that a higher category of PPE is required.
6. For < 25 kA short circuit current available, the Hazard/Risk Category required may be reduced by one
Number.
7. A job safety analysis is required to justify that this task be done with the equipment energized.
8. 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.

70E-37
Report on Comments — Copyright, NFPA NFPA 70E
________________________________________________________________ Number Eligible to Vote: 25
70E-80 Log #70 Final Action: Accept in Principle Ballot Results: Affirmative: 24
( Part 2, Table 3-3.9.1 ) Vote Not Returned: 1 CLIFFDWELLER
________________________________________________________________ Comment on Affirmative:
Submitter: Vincent J. Saporita, Cooper Bussmann DOERING: See my comment on Comment 70E-79 (Log #91).
Comment on Proposal No:70E-99 JACKSON: See my Affirmative with Comment on Comment 70E-1
Recommendation: Add a new “Note 1” as follows, after the first paragraph: (Log #2).
“Both larger and smaller available short circuit currents can result in higher TIEDE: See my comment on public comment 70E-77 (Log #80).
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- 70E-82 Log #100 Final Action: Accept
flash energies may also increase.” Existing “Note” should then become “Note ( Part 2, Table 3-3.9.1 )
2”. ________________________________________________________________
Substantiation: This comment alerts the user that Table 3-3.9.1 is based Submitter: Allen H. Bingham, Bingham Consultants
upon specific values of available short-circuit current and opening times. Comment on Proposal No:70E-96
Specifically, many users do not realize that lower available short-circuit Recommendation: Add a new ASTM test method for determining the arc
currents can also raise the available arc-flash energy, because the opening time rating of eye and face materials as follows:
of the overcurrent protective device may be increased.
Committee Meeting Action: Accept in Principle Table 3-3.8 Standards on Protective Equipment
Insert new note 1 after the text to 3-3.9.1 as follows: Subject Number and Title
“Both larger and smaller available short circuit currents could result in higher
available arc-flash energies. If the available short circuit current increases Head protection ANSI Z89.1, Requirements for Protective
without a decrease in the opening time of the overcurrent protective device, the Headwear for Industrial Workers, 1997
arc-flash energy will increase. If the available short-circuit current decreases,
resulting in a longer opening time for the overcurrent protective device, arc- Eye and face protection ANSI Z87.1, Practice for Occupational and
flash energies could also increase.” Existing “Note” should then become “Note Educational Eye and Face Protection, 1989
2”.
Gloves ASTM D 120-9502, Standard Specification
Committee Statement: The committee understands that this note is to be
inserted after the text 3-3.9.1. Existing note becomes note 2. The comittee for Rubber Insulating Gloves, 1995 2002
made editorial modifications to comply with the NEC Style manual. The Sleeves ASTM D 1051-9502, Standard Specification
committee action on this comment modifies the action taken on Proposal 70E- for Rubber Insulating Sleeves, 1995 2002
99.
Number Eligible to Vote: 25 Gloves and sleeves ASTM F 496-9702, Standard Specification
Ballot Results: Affirmative: 24 for In-Service Care of Insulating Gloves and
Vote Not Returned: 1 CLIFFDWELLER Sleeves, 1997 2002
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log Leather protectors ASTM F 696-9702, Standard Specification
#2). for Leather Protectors for Rubber Insulating
TIEDE: This added note is accurate and needed. However, it introduces a Gloves and Mittens, 1997 2002
conflict with existing notes 3 and 6, which imply that the hazard category may
be reduce with lower short circuit current. Footwear ASTM F 1117-9398, Standard Specification
for Dielectric Overshoe Footwear, 1993
________________________________________________________________ 1998
70E-81 Log #13 Final Action: Reject
( Part 2, Table 3-3.9.1 ) ANSI Z41, Standard for Personnel
________________________________________________________________ Protection, Protective Footwear, 1991
Submitter: Ray A. Jones, Electrical Safety Consulting Services, Inc. / Rep.
ACC Visual inspection ASTM F 1236-9601, Standard Guide for
Comment on Proposal No:70E-98 Visual Inspection of Electrical Protective
Recommendation: The committee action should have been “accept in part.” Rubber Products, 1996 2001
The committee should not accept that protective clothing could mitigate the Apparel ASTM F 1506-0002a, Standard
risk of injury for category 5 exposures. No work tasks that require HRC 5
protective clothing for thermal protection should be executed while the circuit Performance Specification for Textile
is energized and Table 3-3.9.1 should so indicate. Materials for Protective Wearing Apparel for
The table should be revised such that in the table accepted by the committee, Use by Electrical Workers When Exposed
all instances where hazard/risk category 5 is indicated, all information in all to Momentary Electric Arc and Related
columns except the first two should be removed. The term “Note 7” should Thermal Hazards, 19982002a
replace the information that is removed. Note 7 should be revised to read as
follows:
7. A job safety analysis is required to justify that this task be done with the Rainwear ASTM F 1891-0102a, Standard
equipment energized. Specification for Arc and Flame Resistant
7. The degree of hazard and risk is too great for this task to be performed Rainwear, 2002a
while the circuit is energized. This task must be performed only with the
equipment in an electrically safe work condition. (Add)
Substantiation: The committee action suggests that protective clothing can Face Protective Products F2178-02, Standard Test Method for
reduce the risk of injury to an acceptable level where exposure is as high as Determining the Arc Rating of Face
100 cal/cm2. That fact has not been established. Thermal testing as defined in Protective Products, 2002
ASTM standards can determine the thermally protective characteristics. No
tests have been established regarding the blast effects of such an arcing fault;
consequently, the table does not consider hazards associated with arc blast.
It is likely that the blast effects associated with an arc of this magnitude
would injure a worker regardless of the protection from thermal hazards. In
fact, the protective clothing would increase the surface area that would be Substantiation: Use the correct standard and dates for all ASTM standards
exposed to the pressure forces associated with the arc. At the same time, the shown in Table 3-3.8.
physical constraints associated with the clothing would tend to increase the Committee Meeting Action: Accept
likelihood of accidentally initiating an arc. Number Eligible to Vote: 25
Committee Meeting Action: Reject Ballot Results: Affirmative: 24
Committee Statement: See Committee Action and Statement on Comment Vote Not Returned: 1 CLIFFDWELLER
70E-77. Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).

70E-38
Report on Comments — Copyright, NFPA
________________________________________________________________
70E-83 Log #72 Final Action: Reject
( Part 2, Table 3-3.9.1 )
________________________________________________________________
Submitter: Vincent J. Saporita, Cooper Bussmann
Comment on Proposal No:70E-98
Recommendation: Change Table 3-3.9.1 to the following as shown on the
following pages.
Substantiation: Change Table 3-3.9.1 from 4 columns to 8 columns as shown
above. Add column designators “A” through “H” to make it easier to refer
to various columns. Column “B” is necessary so that the user knows the
boundaries (available short circuit current and opening time) within which the
table was developed. The explanation for Columns “C” and “D” is shown in
the notes to the table and the results are based upon the short circuit currents
and durations shown in Column “B”. The Hazard/Risk category of Column
“E” is based upon the larger of either Columns “C” or “D” and is based solely
upon the incident energy and not upon the probability of occurrence. Hazard/
risk categories are based upon Proposal 70E-104. Hazard/risk category 0
is based upon 2 Cal/cm2. Hazard/risk category 1 is based upon 4 Cal/cm2.
Hazard/risk category 2 is based upon 8 Cal/cm2. Hazard/risk category 3 is
based upon 25 Cal/cm2. Hazard/risk category 4 is based upon 40 Cal/cm2.
Hazard/risk category 5 is based upon 100 Cal/cm2. The odds of an incident
occurring must not determine the ATPV rating that an individual wears.
This document must not suggest the use of PPE with ATPV ratings that are
insufficient for the available incident energy, regardless of the odds of an
incident occurring. Column “F” is being left as a reference but is no longer
being used to determine the Hazard/risk category. Columns “G” and “H”
remain unchanged.
Notes 1 and 2 and Legend are unchanged.
Note 3 was changed because, in actuality, available short circuit currents
below 10kA can cause increased arc energies, the same way that larger
available short circuit currents can cause increased arc energies. So, the
reduction in fault current does not necessarily reduce the Hazard/risk category.
Note 4 currently states that fault currents and clearing times are based upon
an 18 inch working distance. However, fault currents and clearing times are
not dependent upon working distance. Therefor Note 4 was changed to alert
the user that variations in fault current and clearing time can result in variations
in arc energies. For example 9kA at 1.0 seconds results in 27.8 Cal/cm2,
whereas 65kA for 2 cycles results in 6.3 Cal/cm2.
Note 5 was changed to accommodate the exclusion of the risk assessment
from the hazard/risk category.
Note 6 was deleted. See substantiation for Note 3.
Note 7 was changed to Note 6. Note 6 was added throughout the table
whenever Hazard/Risk Category 5 was indicated.
Note 8 changed to Note 7.
Table for medium voltage metal clad switchgear and for other medium
voltage equipment was split into two parts, one for 1-15kV and one for greater
than 15 kV to 38 kV.
Committee Meeting Action: Reject
Committee Statement: See Committee Action and Statement on Comment
70E-77.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-84 Log #102 Final Action: Reject
( Part 2, Table 3-3.9.1 )
________________________________________________________________
Submitter: David Soffrin, American Petroleum Institute
Comment on Proposal No:70E-98
Recommendation: Accept the wording as described in Mr. Hamerʼs
affirmative comment.
Substantiation: Changes are required to reflect the definition change for “live
parts.”
Committee Meeting Action: Reject
Committee Statement: The committee did not accept Proposal 70E-98. See
committee action and statement on Comment 70E-77 and Comment 70E-78.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-85 Log #74 Final Action: Accept in Principle
in Part
( Part 2, Tables 3-3.9.1 and 3-3.9.2 )
________________________________________________________________
Submitter: Michael I. Callanan, IBEW
Comment on Proposal No:70E-99
70E-39
NFPA 70E
Recommendation: This proposal should be rejected.
Substantiation: As stated in my negative vote, this proposal and the several
related companion proposals highlights a dangerous trend towards “bigger
and better PPE.” I believe the effort is misguided because it fails to address
the many other serious hazards and risks that a worker may be exposed to
when they perform work at these energy levels. Even if the PPE is suitably
rated for the avaiable incident energy levels that may be available, the PPE is
not designed nor intended to provide adequate protection beyond the thermal
effects of the arc or blast. As data becomes available, I believe Tables 3-3.9.1
and 3-3.9.2 should be modified and adapted to indicate when certain tasks
simply cannot be worked in an energized condition. This will result in greater
worker safety.
Committee Meeting Action: Accept in Principle in Part
Change the reference of category 5 to category 4 in Section 3-3.9.2 of the
committee action of Proposal 70E-99.
Committee Statement: The committee understand that text in this comment
was further modified by the action in Comment 70E-80. The committee does
not accept the rejection of Proposal 70E -99 in its entirety.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
DOERING: See my comment on Comments 70E-79 (Log #79) and 70E-81
(Log #13).
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-86 Log #101 Final Action: Accept in Principle
( Part 2, 3-3.9.1 and 3.3.9.2 )
________________________________________________________________
Submitter: David Soffrin, American Petroleum Institute
Comment on Proposal No:70E-99
Recommendation: Editorial - correct the following under “Committee
Action,” since there are still inaccuracies compared to the original proposal:
1. In the second sentence of 3-3.9.1, delete “to” that appears before “of”.
2. In the third sentence of 3-3.9.1, delete “for” that appears before “with”.
3. In the first sentence of 3-3.9.2, change “3-3.9.2.2” to “3-3.9.2.
Substantiation: See below for correct text:
3-3.9.1. Personal Protective Equipment Required for Various Tools. When
selected in lieu of the Flash Hazard Analysis of 2-1.3.3.3 of Part II, Table
3-3.9.1 of Part II shall be used to determine the Hazard/Risk Category for a
task. The assumed short circuit capacities and fault clearing times for various
tasks are listed in the text and notes to of Table 3-3.9.1 of Part II. For tasks
not listed, or for power systems of with greater than the assumed short circuit
current capacity or for with longer than the assumed fault clearing times, a
flash hazard analysis is required in accordance with 2-1.3.3 of Part II.
Note: Energized parts that operate at less than 50 volts are not required to be
de-energized to satisfy an “electrically safe work condition.” Consideration
should be given to the capacity of the source, any overcurrent protection
between the energy source and the worker, and whether the work task related
to the source operating at less than 50 volts increases exposure to electrical
burns or to explosion from an electric arc.
3-3.9.2 Protective Clothing and Personal Protective Equipment Matrix.
Once the Hazard/Risk Category has been identified, Table 3-3.9.2.2 3-3.9.2
shall be used to determine the required personal protective equipment (PPE)
for the task. Table 3-3.9.2 lists the requirements for protective clothing and
other protective equipment based on Hazard/Risk Category numers 0-5. This
clothing and equipment shall be used when working on or near energized
equipment within the Flash Protection Boundary.
Note 1: See Appendix F of Part II for a suggested simplified approach to
assure adequate PPE for electrical workers within facilities with large and
diverse electrical systems.
Note 2: The PPE requirements of this section are intended to protect a person
from arc-flash and shock hazards. While some situations may result in burns to
the skin, even with the protection described in Table 3-3.9.2, burn injury should
be reduced and survivable. Due to the explosive effect of some arc events,
physical trauma injuries may occur. The PPE requirements of this section do
not provide protection against physical trauma.
Committee Meeting Action: Accept in Principle
Make the following editorial corrections:
1. In the second sentence of 3-3.9.1, delete “of” that appears before “to”.
2. In the third sentence of 3-3.9.1, delete “of” before the word “with” and the
“for “ that appears before “with”.
3. In the first sentence of 3-3.9.2, change “3-3.9.2.2” to “3-3.9.2.
Committee Statement: The committee has made editorial corrections to the
accepted text in Section 3-3.9.1 and 3-3.9.2.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
Report on Comments — Copyright, NFPA NFPA 70E

Column “A” Task Column “B” Column “C” Column “D” Column “E” Column “F” Risk Column Column
(Assumes Equipment Is Energized, ASSUMED SC ARC ARC Hazard / Risk Assessment “G” V- “H” V-
and Work Is Done Within the Flash CURRENT AND ENERGY ENERGY Category^ Rated Rated
Protection Boundary) DURATION^ HAZARD^ HAZARD^ Gloves Tools
(cal/cm2) (cal/cm2)
Panelboards rated 240V and below ____________ ________ ________ ________ __________ ______ _____
-Notes 1 and 3
Operate circuit breaker(CB) or fused 42kA@2 cycles 3.8 2 1 risk extremely N N
switch with covers on low

Operate CB or fused switch with 42kA@2 cycles 3.8 2 1 risk very low N N
covers off

Work on live parts, including voltage 42kA@2 cycles 3.8 2 1 risk moderate Y* Y
testing
Remove/install CBs or fused 42kA@2 cycles 3.8 2 1 risk moderate Y Y
switches
Remove bolted covers (to expose 42kA@2 cycles 3.8 2 1 risk moderate N N
live parts)
Open hinged covers (to expose live 42kA@2 cycles 3.8 2 1 risk extremely N N
parts) low with hinges
Work on live parts of utilization 42kA@2 cycles 3.8 2 1 risk moderate Y* Y
equipment fed directly by a branch
circuit of the panelboard
Panelboards or Switchboards rated _____________ ________ ________ ______ ________ ______ _____
>240V and up to 600V (with molded
case or insulated case circuit breakers
or fused switches) -- Notes 1 and 3
(except as indicated)
Operate CB or fused switch with 36kA@0.1 sec (line- 8.2 11.88 3 risk extremely N N
covers on side exposure) low

Operate CB or fused switch with 36kA@0.1 sec (line- 8.2 11.88 3 risk low N N
covers off side exposure)

Work on live parts, including voltage 36kA@0.1 sec (line- 8.2 11.88 3 risk moderate Y Y
testing (main bus exposure) side exposure)

Work on live parts of utilization 42 kA@2 cycles 3.8 2 1 risk moderate Y Y

equipment fed directly by a branch
circuit of the panelboard or switch-
board
600V Class Motor Control Centers _____________ ________ ________ ______ ________ ______ _____
(MCCs) and Busways --Notes 2
(except as indicated) and 3
Operate CB or fused switch or starter 65kA@1 to 2 cycles N/A 4 to 8 2 risk extremely N N
with enclosure doors closed low

Read a panel meter while operating a 65kA@1 to 2 cycles N/A 4 to 8 2 risk extremely N N
meter switch low

Operate CB or fused switch or starter 65kA@1 to 2 cycles N/A 4 to 8 2 risk moderate N N

with enclosure doors open

70E-40
Report on Comments — Copyright, NFPA NFPA 70E

Diagnostic testing, including voltage 65kA@0.2 sec N/A 43 5-Note 6 risk very low Y Y
testing -- Note 5
Work on live parts within starters on 65kA@0.5 to 2 cycles N/A 2 to 8 2 risk moderate Y Y
the load side of the starter or on the
load side of a busway switchʼs short
circuit protective device. Includes
voltage testing -- Note 5
Work on live parts on the main MCC 42kA@0.33 sec 40 N/A 46 35 5-Note 6 risky Y Y
bus -- Note 4 52kA@0.2 sec N/A 22 4 3
65kA@0.1 sec
Work on live parts on the main MCC 62kA@0.33 sec N/A 68 50 5-Note risky Y Y
bus -- Note 4 76kA@0.2 sec N/A N/A 35 6 5-Note
102kA@0.1 sec 6 4
Work on control circuits while work- 10kA@1 to 2 cycles N/A 1.2 0 risk extremely Y Y
ing near exposed live parts 120V or low
below
Work on control circuits while work- 65kA@0.5 to 2 cycles N/A 2 to 8 2 risk moderate Y Y
ing near exposed live parts >120V

Insert or remove individual starter 42kA@0.33 sec 40 N/A 46 35 5-Note 6 risky Y N

“buckets” from MCC, or plug-in 52kA@0.2 sec N/A 22 4 3
devices from busway --- Note 4 65kA@0.1 sec
Insert or remove individual starter 62kA@0.33 sec N/A 68 50 5-Note risky Y N
“buckets” from MCC, or plug-in 76kA@0.2 sec N/A N/A 35 6 5-Note
devices from busway --- Note 4 102kA@0.1 sec 6 4
Apply safety grounds, after voltage See above N/A See Above See Above risk extremely Y N
test low
Remove bolted covers (to expose See above N/A See Above See Above risk low N N
live parts)
Open hinged covers (to expose live See above N/A See Above See Above risk extremely N N
parts) low
Work on live parts of utilization 65kA@0.5 to 2 cycles N/A 2 to 8 2 risk moderate Y Y
equipment fed directly by a branch
circuit of the MCC or busway
600V Class Switchgear (with power _____________ ________ ________ ______ ________ ______ _____
circuit breakers or fused switches)
--- Note 3
Operate CB or fused switch with 52kA@0.5 sec N/ 77 60 5-Note risk extremely N N
enclosure doors closed 62kA@0.33 sec A N/ 45 30 6 5-Note low
76kA@0.2 sec A N/A 6 5-Note
102kA@0.1 sec N/A 6 4
Read a panel meter while operating a 10kA@1 to 2 cycles N/A 1.2 0 risk extremely N N
meter switch low

Operate CB or fused switch with 52kA@0.5 sec N/ 77 60 5-Note risk moderate N N

enclosure doors open 62kA@0.33 sec A N/ 45 30 6 5-Note
76kA@0.2 sec A N/A 6 5-Note
102kA@0.1 sec N/A 6 4
Work on live parts --- Note 4 35kA@0.5 sec 40 40 52 42 5-Note risk moderate Y Y
42kA@0.33 sec N/A N/A 31 20 6 5-Note 6
52kA@0.2 sec 4 3
65kA@0.1 sec
Work on live parts --- Note 4 52kA@0.5 sec N/ 77 60 5-Note risk moderate Y Y
62kA@0.33 sec A N/ 45 30 6 5-Note
76kA@0.2 sec A N/A 6 5-Note
102kA@0.1 sec N/A 6 4
Diagnostic testing, including voltage Wide Range N/A Wide Range 5 risk very low Y Y
testing -- Note 5
Work on control circuits while work- 10kA@1 to 2 cycles N/A 1.2 0 risk extremely Y* Y
ing near exposed live parts 120V or low
below
Work on control circuits while work- Wide Range N/A Wide Range 5-Note 6 risk very low Y Y
ing near exposed live parts >120V
--Note 5

70E-41
Report on Comments — Copyright, NFPA NFPA 70E

Insert or remove (rack) CBs from 35kA @ 0.5 sec 40 40 52 42 5-Note risk moderate N N
cubicles, doors open or closed --- 42kA@0.33 sec 52kA N/A N/A 31 20 6 5-Note 6
Note 4 @ 0.2 sec 65kA @ 4 3
0.1 sec
Insert or remove (rack) CBs from 52kA@0.5 sec N/ 77 60 5-Note risk moderate N N
cubicles, doors open or closed --- 62kA@0.33 sec A N/ 45 30 6 5-Note
Note 4 76kA@0.2 sec A N/A 6 5-Note
102kA@0.1 sec N/A 6 4
Apply safety grounds, after voltage See above N/A See Above See Above risk extremely Y N
test low
Remove bolted covers (to expose See above N/A See Above See Above risk low N N
live parts)
Open hinged covers (to expose live See above N/A See Above See Above risk extremely N N
parts) low
Work on live parts of utilization 50kA@2 cycles 6 5 2 risk moderate Y Y
equipment fed directly by a feeder
circuit of the switchgear with instan-
taneous fault protection
Other 600V Class Equipment (277V _____________ ________ ________ ______ ________ ______ _____
through 600V, nominal) Equipment
Lighting or small power transformers _____________ ________ ________ ______ ________ ______ _____
(600V maximum)
Remove bolted covers (to expose 65kA@0.1 sec N/A 20 3 risk low N N
live parts)
Open hinged covers (to expose live 65kA@0.1 sec N/A 20 3 risk extremely N N
parts) low
Work on live parts --- Note 4 35kA@0.5 sec 40 40 52 42 5-Note risk moderate Y Y
42kA@0.33 sec N/A N/A 31 20 6 5-Note 6
52kA@0.2 sec 4 3
65kA@0.1 sec
Diagnostic testing, including voltage Wide Range N/A Wide Range 5-Note 6 risk very low Y Y
testing -- Note 5
Apply safety grounds, after voltage See above N/A See Above See Above risk extremely Y N
test low

Insert or remove revenue meters 50kA@0.5 sec, open 42 >100 5-Note 6 risk very low Y N
(kW-hour, at primary voltage and air arc
current)
Insert or remove revenue meters 16kA for 1 sec, open 22 32 4 risk very low Y N
(kW-hour, at primary voltage and air arc
current) -- Applicable to 240V,
single-phase services
Remove or install auxiliary gutter or Wide Range Wide Range Wide Range See Above risk very low N N
wireway cover, with no exposure of
live parts
Remove or install miscellaneous Wide Range Wide Range Wide Range See Above risk very low N N
equipment cover, with no exposure
to live parts
Work on live parts, including voltage 35kA@0.5 sec 40 40 52 42 5-Note risk moderate Y Y
testing --- Note 4 42kA@0.33 sec N/A N/A 31 20 6 5-Note 6
52kA@0.2 sec 4 3
65kA@0.1 sec
Diagnostic testing, including voltage Wide Range N/A Wide Range See Above risk very low Y Y
testing -- Note 5
Apply safety grounds, after voltage See above N/A See Above See Above risk extremely Y N
test low
NEMA E2 (fused contactor) Motor _____________ ________ ________ ______ ________ ______ _____
Starters, 2.3kV through 7.2kV
Operate contactor with enclosure 55kA, 0.5 cycle 2 0.72 0 risk extremely N N
doors closed low
Read a panel meter while operating a 10kA@ 1 to 2 cycles 1.5 0.5 0 risk extremely N N
meter switch low

70E-42
Report on Comments — Copyright, NFPA NFPA 70E

Operate contactor with enclosure 55kA, 0.5 cycle or up 2 86 0.8 31 0 5- risk moderate N N
doors open to 55kA, 0.35 sec (if Note 6
line side involved)
Diagnostic testing, including voltage 55kA, 0.5 cycle 2 0.8 0 risk moderate Y Y
testing
Work on live parts 55kA, 0.5 cycle 2 0.8 0 risky Y Y
Work on control circuits while work- 10kA@1 to 2 cycles 1.5 0.5 0 risk extremely Y* Y
ing near exposed live parts 120V or low
below
Work on control circuits while work- 55kA, 0.5 cycle 2 0.8 0 risk moderate Y Y
ing near exposed live parts >120V

Insert or remove (rack) starters from 55kA, 0.35 sec 86 31 5 Note risk moderate N N
cubicles, doors open or closed 6,7
Insert or remove (rack) starters from 25kA, 0.35 sec 40 14 4 Note risk moderate N N
cubicles, doors open or closed 7
Apply safety grounds, after voltage 55kA, 0.35 sec 86 31 5-Note 6 risk extremely Y N
test low
Remove bolted covers (to expose 55kA, 0.35 sec 86 31 5-Note 6 risk moderate N N
live parts)
Open hinged covers (to expose live 55kA, 0.35 sec 86 31 5-Note 6 risk extremely N N
parts) low
Work on live parts of utilization 55kA, 0.5 cycle 2 0.8 0 risk moderate Y Y
equipment (e.g. motor or transform-
er) fed directly from starter
Metal Clad Switchgear, 1kV to 15kV _____________ ________ ________ ______ ________ ______ _____

Operate CB or fused switch with Wide Range Wide Range Wide Range 5-Note 6 risk extremely N N
enclosure doors closed low
Read a panel meter while operating a 10kA@1 to 2 cycles 3.1 0.5 1 risk extremely N N
meter switch low
Operate CB or fused switch with Wide Range Wide Range Wide Range 5-Note 6 risk moderate N N
enclosure doors open
Work on energized parts, including Wide Range Wide Range Wide Range 5-Note 6 risky Y Y
voltage testing --- Note 5
Work on control circuits while work- Wide Range Wide Range Wide Range 5-Note 6 risk extremely Y* Y
ing near exposed live parts 120V or low
below
Work on control circuits while work- Wide Range Wide Range Wide Range 5-Note 6 risk moderate Y Y
ing near exposed live parts >120V

Insert or remove (rack) CBs from Wide Range Wide Range Wide Range 5 Note risk moderate N N
cubicles, doors open or closed 6,7
Apply safety grounds, after voltage Wide Range Wide Range Wide Range 5-Note 6 risk extremely Y N
test low
Remove bolted covers (to expose Wide Range Wide Range Wide Range 5-Note 6 risk moderate N N
live parts)
Open hinged covers (to expose live Wide Range Wide Range Wide Range 5-Note 6 risk extremely N N
parts) low
Open voltage transformer or control Wide Range Wide Range Wide Range 5-Note 6 risk moderate N N
power transformer compartments
Work on live parts of utilization 40kA @ 0.1sec 40 7 4 risk moderate Y Y
equipment (e.g. motor or transform-
er) fed directly from a feeder CB
-- up to and including 15kV Class
equipment

70E-43
Report on Comments — Copyright, NFPA NFPA 70E

Metal Clad Switchgear, 15kV to _____________ ________ ________ ______ ________ ______ _____
38kV
Operate CB or fused switch with Wide Range Wide Range Wide Range 5-Note 6 risk extremely N N
enclosure doors closed low
Read a panel meter while operating a 10kA@1 to 2 cycles 8 33 4 risk extremely N N
meter switch low
Operate CB or fused switch with Wide Range Wide Range Wide Range 5-Note 6 risk moderate N N
enclosure doors open
Work on energized parts, including Wide Range Wide Range Wide Range 5-Note 6 risky Y Y
voltage testing --- Note 5
Work on control circuits while work- Wide Range Wide Range Wide Range 5-Note 6 risk extremely Y* Y
ing near exposed live parts 120V or low
below
Work on control circuits while work- Wide Range Wide Range Wide Range 5-Note 6 risk moderate Y Y
ing near exposed live parts >120V

Insert or remove (rack) CBs from Wide Range Wide Range Wide Range 5 Note 6,7 risk moderate N N
cubicles, doors open or closed

Apply safety grounds, after voltage Wide Range Wide Range Wide Range 5-Note 6 risk extremely Y N
test low
Remove bolted covers (to expose Wide Range Wide Range Wide Range 5-Note 6 risk moderate N N
live parts)
Open hinged covers (to expose live Wide Range Wide Range Wide Range 5-Note 6 risk extremely N N
parts) low
Open voltage transformer or control Wide Range Wide Range Wide Range 5-Note 6 risk moderate N N
power transformer compartments
Work on live parts of utilization 40kA @ 0.1sec 100 400 5-Note 6 risk moderate Y Y
equipment (e.g. motor or transform-
er) fed directly from a feeder CB
-- up to and including 15kV Class
equipment
Other Equipment 1kV to 15kV _____________ ________ ________ ______ ________ ______ _____

Metal enclosed load interrupter _____________ ________ ________ ______ ________ ______ _____
switches, fused or unfused
--Operate switch, doors closed 40kA @ 0.35 sec 130 545 5-Note 6 risk extremely N N
low
--Work on energized parts, including 40kA @ 0.35 sec 130 545 5-Note 6 risky Y Y
voltage testing
--Remove bolted covers (to expose 40kA @ 0.35 sec 130 545 5-Note 6 risk moderate N N
live parts)
--Open hinged covers (to expose live 40kA @ 0.35 sec 130 545 5-Note 6 risk extremely N N
parts) low
Operate outdoor disconnect switch 40kA @ 0.35 sec 33 136 5-Note 6 risk low Y Y
(hookstick operated @ working dis-
tance of at least 6 feet)
Operate outdoor disconnect switch 40kA @ 0.35 sec 12 50 5-Note 6 risk low Y N
(gang operated from grade @ work-
ing distance of at least 10 feet)
Examine insulated cable, in manhole Wide Range Wide Range Wide Range 5-Note 6 risk moderate Y N
or other confined space
Examine insulated cable, in open Wide Range Wide Range Wide Range 5-Note 6 risk low Y N
area

70E-44
Report on Comments — Copyright, NFPA NFPA 70E

Other Equipment 15kV to 38kV _____________ ________ ________ ______ ________ ______ _____
Metal enclosed load interrupter _____________ ________ ________ ______ ________ ______ _____
switches, fused or unfused
--Operate switch, doors closed 40kA @ 0.35 sec 330 1376 5-Note 6 risk extremely N N
low
--Work on energized parts, including 40kA @ 0.35 sec 330 1376 5-Note 6 risky Y Y
voltage testing
--Remove bolted covers (to expose 40kA @ 0.35 sec 330 1376 5-Note 6 risk moderate N N
live parts)
--Open hinged covers (to expose live 40kA @ 0.35 sec 330 1376 5-Note 6 risk extremely N N
parts) low
Operate outdoor disconnect switch 40kA @ 0.35 sec 83 345 5-Note 6 risk low Y Y
(hookstick operated @ working dis-
tance of at least 6 feet)
Operate outdoor disconnect switch 40kA @ 0.35 sec 30 123 5-Note 6 risk low Y N
(gang operated from grade @ work-
ing distance of at least 10 feet)
Examine insulated cable, in manhole Wide Range Wide Range Wide Range 5-Note 6 risk moderate Y N
or other confined space
Examine insulated cable, in open Wide Range Wide Range Wide Range 5-Note 6 risk low Y N
area

^ For 600V and less, Column “C” was calculated using arc in a box equation at 18 inches (EMB = 1038.7 DB-1.4738tA[0.0093F2-
0.3453F + 5.9675]). This equation is valid between 16kA and 50kA. Column “D” values are based upon IEEE 1584 at 18” with the appropriate spacing
and enclosure. When not in the range for the arc in the box equation, Column “C” values are listed as N/A. The higher value of incident energy between
the two methods was used to determine Column “E” (Hazard Risk Category). Available fault currents and clearing times must be within close proximity
of the values listed to give an accurate depiction of the incident energy. Where lower bolted fault currents are available, overcurrent protective device
clearing times may increase and result in very different incident energy values. Where higher bolted fault values are available overcurrent protective
device clearing times may stay the same or decrease. If clearing times stay the same, incident energy values may increase significantly. If clearing
times decrease, incident energy values may decrease significantly
For 1kV and greater, Column “C” was calculated using E=(793*Ibf*kV*t)/D2 at 36 inches. However, a derivation does appear in 220.2(B). The equa-
tion above yields the equation in 220.2(B) by converting inches to feet, setting E = to 1.2 cal/cm2 and solving for the distance. Column “D” was calcu-
lated using IEEE 1584 at 36”.
Legend:
V-rated Gloves are gloves rated and tested for the maximum line-to-line voltage upon which work will be done.
V-rated Tools are tools rated and tested for the maximum line-to-line voltage upon which work will be done.
Y* See Part II, 3-3.6 for required use of rubber insulating gloves.
Y = yes(required)
N = no(not required)
Notes:
1. 42kA short circuit current available, 0.033 second (2 cycle) fault clearing time.
2. 65kA short circuit current available, 0.033 second (2 cycle) fault clearing time.
3. For short circuit currents available that are less than indicated in Column “B”, consideration of the overcurrent protective device clearing time should
be evaluated to determine the appropriate incident energy.
4. The listed fault current and clearing times may vary considerably, therefore incident energy values can also change accordingly.
5. Hazard/Risk Category is based upon incident energy values that are available and does not take into account the provision of Part II, 3-3.9.4.6 (inter-
ference). During the listed diagnostic testing, there is 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 on live parts, as
with tools.
6. A job safety analysis is required to justify that this task be done with the equipment energized.
7. If approved arc-resistant designs or remote operating (outside the Flash Protection Boundary) techniques are applied that permit closed-door comple-
tion of the task, the HRC can be reduced to 0.

70E-45
Report on Comments — Copyright, NFPA
________________________________________________________________
70E-87 Log #21 Final Action: Hold
( Part 2, Table 3-3.9.1 )
________________________________________________________________
Submitter: Paul S. Case, Fluor Hanford, Inc.
Comment on Proposal No:70E-98
Recommendation: Delete text as shown from the heading for column 1 in
Table 3-3.9.1.
“Task (Assumes Equipment Is Energized)” and Work Is Done Within the
Flash Protection Boundary)
Substantiation: Table 3-3.9.1 includes tasks that are not performed within the
Flash Protection boundary. By definition, as accepted in Proposal 70E-4 (Log
#75), the FPB is an approach limit from exposed live parts. Operating switches
and circuit breakers with covers on is not work within the FPB because live
parts are not exposed, but these tasks are included in Table 3-3.9.1.
Alternate solution would be my comment on Proposal 70E-4 (Log #75).
Committee Meeting Action: Hold
Committee Statement: This comment introduces new material that has not
had public review.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-88 Log #118 Final Action: Accept in Principle
( Part 2, Table 3-3.9.1 )
________________________________________________________________
Submitter: Mary Capelli-Schellpfeffer, CapShell, Inc.
Comment on Proposal No:70E-98
Recommendation: I strongly disagree with the addition of higher energy
levels along with a new “HRC 5.” I recommend deleting HRC 5 Table 3-3.9.1
entries.
Substantiation: The addition of higher energy levels implies that a task could
be done safely at HRC 5 and survived were an electrical incident to occur.
There is no anecdotal or experimental evidence that shows this is possibly true.
The committee incorrectly adopts a damage threshold level as a permissible
exposure limit in the “design” of its HRC ratings. This is a significant and
technically critical error, severely impacting Table 3-3.9.1.
Committee Meeting Action: Accept in Principle
Committee Statement: See Committee Action on Comment 70E-77 which
addresses the concerns of the submitter.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
DOERING: See my comment on Comments 70E-79 (Log #79) and 70E-81
(Log #13).
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-89 Log #117 Final Action: Accept in Part
( Part 2, Tables 3-3.9.1 and 3.3.9.2 )
________________________________________________________________
Submitter: Mary Capelli-Schellpfeffer, CapShell, Inc.
Comment on Proposal No:70E-99
Recommendation: I strongly recommend the deletion of reference to HRC 5.
I recommend the deletion of Note 2.
Substantiation: There are significant technical failings captured in this entry:
1. There is no anecdotal or other evidence that an HRC 5 event is survivable.
2. Tables are designed to permit burn injury as “reduced and survivable”
rather than prevent burns.
3. There is no listing of flammable (explosive) limits, flash point or ignition
temperature to permit the userʼs assessment of hazardous materials potentially
present.
4. Note 2 incorrectly suggests that burns are not physical trauma.
Committee Meeting Action: Accept in Part
Add the following words to the end of existing Note 2 of Section 3-3.9.2:
“...other than exposure to the thermal effects of an arc flash”.
Committee Statement: The committee accepts the first sentence in the
recommendation. See the Committee Action and Statement on Comment 70E-
85 which meets the intent of the submitter. The committee does not accept the
deletion of Note 2, but has revised the Note to meet the intent of the submitter.
The committee understands the action on this comment modifies the text
accepted on Proposal 70E-99.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
70E-46
NFPA 70E
Comment on Affirmative:
CALLANAN: I agree with the committee action not to delete Note 2 as
recommended by the submitter of this comment, and to delete the reference
to HRC 5. I believe there is information contained in this note that provides
insight to the user of this document regarding the intention of the PPE
requirements of this section. However, I feel that submitter of this comment
alerts us to some significant issues that need to be addressed. Unfortunately
the proposed words to make this note more technically correct and create a
better understanding of the intention and limitations of the PPE requirements of
this section is not provided in the recommendation.
DOERING: See my comment on Comments 70E-79 (Log #79) and 70E-81
(Log #13).
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-90 Log #14 Final Action: Reject
( Part 2, Tables 3-3.9.1 and 3.3.9.2 )
________________________________________________________________
Submitter: Ray A. Jones, Electrical Safety Consulting Services, Inc. / Rep.
ACC
Comment on Proposal No:70E-99
Recommendation: The committee action should have been “accept in part.”
The committee should not accept that protective clothing could mitigate the
risk of injury for category 5 exposures. No work tasks that require HRC 5
protective clothing for thermal protection should be executed while the circuit
is energized and Table 3-3.9.1 should so indicate.
The table should be revised such that in the table accepted by the committee,
all instances where hazard/risk category 5 is indicated, all information in all
columns except the first two should be removed. The term “Note 7” should
replace the information that is removed. Note 7 should be revised to read as
follows.
7. A job safety analysis is required to justify that this task be done with the
equipment energized.
7. 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.
Substantiation: The committee action suggests that protective clothing can
reduce the risk of injury to an acceptable level where exposure is as high as
100 cal/cm2. That fact has not been established. Thermal testing as defined in
ASTM standards can determine the thermally protective characteristics. No
tests have been established regarding the blast effects of such an arcing fault;
consequently, the table does not consider hazards associated with arc blast.
It is likely that the blast effects associated with an arc of this magnitude
would injure a worker regardless of the protection from thermal hazards. In
fact, the protective clothing would increase the surface area that would be
exposed to the pressure forces associated with the arc. At the same time, the
physical constraints associated with the clothing would tend to increase the
likelihood of accidentally initiating an arc.
Committee Meeting Action: Reject
Committee Statement: The submitterʼs reference to Note 7 is applicable to
the Table 3-3.9.1 and not the text in 3-3.9.1. See the action on Comment 70E-
77 which meets the intent of the submitterʼs comment.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
DOERING: See my comment on Comments 70E-79 (Log #79) and 70E-81
(Log #13).
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-91 Log #75 Final Action: Accept in Principle
( Part 2, Table 3-3.9.2 )
________________________________________________________________
Submitter: Michael I. Callanan, IBEW
Comment on Proposal No:70E-100
Recommendation: This proposal should be rejected.
Substantiation: As stated in my negative vote, this proposal and the several
related companion proposals highlights a dangerous trend towards “bigger
and better PPE.” I believe the effort is misguided because it fails to address
the many other serious hazards and risks that a worker may be exposed to
when they perform work at these energy levels. Even if the PPE is suitably
rated for the available incident energy levels that may be available, the PPE is
not designed nor intended to provide adequate protection beyond the thermal
effects of the arc or blast. As data becomes available, I believe Tables 3-3.9.1
and 3-3.9.2 should be modified and adapted to indicate when certain tasks
simply cannot be worked in an energized condition. This will result in greater
worker safety.
Committee Meeting Action: Accept in Principle
Revise Table 3-3.9.2 by deleting the “and 5” from the last column heading.
Report on Comments — Copyright, NFPA
Committee Statement: The Committee accepts the deletion of the HRC 5
category reference in the last column of Table 3-3.9.2. However, this has been
accomplished without the need to reject the complete action taken on Proposal
70E-100. See also Comment 70E-77 that meets the intent of the submitter.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
DOERING: See my comment on Comments 70E-79 (Log #79) and 70E-81
(Log #13).
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-92 Log #15 Final Action: Accept in Principle
( Part 2, Table 3-3.9.2 )
________________________________________________________________
Submitter: Ray A. Jones, Electrical Safety Consulting Services, Inc. / Rep.
ACC
Comment on Proposal No:70E-100
Recommendation: The committee action should have been “accept in part.”
The committee should not have accepted the concept of protective clothing for
use in environments where potential exposure is reater than HRC 4.
Substantiation: The committee action suggests that protective clothing can
reduce the risk of injury to an acceptable level where exposure is as high as
100 cal/cm2. That fact has not been established. Thermal testing as defined in
ASTM standards can determine the thermally protective characteristics. No
tests have been established regarding the blast effects of such an arcing fault;
consequently, the table does not consider hazards associated with arc blast.
It is likely that the blast effects associated with an arc of this magnitude
would injure a worker regardless of the protection from thermal hazards. In
fact, the protective clothing would increase the surface area that would be
exposed to the pressure forces associated with the arc. At the same time, the
physical constraints associated with the clothing would tend to increase the
likelihood of accidentally initiating an arc.
Committee Meeting Action: Accept in Principle
Committee Statement: See the Panel Action and Statement on Comment
70E-91 (Log #75) that meets the intent of the submitter.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
DOERING: See my comment on Comments 70E-79 (Log #79) and 70E-81
(Log #13).
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-93 Log #116 Final Action: Reject
( Part 2, Table 3-3.9.2 )
________________________________________________________________
Submitter: Mary Capelli-Schellpfeffer, CapShell, Inc.
Comment on Proposal No:70E-100
Recommendation: I recommend that text under column 4 and 5 in table 3-
3.9.2 be deleted.
Substantiation: Table 3-3.9.2 is titled to indicate that a user can rely on the
table content for clothing and PPE selection for electrical work. However,
the table neglects the arc blast aspect of electrical failures. Arc blast could be
reasonably expected, using the tables “language”, in HRC415 scenarios. As
written, a user would receive inadequate clothing and PPE selection advice
because there in no incorporation of blast protection for blast exposure that
might kill.
Committee Meeting Action: Reject
Committee Statement: The Committee disagrees that the last column of
Table 3-3.9.2 should be deleted. The column is needed to address protective
clothing and PPE for hazard risk category 4. The Committee has taken action
to remove the reference to HRC 5. See the action on Comment 70E-91 (Log
#75) that meets the intent of the submitter.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
DOERING: See my comment on Comments 70E-79 (Log #79) and 70E-81
(Log #13).
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
70E-47
NFPA 70E
________________________________________________________________
70E-94 Log #127 Final Action: Hold
( Part 2, Table 3-3.9.2 )
________________________________________________________________
Submitter: Thomas E. Neal, Neal Associates Ltd.
Comment on Proposal No:70E-100
Recommendation: For Part 2, Table 3-3.9.2, add “Note 10” to read as
follows:
“10. Alternate is to utilize a flash suit with an arc rating at least equivalent to
the Hazard Risk Category Required Minimum Arc Rating (See Part 2, Table 3-
3.9.3). In this case no additional non-FR or FR garments are required.” Insert
“Note 10” in Table 3-3.9.2 under each “X” entry on for Hazard Risk Category
Numbers “3” and “4” and “5” in the first section. (Non-melting or Untreated
Natural Fiber) of the Table labeled “a. T-shirt (short sleeve)” and “c. Pant
(Long). Also insert “Note 10” in the under each “X” entry on Hazard Risk
Category Numbers “3” and “4 and 5” in the second section (FR Clothing) of
the Table labeled “a. Long-sleeve shirt”, “b. Pants” and “c. Coverall”.
Substantiation: The current requirements would lead to wearing more
layers of clothing than needed and would add unnecessarily to discomfort
and potential heat stress of the wearer. If the Arc Rating of the switching suit
is “suitable for the arc flash exposure” as indicated by Part 2, 3-3.9.5.1 and
at least equal to the Minimum Arc Rating for each Hazard Risk Category,
additional layers of clothing are not needed under the switching suit.
Committee Meeting Action: Hold
Committee Statement: The comment introduces new text that has not had
adequate technical review and therefore is being held in accordance with the
NFPA Regulations Section 4-4.6.2.3.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-95 Log #131 Final Action: Accept
( Part 2, Table 3-3.9.2 )
________________________________________________________________
Submitter: Thomas E. Neal, Neal Associates Ltd.
Comment on Proposal No:70E-100
Recommendation: In Note 8 of Part 2, Table 3-3.9.2 delete the words, “hear
protection” and change the designation for e.3 under Category 2 from “AR
(Note 8)” to “X”, i.e. delete “Note 8” for e.3 under Category 2. This will
require hearing protection (ear canal inserts) regardless whether a face shield or
hood is used.
Substantiation: With the current wording of Category 2, Note 8 is designated
under e.1 with an “X” which is a requirement. Since Note 8 is also designated
under e.3 with an “AR” (as required), there is confusion as to whether hearing
protection is a requirement or to be used “as required”. The reader may believe
that if a hood is used, hearing protection is on an “as required” basis, but if a
face shied is used, hearing protection is required. There is no data indicating
that with a hood hearing protection (ear canal inserts) is not needed, thus
hearing protection (ear canal inserts) should be required whether a face shield
or a hood is used for Category 2.
Committee Meeting Action: Accept
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-96 Log #76 Final Action: Accept in Principle
( Part 2, Table 3-3.9.3 )
________________________________________________________________
Submitter: Michael I. Callanan, IBEW
Comment on Proposal No:70E-104
Recommendation: This proposal should be rejected.
Substantiation: As stated in my negative vote, this proposal and the several
related companion proposals highlights a dangerous trend towards “bigger
and better PPE.” I believe the effort is misguided because it fails to address
the many other serious hazards and risks that a worker may be exposed to
when they perform work at these energy levels. Even if the PPE is suitably
rated for the available incident energy levels that may be available, the PPE is
not designed nor intended to provide adequate protection beyond the thermal
effects of the arc or blast. As data becomes available, I believe Tables 3-3.9.1
and 3-3.9.2 should be modified and adapted to indicate when certain tasks
simply cannot be worked in an energized condition. This will result in greater
worker safety.
Committee Meeting Action: Accept in Principle
Revise Table 3-3.9.3 by deleting the last row referencing Hazard Risk
Category 5.
Report on Comments — Copyright, NFPA NFPA 70E
Committee Statement: The Committee accepts the deletion of the HRC 5 ______________________________________________________________
category reference in the last row of Table 3-3.9.3. However, this has been 70E-100 Log #61 Final Action: Accept
accomplished without the need to reject the complete action taken on Proposal ( Part 2, Table 3-3.9.3 )
70E-104. See also Comment 70E-77 that meets the intent of the submitter. ________________________________________________________________
Number Eligible to Vote: 25 Submitter: Robert E. Downey, Allison Transmission
Ballot Results: Affirmative: 24 Comment on Proposal No:70E-102
Vote Not Returned: 1 CLIFFDWELLER Recommendation: We recommend the committee remove the “Total Weight
Comment on Affirmative: oz/yd2” column in Table 3-3.9.3.
DOERING: See my comment on Comments 70E-79 (Log #79) and 70E-81 Substantiation: We believe that protection should be based on the tested
(Log #13). ATV value, and that using the weight reference could lead some persons
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log to misinterpret what was is intended by the column, causing them to select
#2). insufficient protection.
Committee Meeting Action: Accept
________________________________________________________________ Committee Statement: Fabric weight is deleted as per the recommendation
70E-97 Log #129 Final Action: Accept and substantiation on Comment 70E-97.
( Part 2, Table 3-3.9.3 ) Number Eligible to Vote: 25
________________________________________________________________ Ballot Results: Affirmative: 24
Submitter: Thomas E. Neal, Neal Associates Ltd. Vote Not Returned: 1 CLIFFDWELLER
Comment on Proposal No:70E-104 Comment on Affirmative:
Recommendation: In Part 2, Table 3-3.9.3 delete the table column labeled JACKSON: See my Affirmative with Comment on Comment 70E-1
“Total Weight oz/yd^2”. (Log #2).
Substantiation: Protective clothing systems with lighter weights than
indicated in Table 3-3.9.3 continually are being developed and introduced. The
reader may incorrectly conclude that systems with lighter or heavier weights ________________________________________________________________
than indicated in the table are not appropriate. Thus, listing weight ranges for 70E-101 Log #37 Final Action: Accept
each HR Category can create confusion for the user of the standard. What is ( Part 2, Table 3-3.9.3 )
important is protection level, i.e., the Arc Rating column rather than system ________________________________________________________________
weight so the weight ranges can be deleted without causing a loss of important Submitter: Kevin J. Lippert, Eaton/Cutler-Hammer
information for the user of the standard. Comment on Proposal No:70E-104
Committee Meeting Action: Accept Recommendation: For Hazard Risk Category 0, under the column heading
Number Eligible to Vote: 25 “Required Minimum Arc Rating of PPE”, it was changed from “N/A” to “For
Ballot Results: Affirmative: 24 use up to 2 cal/cm2 incident energy exposure, but materials have no arc rating.”
Vote Not Returned: 1 CLIFFDWELLER This change should not be accepted.
Comment on Affirmative: Substantiation: This change qualifies “flammable materials...for use up to 2
JACKSON: See my Affirmative with Comment on Comment 70E-1 cal/cm2.” This essentially permits a 2 cal/cm2 arc rating, which is contradictory
(Log #2). to the statement that these “materials have no arc rating.” In the substantiation,
the submitter acknowledges that arc ignition is possible at 2 cal/cm2 and below.
________________________________________________________________ Knowing this, it would not seem prudent for this Standard to specify their
70E-98 Log #132 Final Action: Accept use for that application. It would be better to simply state “N/A” as was done
( Part 2, Table 3-3.9.3 ) previously.
________________________________________________________________ Committee Meeting Action: Accept
Submitter: Thomas E. Neal, Neal Associates Ltd. Number Eligible to Vote: 25
Comment on Proposal No:70E-104 Ballot Results: Affirmative: 24
Recommendation: In Part 2, Table 3-3.9.3, revise the “Typical number of Vote Not Returned: 1 CLIFFDWELLER
clothing layers is given in parentheses” for Hazard Risk Category 2 from the Comment on Affirmative:
current “(2)” to “(1 or 2)” and the Hazard Risk Category 3 from the current DOERING: Good to get rid of the 2 cal/cm2 value, as its source is suspect.
“(3)” to “(2 or 3)”. As stated in Comment 70E-74 above, typical cotton will not burn at 4.6 cal/
Substantiation: As new clothing systems have been designed for Hazard cm2 99 times out of of 100 incidents.
Risk Categories 2 and 3, systems with fewer layers have become typical. Not I believe the commenter is wrong when he states what we call non-melting
reflecting this in the typical number of layers will be confusing to the reader of flammable materials do not have a cal/cm2 arc rating. Based on the same
the standard and may make the reader conclude that systems with fewer layers comments in 70E-74 the statement in question should read, “For use up to 4.6
are not typical. cal/cm2 incident energy exposure.” The comittee members should support the
Committee Meeting Action: Accept use of 4.6 cal/cm2 as the trigger for requiring FR clothing in future editions,
Number Eligible to Vote: 25 based on the requirement that the electrical worker wear standard cotton
Ballot Results: Affirmative: 23 Negative: 1 clothing at all times at a minimum.
Vote Not Returned: 1 CLIFFDWELLER JACKSON: See my Affirmative with Comment on Comment 70E-1
Explanation of Negative: (Log #2).
CALLANAN: I disagree with the Committee Action on this comment. The
submitter failed to provide any technical substantiation to justify this revision
to Table 3-3.9.3. In addition, this concept is new material and has not had ________________________________________________________________
adequate public review. 70E-102 Log #38 Final Action: Reject
Comment on Affirmative: ( Part 2, Table 3-3.9.3 )
JACKSON: See my Affirmative with Comment on Comment 70E-1 ________________________________________________________________
(Log #2). Submitter: Kevin J. Lippert, Eaton/Cutler-Hammer
Comment on Proposal No:70E-104
Recommendation: The minimum arc rating required for Hazard Risk
________________________________________________________________ Category (HRC) 1 was lowered from 5 to 4 cal/cm2. It should remain at 5
70E-99 Log #135 Final Action: Accept cal/cm2.
( Part 2, Table 3-3.9.3 ) Substantiation: The standard previously established 5 cal/cm2 as the
________________________________________________________________ maximum value for Hazard Risk Category 1. This change implies that FR shirt
Submitter: Vladimir Ostrovsky, W.H. Salisbury & Co. and FR pants are no longer rated up to 5 cal/cm2 alone. This is not correct.
Comment on Proposal No:70E-104 In the substantiation, the submitter states that “The tasks from Table 3-3.9.1
Recommendation: Delete reference to fabric weight. that are designated HRC “1” either fall within 4 cal/cm2, or are low or very
Substantiation: Reference to fabric weight is confusing. Arc protective low exposure risk.” Just because the examples given in Table 3-3.9.1, when
equipment must meet required ATPV vallie. determined by the restrictions given in the footnotes, calculate at less than
Committee Meeting Action: Accept 4 cal/cm2, that is not justification for lowering the entire HRC 1 level by 20
Committee Statement: Fabric weight is deleted as per the recommendation percent. When an appropriate flash hazard calculation determines the level
and substantiation on Comment 70E-97. to be 5 cal/cm2, HRC 1, FR shirt and FR pants rated at 5 cal/cm2 are still
Number Eligible to Vote: 25 appropriate.
Ballot Results: Affirmative: 24 Committee Meeting Action: Reject
Vote Not Returned: 1 CLIFFDWELLER Committee Statement: HRC 1 defined at the new level does not affect
Comment on Affirmative: the application of FR clothing and other equipment as long as the arc flash
JACKSON: See my Affirmative with Comment on Comment 70E-1 calculation methods and PPE conform to the newly defined level.
(Log #2). Number Eligible to Vote: 25
Ballot Results: Affirmative: 22 Negative: 2
70E-48
Report on Comments — Copyright, NFPA
Vote Not Returned: 1 CLIFFDWELLER
Explanation of Negative:
CALLANAN: I disagree with the Committee Action on this comment. I
agree with the submitter of this comment that the original proposal failed to
provide the technical substantiation to warrant lowering the entire HRC 1 level
by 20 percent. The foundation for establishing the present level of protection
is based on published technical information made available to the committee.
“Lowering the bar” on protection without the submitter providing the Technical
Committee with technical substantiation does not seem prudent.
DOERING: In an unusual action I find I agree with Callananʼs negative
comment.
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-103 Log #86 Final Action: Reject
( Part 2, Table 3-3.9.3 )
________________________________________________________________
Submitter: Dale Missey, Cooper Bussman
Comment on Proposal No:70E-104
Recommendation: Add a footnote to Hazard Risk Category in the first
column. It should read as follows:
“Where calculated incident energy exceeds 40 Cal/cm2, installation, repair, or
removal of equipment is prohibited.”
Substantiation: PPE is available to protect against the flash burn associated
with a 100 cal/cm2 incident, but there is no data available that shows a worker
will be protected against the pressures and shrapnel from such an incident.
The proposal adds a new Hazard Risk category 5 which is 250% greater than
the highest rating in the NFPA 70E 23000 edition. No substantiation has been
provided to assure that a worker will be protected from the enormous pressures
and shrapnel at these higher levels. Hazard/Risk Category 5 PPE will still
be required. It must still be worn in situations where there are more than 40
Cal/cm2 available, during the process to determine that equipment is in an
electrically safe work condition, after the equipment has been de-energized and
locked out and tagged off.
Committee Meeting Action: Reject
Committee Statement: The Comment addresses a work practice
consideration that is not appropriately placed within Table 3-3.9.3. This Table
is intended to provide protective clothing characteristics for typical protective
clothing systems.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-104 Log #97 Final Action: Reject
( Part 2, 3-3.9.4.3 )
________________________________________________________________
Submitter: C. Bryan Drennan, Sandia National Laboratories
Comment on Proposal No:70E-52
Recommendation: In Part 2, section 3-3.9.4.3 revise Note 1 to read as
follows:
Note 1: FR garments (e.g., shirts, trousers, and coveralls) worn as underlayers
that thermal hazards generally provide a higher system arc rating and
significantly better protection to thermal hazards than non-melting, flammable
fiber underlayers.
Substantiation: The wording has been modified for grammatical composition
and clarity.
Committee Meeting Action: Reject
Committee Statement: The committee disagrees with the proposed wording
in the comment adds clarity and improves grammatical composition. In
addition, the committee questions how the determination “of significantly
better protection” can be determined. The referenced proposal number should
be 70E-109 Note 2.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-105 Log #128 Final Action: Reject
( Part 2, 3-3.9.5.1 )
________________________________________________________________
Submitter: Thomas E. Neal, Neal Associates Ltd.
Comment on Proposal No:70E-111
Recommendation: After the first sentence of Part 2, 3-3.9.5.1 which reads,
70E-49
NFPA 70E
“Flash suit design shall permit easy and rapid removal by the wearer.” Insert
a new sentence. “Flash suits shall consist of multiple independent clothing
layers as indicated in Part 2, Table 3-3.9.3 or a single garment with one or
more fabric layers permanently sewed together.”
Substantiation: The current wording tends to be confusing in that the word
“suit” suggests a garment with all layers sewed together, but on the other hand,
Part 2, Table 3-3.9.3 shows individual layers of cotton underwear and FR
clothing being used together to achieve an Arc Rating. Adding the proposed
sentence clarifies this potential confusion by indicating that both approaches
are acceptable versions of a flash suit.
Committee Meeting Action: Reject
Committee Statement: The committee believes that the current language does
not restrict the flash suit construction to a single construction method. See
Proposal 70E-111.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-106 Log #59 Final Action: Accept
( Part 2, Table 3-3.9.5.2 )
________________________________________________________________
Submitter: Robert E. Downey, Allison Transmission
Comment on Proposal No:70E-112
Recommendation: We recommend the committee remove Note 2.
Substantiation: Although the text is included as a note, it reads like an
exception. We do not believe the committeeʼs intent is to make such an
exception, and therefore the note should be removed.
Committee Meeting Action: Accept
Number Eligible to Vote: 25
Ballot Results: Affirmative: 23 Negative: 1
Vote Not Returned: 1 CLIFFDWELLER
Explanation of Negative:
DOERING: The committee should have rejected Comment 70E-106.
There are a great many routine tasks, such as testing and inspection, where
a reasonable safety analysis would agree that safety glasses are appropriate.
A similar conclusion would be reached for routine jobs of a long duration
requiring working in less than ideal spaces. As safety glasses should be worn
at all times, they could make a world of difference if there was an unexpected
arc flash.
The committee members should vote negative on Comment 70E-106.
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-107 Log #39 Final Action: Reject
( Part 2, 3-3.9.7.2 )
________________________________________________________________
Submitter: Kevin J. Lippert, Eaton/Cutler-Hammer
Comment on Proposal No:70E-119
Recommendation: The 2 cal/cm2 level should be changed to 1.2 cal/cm2.
“Clothing made from non-melting flammable natural materials, such as
cotton, wool, rayon, or silk shall be permitted for Hazard/Risk Categories 0 and
minus 1 considered acceptable if it is determined by flash hazard analysis that
the exposure level is 1.2 2 cal/cm2, or below, and that the fabric will not ignite
and continue to burn under the arc exposure hazard conditions 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.” The FPNʼs remain as proposed.
Substantiation: Incident energy levels are based upon limiting exposure
to 1.2 cal/cm2 because this is the level determined for a 2nd degree (“just
curable”) burn. The allowance to use known flammable materials, should also
be restricted at/below the 1.2 cal/cm2 level.
Committee Meeting Action: Reject
Committee Statement: The incident energy limit for flammable materials
is higher than for the onset of a second-degree skin burn (blistering). Also
see the substantiation for proposal 70E-104 - “…Establish 2 cal/cm2 to be the
upper limit of application for these non-melting, flammable materials for HRC
0 because the an upper limit is valuable guidance to a user and the probability
of arc ignition of a 4.5 oz/yd2 fabric is extremely low at an exposure of 2.0
cal/cm2 or below.” This has been determined by actual tests on flammable
materials. The fabrics described have been indicated in IEEE paper PCIC 97-35
as providing sufficient protection under the conditions indicated in the text.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
Report on Comments — Copyright, NFPA
_______________________________________________________________
70E-108 Log #4 Final Action: Accept
( Part 2, 3-3.9.8 )
________________________________________________________________
Submitter: National Electrical Code Technical Correlating Committee
Comment on Proposal No:70E-121
Recommendation: It was the action of the Technical Correlating Committee
that the committee reconsider the proposal and replace the words “may be
used” with “shall be permitted” in accordance with the Style Manual.
Substantiation: To comply with the NEC Style Manual.
Committee Meeting Action: Accept
In the exception to 3-3.9.8 replace the first occurrence of the phrase “may
be used” with “shall be permitted to be used”. In addition, replace the word
“may” with “shall be permitted to”.
Committee Statement: The committee accepts the TCC comment and has
reviewed the text and modified it for clarity.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
POTTS: Use of the words “shall be permitted” may cause some confusion in
that work permits have been added to this standard.
________________________________________________________________ Submitter: David Soffrin, American Petroleum Institute
70E-109 Log #96 Final Action: Accept in Principle Comment on Proposal No:70E-25
( Part 2, 3-4.2 )
________________________________________________________________
Submitter: C. Bryan Drennan, Sandia National Laboratories
Comment on Proposal No:70E-137
Recommendation: Revise Part II, Section 3-4.2 to read as follows:
3-4.2 Physical or Mechanical Barriers. Physical or mechanical (field
fabricated) barriers shall be installed no closer than the restricted approach
distance given in Table 220.2(A)(1). FPN: The restricted approach distance
specified in Table 220.2(A)(1) shall be maintained, or the live parts must be
placed in an electrically safe working condition while the barrier is being
installed.
FPN: The restricted approach distance specified in Table 220.2(A)(1) shall
be maintained, or the live parts must be placed in an electrically safe working
condition while the barrier is being installed.
Substantiation: The existing note contains mandatory language. The sentence Number Eligible to Vote: 25
is relocated to the body of the document to comply with the Manual of Style.
Committee Meeting Action: Accept in Principle
Revise the text to read as follows:
“3-4.6 Physical or Mechanical Barriers. Physical or mechanical (field
fabricated) barriers shall be installed no closer than the restricted approach
distance given in Table 3-2.1.2 of Part II. While the barrier is being installed,
the restricted approach distance specified in Table 3-2.1.2 of Part II shall
be maintained, or the live parts shall be placed in an electrically safe work
condition.”
Committee Statement: The committee corrected the section from 3-4.2 to
3-4.6. The note contained language that was in violation of the NEC Style
Manual and the text was editorially revised to improve the clarity of the
requirement.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________ unauthorized people should be secured by a lock or the access blocked by
70E-110 Log #60 Final Action: Accept
( Part 2, Table 3-9.3.3 )
________________________________________________________________ to write a document titled, “Guidelines for Controlling Hazardous Energy
Submitter: Robert E. Downey, Allison Transmission
Comment on Proposal No:70E-104
Recommendation: We recommend the committee remove the “Total Weight
oz/yd ” column in Table 3-3.9.3.
2
Substantiation: We believe that protection should be based on the tested
ATV value, and that using the weight reference could lead some persons
to misinterpret what was is intended by the column, causing them to select
insufficient protection.
Committee Meeting Action: Accept
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
70E-50
NFPA 70E
________________________________________________________________
70E-111 Log #115 Final Action: Reject
( Part 2, 4-3 )
________________________________________________________________
Submitter: Mary Capelli-Schellpfeffer, CapShell, Inc.
Comment on Proposal No:70E-130
Recommendation: I endorse the new section recommended by the submitter.
Substantiation: The audience for NFPA 70E, Part 1, the NEC, is arguably
not the same as the audience for NFPA 70E, Part 2. The submitterʼs new text
bridges the two groups.
I agree with the comments in the explanation of negative.
Committee Meeting Action: Reject
Committee Statement: The committee reaffirms itsʼ position stated in the
ROP related to Proposal 70E-130.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-112 Log #109 Final Action: Reject
( Part 2, 4-3.6 )
________________________________________________________________
Recommendation: Revise the proposed wording as follows:
4-3.6 GFCI Protection Devices. GFCI protection devices shall be tested
before each use per manufacturerʼs instructions.
Substantiation: The wording of the proposal should be revised. The testing
of a GFCI (with the built-in “test” button) should be required before each
use of a connected tool or other piece of equipment. “Per manufacturerʼs
instructions” is redundant and not restrictive enough to provide personnel
safety. The proposed change would require added documentation and record-
keeping requirements that would not significantly enhance safety.
Committee Meeting Action: Reject
Committee Statement: Requiring testing before each use would make it
necessary for users to test a circuit breaker type or other remotely installed
GFCIʼs every time they were going to use any electrical equipment on the
circuit which would be impractical.
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-113 Log #82 Final Action: Reject
( Part 2, 5-4.2.11(d) )
________________________________________________________________
Submitter: J. F. Doering Akron, OH
Comment on Proposal No:70E-136
Recommendation: The change that is proposed by 70E-136 should be
rejected, as it rules out using a method that is widely used to control switching
points that de-energize electric circuits.
Substantiation: Many safety people are thoroughly sold on the need to
lockout energy control points. I believe there opinions are based on the energy
control point being accessible to unauthorized people, be they employees
or the public. Tagging procedures are based on energy control points not
being accessible to untrained people. Energy control points accessible to
appropriate barriers.
I remember working with a NIOSH contractor when he first started a project
During Maintenance and Servicing. He seemed to automatically believe locks
were the only way to go, but after his study of practices and their effectiveness,
he was convinced that tagout methods provided good protection. After they
had finished their study they wrote the following in their published 1983
NIOSH report.
The points of control shall be secured so that unauthorized persons are
prevented from reenergizing the machine, process, or system.
A means of security must be implemented to ensure that the equipment being
maintained or serviced is not somehow reenergized. The guidelines allow a
choice of three methods.
(1) Secure by physical means (“Lockout”) such that reenergizing the system
requires the use of special equipment routinely available only to the person
who applied the control. A warning containing appropriate information shall
be displayed at the point(s) of control.
(2) Post a warning (“Tagout”) at the point(s) of control providing information
as to why the energy sources have been isolated, blocked, or dissipated, the
date, the person(s) responsible for the control measure, and the person(s)
Report on Comments — Copyright, NFPA NFPA 70E
responsible for the work to be accomplished. In addition, access to the control WILMER: Committee Action should have been accept. This would allow
point(s) must be limited to persons who are trained to understand and observe employers to use Tags Plus programs under the conditions allowed by OSHA.
the posted warning. The Committee Action of Accept in Principle still requires lock and tag unless
(3) Post qualified personnel, with the specific responsibility of protecting the equipment design does not allow a lock. Only then can Tags Plus be used.
against unauthorized actuation, at the point(s) of control throughout the OSHA recognizes that Tags Plus programs can be effective and safe. Allowing
maintenance activity. This applies mainly to short duration work in the Tags Plus only when equipment design precludes the use of a lock will be a
immediate vicinity of the control point(s). burden on employers who have used this approach for years.
Committee Meeting Action: Reject Comment on Affirmative:
Committee Statement: The committee reaffirms its position that the use of a JACKSON: See my Affirmative with Comment on Comment 70E-1
lock accompanied with a tag is the preferred procedure. However, the proposal (Log #2).
recognizes that for equipment designs that precludes the use of a lock, a tag
with secondary protection is permissible. See committee action and statement
on Comment 70E-114 (Log #31). ________________________________________________________________
Number Eligible to Vote: 25 70E-115 Log #108 Final Action: Accept
Ballot Results: Affirmative: 23 Negative: 1 ( Part 2, Appendix A, A-1-1 )
Vote Not Returned: 1 CLIFFDWELLER ________________________________________________________________
Explanation of Negative: Submitter: David Soffrin, American Petroleum Institute
DOERING: While the committee reaffirmed its position that the use of a Comment on Proposal No:70E-138
lock accompanied by a tag is the preferred procedure, they did not provide Recommendation: Accept the proposal.
a reason, or did they respond to the fact that “tag only” systems are used Substantiation: The reason given for rejection in the Committee Statement
universally by hundreds of companies, very successfully. A clarification may does not address the substantiation of this proposal. By the action in 70E-
be in order as “lock only” advocates fail to understand that “tag only” does 3b, there is no longer a requirement in the definition of “limited approach
require the energy control point to be secured if accessible to unauthorized boundary” that covers unqualified persons. This proposed explanation in
persons. A better solution than revising 5-4.2.11(d) is to add the following: Appendix A-1.1 is needed as a companion to Proposal 70E-62.
5-4.11(e) If a tagged energy control device is accessible to unauthorized The Committee Meeting Action contained transcription errors.
persons (persons not trained to understand and observe the warning the tag Committee Meeting Action: Accept
conveys), a lock shall be applied, or a qualified person posted to prevent Number Eligible to Vote: 25
unauthorized actuation. Ballot Results: Affirmative: 24
The committee members should vote negative on Comment 70E-113, and Vote Not Returned: 1 CLIFFDWELLER
support a future change to add the suggested 5-4.11(e). Comment on Affirmative:
Comment on Affirmative: JACKSON: See my Affirmative with Comment on Comment 70E-1
CALLANAN: The Panel Statement accompanying the action to reject this (Log #2).
comment greatly enhances an understanding of the “intent” of the committee as
it relates to its position on the use of a lock as the preferred procedure, not as
an alternative. The Panel Statement which states that “the committee reaffirms ________________________________________________________________
its position that the use of a lock accompanied with a tag is the preferred 70E-116 Log #49 Final Action: Accept
procedure” makes the intent of the words in this requirement evident. ( Part 2, Appendix A, 2-3.1.6 )
JACKSON: See my Affirmative with Comment on Comment 70E-1 ________________________________________________________________
(Log #2). Submitter: Louis A. Barrios, Jr., Shell Global Solutions
Comment on Proposal No:70E-139a
Recommendation: Add the following items to the “Identify” block in the Job
________________________________________________________________ Briefing and Planning Checklist:
70E-114 Log #31 Final Action: Accept in Principle What are the shock protection boundaries?
( Part 2, 5-4.2.11(d) ) What is the flash protection boundary?
________________________________________________________________ What is the available incident energy?
Submitter: Kathy Wilmer, Duke Power Co. / Rep. Edison Electric Institute Substantiation: The recommended additions provide very clear guidance
Comment on Proposal No:70E-136 for individuals planning work on or near potentially live parts to identify the
Recommendation: Reject this proposal. shock and flash boundaries and the available incident energy before work is
Substantiation: Edison Electric Institute opposes the committee action. performed rather than relying on general statements like “what are the hazards”
OSHA specifically allows tagout only (no locks) if secondary means of and “potential for arc flash”.
protection are used (i.e. Tags Plus). Many employers have adopted this Committee Meeting Action: Accept
approach successfully. Revising 70E to require lockout in all cases except Number Eligible to Vote: 25
where equipment design precludes lock installation will add an unnecessary Ballot Results: Affirmative: 24
burden to employers. Vote Not Returned: 1 CLIFFDWELLER
Committee Meeting Action: Accept in Principle Comment on Affirmative:
Revise Section 5-4.2.11(d) to read as follows: JACKSON: See my Affirmative with Comment on Comment 70E-1
“(d) The use of tagout procedures without a lock shall be permitted only in (Log #2).
cases where equipment design precludes the installation of a lock on an energy
isolation device(s). Where tagout is employed, at least one additional safety
measure shall be employed. In such cases, the procedure shall clearly establish ________________________________________________________________
responsibilities and accountability for each person that might be exposed to 70E-117 Log #40 Final Action: Accept in Principle
electrical hazards.” ( Part 2, Appendix B )
Committee Statement: The committee disagrees that Proposal 70E-136 ________________________________________________________________
should be rejected. See action on Comment 70E-113 (Log # 82). The Submitter: Kevin J. Lippert, Eaton/Cutler-Hammer
committee agrees with the point in the submitters substantiation that a Comment on Proposal No:70E-157a
secondary means of protection is required when a tag only procedure is Recommendation: The equations throughout this Annex should be updated to
used. The committee has added a new sentence to address this concern. The reflect those contained in IEEE P1584 - 2002 “Arc Flash Hazard Calculations”.
committee disagrees with the last sentence of the submitters substantiation that Substantiation: There has been a significant amount of resources dedicated
the requirements in all cases will add an “unnecessary burden” to employers. to the development of IEEE P1584. Those equations are considered to be
The first sentence was revise by the addition of the words “of a lock on” to the most accurate method of determining indecent energy to date. NFPA 70E
address the comment raised in a negative vote on Proposal 70E-136. should use the same information, and not have possible conflicting methods for
Number Eligible to Vote: 25 performing the calculations.
Ballot Results: Affirmative: 22 Negative: 2 Committee Meeting Action: Accept in Principle
Vote Not Returned: 1 CLIFFDWELLER Committee Statement: See Committee Action and Statement on Comment
Explanation of Negative: 70E-132 (Log #66).
DOERING: The committees action continues to essentially prohibit “tag Number Eligible to Vote: 25
only” systems. See my comments on 70E-113 (Log #82) negative comment on Ballot Results: Affirmative: 24
Proposal 70E-136. The committee members should vote negative on Comment Vote Not Returned: 1 CLIFFDWELLER
70E-114. Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).

70E-51
Report on Comments — Copyright, NFPA NFPA 70E
________________________________________________________________ _______________________________________________________________
70E-118 Log #98 Final Action: Reject 70E-121 Log #55 Final Action: Accept in Principle
( Part 2, Appendix B ) ( Part 2, B-5 )
________________________________________________________________ ________________________________________________________________
Submitter: Allen H. Bingham, Bingham Consultants Submitter: Robert E. Downey, Allison Transmission
Comment on Proposal No:70E-157a Comment on Proposal No:70E-114
Recommendation: Remove formulas and related material that were derived Recommendation: I recommend removing the reference requiring “4 cal/cm2”
from IEEE P1584 standard because of copyright infringement. Make a and just require the heavy duty footwear.
bibliographical reference to P1584. Substantiation: I do not believe there is technical basis for the 4 cal/cm2
Substantiation: Material from IEEE P1584 is copyrighted. Without number. I also do not believe there is footwear currently in the marketplace
permission this information should not be used within an NFPA standard. that has been tested and which is being labeled with an ATV value – implying a
Committee Meeting Action: Reject requirement which canʼt be met.
Committee Statement: The concerns of the submitter have been addressed Committee Meeting Action: Accept in Principle
by the Committee Action on Comment 70E-132 (Log #66). NFPA staff has Revise the text to read as follows:
reported that the copyright issues with IEEE 1584 have been resolved. “Heavy duty leather work shoes provide some arc-flash protection to the feet
Number Eligible to Vote: 25 and shall be used in all tasks in Hazard/Risk Category 2 and higher.”
Ballot Results: Affirmative: 24 Committee Statement: The text in Proposal 70E-114 does not require a rating
Vote Not Returned: 1 CLIFFDWELLER for leather shoes. Instead, the requirement is for leather shoes shall be worn in
Comment on Affirmative: environments for hazard/risk Category 2 exposures and above.
JACKSON: See my Affirmative with Comment on Comment 70E-1 Number Eligible to Vote: 25
(Log #2). Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
________________________________________________________________ Comment on Affirmative:
70E-119 Log #58 Final Action: Accept JACKSON: See my Affirmative with Comment on Comment 70E-1
( Part 2, Appendix B, Table B-1 ) (Log #2).
________________________________________________________________
Submitter: Robert E. Downey, Allison Transmission
Comment on Proposal No:70E-139 ________________________________________________________________
Recommendation: The header in the right-most column of Table B1 should 70E-122 Log #16 Final Action: Accept
just read “Flash Protection Boundary.” All of the other text currently shown ( Part 2, Appendix G )
should be moved to a note. ________________________________________________________________
Substantiation: The text as written is grammatically difficult, and tends to Submitter: Ray A. Jones, Electrical Safety Consulting Services, Inc. / Rep.
confuse the real purpose of the column. ACC
Committee Meeting Action: Accept Comment on Proposal No:70E-152
Committee Statement: See committee action and statement on Comment Recommendation: The committee action should have been “accept in part.”
70E-120. The reference to the temperature of the sun should be removed. The second
Number Eligible to Vote: 25 paragraph that covers arc flash should be revised to read as follows:
Ballot Results: Affirmative: 24 Arch Flash. When an electric current passes through air between ungrounded
Vote Not Returned: 1 CLIFFDWELLER conductors or between ungrounded conductors and grounded conductors, the
Comment on Affirmative: temperatures can reach 35,000°F., or about four times the temperature of the
JACKSON: See my Affirmative with Comment on Comment 70E-1 sun. Exposure to extreme temperatures frequently results in burns to the skin
(Log #2). directly and/or ignition of clothing, which causes additional burn injury. The
majority of hospital admissions due to electrical accidents are from arc-flash
burns, not from shocks. Each year there are more than 2,000 people admitted
________________________________________________________________ to burn centers with severe arc-flash burns. Arc flashes can and do kill at
70E-120 Log #69 Final Action: Accept in Principle distances of 10 ft. and greater.
in Part Substantiation: Relating the temperature of an arc to the temperature of
( Part 2, Appendix B, Table B-1 ) the sun is incorrect. It is my understanding that the sun is a thermonuclear
________________________________________________________________ furnace with an internal temperature of many millions of degrees F. In fact,
Submitter: Vincent J. Saporita, Cooper Bussmann the temperature of an electrical arc is insignificant in comparison to the
Comment on Proposal No:70E-139 fusion reaction occurring within our nearest star. The comparison with the
Recommendation: Change “Limit Skin Temperature” to “Limit Skin temperature of the sun should be removed.
Damage” in the most right-hand column heading. Committee Meeting Action: Accept
Add ranges for the arc-flash boundary column as follows: Number Eligible to Vote: 25
46.0 (no change) Ballot Results: Affirmative: 24
14.1-21.0 Vote Not Returned: 1 CLIFFDWELLER
3.3-5.8 Comment on Affirmative:
7.3-14.4 JACKSON: See my Affirmative with Comment on Comment 70E-1
5.5-6.8 (Log #2).
3.7-7.5
0.74-0.86
2.8-5.3 ________________________________________________________________
2.3-3.9 70E-123 Log #57 Final Action: Accept in Principle
Substantiation: Damage replaces temperatures because “temperature” is not ( Part 2, Appendix G )
limited to a second degree burn but “damage” is limited to a second degree ________________________________________________________________
burn. The range was added for the arc-flash boundaries in the last column to Submitter: Robert E. Downey, Allison Transmission
account for the new calculation methods in the new IEEE P1584. Comment on Proposal No:70E-152
Committee Meeting Action: Accept in Principle in Part Recommendation: We recommend the committee remove the reference to the
Accept the change from “Limit Skin Temperature” to “Limit Skin Damage”. temperature of the sun.
Do not accept the change to provide a range of values as it may tend to confuse Substantiation: We believe that the sun temperature varies based on where
the user. Existing values in the right hand column of Table B-1 as referenced on or in the sun is meant, and rather than create confusion, we should just
in Proposal 70E-139 to remain unchanged. reference the temperature.
Committee Statement: Changing the column values would conflict with the Committee Meeting Action: Accept in Principle
text in existing B-1. The Committee recognizes that the change to “Limit Skin Committee Statement: See Committee Action on Comment 70E-122 (Log
Damage” will appear in a note to the table due to the action on Comment 70E- #16) which meets the intent of the submitter.
119. Number Eligible to Vote: 25
Number Eligible to Vote: 25 Ballot Results: Affirmative: 24
Ballot Results: Affirmative: 24 Vote Not Returned: 1 CLIFFDWELLER
Vote Not Returned: 1 CLIFFDWELLER Comment on Affirmative:
Comment on Affirmative: JACKSON: See my Affirmative with Comment on Comment 70E-1
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log (Log #2).
#2).

70E-52
Report on Comments — Copyright, NFPA
________________________________________________________________
70E-124 Log #126 Final Action: Reject
( Part 2, Appendix G )
________________________________________________________________
Submitter: Edward G. Jacobson Los Alamos, NM
Comment on Proposal No:70E-152
Recommendation: In the proposed Appendix G include a table or set of
bar graphs that show year-by-year for the past 10 or 20 years the number of
electrocutions resulting from contact with 120 VAC, with 208VAC, with 277/
480 with 4160, and with 13.8kV and above. ( A more detailed breakout above
480 might be useful if such data is available.) Include a similar table or graph
showing deaths and severe injuries resulting from arc blast and burns at the
various voltages for each year.
Substantiation: Most electrical workers are aware that muscle responses
to contact with 120, 208, and 480 are different and approach work involving
each with a somewhat different attitude. It would be useful if there were a
consolidated, easy-to-read source of injury data to help them evaluate the
relative hazards of each as actual matters of life and death. With itʼs ever
increasing complexity and additions of constraints on individual worker
freedom to make decisions, the benefits of 70E for electricians and other
electrical workers may be perceived as decreasing.
Committee Meeting Action: Reject
Committee Statement: The commentors recommendation offers no specific
proposed text that the committee can address and therefore is in violation of
NFPA Regulations Section 4-4.5.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-125 Log #32 Final Action: Reject
( Part 2, Appendix G )
________________________________________________________________
Submitter: Kathy Wilmer, Duke Power Co. / Rep. Edison Electric Institute
Comment on Proposal No:70E-153
Recommendation: Reject this proposal.
Substantiation: Edison Electric Institute opposes the committee action. The
proposed work permit contains a list of specific items that must be reviewed
and checked off prior to work. Management signature is required for all
energized work. This permit adds an unnecessary burden to employers who
choose to work on energized systems. Performing the items listed on the
permit is already required by the standard. Employers can ensure that those
requirements are achieved by a variety of means – procedures, work orders,
pre-job briefings, etc. The requirement for a specific, detailed written permit is
burdensome and unnecessary.
Committee Meeting Action: Reject
Committee Statement: The Committee re-affirms its position on Proposals
70E-63 and 70E-153. The use of an electrical work permit will enhance the
safety of employees working on or near energized conductors or equipment
by providing one additional administrative control that will reinforce the safe
work practices and procedures that must be employed for the perspective task.
The permit system should also reinforce the provision that the employer must
demonstrate that deenergizing the circuit or equipment is infeasible or would
create a greater hazard. The committee notes that Appendix G permit is only a
example and not a mandatory requirement.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 21 Negative: 3
Vote Not Returned: 1 CLIFFDWELLER
Explanation of Negative:
BINGHAM: See my Explanation of Negative on Comment 70E-62
(Log #30).
DOERING: Qualified electrical workers and their immediate supervisors
should b able to decide how to do a job. The introduction of a “Energized
Electrical Work Permit” appears to be an effort to make it so onerous to do
a job energized, based on the belief that such work presents an unacceptable
hazard, that every job will be done deenergized. Certainly companies that do
not have qualified electrical personnel may wish to institute such a procedure,
but it should not be a requirement. See my comments on 70E-62.
The committee members should vote negative on Comment 70E-125.
WILMER: EEI opposes the Committee Action. The Committee Action
should be Accept which would eliminate the new requirement for a written
permit for energized work. A new requirement for a detailed written permit
for all energized work is a burden to employers. Performing the items listed
on the permit is already required by standard. Employers can ensure that those
requirements are achieved by a variety of means - procedures, work orders,
pre-job briefings, etc. This proposal arbitrarily requires a written permit even
if employers have other satisfactory means of ensuring that the requirements
of the standard are being met. This requirement is an unnecessary burden on
employers.
70E-53
NFPA 70E
Comment on Affirmative:
CALLANAN: I agree with the action by the committee on this comment
and the Panel Statement supporting the action. I do not feel that a permit
system “adds an unnecessary burden to employers who chose to work on
energized systems” or “is burdensome and unnecessary” as suggested in the
substantiation. There are several significant issues addressed in the Panel
Statement that clearly demonstrate the commitment of the committee to the
permit system. These include recognizing that an electrical work permit “will
enhance the safety of employees ... by providing one additional administrative
control that will reinforce the safe work practices and procedures...”, and that
“ the permit system should also reinforce the provision that the employer must
demonstrate that deenergizing the circuit or equipment is infeasible or would
create a greater hazard.”
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-126 Log #71 Final Action: Accept
( Part 2, Apendix G, Table G-1 )
________________________________________________________________
Submitter: Vincent J. Saporita, Cooper Bussmann
Comment on Proposal No:70E-151
Recommendation: Reject this proposal and delete Table G-1.
Substantiation: This is a companion comment for 70E-98. If our comment
on 70E-98 is accepted, this material will be in the main text of the document
and not needed here in the Appendix.
Committee Meeting Action: Accept
Committee Statement: Due to action on Comment 70E-77 there is no longer
a need for proposed Appendix G.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
BINGHAM: I support the action of the committee. The table was added
within the body of the text and is not needed in Appendix G.
JACKSON: See my Affirmative with Comment on Comment 70E-1
(Log #2).
________________________________________________________________
70E-127 Log #34 Final Action: Hold
( Part 2, Appendix G, Table G-1 )
________________________________________________________________
Submitter: Edwin Scherry, PC&E
Comment on Proposal No:70E-151
Recommendation: 600V MCC needs to distinguish between Type I and Type
2 starter protection as described by IEC 947. (Exact wording would depend on
how results are presented)
Possibly: “Operate CB or fused switch or starter with enclosure doors open
- Type 2 starter only” — “Diagnostic testing, including voltage testing - Type 2
starter only” — “Working on live parts within starters on load side of starter...
Type 2 starter only” — “Work on control circuits while working near exposed
live parts >120V - Type 2 starter only”
In addition there should be more restrictive conditions on working Type 1
starters with doors open while the starter is live.
Substantiation: In MCCʼs below 600V, Type 1 protection allows damage to
the motor starter componente in their interruption of a downstream fault and
subsequently there could be particles or molten metal projected if the enclosure
is not closed. There should be a distinction between the two Types of starters
1 and 2. Type 2 starters does NOT allow damage to starter components so if a
failure would occur then only the arc flash would be the source of energy.
It is realized that PPE is not a level of protection for molten metal or other
foreign objects, however unless a distinction is made in the two Types of
starters personnel may forget that there is additional risk exposure for a Type 1
starter.
Committee Meeting Action: Hold
Committee Statement: This comment introduces new material that has not
had public review and should be placed on hold and become a proposal in the
next revision cycle.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
Report on Comments — Copyright, NFPA
________________________________________________________________
70E-128 Log #67 Final Action: Hold
( Part 2, Appendix G, Table G-1 )
________________________________________________________________
Submitter: Paul S. Hamer, Chevron Texaco Energy Research and
Technology Company
Comment on Proposal No:70E-151
Recommendation: Revise the table in Appendix G as shown on the following
pages.
These revisions are proposed due to the newly-issued IEEE Std 1584-2002,
IEEE Guide for Performing Arc-Flash Hazard Calculations, which the latest
information available for calculating arc-flash energy.
Substantiation: When the proposal was submitted, the only equations
available were those from the existing NFPA 70E-2000, Appendix B-5, and
those originating from the Lee equations. The equations from B-5 introduce
serious errors when applied outside the applicable range of 16 to 50 kA, which
was done for the original proposal. As part of this substantiation, see the
attached modified “Appendix G” table and the corresponding IEEE Std 1584
calculation spreadsheet. Following is a summary of the principal changes:
• Panelboards rated 240 V and below – All HRCs become “0” due to lower
calculated energies using IEEE 1584
• Panelboards or Switchboards rated >240 V and up to 600 V – First itemʼs
current increased to 75 kA correspond to upper limit of HRC 3. Second and
third itemʼs current reduced to 24 kA to stay within HRC 2.
• 600 V Class Motor Control Centers (MCCs) and Busways – Allowable
fault levels revised to correspond to the upper limits of HRC 4 and 5 with
common upstream 600 V clearing times of 0.33, 0.2, and 0.1 second.
• 600 V Class Switchgear – Allowable fault levels revised to correspond to
the upper limits of HRC 4 and 5 with common 600 V CB clearing times of 0.5,
0.33, 0.2, and 0.1 second. Recalculated 240V revenue meter energy.
• Other 600 V Class (277 V through 600 V, nominal) Equipment – One
HRC level changed. Allowable fault levels revised to correspond to the upper
limits of HRC 4 with common 600 V CB clearing times of 0.5, 0.33, 0.2, and
0.1 second.
• NEMA E2 (fused contactor) Motor Starters – Three HRC levels changed
and some recalculations made for energy. Allowable fault levels changed to 14
kA correspond to the upper limits of HRC 2.
• Metal Clad Switchgear – One proposed HRC change, but more background
levels given in the modified “Appendix G”
• Other Equipment 1 kV to 38 kV – Three HRC levels adjusted due to
calculation refinements, but more background guidance given in the modified
“Appendix G”
• Changed the asterisked footnote to refer to IEEE Std 1584-2000.
Committee Meeting Action: Hold
Committee Statement: The introduction of information from IEEE Std.
1584 (published in September 2002, after the publication of the ROP for 70E)
included in this comment has not had public review, therefore the Committee
Action is to “hold” the comment until the next revision cycle.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-129 Log #35 Final Action: Reject
( Part 2, Appendix XXX )
________________________________________________________________
Submitter: Edwin Scherry, PC&E
Comment on Proposal No:70E-157a
Recommendation: Discrepancy in results from Table B-2 Equations for
1000V to 5000V and for above 5000V. Possibly change equations.
Substantiation: The equations for Ei and Db are essentially the same for
1000V to 5000V and for above 5000V except for a multiplying factor, 21.8
and 16.5 respectively. These appear backward or in some other way incorrect
since it would seem that at a higher voltage the flash protection distance should
increase and so too should the incident energy.
Committee Meeting Action: Reject
Committee Statement: The commentors recommendation offers no specific
proposed text that the committee can address and therefore is in violation
of NFPA Regulations Section 4-4.5. The equations in question have been
replaced by Committee Action on Comment 70E-132 (Log #66).
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
70E-54
NFPA 70E
________________________________________________________________
70E-130 Log #56 Final Action: Reject
( Part 2, Appendix XXX )
________________________________________________________________
Submitter: Robert E. Downey, Allison Transmission
Comment on Proposal No:70E-157a
Recommendation: We recommend the committee consider a re-submission of
the material based on the final P1584 document. We have requested that Craig
Wellman provide his own independent comment in this regard.
Substantiation: The current material is based on the P1584 draft in use at the
time of the comment. If it is to be used, it needs to be updated to reflect the
published document.
Committee Meeting Action: Reject
Committee Statement: The commentors recommendation offers no specific
proposed text that the committee can address and therefore is in violation of
NFPA Regulations Section 4-4.5.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
________________________________________________________________
70E-131 Log #114 Final Action: Reject
( Part 2, Appendix XXX )
________________________________________________________________
Submitter: Mary Capelli-Schellpfeffer, CapShell, Inc.
Comment on Proposal No:70E-157a
Recommendation: I strongly disagree with the Committee Action to Accept
this proposal. I recommend Annex XXX be deleted in its entirety.
Substantiation: The Annex text specifically states ”Electrode gap, electrode
configuration, system x/R, box dimensions, and box electrode gap had no
statistical correlation to arcing current, arching voltage, or energy.” If there
was no relationship to these critical features of an arc event, there seems to
be no scientific validity to them pursuing even more information thru the use
of graphs, curve fits equations or other data manipulation. It is not legitimate
to pretend the calculations proposed fit the industrial case workers may face
without stronger experimental design, testing, and then validation to other than
laboratory conditions.
Committee Meeting Action: Reject
Committee Statement: The committee recognizes that the material in the
annex is not mandatory, but it does provide guidance.
Number Eligible to Vote: 25
Ballot Results: Affirmative: 24
Vote Not Returned: 1 CLIFFDWELLER
Comment on Affirmative:
CALLANAN: I agree with the Committee Action not to delete Annex XXX
in its entirety as recommended by the submitter of this comment, and with
the Committee Statement that recognizes that the information in the annex
provides guidance and is not mandatory. However, I feel that submitter of
this comment alerts us to some significant issues that need to be addressed.
Unfortunately the proposed words to make this annex more technically correct
are not provided in the recommendation.
JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
#2).
 Table G-1 Background for Hazard/Risk Category Selections of Part II, Table 3-3.9.1
Task (Assumes Equipment Is Energized, and Work ASSUMED SC ARC ENERGY HAZARD Hazard/ Risk SUBSTANTIATION FOR V-rated V-rated
Is Done Within the Flash Protection Boundary) CURRENT AND AND RISK ASSESSMENT * Category SELECTION OF HAZARD/RISK Gloves Tools
DURATION * CATEGORY
Panelboards rated 240 V and below – Notes 1 and 3 — — — — — —

Operate circuit breaker (CB) or fused switch with 42 kA, 2 cycles 3.8 2 cal, risk extremely low 0 Energy low and risk extremely low → N N
covers on reduce -3 from HC 1

Operate CB or fused switch with covers off 42 kA, 2 cycles 3.8 2 cal, risk low 0 Energy low and risk very low → reduce N N
-1 from HC 1
Report on Comments — Copyright, NFPA

Work on exposed live parts, including voltage testing 42 kA, 2 cycles 3.8 2 cal, risk moderate 10 Energy low and risk moderate → HC Y* Y
1 0. Insulating gloves/tools required,
as applicable, if the restricted approach
boundary is likely to be breached.

Remove/install CBs or fused switches 42 kA, 2 cycles 3.8 2 cal, risk moderate 10 Energy low and risk moderate → HC 1 Y Y
0. Insulating gloves/tools required due to
the nature of the task.

70E-55
Remove bolted covers (to expose uncover exposed live 42 kA, 2 cycles 3.8 2 cal, risk moderate 10 Energy low and risk moderate → HC 1 0 N N
parts)

Open hinged covers (to expose uncover exposed live 42 kA, 2 cycles 3.8 2 cal, risk extremely low 0 Energy low and risk extremely low → N N
parts) with hinges reduce -3 from HC 1

Work on exposed live parts of utilization equipment fed 42 kA, 2 cycles 3.8 2 cal, risk moderate 10 Energy low and risk moderate → HC Y* Y
directly by a branch circuit of the panelboard 1 0. Insulating gloves/tools required,
as applicable, if the restricted approach
boundary is likely to be breached.

Panelboards or Switchboards rated >240 V and — — — — — —

up to 600 V (with molded case or insulated case
circuit breakers or fused switches) — Notes 1 and 3
(Except as indicated)
NFPA 70E
 Table G-1 Background for Hazard/Risk Category Selections of Part II, Table 3-3.9.1
Operate CB or fused switch with covers on 36 75 kA, 0.1 second 8 25 cal, risk extremely low 0 Energy low and risk extremely low → N N
(line-side exposure) reduce -3 from HC 2 3

Operate CB or fused switch with covers off 36 24 kA, 0.1 second 8 cal, risk low 1 Risk low → reduce -1 from HC 2 N N
(line-side exposure)

Work on exposed live parts, including voltage testing 36 24 kA, 0.1 8 cal, risk moderate 2 Risk moderate → HC 2. Insulating Y Y
(maximum of 36 24 kA for 0.1 sec, main bus exposure) second (line-side gloves/tools required due to the nature
Report on Comments — Copyright, NFPA

exposure) of the task.

Work on exposed live parts of utilization equipment 42 kA, 2 cycles 3.8 4.6 cal, risk moderate 1 Energy low and risk moderate → HC 1. Y Y
fed directly by a branch circuit of the panelboard or Insulating gloves/tools required due to
switchboard the nature of the task.

600 V Class Motor Control Centers (MCCs) and — — — — — —

Busways – Notes 2 (except as indicated) and 3

70E-56
Operate CB or fused switch or starter with enclosure 65 kA, 1 to 2 cycles 5 4 to 10 8 cal, risk extremely 0 Risk extremely low → reduce -3 from N N
doors closed low HC 3 2

Read a panel meter while operating a meter switch 65 kA, 1 to 2 cycles 5 4 to 10 8 cal, risk extremely 0 Risk extremely low → reduce -3 from N N
low HC 3
Operate CB or fused switch or starter with enclosure 65 kA, 1 to 2 cycles 5 4 to 10 8 cal possible, risk 2 Risk moderate → HC 2 N N
doors open moderate

Diagnostic testing, including voltage testing -- Note 5 65 kA, 0.2 sec 67 43 cal, see note 5, risk very 2 Risk very low → reduce -2 from HC 4, Y Y
low consider note 5. Insulating gloves/tools
required due to the nature of the task.
NFPA 70E
 Table G-1 Background for Hazard/Risk Category Selections of Part II, Table 3-3.9.1 (continued)
Work on exposed live parts within starters on the load 65 kA, 0.5 to 2 2 to 11 8 cal possible, see note 2 Risk moderate → HC 2 -- fault clearing Y Y
side of the starter or on the load side of a busway cycles 5, risk moderate likely to be ~ 1 cycle. Insulating gloves/
switchʼs short circuit protective device. Includes tools required due to the nature of the
voltage testing -- Note 5 task.

Work on exposed live parts on the main MCC bus 42 36 kA for 0.33 40 cal, risky 4 Risky → HC 4. Insulating gloves/tools Y Y
(maximum of 42 36 kA for 0.33 sec, 52 60 kA for 0.2 sec, 52 60 kA for 0.2 required due to the nature of the task.
sec, or 65 120 kA for 0.1 sec) -- Note 4 sec, or 65 120 kA for
0.1 sec

Work on exposed live parts on the main MCC bus 62 92 kA for 0.33 100 cal, risky 5 Risky → HC 5 Y Y
(maximum of 62 92 kA for 0.33 sec, 76 150 kA for 0.2 sec, 76 150 kA for Note 7 This type of work at these energy levels
sec, or 102 200 kA for 0.1 sec) -- Note 4 0.2 sec, or 102 200 not recommended with present designs
Report on Comments — Copyright, NFPA

kA for 0.1 sec and engg practices. Insulating gloves/

tools required due to the nature of the
task.

Work on control circuits while working near exposed < 10 kA, 1 to 2 < 1.2 cal, risk extremely low 0 Risk extremely low → reduce -3 from Y* Y
live parts 120 V or below cycles HC 0. Insulating gloves/tools required,
as applicable, if the restricted approach
boundary is likely to be breached

70E-57
Work on control circuits while working near exposed 65 kA, 0.5 to 2 2 to 11 8 cal, risk moderate 2 Risk moderate → HC 2. Insulating Y Y
live parts >120 V cycles gloves/tools required due to the nature
of the task.

Insert or remove individual starter “buckets” from 42 36 kA for 0.33 40 cal, risky 4 Risky → HC 4. Insulating gloves Y N
MCC, or plug-in devices from busway (maximum of 42 sec, 52 60 kA for required due to the nature of the task.
36 kA for 0.33 sec52 60 kA for 0.2 sec, or 65 120 kA 0.2 sec, or 65 120
for 0.1 sec)— Note 4 kA for 0.1 sec

Insert or remove individual starter “buckets” from 62 92 kA for 0.33 100 cal, risky 5 Risky → HC 5 Y N
MCC, or plug-in devices from busway (maximum of 62 sec, 76 150 kA for Note 7 This type of work at these energy levels
92 kA for 0.33 sec, 76 150 kA for 0.2 sec, or 102 200 0.2 sec, or 102 200 not recommended with present designs
kA for 0.1 sec)— Note 4 kA for 0.1 sec and engg practices. Insulating gloves
required due to the nature of the task.

Apply safety grounds, after voltage test See above Up to 100 cal, risk extremely 2 Risk extremely low → reduce -3 from Y N
low after test HC 5. Insulating gloves required due to
the nature of the task.
NFPA 70E
 Table G-1 Background for Hazard/Risk Category Selections of Part II, Table 3-3.9.1 (continued)
Remove bolted covers (to expose uncover exposed live See above Up to 100 cal, risk low 4 Risk low → reduce -1 from HC 4 or 5 N N
parts)

Open hinged covers (to expose uncover exposed live See above Up to 100 cal, risk extremely 2 Risk extremely low → reduce -3 from N N
parts) low with hinges HC 4 or 5

Work on exposed live parts of utilization equipment fed 65 kA, 0.5 to 2 2 to 11 8 cal, risk moderate 2 Risk moderate → HC 2. Insulating Y Y
directly by a branch circuit of the MCC or busway cycles gloves/tools required due to the nature
of the task.
600 V Class Switchgear (with power circuit breakers — — — — — —
or fused switches) — Note 6

Operate CB or fused switch with enclosure doors closed

Report on Comments — Copyright, NFPA

52 68 kA for 0.5 sec, Up to 100 cal, risk extremely 0 Risk extremely low → reduce -3 from N N
62 104 kA for 0.33 low HC 5, plus allow for shielding from
sec, 76 175 kA for hazard by closed and latched door and
0.2 sec, or 102 200 distance from hazard is > 18 inches
kA for 0.1 sec

Read a panel meter while operating a meter switch < 10 kA, 1 to 2 < 1.2 cal, risk extremely low 0 Energy low, risk extremely low N N
cycles
Operate CB with enclosure doors open 52 68 kA for 0.5 sec, Up to 100 cal, risk very low 2 Risk very low, distance from hazard is > N N
62 104 kA for 0.33 and CB is “dead front” 18 inches → reduce -3 from HC 5

70E-58
sec, 76 175 kA for
0.2 sec, or 102 200
kA for 0.1 sec

Operate fused switch with enclosure doors open See above Up to 100 cal, risk moderate 5 Risk moderate → HC 5 N N
Note 7 This type of work at these energy levels
not recommended with present designs
and engg practices

Work on exposed live parts, (maximum of 35 26 kA for 35 26 kA for 0.5 sec, Up to 40 cal, risk moderate 4 Risk moderate → HC 4. Insulating Y Y
0.5 sec, 42 40 kA for 0.33 sec, 52 67 kA for 0.2 sec, or 42 40 kA for 0.33 gloves/tools required due to the nature
65 135 kA for 0.1 sec) -- Note 4 sec, 52 67 kA for 0.2 of the task.
sec, or 65 135 kA for
0.1 sec

Work on exposed live parts, (maximum of 68 kA for 52 68 kA for 0.5 sec, Up to 100 cal, risk moderate 5 Risk moderate → HC 5 Y Y
0.5 sec, 62 104 kA for 0.33 sec, 76 175 kA for 0.2 sec, 62 104 kA for 0.33 Note 7 This type of work at these energy levels
or 102 200 kA for 0.1 sec) – Note 4 (Note 6 does not sec, 76 175 kA for not recommended with present designs
apply) 0.2 sec, or 102 200 and engg practices. Insulating gloves/
kA for 0.1 sec tools required due to the nature of the
task.
NFPA 70E
 Table G-1 Background for Hazard/Risk Category Selections of Part II, Table 3-3.9.1 (continued)
Diagnostic testing, including voltage testing -- Note 5 Wide range Up to 100 cal, see Note 5, risk 2 Risk very low → reduce -2 from HC 4 Y Y
very low or 5; consider Note 5. Insulating gloves/
tools required due to the nature of the
task.

Work on control circuits while working near exposed < 10 kA, 1 to 2 < 1.2 cal, risk extremely low 0 Energy low and risk extremely low. Y* Y
live parts 120 V or below cycles Insulating gloves/tools required, as
applicable, if the restricted approach
boundary is likely to be breached.

Work on control circuits while working near exposed Wide range Up to 100 cal, see Note 5, risk 2 Risk very low → reduce -2 from HC Y Y
live parts >120 V-- Note 5 very low 4 or 5; consider Note 5. Insulating
Report on Comments — Copyright, NFPA

gloves/tools required due to the nature

of the task.

Insert or remove (rack) CBs from cubicles, doors open 35 26 kA for 0.5 sec, 40 cal, risk moderate 4 Risk moderate → HC 4 N N
or closed , (maximum of 35 26 kA for 0.5 sec, 42 40 kA 42 40 kA for 0.33
for 0.33 sec, 52 67 kA for 0.2 sec, or 65 135 kA for 0.1 sec, 52 67 kA for 0.2
sec) -- Note 4 sec, or 65 135 kA for
0.1 sec

70E-59
Insert or remove (rack) CBs from cubicles, doors open 52 68 kA for 0.5 sec, 100 cal, risk moderate 5 Risk moderate → HC 5 N N
or closed (maximum of 68 kA for 0.5 sec, 62 104 kA 62 104 kA for 0.33
for 0.33 sec, 76 175 kA for 0.2 sec, or 102 200 kA for sec, 76 175 kA for
0.1 sec) -- Note 4 (Note 6 does not apply) 0.2 sec, or 102 200
kA for 0.1 sec

Apply safety grounds, after voltage test See above Up to 100 cal, risk extremely 2 Risk extremely low → reduce -3 from Y N
low after test HC 5. Insulating gloves required due to
the nature of the task.

Remove bolted covers (to expose uncover exposed live See above Up to 100 cal, risk low 4 Risk low → reduce -1 from HC 4 or 5 N N
parts)

Open hinged covers (to expose uncover exposed live See above Up to 100 cal, risk extremely 2 Risk extremely low → reduce -3 from N N
parts) low with hinges HC 4 or 5

Work on exposed live parts of utilization equipment 50 72 kA for 2 cycles 6 8 cal, risk moderate 2 Risk moderate → HC 2. Insulating Y Y
fed directly by a feeder circuit of the switchgear with gloves/tools required due to the nature
instantaneous fault protection of the task.
NFPA 70E
 Table G-1 Background for Hazard/Risk Category Selections of Part II, Table 3-3.9.1 (continued)
Other 600 V Class (277 V through 600 V, nominal) — — — — — —
Equipment

Lighting or small power transformers (600 V, — — — — — —

maximum)

-- Remove bolted covers (to expose uncover 65 75 kA for 0.1 sec 40 cal, risk low 32 Risk low → reduce -1 from HC 4 3 N N
exposed live parts)

-- Open hinged covers (to expose uncover 65 75 kA for 0.1 sec 40 cal, risk extremely low 1 Risk extremely low → reduce -3 from N N
exposed live parts) with hinges HC 4
Report on Comments — Copyright, NFPA

-- Work on exposed live parts (maximum Up to 52 kA for 0.2 Up to 40 cal, risk moderate 4 Risk moderate → HC 4. Insulating Y Y
short circuit at primary voltage of 35 24 kA sec, or 65 kA for gloves/tools required due to the nature
for 0.5 sec, 42 36 kA for 0.33 sec, 52 60 0.1 sec of the task.
kA for 0.2 sec, or 65 120 kA for 0.1 sec) - 24 kA for 0.5 sec,
- Note 4 36 kA for 0.33 sec,
60 kA for 0.2 sec, or
120 kA for 0.1 sec
-- Diagnostic testing, including voltage Wide range Up to 100 cal, see Note 5, risk 2 Risk very low → reduce -2 from HC Y Y
testing – Note 5 very low 4 or 5; consider Note 5. Insulating

70E-60
gloves/tools required due to the nature
of the task.

-- Apply safety grounds, after voltage test See above Up to 100 cal, risk extremely 2 Risk extremely low → reduce -3 from Y N
low after test HC 5. Insulating gloves required due to
the nature of the task.

Insert or remove revenue meters (kW-hour, at primary 50 45 kA for 0.5 sec, Up to ~ 40 cal, risk very low if 2 Risk very low → reduce -2 from HC Y N
voltage and current) open air arc load disconnected 4. Insulating gloves required due to the
nature of the task
.

Insert or remove revenue meters (kW-hour, at primary 16 kA for 1 sec, open Up to ~ 20 14 cal, risk very 1 Risk very low → reduce -2 from HC Y N
voltage and current) -- Applicable to 240 volt, single- air arc low if load disconnected 3. Insulating gloves required due to the
phase services nature of the task.

Remove or install auxiliary gutter or wireway cover, Wide range Risk very low 1 Risk very low → reduce -2 from HC 3 N N
with no exposure hazard of exposed live parts

Remove or install miscellaneous equipment cover, with Wide range Risk very low 1 Risk very low → reduce -2 from HC 3 N N
no exposure hazard of exposed live parts
NFPA 70E
 Table G-1 Background for Hazard/Risk Category Selections of Part II, Table 3-3.9.1 (continued)
Work on exposed live parts, including voltage testing 35 24 kA for 0.5 sec, 40 cal, risk moderate 4 Risk moderate → HC 4. Insulating Y Y
(maximum short circuit at primary voltage of 35 24 kA 42 36 kA for 0.33 gloves/tools required due to the nature
for 0.5 sec, 42 36 kA for 0.33 sec, 52 60 kA for 0.2 sec, sec, 52 60 kA for 0.2 of the task.
or 65 120 kA for 0.1 sec) -- Note 4 sec, or 65 120 kA for
0.1 sec

Diagnostic testing, including voltage testing -- Note 5 Wide range Up to 100 cal, see Note 5, risk 2 Risk very low → reduce -2 from HC Y Y
very low 4 or 5; consider Note 5. Insulating
gloves/tools required due to the nature
of the task.

Apply safety grounds, after voltage test Wide range Up to 100 cal, risk extremely 2 Risk extremely low → reduce -3 from Y N
low after test HC 5. Insulating gloves required due to
Report on Comments — Copyright, NFPA

the nature of the task.

NEMA E2 (fused contactor) Motor Starters, 2.3 kV — — — — — —

through 7.2 kV

Operate contactor with enclosure doors closed 55 kA, 0.5 cycle Up to 2 < 1.2 cal, risk 0 Energy low, risk extremely low N N
extremely low

Read a panel meter while operating a meter switch < 10 kA, 1 to 2 < 1.2 cal, risk extremely low 0 Energy low, risk extremely low N N

70E-61
cycles
Operate contactor with enclosure doors open 55 kA, 0.5 cycle or 2 cal (risk moderate) to 85 35 2 Risk extremely low for high-energy N N
up to 55 kA, 0.35 cal (risk extremely low) exposure → reduce -3 from HC 5
sec (if line side
involved)

Diagnostic testing, including voltage testing 55 kA, 0.5 cycle Up to 2 < 1.2 cal, risk 2 Risk moderate and higher energy Y Y
moderate exposure possible → HC 2. Insulating
gloves/tools required due to the nature
of the task.

Work on exposed live parts 55 kA, 0.5 cycle Up to 2 < 1.2 cal, risky 3 Risky and higher energy exposure Y Y
possible → HC 3. Insulating gloves/
tools required due to the nature of the
task.
NFPA 70E
 Table G-1 Background for Hazard/Risk Category Selections of Part II, Table 3-3.9.1 (continued)
Work on control circuits while working near exposed < 10 kA, 1 to 2 < 1.2 cal, risk extremely low 0 Energy low and risk extremely low. Y* Y
live parts 120 V or below cycles Insulating gloves/tools required, as
applicable, if the restricted approach
boundary is likely to be breached.

Work on control circuits while working near exposed 55 kA, 0.5 cycle Up to 2 < 1.2 cal, risk 3 Work proximity could be closer than Y Y
live parts >120 V moderate 36 inches and risk moderate → HC 3.
Insulating gloves/tools required due to
the nature of the task.
Report on Comments — Copyright, NFPA

Insert or remove (rack) starters from cubicles, doors 55 kA, 0.35 sec Up to 85 35 cal, risk moderate 45 Risk moderate → HC 4 5 N N
open or closed –maximum upstream fault and clearing Note 8
time 55 kA for 0.35 sec

Insert or remove (rack) starters from cubicles, doors 25 14 kA, 0.35 sec Up to 40 8 cal, risk moderate 24 Risk moderate → HC 2 4 N N
open or closed – maximum upstream fault and clearing Note 8
time 25 14 kA for 0.35 sec

Apply safety grounds, after voltage test 55 kA, 0.35 sec Up to 85 35 cal, risk 2 Risk extremely low → reduce -3 from Y N

70E-62
extremely low after test HC 5. Insulating gloves required due to
the nature of the task.

Remove bolted covers (to expose uncover exposed live 55 kA, 0.35 sec Up to 85 35 cal, risk moderate 4 to 5 Risk moderate → HC 4 or 5 N N
parts) Note 7

Open hinged covers (to expose uncover exposed live 55 kA, 0.35 sec Up to 85 35 cal, risk 2 Risk extremely low → reduce -3 from N N
parts) extremely low with hinges HC 4 or 5

Work on exposed live parts of utilization equipment 55 kA, 0.5 cycle Up to 2 < 1.2 cal, risk 1 Energy low and risk moderate → HC 1 Y Y
(e.g., motor or transformer) fed directly from the starter moderate

Metal Clad Switchgear, 1 kV to 38 kV — — — — — —

Operate CB or fused switch with enclosure doors closed Wide range Up to 100 cal, risk extremely 2 Risk extremely low → reduce -3 from N N
low Note 8 HC 5
NFPA 70E
 Table G-1 Background for Hazard/Risk Category Selections of Part II, Table 3-3.9.1 (continued)
Read a panel meter while operating a meter switch < 10 kA, 1 to 2 < 1.2 cal, risk extremely low 0 Energy low, risk extremely low N N
cycles
Operate CB or fused switch with enclosure doors open Wide range – 40 to 100 105 cal, risk low to 4 to 5 Risk moderate → HC 5 at 100 cal N N
31.5 kA, 40 kA, moderate Note 7 exposure level
and 50 kA short 38 kV Class (0.1 sec) – 65 to This type of work at these energy levels
circuit ratings for 105 cal (HC 5) not recommended with present designs
all voltages. 0.1 sec 15 kV Class (0.7 sec) – 38 to and engg practices
duration for 38 kV 62 cal (HC 4 to 5)
and 0.7 sec for other 5 kV Class (0.7 sec) –
voltages 34 to 55 cal (HC 4 to 5)
Work on exposed live energized parts, including voltage Wide range Up to 100 cal, risky, see above 4 to 5 Risky → HC 5 at 100 cal exposure level Y Y
Report on Comments — Copyright, NFPA

testing – Note 5 (see above) and Note 5 This type of work at these energy levels
not recommended with present designs
and engg practices. Insulating gloves/
tools required due to the nature of the
task.

Work on control circuits while working near exposed < 10 kA, 1 to 2 < 1.2 cal, risk extremely low 0 Energy low and risk extremely low. Y* Y
live parts 120 V or below cycles Insulating gloves/tools required, as
applicable, if the restricted approach
boundary is likely to be breached.

70E-63
Work on control circuits while working near exposed Wide range 40 to 100 cal, risk moderate 4 to 5 Risk moderate → HC 5 at 100 cal Y Y
live parts >120 V (see beginning of Note 7 exposure level
this section) This type of work at these energy levels
not recommended with present designs
and engg practices. Insulating gloves/
tools required due to the nature of the
task.

Insert or remove (rack) CBs from cubicles, doors open Wide range 40 to 100 cal, risk moderate 5 Risk moderate → HC 5 at 100 cal N N
or closed (see beginning of Note 8 exposure level
this section) “Open door” work at these energy levels
not recommended with present designs
and engg practices

Apply safety grounds, after voltage test Wide range Up to 100 cal, risk extremely 2 Risk extremely low → reduce -3 from Y N
(see beginning of low after test HC 5. Insulating gloves required due to
this section) the nature of the task.
NFPA 70E
 Table G-1 Background for Hazard/Risk Category Selections of Part II, Table 3-3.9.1 (continued)
Remove of bolted covers (to expose uncover exposed Wide range Up to 100 cal, risk moderate 4 to 5 Risk moderate → HC 4 or 5 N N
live parts) (see beginning of Note 7
this section)
Open hinged covers (to expose uncover exposed live Wide range Up to 100 cal, risk extremely 2 Risk extremely low → reduce -3 from N N
parts) (see beginning of low with hinges HC 4 or 5
this section)
Open voltage transformer or control power transformer Wide range Up to 100 cal, risk moderate 5 Risk moderate → HC 4 or 5 N N
compartments (see beginning of
this section)

Work on exposed live parts of utilization equipment 40 kA, 0.1 sec Up to 40 84 cal at 34.5 kV, 7 24 Risk moderate → HC 4 or 2. Insulating Y Y
Report on Comments — Copyright, NFPA

(e.g., motor or transformer) fed directly from a feeder cal at 13.8 kV, and 6 cal at 4.16 gloves/tools required due to the nature of
circuit breaker -- up to and including 15 kV Class kV; risk moderate the task. Task not recommended above
equipment 15 kV Class.

Other Equipment 1 kV to 38 kV — — — — — —

Metal enclosed load interrupter switches, fused or — — — — — —

unfused

70E-64
-- Operate switch, doors closed 40 kA, 0.35 sec Up to 300 cal at 34.5 kV, up to 2 Risk extremely low → reduce -3 from N N
118 25 cal at 13.8 kV, 22 cal at Note 8 HC 5, , plus allow for shielding from
4.16 kV; risk extremely low hazard by sheet metal enclosure

--Work on exposed live energized parts,
including voltage testing
40 kA, 0.35 sec Up to 300 cal at 34.5 kV, up to
118 25 cal at 13.8 kV, and 22
cal at 4.16 kV; risk high -- see
Note 5
4 3 to 5 Risky → HC 5 at 100 cal exposure level Y Y
This type of work at these energy levels
not recommended with present designs
and engg practices. Insulating gloves/
tools required due to the nature of the
task.

-- Remove bolted covers - up to and
including 15 kV Class equipment (to expose
uncover exposed live bare, energized parts)
-- Open hinged covers (to expose uncover
exposed live bare, energized parts)
40 kA, 0.35 sec Up to 300 cal at 34.5 kV, up to
118 25 cal at 13.8 kV, and 22
cal at 4.16 kV; risk moderate
40 kA, 0.35 sec Up to 300 cal at 34.5 kV, up to
118 25 cal at 13.8 kV, and 22
cal at 4.16 kV;, risk extremely
low with hinges
4 3 to 5 Risk moderate → HC 4 or 3 N N
Note 7 This type of work at the 38 kV Class
energy levels not recommended with
present designs and engg practices.
3 Risk extremely low → reduce -3 from N N
HC 4 or 5, plus allow for shielding from
hazard by sheet metal
NFPA 70E
 Table G-1 Background for Hazard/Risk Category Selections of Part II, Table 3-3.9.1 (continued)
Operate outdoor disconnect switch (hookstick operated) 40 kA, 0.35 sec Up to 30 74 cal at 34.5 kV, and 3 Risk low → reduce -1 from HC 4. Y Y
30 cal at lower voltages; risk Insulating gloves/tools required due to
low and distance at least 6 feet the nature of the task.

Operate outdoor disconnect switch operation (gang- 40 kA, 0.35 sec Up to 10 cal, risk low and 2 Risk low → reduce -1 from HC 3. Y N
operated, from grade) distance is great (assumed 10 Insulating gloves required due to the
feet) nature of the task.

Examine insulated cable, in manhole or other confined Wide range of energy and 4 Risk moderate → HC 4 or 5. Insulating Y N
Report on Comments — Copyright, NFPA

space confined space, risk moderate Note 7 gloves required due to the nature of the
task.
Examine insulated cable, in open area Wide range of energy, risk low 2 Risk low → reduce -1 from HC 3. Y N
Insulating gloves required due to the
nature of the task.
* All LV incident arc energies calculated using the techniques given in IEEE Std 1584-2002. “arc in a box” equation at 18 inches (unless noted) and HV incident arc energy calculated
using E = (793*I*kV*t) / D2 at 36 inches. This equation does not appear in this form in NFPA 70E. However, a derivation does appear in 2-1.3.3.2. The equation above yields the
equation in 2-1.3.3.2 by converting inches to feet, setting E = to 1.2 cal/cm2 and solving for the distance.

70E-65
Legend:
V-rated Gloves are gloves rated and tested for the maximum line-to-line voltage upon which work will be done.
V-rated Tools are tools rated and tested for the maximum line-to-line voltage upon which work will be done.

Y* See Part II, 3-3.6 for required use of rubber insulating gloves
Y = yes (required)
N = no (not required)
Notes:
1. 42 kA short circuit current available, 0.03 second (2 cycle) fault clearing time.
2. 65 kA short circuit current available, 0.03 second (2 cycle) fault clearing time.
3. For < 10 kA short circuit current available, the Hazard/Risk Category required may be reduced by one
Number.
4. The listed fault current and upstream protective device clearing times are based on an 18-inch working distance
5. Hazard/Risk Category takes into account the provision of Part II, 3-3.9.4.6 (interference). During the listed diagnostic testing, there is 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 on exposed live parts,
as with tools. A job safety analysis may indicate that a higher category of PPE is required.
6. For < 25 kA short circuit current available, the Hazard/Risk Category required may be reduced by one
Number.
7. A job safety analysis is required to justify that this task be done with the equipment energized.
8. 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.
NFPA 70E
Report on Comments — Copyright, NFPA NFPA 70E
________________________________________________________________ En is incident energy (J/cm2) normalized for time and distance
70E-132 Log #66 Final Action: Accept in Principle K1 is-0.792 for open configurations (no enclosure) and
( Part 2, Appendix XXX ) is 0.555 for box configurations (enclosed equipment)
________________________________________________________________ K2 is 0 for ungrounded and high-resistance grounded systems and
Submitter: Daniel R. Neeser, Cooper Bussmann
Comment on Proposal No:70E-157a is 0.113 for grounded systems
Recommendation: Replace the recommended “Sample Calculation of G is the gap between conductors (mm) (see Table 1)
Incident Energy and Flash Protection Boundary” (entire Proposal) with the
following: Then:

Part II, Annex B, Sample Calculation of Incident Energy and Flash En=10lgEn (5)
Protection Boundary
This annex is not a part of the requirements of this NFPA document but is Finally, convert from normalized:
included for informational purposes only.
B.1 Ranges of Models. The empirically derived model, based upon statistical
analysis and curve fitting programs, is applicable for systems with:
⎛ t ⎞ ⎛ 610 x ⎞
E = 4.184C f E n ⎜ ⎟ ⎜ x ⎟
⎝ 0.2⎠ ⎝ D ⎠
— Voltages in the range of 208 V-15 000 V, three-phase. (6)
— Frequencies of 50 Hz or 60 Hz.
— Bolted fault current in the range of 700 A-106 000 A. where
— Grounding of all types and ungrounded.
— Equipment enclosures of commonly available sizes. E is incident energy (J/cm2)
— Gaps between conductors of 13 mm-152 mm. Cf is a calculation factor
— Faults involving three phases. 1.0 for voltages above 1kV, and
1.5 for voltages at or below 1kV
A theoretically derived model is applicable for three-phase systems in open En is incident energy normalized
air substations, and open air transmission and distribution systems. This model t is arcing time (seconds)
is intended for applications where faults will escalate to three-phase faults. D is distance from the possible arc point to the person (mm)
Where this is not possible or likely, this model will give a conservative result. x is the distance exponent from Table 1
Where single-phase systems are encountered, this model will provide conserva-
tive results. The other cases are handled similarly.

B.2 Arcing Current. The predicted three-phase arcing current must be found B.4 Incident Energy – Theoretical Method. For cases where voltage is
so the operating time for protective devices can be determined. over 15 kV, or gap is outside the range of the model, the theoretically derived
For applications with a system voltage under 1000 V solve the equation (1): method can be applied.

1g Ia=K+ 0.662 lgIbf+ 0.0966 V+ 0.000526 G + 0.5588 V(lg Ibf)-0.00304 G (lg Table 1-Factors for equipment and voltage classes
Ibf) (1) System voltage Equipment type Typical gap Distance x
(kV) between conduc- factor
Where tors (mm)
Open air 10-40 2.000
Switchgear 32 1.473
lg is the log10 MCC and panels 25 1.641
0.208-1 Cable 13 2.000
Ia is arcing current (kA) Open air 102 2.000
K is-0.153 for open configurations and >1-5 Switchgear 13-102 0.973
Cable 13 2.000
is-0.097 for box configurations Open air 13-153 2.000
Ibf phase faults (symmetrical rms) (kA) >5-15 Switchgear 153 0.973
Cable 13 2.000
V is system voltage (kV)
G is the gap between conductors, (mm) (see Table 1)
⎛ t ⎞
E = 2.142 × 106 VIbf ⎜ 2 ⎟
For applications with a system voltage of 1000 V and higher solve the equa- ⎝D ⎠
tion (2): (7)

1gIa= 0.00402+0.983 lg Ibf (2) where

The high-voltage case makes no distinction between open and box configura- E is incident energy (J/cm2)
tions. V is system voltage (kV)
Convert from lg: t is arcing time (seconds)
D is distance from possible arc point to person (mm)
Ibf is bolted fault current
Ia = 10lgIa (3)
For voltages over 15 kV, arc fault current is considered to be equal to the
Calculate a second arc current equal to 85 percent of Ia, so that a second arc bolted fault current.
duration can be determined. This second arc current accounts for variations
in the arcing current and the time for the overcurrent device to open. Incident B.5 Flash-Protection Boundary. For the empirically derived model:
energy is calculated using both values (Ia and .85Ia) and the higher value is
1
utilized.
⎡ ⎛ t ⎞ ⎛ 610 ⎞ ⎤ x
x

B.3 Incident energy – Empirically derived method. First find the log10 of DB = ⎢ 4.184Cf E n ⎜ ⎟ ⎜ ⎥
the incident energy normalized. This equation is based on data normalized ⎢⎣ ⎝ 0.2⎠ ⎝ EB ⎟⎠ ⎥
⎦ (8)
for an arc time of 0.2 seconds and a distance from the possible arc point to the
person of 610 mm.
For the theoretically derived method:
lg En=K1+K2+ 1081 lg Ia+ 0.0011 G (4)

where

70E-66
Report on Comments — Copyright, NFPA NFPA 70E
E = 4.184(0.0143Ibf2-1.3919Ibf + 34.045) (16)

For Ibf, such that 44.1 kA < Ibf < 106 kA, E=1.63
(9)
For Ibf > 106 kA, contact manufacturer for information.
where
(D) Equatins for Class L fuses 601 A-800 A
DB is the distance of the boundary fromm the arcing point (mm)
Cf is a calculation factor For Ibf , 15.7 kA, calculate arcing current and use time-current curves to
1.0 for voltages above 1 kV, and determine energy.
1.5 for voltages at or below 1 kV,
En is incident energy normalized For Ibf, such that 15.7 kA < Ibf < 44.1,
EB is incident energy in J/cm2 at the boundary distance
t is time (seconds) E = 4.184 (-0.0601 Ibf+2.8992) (17)
x is the distance exponent from Table 1
Ibf is bolted fault current For Ibf, such that 44.1 kA , Ibf< 106 kA, E = 1.046

EB can be set at 5.0 J/cm2 for bare skin (no hood) or at the rating of proposed For Ibf > 106 kA, contact manufacturer for information.
PPE.
(E) Equatins for class RK1 fuses 401 A-600 A
B.6 Current Limiting Fuses. Formulae for calculating arc-flash energies for
use with current-limiting Class L and Class RK1 fuses have been developed. For Ibf < 8.5 kA, calculate arcing current and use time-current curves to
These formulae were developed based upon testing at 600 v and a distance of determine energy.
455 mm using one manufacturerʼs fuses. The variables are as follows:
For Ibf, such that 8.5 kA < Ibf < 14 kA,
Ibf is bolted fault current for three-phase faults (symmetrical RMS)(kA)
E is incident energy (J/cm2). E = 4.184 (-3.0545 Ibf + 43.364) (18)

(A) Equations for Class L fuses 1601 A-2000 A For Ibf, such that 14 kA < Ibf< 15.7 kA, E=2.510

For Ibf<22.6 kA, calculate arcing current and use time-current curves to deter-
mine energy.
For Ibf, such that 22.6 kA <Ibf < 65.9 kA,
E=4.184 (-0.1284Ibf+ 32.262)
For Ibf, such that 65.9 kA < Ibf<106 kA,
E=4.184(-0.5177 Ibf+57.917)
For Ibf>106 kA, contact manufacturer for information.
For Ibf, such that 15.7 kA < Ibf < 22.6 kA,
E = 4.184 (-0.0507 Ibf + 1.3964) (19)
For Ibf, such that 22.6 kA < Ibf < 106 kA, E = 1.046
(10)
For Ibf > 106kA, contact manufacturer for information.
(F) Equations for Class RK1 fuses 201 A-400 A
(11)
For Ibf < 3.16 kA, calculate arcing current and use time-current curves to
determine energy.

(B) Equations for Class L fuses 1201 A-1600 A For Ibf, such that 3.16 kA < Ibf < 5.04 kA,

For Ibf < 15.7 kA, calculate arcing current and use time-current curves to
determine energy.
For Ibf, such that 15.7 kA < Ibf < 31.8 kA,
E = 4.184(-0.1863 Ibf + 27.926)
For Ibf, such that 31.8 kA < Ibf < 44.1 kA,
E = 4.184 (-1.5504Ibf + 71.303)
For Ibf, such that 44.1 kA < Ibf < 65.9 kA, E is 12.3 J/cm2
For Ibf, such that 65.9 kA , Ibf < 106 kA,
E = 4.184 (-19.053 Ibf + 96.808) (20)
For Ibf,, such that 5.04 kA < Ibf, < 22.6 kA,
E = 4.184 (-0.0302 Ibf + 0.9321) (21)
(12)
For Ibf, such that 22.6 kA < Ibf < 106 kA, E = 1.046
For Ibf > 106 kA, contact manufacturer for information.
(13)
(G) Equations for Class RL1 fuses 101A-200 A
For Ibf < 1.16 kA, calculate arcing current and use time-current curves to
determine energy.

E = 4.184 (-0.0631 Ibf+ 7.0878) (14) For Ibf, such that 1.16 kA < Ibf < 1.6 kA,

For Ibf > 106 kA, contact manufacturer for information. E = 4.184 (-18.409 Ibf + 36.355) (22)

(C) Equations for Class L fuses 801 A-1200 A For Ibf, such that 1.6 kA < Ibf < 3.16 kA,

For Ibf < 15.7 kA, calculate arcing current and use time-current curves to E = 4.184 (-4.2628 Ibf + 13.721) (23)
determine energy.
For Ibf, such that 3.16 kA < Ibf < 106 kA, E = 1.046
For Ibf, such that 15.7 kA < Ibf ≤ 22.6 kA,
For Ibf > 106 kA, contact manufacturrer for information.
E = 4.1844(-0.1928Ibf + 14.226) (15)
(H) Equations for Class RK1 fuses up to 100 A
For Ibf, such that 22.6 kA < Ibf < 44.1 kA,

70E-67
Report on Comments — Copyright, NFPA NFPA 70E
For Ibf < 0.65 kA, calculate arcing current and use time-current curves to
determine energy.

For Ibf, such that 0.65 kA < 1.1 kA,

E = 4.184 (-11.176 Ibf + 13.565) (24)

For Ibf, such that 1.16 kA < Ibf < 1.4 kA,

E = 4.184 (-1.4583 Ibf + 22.222917) (25)

For Ibf, such that 1.4 kA < Ibf < 106 kA, E = 1.046

For Ibf > 106 kA, contact manufacturer for information.

B.7 Low-voltage Circuit Breakers. Equations have been developed, as shown

in Table 2, for systems using low-voltage curcuit breakers that will output
values for incident energy and flash-protection boundary when the available
bolted fault current is known or can be calculated. The equations do not
require availability of the time-current curves for the circuit breaker, but mush
be used within the appropriate range indicated below. For conditions of bolted
fault current below the range indicated, the arcing current, incident energy, and
flash-protection boundary equations must be used (see C.2, C.3, and C.5).

Table 2 —Equations for incident energy and flash-protection boundary by

circuit breaker type and rating
480 V and lower 575-690 V
Rating (A) Breaker type Trip unit type Incident energy Flash boundary Incident energy Flash boundary
(J/cm ) a
2
(mm) (J/cm )2
(mm)
100-400 MCCB TM or M 0.189 Ibf,+0.548 9.16 Ibf,+194 0.271 Ibf,+0.180 11.8 Ibf,+196
600-1200 MCCB TM or M 0.223 Ibf,+1.590 8.45 Ibf+364 0.335 Ibf,+0.380 114Ibf+369
600-12 MCCB E,LI 0.377 Ibf+1.360 12.50 Ibf+428 0.468 I +4.600 14.3 Ibf+568
1600-6000 MCCB or ICCB TM or E, LI 0.448 Ibf+3.000 11.10 I +696 0686 Ibfbf++0.165 16.7 Ibf+606
800-6300 LVPCB E, LI b 0.636 Ibf+3.670 14.50 Ibfbf+786 0.958 Ibf+0.292 19.1 I +864
800-6300 LVPCB E,, LS 4.560 Ibf++27.230 47.20 Ibf+2559 5,759 Ibf++2.170 62.4 Ibfbf+2930
a
Ibf is in ka, working distance is 460 mm.
b
Short time delay is assumed to be set at maximum.

The types of circuit breakers are as follows:

— MCCB: molded-case circuit breaker

— ICCB: insulated-case circuit breaker
— LVPCB: low-voltage power circuit breakers

— TM: Thermal-magnetic tri units.

— M: Magnetic (instantaneous only)trip units.
— E: Electronic trip units have three characteristics that may be used
searately or in combination,

— (L) long-time
— (S) short-time and
— (I) instantaneous. A trip unit may be sesignated LI when it has both long-
time and instantaneous features. Other common designations are LS and LSI.

The range of these equatios is 700 A-106 000 A for the voltages shown in
Table 5. Each equation is applicable for the range I1< Ibf< I2.

I2 is the interrupting rating of the CB at the voltage of interest.

I1 is the minimum bolted fault current at which this method can be applied.
I1 is the lowest bolted fault current level that generates arcing current great
enough for instantaneous tripping to occur or for circuit breakers with no
instantaneous trip, the lowest current at which short time tripping occurs.
To find I1, use the manufacturerʼs time-current corve, if it is readily available,
and take the instantaneous trip value, It , from the curve as shown in figure
1. If the curve is not available, but the instantaneous trip setting is shown on
the breaker, use that setting. When the tripping current, It, is not known, use
a default value of 10 times the continuous current rating of the CB, except for
Cbs rated 100 A and below, use a default value of It = 1300 A. Where an LS
trip unit is used, It is the short-time pick-up current.
The corresponding bolted fault current, Ibf is found by solving the model
equation for arc current for box configurations by substituting It for arcing
current- The 1.3 factor in Equation (26) adjusts current to the top of the
tripping band.

70E-68
Report on Comments — Copyright, NFPA NFPA 70E
B-6-2 Arcing Current. To determine the operating time for protective devices,
find the predicted three-phase arcing current.

For applications with a system voltage under 1 kV, solve the following
equation (1):

lgIa = K + 0.662lg Ibf + 0.0966V + 0.000526G + 0.5588V (lgIbf) – 0.00304G

(lgIbf) (1)

Where:

lg = the log10
Ia = arcing current in kA
K = –0.153 for open air arcs
= –0.097 for arcs-in-a-box
I bf = bolted three-phase available short-circuit current (symmetrical
rms) (kA)
V = system voltage in kV
Figure 1—typical circuit breakers time-current characteristic G = conductor gap (mm) (See Table 1.)

For systems greater than or equal to 1kV, use equation (2):

lg (1.3 It)= 0.084 + 0.096 V + 0.586 (lg Ibf) + 0.559 V (lg Ibf) lg/a = 0.00402 + 0.983 lg/bf (2)
(26)
This higher voltage formula is utilized for both open-air arcs and for arcs-in-a-
Solving for Ibf at the point It for 600 V: box.
Convert from lg:
lg I1 = 0.0281 + 1.09 lg (1.3 It) (27)
la = 10lg/a (3)
Solving for Ibf at the point It for 480 V and lower:
Use .85Ia to find a second arcing time. This second arc current accounts for
variations in the arcing current and the time for the overcurrent device to open.
lg I1 = 0.04407 + 1.17 lg (1.3 It) (28) Calculate the incident energy using both values (Ia and 0.85 Ia), and use the
higher value.
Ibf = I1=10lgI1 (29)
B-6-3 Incident Energy at Working Distance—Empirically Derived
Substantiation: Since Panel Proposal 157a was developed and voted upon Equation. To determine the incident energy using the empirically derived
by the NFPA 70E panel, considerably more work was completed in the area equation, determine the log10 of the normalized incident energy. This equation
of arc-flash calculation and arc-flash boundary determination. Results of this is based on data normalized for an arc time of 0.2 seconds and a distance from
recently completed work are found in the new IEEE P1584 Standard “Draft the possible arc point to the person of 610 mm.
Guide for Arc Flash Hazard Calculations”. The material in this comment
is taken almost directly from the P1584 document. This material covers a lg En = k1 + k2 + 1.081lg/a = 0.0011G (4)
greater range of voltages and available short circuit currents, so it will greatly
improve the userʼs ability to accurately predict the available arc-fault energies.
NFPA and IEEE will need to work out some sort of agreement on the copyright Where:
issues.
Committee Meeting Action: Accept in Principle
Revise text to read as follows: En = incident energy (J/cm2) normalized for time and distance
B-6 Basic Equations for Calculating Incident Energy and Flash- k1 = –0.792 for open air arcs
Protection Boundary. The following information offers equations for
estimating incident energy and flash-protection boundaries based on statistical = –0.555 for arcs-in-a-box
analysis and curve fitting of available test data. An IEEE working group k2 = 0 for ungrounded and high-resistance grounded systems
produced the data from tests it performed to produce models of incident energy.
Based upon the selection of standard personal protective equipment (PPE) = –0.113 for grounded systems
levels (1.2, 8, 25, 40, and 100 cal/cm2), it is estimated that the PPE will be G = the conductor gap (mm) (See Table 1.)
adequate or more than adequate to protect the employee from second-degree
burns in 95 percent of the cases.
FPN: When incident energy exceeds 40 cal/cm2 at the working distance, Then:
greater emphasis than normal should be placed on de-energizing before
working on or near the exposed electrical conductors or circuit parts. En = 10lgEn (5)
The complete data, including a spreadsheet calculator to solve the equations,
may be found in the IEEE Guide for Performing Arc Flash Hazard Calculations Converting from normalized:
(IEEE Std 1584™-2002). It can be ordered from the Institute of Electrical and
Electronics Engineers, Inc., 3 Park Avenue, New York, NY 10016-5997. ⎛ 610 x ⎟⎞⎟⎟
B-6-1 System Limits. An equation for calculating incident energy can be
(
E = 4.184C1En 1 0.2 ⎜⎜ x ⎟⎟⎟⎟
⎜ D ⎟⎟⎟ ) (6)

empirically derived using statistical analysis of raw data along with a curve-
⎝ ⎟⎟⎠
Where:
fitting algorithm. It may be used for systems with the following limits:
E = incident energy in J/cm2
• 0.208 kV to 15 kV, three-phase
• 50 Hz to 60 Hz Cf = calculation factor
• 700 A to 106,000 A available short-circuit current 1.0 for voltages above 1kV
• 13 mm to 152 mm conductor gaps
1.5 for voltages at or below 1 kV
For three-phase systems in open-air substations, open-air transmission systems, En = incident energy normalized
and distribution systems, a theoretically derived model is available. This
theoretically derived model is intended for use with applications where faults t = arcing time (seconds)
will escalate to three-phase faults. Where such an escalation is not possible or D = distance (mm) from the arc to the person (working distance)
likely or where single-phase systems are encountered, this equation will likely
provide conservative results. X = the distance exponent from Table 1

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Report on Comments — Copyright, NFPA NFPA 70E
V = system voltage in kV
Table 1 Factors for Equipment and Voltage Classes
System Type of Typical Distance FPN: These equations may be used to determine if selected PPE is adequate to
prevent thermal injury at a specified distance in event of an arc flash.
Voltage Equipment Conductor Gap X-Factor
(kV) (mm) B-6-6 Current-Limiting Fuses. The formulae in this section were developed
Open-air 10–40 2.000 for calculating arc-flash energies for use with current-limiting Class L and
Class RK1 fuses. The testing was done at 600 volts and at a distance of
0.208–1 Switchgear 32 1.473 455 mm, using commercially available fuses from one manufacturer. The
following variables are noted:
MCCs and panels 25 1.641
Cables 13 2.000 Ibf = available three-phase bolted-fault current (symmetrical RMS)
(kA)
Open-air 102 2.000
E = incident energy (J/cm2)
> 1–5 Switchgear 13–102 0.973
Cables 13 2.000
(A) Class L Fuses 1,601 A – 2,000 A
Open-air 13–153 2.000
> 5–15 Switchgear 153 0.973
Where Ibf <22.6 kA, calculate the arcing current per Equation (1) and use time-
Cables 13 2.000 current curves to determine the incident energy per Equations (4), (5), and (6).

B-6-4 Incident Energy at Working Distance—Theoretical Equation. The Where 22.6 kA ≤ Ibf ≤ 65.9 kA
theoretically derived equation can be applied in cases where the voltage is over
15 kV or the gap is outside the range. E = 4.184 (– 0.1284 Ibf + 32.262) (10)

⎛ t ⎟⎟⎞
E = 2.142 ×10 6V / bf ⎜⎜ 2 ⎟⎟⎟⎟⎟⎟ Where 65.9 kA < Ibf ≤ 106 kA
⎝ D ⎟⎟⎟⎟ (7)
⎠ E = 4.184 (– 0.5177 Ibf + 57.917) (11)
Where:

Where Ibf > 106 kA, contact manufacturer.

E = incident energy (J/cm2)
V = system voltage (kV)
(B) Class L Fuses 1,201 A – 1,600 A
t = arcing time (seconds)
D = distance (mm) from the arc to the person (working distance)
Where Ibf <15.7 kA, calculate the arcing current per Equation (1) and use time-
Ibf = available three-phase bolted-fault current
current curves to determine the incident energy per Equations (4), (5), and (6).

For voltages over 15 kV, arcing-fault current and bolted-fault current are
considered equal. Where 15.7 kA ≤ Ibf ≤ 31.8 kA

B-6-5 Flash-Protection Boundary. The flash-protection boundary is the E = 4.184 (– 0.1863 Ibf + 27.926) (12)
distance at which a person is likely to receive a second-degree burn. The onset
of a second-degree burn is assumed to be when the skin receives 5.0 J/cm2 of
incident energy. Where 31.8 kA < Ibf < 44.1 kA

For the empirically derived equation: E = 4.184 (– 1.5504 Ibf + 71.303) (13)
(8)
1
⎡ ⎛ t ⎟⎞⎟⎟ ⎛ 610 x ⎟⎟⎞⎟ ⎤x Where 44.1 kA ≤ Ibf ≤ 65.9 kA,
⎟⎟⎟
DB = ⎢⎢ 4.184C t E n ⎜⎜ ⎟⎟⎟ ⎜
⎢⎣ ⎝ 0.2 ⎟⎟⎟⎟
⎟ ⎜⎜ EB ⎟⎟⎟⎟⎟
⎠ ⎝ ⎟⎟⎠ ⎦ E = 12.3 J/cm2 (14)

For the theoretically derived equation: Where 65.9 kA < Ibf ≤ 106 kA
⎛ t ⎟⎞⎟⎟ (9)
DB = 2.142 ×10 6V / bf ⎜ ⎟ E = 4.184 (– 0.0631 Ibf + 7.0878) (15)
⎜⎝ E B ⎟⎟⎟⎟
⎟⎟⎠
Where Ibf > 106 kA, contact manufacturer.
Where:

(C) Class L Fuses 801 A – 1,200 A

DB = the distance (mm) of the flash-protection boundary from the
arcing point
Cf = a calculation factor Where Ibf <15.7 kA, calculate the arcing current per Equation (1) and use time-
current curves to determine the incident energy per Equations (4), (5), and (6).
1.0 for voltages above 1 kV
1.5 for voltages at or below 1 kV Where 15.7 kA ≤ Ibf ≤ 22.6 kA,
En = incident energy normalized
EB = incident energy in J/cm2 at the distance of the flash-protection E = 4.184 (– 0.1928 Ibf + 14.226) (16)
boundary
t = time (seconds) Where 22.6 kA < Ibf ≤ 44.1 kA,
X = the distance exponent from Table 1
E = 4.184 (0.0143 Ibf 2 – 1.3919 Ibf + 34.045) (17)
Ibf = bolted three phase available short-circuit current

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Report on Comments — Copyright, NFPA NFPA 70E
Where 44.1 kA < Ibf ≤ 106 kA, (G) Class RK1 Fuses 101 A – 200 A
E = 1.63 (18)

Where Ibf > 106 kA, contact manufacturer. Where Ibf <1.16 kA, calculate the arcing current per Equation (1) and use time-
current curves to determine the incident energy per Equations (4), (5), and (6).

(D) Class L Fuses 601 A – 800 A Where 1.16 kA ≤ Ibf ≤ 1.6 kA,

E = 4.184 (– 18.409 Ibf + 36.355) (28)

Where Ibf <15.7 kA, calculate the arcing current per Equation (1) and use time-
current curves to determine the incident energy per Equations (4), (5), and (6).
Where 1.6 kA < Ibf ≤ 3.16 kA,
Where 15.7 kA ≤ Ibf ≤ 44.1 kA,
E = 4.184 (– 4.2628 Ibf + 13.721) (29)
E = 4.184 (– 0.0601 Ibf + 2.8992) (19)
Where 3.16 kA < Ibf ≤ 106 kA,
Where 44.1 kA < Ibf ≤ 106 kA,
E = 1.046 (20) E = 1.046 (30)

Where Ibf > 106 kA, contact manufacturer. Where Ibf > 106 kA, contact manufacturer.

(E) Class RK1 Fuses 401 A – 600 A (H) Class RK1 Fuses 1 A - 100 A

Where Ibf <8.5 kA, calculate the arcing current per Equation (1) and use time- Where Ibf <0.65 kA, calculate the arcing current per Equation (1) and use time-
current curves to determine the incident energy per Equations (4), (5), and (6). current curves to determine the incident energy per Equations (4), (5), and (6).

Where 8.5 kA ≤ Ibf ≤ 14 kA, Where 0.65 kA ≤ Ibf ≤ 1.16 kA,

E = 4.184 (– 3.0545 Ibf + 43.364) (21) E = 4.184 (– 11.176 Ibf + 13.565) (31)

Where 14 kA < Ibf ≤ 15.7 kA, Where 1.16 kA < Ibf ≤ 1.4 kA,

E = 2.510 (22) E = 4.184 (– 1.4583 Ibf + 2.2917) (32)

Where 15.7 kA < Ibf ≤ 22.6 kA Where 1.4 kA < Ibf ≤ 106 kA,

E = 4.184 (– 0.0507 Ibf + 1.3964) (23) E = 1.046 (33)

Where 22.6 kA < Ibf ≤ 106 kA, Where Ibf > 106 kA, contact manufacturer.

B.6.6 Low-Voltage Circuit Breakers. The equations in Table 2 can be used

E = 1.046 (24) for systems with low-voltage circuit breakers. The results of the equations will
determine the incident energy and flash-protection boundary when Ibf is within
Where Ibf > 106 kA, contact manufacturer. the range as described. Time-current curves for the circuit breaker are not
necessary within the appropriate range.

(F) Class RK1 Fuses 201 A – 400 A

When the bolted-fault current is below the range indicated, calculate the arcing
current per Equation (1) and use time-current curves to determine the incident
energy per Equations (4), (5), and (6).
Where Ibf <3.16 kA, calculate the arcing current per Equation (1) and use time-
current curves to determine the incident energy per Equations (4), (5), and (6).

Where 3.16 kA ≤ Ibf ≤ 5.04 kA,

E = 4.184 (– 19.053 Ibf + 96.808) (25)

Where 5.04 kA < Ibf ≤ 22.6 kA,

E = 4.184 (– 0.0302 Ibf + 0.9321) (26)

Where 22.6 kA < Ibf ≤ 106 kA,

E = 1.046 (27)

Where Ibf > 106 kA, contact manufacturer.

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Report on Comments — Copyright, NFPA NFPA 70E

Table 2 Incident Energy and Flash-Protection Boundary by Circuit Breaker Type and Rating
480 V and Lower 575 – 600 V
Rating Breaker Trip-unit Incident energy (J/cm )a 2
Flash boundary Incident energy Flash boundary
(A) type type (mm) (J/cm2) (mm)
100 – TM
400 MCCB or M 0.189 Ibf +0.548 9.16 Ibf + 194 0.271 Ibf + 0.180 11.8 Ibf + 196
600 – TM
1,200 MCCB or M 0.223 Ibf +1.590 8.45 Ibf +364 0.335 Ibf +0.380 11.4 Ibf +369
600 –
1,200 MCCB E, LI 0.377 Ibf +1.360 12.50 Ibf +428 0.468 Ibf + 4.600 14.3 Ibf + 568
1,600 – MCCB or TM
6,000 ICCB or E, LI 0.448 Ibf + 3.000 11.10 Ibf + 696 0.686 Ibf +0.165 16.7 Ibf + 606
800 –
6,300 LVPCB E, LI 0.636 Ibf + 3.670 14.50 Ibf + 786 0.958 Ibf + 0.292 19.1 Ibf + 864
800 –
6,300 LVPCB E, LSb 04.560 Ibf + 27.230 47.20 Ibf + 2660 6.860 Ibf + 2.170 62.4 Ibf + 2930

At 480 V and lower,

a – Ibf is in kA; working distance is 455 mm (18 inches).
lgI1 = 0.0407 + 1.17 lg(1.3 It) (36)
b – Short-time delay is assumed to be set at maximum.
Ibf = I1 = 10
lgI1
(37)
Where:
B.6.7 References. The complete data, including a spreadsheet calculator to
• MCCB = Molded-case circuit breaker solve the equations, may be found in the IEEE Guide for Performing Arc-Flash
• ICCB = Insulated-case circuit breaker Hazard Calculations (IEEE Std 1584TM-2002). IEEE publications are available
• LVPC = Low-voltage power circuit breaker from the Institute of Electrical and Electronic Engineers, 445 Hoes Lane, P.O.
• TM = Thermal-magnetic trip units Box 1331, Piscataway, NJ 08855-1331, USA (http://standards.ieee.org/).
• M = Magnetic (instantaneous only) trip units Committee Statement: The committee accepted the revised text that more
• E = Electronic trip units have three characteristics that may accurately depicts the intent of the calculation method described in IEEE
be used separately or in combination: Standard 1584. The revised text has been agreed to by the IEEE Standards
Association and the NFPA.
– L Long-time The committee intent is for the new language to begin at B.6 and to follow
– S Short-time the existing text in 70E-2000 following item B 5.3.
– I Instantaneous Number Eligible to Vote: 25
Ballot Results: Affirmative: 23 Negative: 1
Vote Not Returned: 1 CLIFFDWELLER
The range of available three-phase bolted–fault currents is from 700 A Explanation of Negative:
– 106,000 A. BINGHAM: The committee meeting action should have been reject.
Each Equation is applicable for the range I1 < Ibf < I2. This addition in the appendix allows several ways to calculate the incident
energy from an arc flash which gives as many different answers. Which
I2 is the interrupting rating of the CB at the voltage of interest. is correct? Which method is to be used in Table 3-3.9.1? Before adding
I1 is the minimum available three-phase, bolted, short-circuit current at which another method, the committee should determine which method gives the most
this method can be applied. I1 is the lowest available three-phase, bolted, conservative value that is within reason.
short-circuit current level that causes enough arcing current for instantaneous In addition, since there was not a NFPA 70E task group established to conduct
tripping to occur or for circuit breakers with no instantaneous trip, that causes an analysis of the validity of IEEE 1584 along with all of the other hazard
short-time tripping to occur. analysis approaches, and if the committee feels this strong regarding the usage
of 1584, do not place a reference in the Appendix. Just because it is an IEEE
In order to find I1, the instantaneous trip (It ) of the circuit breaker must be standard is not sufficient justification for inclusion.
found. This can be determined from the time-current curve, or it can be The committee should state which method was used to determine incident
assumed to be 10 times the rating of the circuit breaker for circuit breakers energy values in the main body of 70E.
rated above 100 amperes. For circuit breakers rated 100 amperes and below, Comment on Affirmative:
a value of It = 1,300 A can be used. When short-time delay is utilized, It is the JACKSON: See my Affirmative with Comment on Comment 70E-1 (Log
short-time pick-up current. #2).
WILMER: EEI supports the Committee Action of adding the calculation
method from IEEE 1584 to the Annex. However, the committee needs to
The corresponding bolted-fault current, Ibf, is found by solving the equation for
address the issue of multiple methods. At least 5 methods are recognized
arc current for box configurations by substituting It for arcing current. The 1.3
by the committee for the calculation of incident energy (Part II Appendix
factor in Equation (35) adjusts current to the top of the tripping band.
B Sections B-2 and B-5; IEEE 1584; Heat Flux Calculator; and Arc Pro
software). All the methods are considered “correct”, yet they all provide
lg(1.3 It) = -0.084 + 0.096V + 0.586(lgIbf) + 0.559V(lgIbf) (34)
different answers. Getting different answers using different methods will lead
users of the standard to lose confidence in the validity of any the calculations.
At 600 V,
They canʼt all be right. If the committee canʼt agree on one method, then they
need to define the parameters under which each method could be performed.
lgI1 = 0.0281 + 1.09lg(1.3 It) (35)

70E-72