I've noticed the 2018 version of 70E speaks of "leather footwear" and at other times "heavy-duty leather footwear" for arc flash protection of the feet. However 70E doesn't provide a definition or a description of what either are or the differences between the two.

I reached out to an "expert" at NFPA (who I won't mention by name) and the answer he provided amounted to nothing more than generalities or a reference to "heavy-duty gloves". And he calls himself the expert??

So does anyone have any history or an explanation what constitutes "leather footwear" versus "heavy-duty leather footwear"? And the caveat of "As Needed"?

I'll provide a few examples where these terms are used.

Art 130.7(C)(10)(e) requires "heavy-duty leather footwear" when the incident energy is greater than 4 cal/cm2.

Table 130.7(C)(15)(c) Personal Protective equipment requires "leather footwear (As needed)" for PPE category 1(min of 4 cal/cm2) then mandates "leather footwear" for category 2, 3 and 4.

Table 130.5(G) requires "leather footwear" when incident energy is 1.2 cal/cm2 to 12 cal/cm2 then again when exposure is greater than 12 cal/cm2.

Then finally, Table H.3 from Annex H states "Exposures less than or equal to 4 cal/cm2", "Heavy-duty leather footwear (as needed)" but if exposure is greater than 4 cal/cm2 then "Heavy-duty leather footwear"

To me, this is an example of where common sense should prevail.

Leather footwear:



Heavy-duty leather footwear:



Finally, I think NFPA 70E is discriminatory against vegans and offensive by specifically stating footwear must be made of leather.

Yes common sense should prevail however when we speak of safety standards, especially electrical safety, then clear and concise definitions are necessary to avoid confusion (case in point) and consistency across the various industries that are incorporating 70E into their ESPs.

I work in an industry where many of our electricians and other qualified electrical workers become self-appointed "shop lawyers". Some have best of intentions and want to learn however many just want to stir the pot because they're not happy about a new electrical safety rule or requirement they have to adhere to. But we work in a very specialized industry where we get paid by the hour and not by the numbers of jobs we can knock out quickly. In fact, our management tells our employees in writing to follow the safety rules and procedure directions as written regardless of how long it may take them.

And I never really thought about the connection between NFPA and the vegans but you may be onto something here.

Some further thoughts on the subject,
https://www.e-hazard.com/blog/is-there- ... -footwear/

"Arc flash protection — The standard recognizes that leather work shoes typically provide excellent arc flash protection and requires them for exposures greater than HRC 2. The standard assumes equal arc flash protection from dielectric shoes."
https://www.ecmweb.com/ops-amp-maintena ... c-exposure

This is one of those areas where each section you reference was likely written and/or modified at different times, likely by different people, and no one on the committee has gone back through to make sure the verbage is clear, and as you state, *defined*. I believe this is where the "as needed" comes in to play, attempting to fall back on other areas of 70E or other codes that define shoe requirements, and they just never removed/adjusted that statement.

I think bbaumer's photographic definition is correct. The shoe industry generally defines heavy-duty to mean work boots. I would argue in our industry we would want that term to also include EH rated and I could make the argument that 6" minimum height should also be considered (as does my company as part of our corporate PPE guidelines).

As for the Vegan issue, I would have to imagine any shoe that can meet an 8cal rating should be fine as per the leather requirement, as the above reference shoes the code implication that the leather is chosen to meet that cal level.

All in all, there appears to be much room for improvement on the shoe issue in 70E.

Thanks SteveA for the links. Hugh's always been one of my "go to" guys when it comes to arc flash and electrical safety but I must have missed this article so I really appreciate it.

I'm thinking we're going to have to add a definition into our electrical safety procedure, which will provide our people with some guidance on what constitutes "Heavy Duty leather footwear" for our station. I like your suggestion about the EH rating and a minimum of 6" of height.

Like I stated in my previous comment, we have too many "shop lawyers" who formulate their own definitions based on convenience rather than their safety. I understand change is not pleasant and additional electrical safety requirements are not fun but in the end if they get to go home to their families in the same condition they came to work in then they've won. Unfortunately that concept is hard to embrace if the individual doesn't hold to it as a core value. This is why I believe the electrical safety culture (or any safety culture) of a company's employees, frontline and management, is the long term sustainability factor for any effective electrical safety program. If your people are wanting to do the right thing and placing safety their top priority then you'll have a winning hand.

However I'm also a realist who doesn't believe in utopian ideologies, be in electrical safety or other key areas. A healthy electrical safety culture isn't born, it's developed through lots of hard work and effort and must be constantly monitored, evaluated and audited for gaps and areas for improvement.

Thanks again.

Any concern over the vinyl collar at the top of that unrated work boot above? Very close to the skin when worn.

We have the same wording up here in Canada under CSA Z462. Looks like kind of an oversight with both standards. Both using leather footwear and heavy duty leather I think that the link to the article Steve M has sent to oyu from Hugh Hoagland is excellent and I would like to utilize it myself. I also agree the comon sense will always prevail. Several years back tests were conducted up here at Kinectrics on rubber insulated gloves with leather protectors against arc flash. To make a long story short, leather has proven to be a very good opponent against at least the incident energy from an arc flash. Being on the technical committee up here for Z462, I will make a note on this heavy duty or just leather footwear issue, as you bring up a good point

Awesome Leonard,

I hope someone on the 70E technical committee will do the same. I've submitted some public inputs with recommendations to provide some kind of clarification between the two but it wasn't accepted, i.e. Rejected.

What's interesting though is the fact when you speak to some of the committee members their standard answer is "Good idea, submit a public input". In fact this was the exact answer that was given at the recent IEEE ESW in Reno, NV during a Q&A that follows one of the presentations. I asked a question of one of the presenters regarding a different 70E topic and his answer to me in front of several hundred people was "That's a good point, submit a public input."
Well I couldn't resist so my reply in front of the same hundreds of people was "I did but you guys rejected it."

I wasn't trying to embarrass anyone but to make a point however I'm not sure if I made too many friends with some of the committee members that day.

Oh well, I've learned if something is important to you and you believe it adds value to safety then the English word 'Tenacity' should be our default.
Like the old saying goes, "The squeaky wheel gets the grease" but at the same time "The squeaky wheel also gets replaced" is true as well.