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