NFPA 70E 2021: Article 120 Energized Electrical Work Permit. Section (C): Exceptions to Work Permit: from (2) to (4) do not make logical sense.

The EEWP is required under two conditions. 1. When working within the RAB, and 2. When an employee interacts with equipment not exposed which will put him under an increased likelihood of injury due to an arc flash event.

There are three exceptions to this rule that, to me, are not logical.

Exception (2): Thermography, ultrasound, or visual inspections if the RAB is not crossed.
My comment on this exception: This exception applies only when an EEWP is required for condition (1) above, working on energized and exposed electrical equipment. The employee does not need an EEWP because the RAB is not crossed. Therefore, why this is an exception?

Exception (3): Access to and egress from an area with energized electrical equipment if no electrical work is performed and the RAB is not crossed.
My comment on this exception: This exception does not apply to any of the two conditions that require an EEWP. The employee is not working on exposed electrical equipment and is not interacting with enclosed energized electrical equipment. Additionally, the employee does not need an EEWP because the RAB is not crossed. Therefore, why this is an exception?

Exception (4): General housekeeping and miscellaneous non-electrical tasks and the RAB is not crossed.
My comment on this exception: This exception does not apply to any of the two conditions that require an EEWP. The employee is not working on exposed electrical equipment and is not interacting with enclosed energized electrical equipment. Additionally, the employee does not need an EEWP because the RAB is not crossed. Therefore, why this is an exception?

I'm not sure for the exceptions, but I do know of some electrical safety pros who would require PPE if folks were walking in an electrical room with no shock risk, as an example. I want to say it was to clarify that individuals in this case are not "working" on the equipment or interacting with it and therefore don't need PPE, arc flash or otherwise.

With regards to exception #1, I would agree with you that an EEWP is not required as those are troubleshooting activities expressly exempt from EEWPs. Maybe some safety professionals were requiring it?

I must also point out, of course I'm sure you are aware, that the arc flash boundary can exceed the restricted approach, so arc flash PPE may be required regardless in the case of open equipment, opening/closing breakers, etc.

Mike

Hi All, I am not sure if this will answer the inquiries here, however as an electrician I have always looked at the way 70E defines the 2 categories of "working on" - diagnostic and repair. Obviously you would not need the EEWP for diagnostic work. However in the unlikely that a repair must be performed energized you are for sure crossing the RAB so a EEWP would be required. However never have I done an EEWP for thermography. And especially not for someone walking into an electrical room to check the fire extinguisher, security panel etc. Simply, if the RAB is crossed you could be dealing with exposed energized conductors pending on the equipment age. If it is something other than diagnostic work, implement an EEWP. Myself personally I try to avoid the EEWP system as it can be complicated.
Hope that this is of some help

The employer's Electrical Safety Program provides clarity and documents exemptions.

There is confusion in industry due to myths and misinformation from non-compliant "Arc Flash Awareness" or "Arc Flash Training" and over the last 10 years in PE or P.Eng. issued reports that provide information to the client that should not be in the report from an EE who is NOT an NFPA 70E or CSA Z462 SME. So within the employer's Electrical Safety Program it should:

1. Define what energized electrical work tasks are. As per Definition yes, diagnostics/trouble shooting, or repair/alteration.
2. The ESP should also advise that isolation related energized work tasks are defined as racking in and out power circuit breakers and installing temporary protective grounds.
3. Define that "Operating" energized electrical equipment is NOT maintenance and is NOT energized work.

The Electrical Safety Program should then include an "Energized Electrical Work Permit Policy." Within this policy section of the Electrical Safety Program it defines the exemptions:

1. Operating energized electrical equipment.
2. Using a test instrument for diagnostics, troubleshooting or specialized electrical equipment testing.
3. Entering an Electrical Room or being in proximity to energized electrical equipment.
4. General housekeeping and non-electrical work within an Electrical Room or around energized electrical equipment.
5. Thermography, ultrasound testing and RAB is not crossed.
6. Opening a hinged door.
7. Removing a bolt on cover.
8. Racking in and out power circuit breakers.
9. Installing temporary protective grounds.

Terry:

Thanks for your response. In principle, I agree with all your points.

But, I do not understand how that answers the question that I asked.

The question is that the exceptions for an EEWP do not make sense, not because I do not agree with them, but because they have logical contradictions that are very obvious to me.

The first exception makes logical sense. All of the others don't.

The first exception, which makes sense, applies to activities performed inside the RAB. An EEWP is required, by definition, when you have activities inside the RAB.

The other exceptions, which do not make sense, apply to activities outside the RAB. But an EEWP is not required for activities outside the RAB. Therefore, these activities could have been done without a RAB and the exception is not required.

I have been asking this specific question many times in this forum, but, so far, nobody is addressing this issue heads on.

Simple interpretation, an EEWP is required for all energized electrical work tasks where a Qualified Person is exposed to arc flash and/or shock hazards UNLESS exempted. A Risk Assessment Procedure SHALL be implemented for all expected work tasks that may be performed at the employer's worksite.

The employer shall document all exemptions based on acceptable justification in their company's Electrical Safety Program. All Qualified Persons SHALL receive ESP Roll Out / Orientation training to ensure they understand the employer's (not the training company's communicated information) policies, practices and procedural requirements.

Justification is increased risk or hazard or infeasibility due to equipment design or operation limitations.

The documented definition of what energized electrical work is required.

Terry:

Again, I agree with your interpretation and procedures. But that is not the question.

This is not about what is the proper procedure to follow or not. What is the proper interpretation or not. This is about a consensus standard with an illogical exemption.

To separate my issue from what is correct or not related to electrical safety, I will express my concern by comparing it to a logical problem in another situation.


Let's assume that we are establishing the rules to obtain a permit to drive. The general rule is that you need to be 18 years old. So anybody that wants to drive, should be at least 18 years old. Then, there is a set of exemptions to this general rule.

The first exception is that you can still get a permit to drive, even if you are less than 18 years if you have taken several psychological tests and passed.

The second exception is that you can still get a permit if you are 20 years old but have blue eyes.

This second exception is illogical because you already met the requirement of being at least 18 years old, so no matter your age after 18 or what colors of eyes you got, you can get your license and you do not need an exception.

Similar illogical exceptions are written in the NFPA 70E. And I believe that they should eliminate these logical exceptions, especially considering that this is a reputable consensus standard and this reflects a faulty thought process from the publisher.

The general rule in NFPA 70E is that if you are inside the RAB you need an EEWP, but if you are out, then you do not need it, no matter if you are passing by, doing visual inspections or any other activity out of the RAB.

Great observation. First - these are my thoughts and may or may not represent any of the committees that I am part of (my usual disclaimer)


You might have hit on something here. I reviewed the past editions of NFPA 70E and found where this became tangled. There was a change between the 2012 edition and the 2015 edition that may be the cause of confusion.

The 2012 Edition of NFPA 70E referenced the Limited Approach Boundary (LAB) and not the Restricted Approach Boundary (RAB) for the EEWP requirement.

The 2015 Edition of NFPA 70E changed the EEWP requirement from LAB to RAB but nothing was done about the exception. I believe the intent for the exception is to permit thermography but emphasizing you still can’t cross the RAB which is technically implied with the main requirement. Perhaps the thought was to emphasize the RAB requirement doesn’t go away just because you are performing thermography but it could be confusing as you point out. I wasn’t part of the 70E technical committee back then so I don’t have the history.

Here are 2 examples to illustrate the difference between the 2012 and 2015 editions.
-----------------------------
2012 Edition
480 V. Example

LAB 42 inches for EEWP
RAB 12 inches for Exception

The thermography exception is working within the LAB of 42 inches and no closer than the RAB 12 inches
This made sense. When you are within the LAB but not RAB you do not need EEWP for thermography.

------------------------------
2015 Edition
480 V. Example

RAB 12 inches for EEWP
RAB 12 inches for Exception

EEWP is required when working within the RAB - 12 inches
Thermography exception to EEWP if working outside of RAB – 12 inches
One could argue that the RAB requirement for the exception is inherent with main requirement so it may be redundant.

I had to do a bit of digging but I believe the issue is the change from the 2012 Edition to the 2015 Edition.

If you have ideas for clarification of the language, perhaps submit public input (proposals) for the next edition of NFPA 70E. The call for Public Input is open with a deadline of June 1, 2021. You can find the information at nfpa.org

I agree.

They changed the main rule and did not realized the impact of this change on the exceptions.

Thanks.

FYI RECS:
https://www.nfpa.org/codes-and-standard ... extedition

The above link is a good way to let NFPA know of this and as Jim mentioned the due date is June 1st of this year, so....