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M E M O R A N D U M TO: NEC Technical Correlating Committee FROM: Kim Shea DATE: January 19, 2011 SUBJECT: NFPA 70E ROC TCC Letter Ballot (A2011) In accordance with the NFPA Regulations Governing Committee Projects, attached is the Letter Ballot on the Report on Comments (ROC) for the 2011 Edition of NFPA 70E. Also attached is a copy of the Comments. Please note the ballot has two parts: Part 1 is a Letter Ballot on the Technical Correlating Committee Amendments to the ROC (TCC Notes), and not on the Comments themselves. Reasons must accompany “Negative” and “Abstaining” votes. Part 2 is an Informational Letter Ballot Authorizing the Release of the ROC. Negative votes are limited to subjects within the purview of the TCC. Opposition on a strictly technical basis is not sufficient grounds for substantiating a negative vote. If you have correlation issues please identify and describe your concerns in the area of the ballot form for identification of correlation issues. Please complete and return your ballot as soon as possible but no later than Tuesday, January 25, 2011. As noted on the ballot form, please return the ballot to Kim Shea via e-mail to [email protected] or via fax to 617 984-7070. You may also mail your ballot to the attention of Kim Shea at NFPA, 1 Batterymarch Park, Quincy, MA 02169. The return of ballots is required by the Regulations Governing Committee Projects. As usual, nonvoting members (for example, the nonvoting technical committee chairs) need not return ballots. Attachments: Ballot Form NFPA 70E Comments

Report on Comments – June 2011 NFPA 70E_______________________________________________________________________________________________70E-1 Log #38 EEW-AAA

_______________________________________________________________________________________________Technical Correlating Committee on National Electrical Code®,

70E-1The Technical Correlating Committee directs the committee to reconsider this proposal because

the “Forward” is outside the scope of the committee. The committee should consider relocating the recommended textinto Article 90.

This is a direction from the Technical Correlating Committee on National Electrical Code® inaccordance with 3.4.2 and 3.4.3 of the Regulations Governing Committee Projects.

The Committee accepts the Technical Correlating Committee (TCC) direction to reconsiderProposal 70E-1 and rejects Proposal 70E-1. The Committee notes that the Standards Council (August 3-5, 2010) hasreviewed a request of the Chairs of the NEC Technical Correlating Committee and the Technical Committee (TC) onElectrical Safety in the Workplace that the 2012 edition of NFPA 70E not become effective until 180 days from the dateof issuance by the Standards Council. The Council voted to deny the request and notes that the effective date of thisand all NFPA codes and standards should remain as 20 days after issuance from the Standards Council. The effectivedate of codes and standards is in the purview of the Council as noted in 4.8.2 of the Regulations Governing CommitteeProjects and the Council sees no reason to deviate. The Council noted that delaying the effective date could inhibitusers who wish to implement the codes and standards sooner, and that in any event, NFPA codes and standards arevoluntary and users who adopt or use voluntary codes and standards can decide when and how to implement their use.

Affirmative: 22 Negative: 2 Abstain: 1

BARRIOS, L.: It is unreasonable for the Standards Council to expect users to fully comply with the Standard within 20days of issuance. As originally proposed in proposal 70E-1 and in subsequent comments, 180 day implementation (orlonger) is more reasonable. The Standards Council also bases it's argument that "NFPA codes and standards arevoluntary and users who adopt or use voluntary codes and standards can decide when and how to implement their use."If this is the case, then an effective date should not even be identified. Interesting enough, this TCC comment was notagainst the proposal, but suggested relocating it to Article 90.HICKMAN, P.: We disagree that 20 days is a reasonable time frame for employers update policies and procedures

and train their workers in the new standard that supersedes all previous editions.

WALLIS, D.: I am abstaining in accordance with my agency’s policy requiring abstentions on technical issues.

_______________________________________________________________________________________________70E-1a Log #CC11 EEW-AAA

_______________________________________________________________________________________________Technical Committee on Electrical Safety in the Workplace,

70E-378Revise "leather gloves" to "heavy duty leather gloves" in Table 130.7(C)(10) and any other

occurrence in the standard.This recommendation is for correlation with the committee action on Comment 70E-378.

Affirmative: 24 Abstain: 1


1Printed on 1/19/2011



70E-3The Technical Correlating Committee directs that the action on this proposal be reconsidered and

clarified as to which extracts and references are being revised, if any.This is a direction from the Technical Correlating Committee on National Electrical Code® in

accordance with 3.4.2 and 3.4.3 of the Regulations Governing Committee Projects.

In Table 130.7(C)(8), change “Subject “ Apparel” as follows:Subject “Apparel Arc-Rated”; Document Title “Standard Performance Specification for Flame Resistant and Arc Rated

Textile Materials for Wearing Apparel for Use by Electrical Workers Exposed to Momentary Electric Arc and RelatedThermal Hazards”; Document Number and Revision “ASTM F1506-10a”.For Table 130.7(C)(8), Subject “Fall Protection”, the Document Number and Revision is “ASTM F887-10”.The following references in Annex A are to be updated as follows:A.3.1 ANSI PublicationsANSI A14.3, Safety Requirements for Fixed Ladders, 2002 2008.ANSI A14.4, Safety Requirement for Job-Made Ladders, 2002 2009.ANSI A14.5, Safety Requirements for Portable Reinforced Plastic-Ladders, 2000 2007.ANSI Z87.1, Practice for Occupational and Educational Eye and Face Protection, 2003 2010.ANSI Z89.1, Requirements for Protective Headwear for Industrial Workers, 2003 2009.A.3.2 ASTM Publications.ASTM D 120-09, Standard Specification for Rubber Insulating Gloves, 2002a (R 2006).ASTM D 1051-08, Standard Specification for Rubber Insulating Sleeves, 2007.ASTM F 478-09, Standard Specification for In-Service Care of Insulating Line Hose and Covers, 1999 (R 2007).ASTM F 496-08, Standard Specification for In-Service Care of Insulating Gloves and Sleeves, 2006.ASTM F 855-09, Standard Specification for Temporary Protective Grounds to Be Used on De-energized Electric Power

Lines and Equipment, 2004.ASTM F 887-10, Standard Specification for Personal Climbing Equipment, 2005.ASTM F1116-03(2008), Standard Test Method for Determining Dielectric Strength of Dielectric Footwear.ASTM F 1117-03(2008), Standard Specification for Dielectric Overshoe Footwear, 2003.ASTM F1296-08, Standard Guide for Evaluating Chemical Protective Clothing.ASTM F 1506-10a, Standard Performance Specification for Flame Resistant and Arc Rated Textile Materials for

Wearing Apparel for Use by Electrical Workers Exposed to Momentary Electric Arc and Related Thermal Hazards,2002a.ASTM F1742-03e1, Standard Specification for PVC Insulating Sheeting.ASTM F 2178-08, Standard Test Method for Determining the Arc Rating and Standard Specification for Face

Protective Products, 2006.ASTM F 2249-03(2009), Standard Specification for In-Service Test Methods for Temporary Grounding Jumper

Assemblies Used on De-Energized Electric Power Lines and Equipment, 2003.ASTM F2522-05, Standard Test Method for Determining the Protective Performance of a Shield Attached on Live Line

Tools or on Racking Rods for Electric Arc Hazards.ASTM F2676-09, Standard Test Method for Determining the Protective Performance of an Arc Protective Blanket for

Electric Arc Hazards.ASTM F2677–08a, Standard Specification for Electrically Insulating Aprons.The following references in Annex B are to be updated as follows:B.1.2 ANSI PublicationsANSI/ASSE Z244.1, Control of Hazardous Energy — Lockout/Tagout and Alternative Methods, 2003 (R 2008).B.1.4 IEEE PublicationsIEEE 484, Recommended Practice for Installation Design and Installation of Vented Lead-Acid Batteries for Stationary

Applications, 2002 (R 2008).IEEE 485, IEEE Recommended Practice for Sizing Lead-Acid Storage Batteries for Stationary Applications, 1997 (R

2003).IEEE 516, Guide for Maintenance Methods on Energized Power Lines, 2003 2009.


Report on Comments – June 2011 NFPA 70EB.1.6 UL Publications. Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062-2096.ANSI/UL 943, Standard for Ground-Fault Circuit Interrupters, 2006 2010.ANSI/UL 1203, Explosion-Proof and Dust-Ignition-Proof Electrical Equipment for Use in Hazardous (Classified)

Locations, 2006, Revised 2009.Separate comments have been prepared to update any extracted material

The committee accepts the direction of the Technical Correlating Committee to reconsider itsaction on Proposal 70E-3 and clarifies the action.



_______________________________________________________________________________________________70E-3 Log #243 EEW-AAA

_______________________________________________________________________________________________Bobby J. Gray, Hoydar/Buck, Inc.

70E-1The committee action on the proposal is correct and should be reconfirmed.

Implementation of new editions of NFPA 70E presents unique challenges to users not encounteredthrough implementation of other NFPA documents. For example, the critical application of work practices to preventdeath to workers must be analyzed in detail before an employer applies them. An adequate analysis could takesubstantial time to be performed competently. Once the analysis is complete, procedures implementing NFPA 70Erequirements must be changed and reviewed by all stakeholders before being issued. Additionally, training of allaffected workers is necessary to ensure complete understanding and implementation without error. For largecompanies, the time needed to complete the necessary training could extend into months. The 2007 revision to OSHASubpart S, with similar requirements and implementation challenges, allowed employers 180 days to implement the newedition. NFPA 70E should use the OSHA model as a benchmark to ensure due diligence is used in this important task.

See the committee statement on Comment 70E-1. The Committee notes that the StandardsCouncil has concluded that the effective date of this NFPA standard should remain as 20 days after issuance from theStandards Council.


BARRIOS, L.: See my negative ballot comment on Comment 70E-1.GRAY, B.: Implementation of new editions of NFPA 70E presents unique challenges to users such as DOE. For

example, application of work practices to prevent death to workers must be analyzed in detail before an employerapplies them. An analysis for large facilities could take substantial time to be performed correctly. Once the analysis iscompleted, the sites procedures would need to be updated to implement the new NFPA 70E requirements. Then theaffected workers will need to be trained to ensure complete understanding and implementation. For large facilities, thetime needed to complete the analysis and training could extend into several months. The implementation of 10 CFR 851required the DOE sites to perform a gap analysis which would be required for this standard the the companies wouldneed to implement the new changes and train the employees. This approach took place when the present NFPA 70Ewas adopted by DOE and this resulted in a delay in the implementation of the current NFPA 70E and placed thecompanies at risk when the standards stated one date and the companies could not even get the books before it wasplaced in effect. NFPA needs to adopt the time frame that allows governing bodies the ability to require companies toadopt the standard within a reasonable time frame.HICKMAN, P.: See our explanation of negative on comment 70E-1.




_______________________________________________________________________________________________Paul S. Hamer, Chevron Energy Technology Company

70E-1Change to: “It is not the intent that tThis standard becomes effective until 180 days one year from

the date of issue by the Standards Council.”The next part of this comment is directed at the Technical Correlating Committee. In line with the above, I also believe

that the three-year updates on 70E are too frequent. There is barely a completed internal company revision andapproval of its standard before the NFPA standard is revised again. The 70E standard should be on a 5 or 6 year cycle(6 years is preferred, since 70E would then be on an “every other cycle” with the NEC) to keep from constantly having tomodify internal company standards. Most of the prior editions of 70E were on greater than a three-year revision cycle.

The present phrasing is awkward, which is why the sentence is restructured to make the statement ina positive sense.It takes a significant amount of time, usually over a year, to make required changes to a company’s internal safe work

practice standard (and associated training) to be in alignment with the new edition of NFPA 70E following its release.The proposed “one year” time frame is reasonable and realistic.

See the committee statements on Comments 70E-1 and 70E-3.


BARRIOS, L.: See my negative ballot comment on Comment 70E-1.HICKMAN, P.: See our explanation of negative on comment 70E-1.


_______________________________________________________________________________________________70E-5 Log #330 EEW-AAA

_______________________________________________________________________________________________Michael K. Toney, Friendswood, TX

70E-1Revise text to read as follows:

It is not the intent that This standard becomes effective until 180 days one year from the date of issue by the StandardsCouncil.

Technical Correlating Committee - I recommend the committee consider putting 70E on a six yearrevision cycle to allow time for revisions to be implemented and experienced gained before making changes as is thecase with the current 3 year cycle.More time is needed for employers to revise work procedures, provide training and audit to meet the intent of the

revisions. Putting in the one year after the issue date and going to a six year revision cycle would be a much morereasonable time frame.







_______________________________________________________________________________________________Louis Barrios, Shell Projects & Technology

70E-1The committee action should have been to Accept in Principle and to modify the last statement of

the proposal to “The Standard becomes effective one year after the date of issue by the Standards Council.”The suggested change rewords the proposal to positive language, which should be clearer to the user.

Also modified effective date to a more realistic time frame for full implementation. By comparison, it is not unusual forstate and local jurisdictions to take 1-3 years to adopt the latest edition of National Electrical Code, which does notbecome mandatory until adoption.





_______________________________________________________________________________________________70E-7 Log #13 EEW-AAA


70E-8The Technical Correlating Committee directs that this proposal be reconsidered. The intent of this

proposal was to delete 90.2(A)(1) through (4). The revisions to 90.2(B)(5) in the 2011 NEC should be correlated withthis section in NFPA 70E.In addition, the Technical Correlating Committee directs that further consideration be given to the comments expressed

in the voting.This is a direction from the Technical Correlating Committee on National Electrical Code® in


The committee action on Comment 70E-8 meets the intent of the Technical CorrelatingCommittee recommendation.





_______________________________________________________________________________________________The Technical Correlating Committee directs that committee action be revised to correlate and provide

additional clarity between both NFPA 70 and NFPA 70E documents as follows:

This standard addresses electrical safety-related work practices for employee workplaces that arenecessary for the practical safeguarding of employees relative to the hazards associated with electrical energy duringactivities such as the installation, inspection, operation, maintenance, and demolition of electric conductors, electricequipment, signaling and communications conductors and equipment, and raceways. This standard also includes safework practices for employees performing other work activities that can expose them to electrical hazards as well as safework practices for the following:(1) Installations of conductors and equipment that connect to the supply of electricity(2) Installations used by the electric utility, such as office buildings, warehouses, garages, machine shops, and

recreational buildings that are not an integral part of a generating plant, substation, or control center.This standard does not cover safety-related work practices for the following:

(1) Installations in ships, watercraft other than floating buildings, railway rolling stock, aircraft, or automotive vehiclesother than mobile homes and recreational vehicles(2) Installations underground in mines and self-propelled mobile surface mining machinery and its attendant electrical

trailing cable(3) Installations of railways for generation, transformation, transmission, or distribution of power used exclusively for

operation of rolling stock or installations used exclusively for signaling and communications purposes(4) Installations of communications equipment under the exclusive control of communications utilities located outdoors

or in building spaces used exclusively for such installations(5) Installations under the exclusive control of an electric utility where such installations:

a. Consist of service drops or service laterals, and associated metering, orb. Are located in legally established easements or rights-of-way designated by or recognized by public servicecommissions, utility commissions, or other regulatory agencies having jurisdiction for such installations, orc. Are on property owned or leased by the electric utility for the purpose of communications, metering, generation,control, transformation, transmission, or distribution of electric energy, ord. Are located by other written agreements either designated by or recognized by public service commissions, utilitycommission, or other regulatory agencies having jurisdiction for such installations. These written agreements shall belimited to installations for the purpose of communications, metering, generation, control, transformation, transmission, ordistribution of electric energy where legally established easements or rights-of-way cannot be obtained. Theseinstallations shall be limited to federal lands, Native American reservations through the U.S. Department of the InteriorBureau of Indian Affairs, military bases, lands controlled by port authorities and state agencies and departments, andlands owned by railroads.

Kathleen Wilmer, Duke Energy70E-8

Edison Electric Institute agrees with the TCC that committee action should be reconsidered. Actionshould have been accept in principle. Text should be revised as shown:" 90.2 Scope.(A) Covered. This standard address electrical work practices safety requirements for employees that are necessary to

provide a practical safe workplace relative to the hazards associated with electrical energy for the practical safeguardingof employees during activities such as the installation, operation, maintenance, and demolition of electric conductorsand equipment, and raceways the following. This standard also includes safe work practices for employees performingother work activities that can expose them to electrical hazards.(B) Not Covered. This standards does not cover work practices for:(1) Installations in ships, watercraft other than floating buildings, railway rolling stock, aircraft, or automotive vehicles

other than mobile homes and recreational vehicles(2) Installations underground in mines and self-propelled mobile surface mining machinery and its attendant electrical



Report on Comments – June 2011 NFPA 70Eoperation of rolling stock or installations used exclusively for signaling and communications purposes(4) Installations of communications equipment under the exclusive control of communications utilities located outdoors

or in building spaces used exclusively for such installations(5) Installations under the exclusive control of an electric utility, where such installations:(a) Consist of service drops or service laterals, and associated metering, or (b) Are located in legally established

easements or rights-of-way designated by or recognized by public service commissions, utility commissions, or otherregulatory agencies having jurisdiction for such installations, or (c) Are on property owned or leased by the electricutility for the purpose of communications, metering generation, control, transformation, transmission, or distribution ofelectric energy."Item 2. In addition, the NFPA 70 Code-making Panel No. 1 has unanimously accepted Comment 1-23 on 90.2(B)(5)

for the 2011 National Electrical Code, which is the consensus of the NEC-NESC Ad Hoc on this section. The result ofthis action will require correlation of the scopes of NFPA Standards 70E and 70. The action of the Technical Committeeshould have been to accept 70E-8 in principle with this change to 90.2(B)(5):"(5) Installations under the exclusive control of an electric utility where such installations:a. Consist of servicedrops or service laterals, and associated metering, or

bc. Are on property owned or leased by the electric utility for the purpose of communications, metering, generation,control, transformation, transmission, or distribution or electric energy, orcb. Are located in legally established easements or rights of way designated by or recognized by public service

commissions, utility commissions, or other regulatory agencies having jurisdiction for such installations, ord. Are located by other written agreements either designated by or recognized by public service commissions, utility

commissions, or other regulatory agencies having jurisdiction for such installations. These written agreements shall belimited to installations for the purpose of communications, metering, generation, control, transformation, transmission, ordistribution of electric energy where legally established easements or rights-of way cannot be obtained. Theseinstallations shall be limited to Federal Lands, Native American Reservations through the U.S. Department of the InteriorBureau of Indian Affairs, Military bases, lands controlled by port authorities and State Agencies and departments, andlands owned by railroads."

Item 1. The revised 90.2(A) items were to be in concert with the new Committee Scope for NFPA 70Ebased on the NEC TCC Task Group on 70E Scope. These proposed changes were made to make it clear that thestandard covers work practices, rather than installations. It is apparent that the Task Group’s legislative text was nottranscribed properly for the 70E Technical Committee’s action.Item 2. In addition, the NFPA 70 Code-Making Panel 1 has unanimously accepted Comment 1-23 on 90.2(B)(5) for the

2011 National Electrical Code, which is the consensus of the NEC-NESC Ad Hoc on this section. The result of thisaction will require correlation of the scopes of NFPA Standards 70E and 70.

Revise 90.2 to read90.2 Scope.(A) Covered. This standard addresses electrical work practices for employee workplaces that are necessary for the

practical safeguarding of employees relative to the hazards associated with electrical energy during activities such asthe installation, inspection, operation, maintenance, and demolition of electric conductors, electric equipment, signalingand communications conductors and equipment, and raceways. This standard also includes safe work practices foremployees performing other work activities that can expose them to electrical hazards.(B) Not Covered. This standard does not cover work practices for:(1) Installations in ships, watercraft other than floating buildings, railway rolling stock, aircraft, or automotive vehicles




or in building spaces used exclusively for such installations(5) Installations under the exclusive control of an electric utility where such installations:a. Consist of service drops or service laterals, and associated metering, orb. Are on property owned or leased by the electric utility for the purpose of communications, metering, generation,

control, transformation, transmission, or distribution of electric energy, orc. Are located in legally established easements or rights-of-way, ord. Are located by other written agreements either designated by or recognized by public service commissions, utility

commissions, or other regulatory agencies having jurisdiction for such installations. These written agreements shall be


Report on Comments – June 2011 NFPA 70Elimited to installations for the purpose of communications, metering, generation, control, transformation, transmission, ordistribution of electric energy where legally established easements or rights-of way cannot be obtained. Theseinstallations shall be limited to Federal Lands, Native American Reservations through the U.S. Department of the InteriorBureau of Indian Affairs, Military bases, lands controlled by port authorities and State Agencies and departments, andlands owned by railroads.

The committee has revised this recommendation to clarify the scope and has incorporated therevision resulting from the committee action on Proposal 70E-9. This action meets the recommendation of the TechnicalCorrelating Committee in Proposal 70E-8 and its subsequent Comment 70E-7.


NEITZEL, D.: I agree with David Pace's negative vote and comment that the "accepted action does not addresswhether office buildings, warehouses or other structures not used for generation of electricity are covered by thisstandard. The accepted wording could easily be interpreted that these facilities are not covered because they are onproperty where generation occurs. Facilities and structures not used for generation should be covered by this standard.The physics of electricity do not change because the facility is on property where generation occurs."PACE, D.: The accepted action does not address whether office buildings, warehouses or other structures not used

for generation of electricity are covered by this standard. The accepted wording could easily be interpreted that thesefacilities are not covered because they are on property where generation occurs. Facilities and structures not used forgeneration should be covered this standard. The physics of electricity do not change because the facility is on propertywhere generation occurs.


_______________________________________________________________________________________________70E-9 Log #156 EEW-AAA

_______________________________________________________________________________________________James T. Dollard, Jr., IBEW Local 98

70E-8Accept the proposal in principle as modified by Mr. Hickman in his negative comment.

The action on this proposal should have been to Accept in Principle. This proposal to revise 90.2 wassubmitted by the NEC TCC to revise the scope of NFPA 70E as suggested by the NEC TCC Task Group on 70E. Theseproposed changes were made to provide clarity to the user of the document, making it clear that the standard coverswork practices, and does not contain installation requirements. It is apparent that the Task Group’s legislative text wasnot transcribed properly for the 70E Technical Committee’s action. Additionally, 90.2(B)(5) must be revised to correlatewith the 2011 NEC.

See the committee action and statement on Comment 70E-8.


NEITZEL, D.: See my explanation on Comment 70E-8.PACE, D.: See my explanation on Comment 70E-8.




_______________________________________________________________________________________________John F. Boothroyd, Entergy Fossil Operations

70E-8Edison Electric Institute agrees with the TCC that the committee action should be reconsidered.

The action should have been accept in principle. Text should be revised as shown:"90.2 Scope.(A) Covered. this standard addresses electrical work practices safety requirements for employees that are necessary

to provide a practical safe workplace relative to the hazards associated with electrical energy for the practicalsafeguarding of employees during activities such as the installation, operation, maintenance, and demolition of electricconductors, electric equipment, signaling and communications conductors and equipment, and raceways the following:.This standard also includes safe work practices for employees performing other work activities that can expose them toelectrical hazards.(B) Not Covered. This standard does not cover work practices for:(1) Installations in ships, watercraft other than floating buildings, railway rolling stock, aircraft, or automotive vehicles




or in building spaces used exclusively for such installations(5) Installations under the exclusive control of an electric utility, where such installations:

a. Consists of service drops or service laterals, and associated metering, orb. Are located in legally established easements or rights-of-way designated by or recognized by public service

commissions, utility commissions, or other regulatory agencies having jurisdiction for such installations, orc. Are on property owned or leased by the electric utility for the purpose of communications, metering, generation,

control, transformation, transmission, or distribution of electric energy."Item 2. In addition, the NFPA 70 Code-Making Panel No. 1 has unanimously accepted Comment 1-23 on 90.2(B)(5)

for the 2011 National Electrical Code, which is the consensus of the NEC-NESC Ad Hoc on this section. The result ofthis action will require correlation of the scopes of NFPA Standards 70E and 70. The action of the Technical Committeeshould have been to accept 70E-8 in principle with this change to 90.2(B)(5):"(5) Installations under the exclusive control of an electric utility where such installations:

a. Consist of service drops or service laterals, and associated metering, orbe. Are on property owned or leased by the electric utility for the purpose of communications, metering, generation,

control, transformation, transmission, or disbrituation of electric energy, orcb. Are located in legally established easements or rights-of-way designated by or recognized by public commissions,

utility commissions, or other regulatory agencies having jurisdiction for such installations, ord. Are located by other written agreements either designated by or recognized by public service commissions, utility

commissions, or other regulatory agencies having jurisdiction for such installations. These written agreements shall belimited to installations for the purpose of communications, metering, generation, control, transformation, transmission, ordistribution of electric energy where legally established easements or rights-of-way cannot be obtained. Theseinstallations shall be limited to Federal Lands. Native American Reservations through the U.S. Department of the InteriorBureau of Indian Affairs, Military bases, lands controlled by port authorities and state agencies and departments andlands owned by railroads."

Item 1. The revised 90.2(A) items were to be in concert with the new Committee Scope for NFPA 70Ebased on the NEC TCC Task Group on 70E Scope. These proposed changes were made to make it clear that thestandard covers work practices, rather than installations. It is apparent that the Task Group's legislative text was nottranscribed properly for the 70E Technical Committee's action.Item 2. In addition, the NFPA 70 Code-making Panel No. 1 has unanimously accepted Comment 1-23 on 90.2(B)(5)

for the 2011 National Electrical Code, which is the consensus of the NEC-NESC Ad Hoc on this section. The result ofthis action will require correlation of the scopes of NFPA Standards 70E and 70.



Report on Comments – June 2011 NFPA 70E




_______________________________________________________________________________________________70E-11 Log #395 EEW-AAA

_______________________________________________________________________________________________Paul Dobrowsky, Holley, NY

70E-10Accept the comment in principle using Mr. Hamer's Ballot Statement adding the following words:

and for non-electrical activities that can expose unqualified persons to electrical hazards”.Section 90.1 is very general but does not include the details of what is covered as does 90.2. Many

other trades are exposed to the hazards of electricity even though they may not specifically intending to use electricityfor a given task. As presently written 90.2 is not clear that the standard applies to employees doing non -electrical work.Employerrs such as roofing contractors should have an electrical safety program that makes their employees aware ofthe hazards such as for over head lines.

The committee action on Comment 70E-8 meets the intent of the recommendation.




_______________________________________________________________________________________________70E-12 Log #14 EEW-AAA


70E-11It was the action of the Technical Correlating Committee that this proposal be reconsidered and

correlated with the action taken on Proposal 70E-8.This is a direction from the Technical Correlating Committee on National Electrical Code® in




NEITZEL, D.: See my explanation on Comment 70E-8.


PACE, D.: See my explanation on Comment 70E-8.




70E-11Reject the proposal.

The action of the NFPA 70E Technical Committee on this comment must be correlated with the actionon comments to proposal 70E-8 that seeks to delete the list items in 90.2(A).While the submitters’ intent is safety driven and his claim that the hazards are the same is correct, the scope of this

document should not apply to integral portions of generating plants, substations and control centers that are usedexclusively for transmission and distribution by electric utilities. This debate was prominently settled last cycle. Electricalutilities choose to use the NESC to provide safe working conditions.It should be noted for the record that the scope of this document is under the purview of the NEC TCC and has been

revised as seen in the text of proposal 70E-8 and the associated negative comments.

The committee notes that the subject of the recommendation has been deleted by thecommittee action on Comment 70E-8.






_______________________________________________________________________________________________Bobby J. Gray, Hoydar/Buck, Inc.

70E-12The committee action on the proposal should have been Accept in Principle with the following

revisions made to the proposal text:90.5 Enforcement. This standard is intended to be suitable for mandatory application by governmental bodies

employers and other entities that exercise legal jurisdiction over electrical installations and safe electrical work practices.The authority having jurisdiction for enforcement of the standard has the responsibility for making interpretations of therules,; for deciding on the approval of the work practices, procedures, and methods,; and for granting the specialpermission contemplated in a number of the rules.By special permission, the authority having jurisdiction may waive specific requirements in this standard or shall bepermit-permitted to approve alternative methods where it is assured that equivalent objectives can be achieved byestablishing and maintaining effective safety.Informational Note: The range of enforcement and allowance for the designated authority having jurisdiction may belimited by federal or local enforcement authorities that exercise jurisdiction over the safety of individual or public worklocations.

The existence of the authority having jurisdiction is recognized through definition and in specificreferences within NFPA 70E, 2009. What is lacking in the document is the general acceptance of the responsibility anddefinition of the authority of the AHJ that is described in other NFPA work practice standards such as NFPA 25. Withouta skilled and knowledgeable individual or cornmittee to apply and enforce the standard to the intent of the authors, thepotential exists for indecision or worse--dangerous decisions. By establishing the responsibility and authority of the AHJ,the Technical Committee can send a message to the employer that emphasizes the importance of a knowledgeableelectrical safety expert to provide guidance and correction to unsafe work practices.The TC is correct in objecting to references to installations since installations are outside the scope of the standard and

are within the authority of the NEC inspectors. The TC also can correct misconceptions by some that the AHJ forelectrical work practices must be an NEC inspector, even though the definition and NFPA governing documents clearlydescribe otherwise. In absence of the recognition for the authority having jurisdiction, the employer is given impliedlicense to choose which parts of NFPA 70E to incorporate and how to implement the rules.As an example of the need for an AHJ, consider the following: currently, no mandatory for estimating incident energy

exposure exists in the standard. So, technically an employer could choose to complete an arc flash hazard analysis byintuition and be compliant. Clearly, the intent of the TC is to use a method that is recognized as a bestpractice. A delegated AHJ would ensure that due diligence is used in determining potential arc flash exposure and thatappropriate protection methods are employed.The TC has done an excellent job of balancing minimum safe requirements against allowing the employer to comply in

a method that best fits their individual work place. However, providing latitude in methods of compliance, presents theincreased risk of misapplication of the rules. Each job location potentially is unique and presents conditions notanticipated by the TC or its task groups. A knowledgeable AHJ representing the employer or other governing agency willreduce the risk of under- or over-prescribing compliance techniques, thus increasing safety and confidence in use of thestandard. By adopting the proposal as revised by this comment, the employer or enforcing agency is empowered, if notencouraged, to vest authority in a qualified entity to remove any subjectivity from application of the rules. This will makeuse of the document safer for workers, more credible for employers, and relieve the temptation for workers or others tomisinterpret the intent of the rules.

The committee reinforces its previous position that NFPA 70E is a standard, and not a code,and therefore enforcement of the requirements in the standard is the responsibility of any entity that chooses to adopt it.


DROBNICK, D.: The acceptance of this comment would establish formal authority for electrical safety professionalworking at Department of Energy locations as required by the adoption of 10CFR 851.GRAY, B.: The TC has failed to provide a technical substantiation in sufficient detail that explains the rational for


Report on Comments – June 2011 NFPA 70Erejecting this comment and the associated proposal as required by Section 4.4.6.3 of the Regulations GoverningCommittee Projects. The provided statement implies that the implementing agency for adopting a code is notresponsible for enforcement of that code but does have that responsibility for a standard, which clearly is not factual.The statement also implies that the authority-having-jurisdiction concept is not applicable to a standard, which is clearlycontrary to the definition of Authority Having Jurisdiction in Article 100 of NFPA 70E, 2009. If the TC feels that safety ofthe workers would be compromised by establishment of parameters of authority and responsibility for an entitydelegated to approve electrical safety procedures and enforce implementation of the mandatory rules, the proposalsubmitter deserves to be provided that information rather than be confused by inaccurate or contradictory statements.


_______________________________________________________________________________________________70E-15 Log #408 EEW-AAA

_______________________________________________________________________________________________T David Mills, Savannah River Nuclear Solutions, LLC

70E-12The Committee action should have been "Accept" for this proposal.

The statement, "This document is a consensus standard suitable for adoption by employers. The entity(employer) that adopts NFPA 70E is responsible for enforcement of the requirements in the standard." does nothing toaddress the issue. The intent of the original proposal was to allow for proper enforcement by an AHJ, or SME if youprefer, and to allow a decision to be made in the field that is not simply black and white as the wording in the documenttends to read. The committee must understand that this document has already been made "LAW" for the Department ofEnergy (DOE) and we are required to follow the document in its entirety. We cannot choose which sections to follow orwhich ones are considered just a good idea and not a requirement. We are bound by law (10CFR851) to follow NFPA70E. This is a situation where fines could be assessed against sites found to be out of compliance with the document.The proposal requested similar wording to that found in NFPA 70 for enforcement, since by law we at DOE sites must

assure that all parts of NFPA 70E are followed. The proposed text allows the AHJ the same flexibility to use technicaljudgment to appropriately apply the requirements of the document as is afforded the AHJ for NFPA 70.For example, 130.3(C) states: "(C) Equipment Labeling. Equipment shall be field marked with a label containing the

available incident energy or required level of PPE."If I had elected to use Table 130.7(C)(9) in lieu of an analysis (as is allowed in 130.3 Exception 2), I would not have the

incident energy value to place on the label nor would I be able to make a meaningful label from the tasks listed in Table130.7(C)(9) as there would be several levels of PPE cited there dependent on the task. There is no built-in fix for thissituation without the proposed enforcement clause.I request the committee to carefully reconsider and refer to the explanation of negative provided by Mr. Gray to fully

understand the untenable situation in which the largest single user (DOE) of NFPA 70E finds itself.

See the committee statement on Comment 70E-14.


GRAY, B.: See my negative comment for 70E-14.



Report on Comments – June 2011 NFPA 70E_______________________________________________________________________________________________70E-15a Log #CC2 EEW-AAA


70E-3Revise the defined term to the 2011 NEC definition for

This definition is extracted from NFPA 70. Per Proposal 70E-3 and Comment 70E-2 the committee hasreviewed this definition in the 2011 NEC and determined that the extract should be updated in the 2012 edition of NFPA70E.



_______________________________________________________________________________________________70E-15b Log #CC3 EEW-AAA






_______________________________________________________________________________________________70E-15c Log #CC4 EEW-AAA







Report on Comments – June 2011 NFPA 70E_______________________________________________________________________________________________70E-15d Log #CC5 EEW-AAA






_______________________________________________________________________________________________70E-15e Log #CC6 EEW-AAA

_______________________________________________________________________________________________The Technical Correlating Committee directs that the term “service point” and its definition be retained.

The definition shall be revised to correlate with the 2011 NEC edition and shall include the informational note.The service point definition is necessary since the term is used within the definitions of service drop and service lateral

and may reduce the clarity of the document if it is removed.

Technical Committee on Electrical Safety in the Workplace,70E-3 & 70E-14

Delete the following terms from Article 100 (Definitions):AmpacityCutout BoxNeutral ConductorService PointService Conductor

These definitions are extracted from NFPA 70. Per Proposal 70E-3, Comment 70E-2 and theaffirmative ballot statement on Proposal 70E-14, the committee has reviewed Article 100 and determined that thedefinitions of these terms are either not used in the standard or are not essential to the use of the standard.



DROBNICK, D.: The Committee correctly removed unused definitions that were submitted with my affirmativecomment on Proposal 70E-14 (Log #CP1).


Report on Comments – June 2011 NFPA 70E_______________________________________________________________________________________________70E-15f Log #CC10 EEW-AAA


70E-260Add the definition of from the 2011 NEC to read:

Dwelling Unit. A single unit, providing complete and independent living facilities for one or more persons, includingpermanent provisions for living, sleeping, cooking, and sanitation. [70, 2011]

The definition of dwelling unit is necessary for correlation with the committee action on CommitteeComment 70E-248a (Log #CC7).


DROBNICK, D.: The Committee Action should have been Reject. This definition does not comply with Section 2.2.2.1of the NEC Style Manual (2003), which requires that a term be used in two or more articles before a definition isprovided in Article 100.


_______________________________________________________________________________________________70E-16 Log #246 EEW-AAA


70E-17Revise the wording of the proposal as follows:

Arc Flash. An event that is accompanied by an uncontrolled release of energy in the form of exceptionally high heatand light, and may include an arc blast. It is a self-sustaining arc event that creates ionization of the air in the vicinity ofthe initiating arc luminous discharge and will continue until the current flow to the location is interrupted.

There is a need to differentiate between an “arc,” which may not radiate significant energy, and an “arcflash,” which does. The added underlined word “an” is editorially added for grammatical reasons and the word “arc” isreplaced by “event” to avoid using the defined word or term in the definition. “Luminous discharge” is used instead of“arc” per the IEEE Standard Dictionary of Terms.

The Committee does not agree that a definition of arc flash is needed. Annex K provides insighton what an arc flash is.


GRAY, B.: Annex K does not provide sufficient information or requirements to enable a user to distinguish between theevent causing the catastrophic results described in Annex K and the broad range of hazards associated with otherhazards resulting from arcs, sparks, and thermal conductance exposure. Definitions are needed to help usersunderstand the terms, potential exposures, and appropriate controls in order to maintain credibility of the document.




_______________________________________________________________________________________________Stephen Crimaudo, American Petroleum Institute

70E-17The committee action should have been to Accept in Principle.

Revise the wording of the proposal as follows:Arc Flash. An event that is accompanied by an uncontrolled release of energy in the form of exceptionally high heat

and light, and may include an arc blast. It is a self-sustaining arc event that creates ionization of the air in the vicinity ofthe initiating a arc luminous discharge and will continue until the current flow to the location is interrupted.

There is a need to differentiate between an "arc", which may not radiate significant energy, and an "arcflash,· which does. The added underlined word "an" is editorially added for grammatical reasons and the word "arc" isreplaced by "event" to avoid using the defined word or term in the definition. "Luminous discharge" is used instead of"arc" per the IEEE Standard Dictionary of Terms.



GRAY, B.: See my negative comment on 70E-16.


_______________________________________________________________________________________________70E-18 Log #15 EEW-AAA


70E-20The Technical Correlating Committee directs that further consideration be given to the comments

expressed in the voting.The use of the two terms “Arc Flash Hazard Analysis” and “Incident Energy Analysis” could result in a lack of

correlation within the document.This is a direction from the Technical Correlating Committee on National Electrical Code® in


The committee agrees that an incident-energy analysis is a component of an arc-flash hazardanalysis and reduces the possibility of confusion mentioned by the Technical Correlating Committee (TCC). See thecommittee action on Comments 70E-19 and 70E-41 which address the concern of the TCC.






70E-20Modify the text accepted in the Committee Meeting Action as suggested by Mr. Hickman’s

Comment on Affirmative, and include changes as suggested by Mr. Hamer in his Comment on Affirmative:. A study component of an arc flash hazard analysis, used to predict the incident energy heat

flux of an arc flash, over a period of time, for a specified set of conditions.Informational Note: The conventional units of heat flux over time is either joules/cm2 or calories/cm2.

This is an improved definition, since it would not use the defined term “incident energy” within thedefinition. It also clarifies that an “incident energy analysis” is one component of an “arc flash hazard analysis.”

The committee accepts the recommendation to include "component of an arc flash hazard analysis" in the definition andrejects the remainder of the recommendation.

The committee does not accept replacing "incident energy" with "heat flux of an arc flash over aperiod of time" as is defined in the standard and is the appropriate term to use in the definition of

. Additionally, the committee does not accept the recommended informational note as it doesnot provide additional clarity to the definition of In regard to the accepted portion of therecommendation see the committee action on Comment 70E-41.



_______________________________________________________________________________________________70E-20 Log #16 EEW-AAA


70E-22The Technical Correlating Committee directs that the committee clarify the committee action taken

on this proposal.This is a direction from the Technical Correlating Committee on National Electrical Code® in


The Committee action on Proposal 70E-22 revises the definition to include only the firstsentence as shown in the recommendation. The new Informational Note as modified by the committee actionaddressed the substantiation citing the definition as being too restrictive.





_______________________________________________________________________________________________The Technical Correlating Committee directs that this comment be reported as “Hold” since the removal

of the term “and nose” introduces a new concept that has not had public review.Drake A. Drobnick, Saline, MI

70E-27Remove the words "and nose" from the definition.

There is no reason to leave the nose exposed. The eyes are protected by safety glasses or goggles.See substantiation in Proposal 70E-380 (Log #244).


BARRIOS, L.: Insufficient technical substantiation was provided for the change. The arc rated face shield that will beworn in addition to the balaclava sock hood will provide protection to the face area not covered by the balaclava.Mandating covering both the mouth and nose may restrict breathing. The substantiation provided in Proposal 70E-380addresses testing that was performed for exposures above 12 cal/cm2. The substantiation provided does not supportmandating covering the nose and mouth for whenever a balaclava is worn.CARPENTER, T.: The committee action should have been to reject. The change requested was not part of the

original proposal (70E-27), nor was it part of the referenced proposal substantiation (70E-380). As such, it has not hadpublic review.HITTEL, M.: The original Proposal 70E-27 only sought to strike the use of "FR" from the definition. This comment is

deleting the words "and nose" and references substantiation from Proposal 70E-380 to justify deletion of thoseadditional words from the definition where there is no suggestion to remove the words "or nose" in Proposal 70E-380.NEITZEL, D.: I agree with the negative comment by Mike Hittel that "The original Proposal 70E-27 only sought to

strike the use of "FR" from the definition. This comment is deleting the words "and nose" and references substantiationfrom Proposal 70E-380 to justify deletion of those additional words from the definition where there is no suggestion toremove the words "or nose" in Proposal 70E-380." I also agree with the negative comment by Tom Carpenter that "Thecommittee action should have been to reject. The change requested was not part of the original proposal (70E-27), norwas it part of the referenced proposal substantiation (70E-380). As such, it has not had public review."


DROBNICK, D.: I disagree with my esteemed colleague’s negative vote on the removal of the term “nose” from thedefinition of balaclava. The substantiation for Proposal 70E-380 was based upon testing performed by Dr. Tom Neal onface shield/balaclava combinations. His results indicated that facial areas including the nose and mouth covered by abalaclava when worn under a face shield provided burn protection when tested at various angles for exposures greaterthan 40 cal/cm2.HALE, L.: The intent of the submitter was met in in ROP 70E-27.WIDUP, R.: Agree with committee action - current arc-rated balaclava designs are commercially available to protect

the nose and it should be included.



_______________________________________________________________________________________________Danny Liggett, DuPont Company

70E-30This Proposal should have been Rejected.

I agree with Mr. Hamer’s statement that the wording in the 70E-2009 accurately described the intent.While some may wish to apply arc flash protection outside of this boundary nothing in this standard or this definitionrestricts that.Removal of the word “protection” may send an unintended signal.

The definitions of the shock boundaries do not feature the word “Protection”. Also, a boundarydoes not “provide” protection.


BARRIOS, L.: The term "arc flash protection boundary" is well understood to be the point at which persons arerequired to wear arc flash protection PPE. 130.3(B) of the 2009 edition of the Standard states that where it has beendetermined that work will be performed within the Arc Flash Protection Boundary..., one of the following methods shallbe used for the selection of protective clothing and other personal protective equipment. The committee statement that"a boundary does not provide protection" is terse and does not justify removing the "protection" from the term.HITTEL, M.: The action should be accept. The committee statement that "a boundary does not 'provide' protection"

is premised on an interpretation that the word boundary is a modifier of the word protection. This is an inaccurateinterpretation. The words "arc flash protection" modifies the word "boundary" and is accurate and appropriate in that it isthe threshold beyond which arc flash protection is required. The standard does not preclude the use of arc flashprotection outside of this boundary.NEITZEL, D.: I agree with the negative comments by Louis Barrios, Mike Hittel, and David Pace and restates the

comments they made, that:“The term "arc flash protection boundary" is well understood to be the point at which persons are required to wear arc

flash protection PPE. 130.3(B) of the 2009 edition of the Standard states that where it has been determined that workwill be performed within the Arc Flash Protection Boundary..., one of the following methods shall be used for theselection of protective clothing and other personal protective equipment. The committee statement that "a boundarydoes not provide protection" is terse and does not justify removing the "protection" from the term.The action should be accept. The committee statement that "a boundary does not 'provide' protection" is premised on

an interpretation that the word boundary is a modifier of the word protection. This is an inaccurate interpretation. Thewords "arc flash protection "modifies the word "boundary" and is accurate and appropriate in that it is the thresholdbeyond which arc flash protection is required. The standard does not preclude the use of arc flash protection outside ofthis boundary.This comment should have been an accept. As Mr. Hamer points out, the definition as it is currently written establishes

a boundary within which protection is not required by other parts of the 70E document. The term is well understood andthere is no compelling reason to change. Changing, however, does present the potential for this term to bemisunderstood. The existing wording should be retained.

PACE, D.: This comment should have been an accept. As Mr. Hamer points out, the definition as it is currently writtenestablishes a boundary within which protection is not required by other parts of the 70E document. The term is wellunderstood and there is no compelling reason to change. Changing, however, does present the potential for this term tobe misunderstood. The existing wording should be retained.





70E-30Reject the proposed change and add “protection” to the term, “Boundary, Arc Flash Protection” as

it now exists in the 2009 edition.The definition, as it reads, does establish a boundary within which protection is not required by other

parts of the standard. The term has been well understood since the 1995 edition of NFPA 70E and there is not acompelling reason to change it.



BARRIOS, L.: See my negative ballot comment on Comment 70E-22.HITTEL, M.: See my Explanation of Negative on Comment 70E-22 (Log #168).NEITZEL, D.: See my negative ballot comment on Comment 70E-22 (Log #168).PACE, D.: See my explanation of negative for comment 70E-22.


_______________________________________________________________________________________________70E-24 Log #290 EEW-AAA


70E-30The committee should have rejected this proposal and should retain the word "protection" in

"Boundary, Arc Flash Protection."The present term, "arc flash protection boundary" correctly reflects that protection is required when

work is performed within the boundary, as required in 130.3(B). The term has been well understood since the 1995edition of NFPA 70E and there is not a compelling reason to change it. Deletion of "protection" may negatively impactthe clarity of the term and definition.



BARRIOS, L.: See my negative ballot comment on Comment 70E-22.HITTEL, M.: See my Explanation of Negative on Comment 70E-22 (Log #168).NEITZEL, D.: See my negative ballot comment on Comment 70E-22 (Log #168).PACE, D.: See my explanation of negative for comment 70E-22.




_______________________________________________________________________________________________Daniel T. Roberts, Schneider Electric

70E-30The committee action on ROP-30 deleted the word “protection” from all instances of the term “arc

flash protection boundary.” The committee action should have also directed that all instances where related terms suchas “flash protection boundary,” “flash hazard boundary,” and “flash boundary” also be modified to the new term “arc flashboundary.”The following references from the ROP draft indicate where these related terms may be found:Eight (8) instances where the term “flash protection boundary” is used-1. Section 90.42. Figure C.1.2.43. Section D.24. Table D.2 column 75. Section D.46. Section D.77. Table H.4.1 Note 5 first sentence8. Table H.4.1 Note 5 second sentenceOne (1) instance where the term “flash hazard boundary” is used-1. Section 130.4(B) informational noteTwo (2) instances where the term “flash boundary” is used-1. Table D.7.7 column 52. Table D.7.7 column 5

This action should be taken to correlate with the action taken on ROP-30 and to ensure the consistentuse of a single term “arc flash boundary” throughout the document.


BARRIOS, L.: See my negative ballot comment on Comment 70E-22.HITTEL, M.: The action should be reject. The committee statement that "a boundary does not 'provide' protection" is

premised on an interpretation that the word boundary is a modifier of the word protection. This is an inaccurateinterpretation. The words "arc flash protection" modifies the word "boundary" and is accurate and appropriate in that it isthe threshold beyond which arc flash protection is required. The standard does not preclude the use of arc flashprotection outside this boundary.NEITZEL, D.: See my negative ballot comment on Comment 70E-22 (Log #168).





70E-37Reject the proposal and replace the definition with the one used in the 2011 NEC.

The definition of Building in NFPA 70E should not be different than what is in the NEC. Although NFPA70E could be applied to a building designed to another installation code it is frequently used with NEC applications andby people that are used to using the NEC. Using different definitions in NFPA 70E as compared to the NEC, withoutgood reason, can create confusion. If the NFPA101 definition is the preferred one then the NEC and NFPA 70E shouldboth match it. Apparently NEC panel 1 did not accept the NFPA 101 definition. Additionally it is misleading to indicatethat the proposer was the NFPA 70E committee.



_______________________________________________________________________________________________70E-27 Log #249 EEW-AAA


70E-38Recommend relocating the definition of “Conductor, Bare” from Article 100 of the existing NFPA

70E-2009 to Article 130, where the term appears numerous times in the context of the descriptions in existing Table130.7(C)(9)

The term “bare … conductor” exists many places in Table 130.7(C)(9). A definition is needed.

The committee directs that the definition be retained in Article 100 and not moved to Article 130.Although the term is currently used in only Article 130, it is a general term and does not have a

definition that is unique to a specific article in the standard. Therefore retaining the definition in Article 100 isappropriate.


DROBNICK, D.: The Committee action should have been Accept. The two definitions as added are each used in onlyone sub-division. The NEC Style Manual requires this type of definition to be placed within that respective sub-divisionnot in Article 100. Additionally, the Committee could have chosen to place the terms into Article 100 and use areference pointer to the sub-division to inform the user that each definition is located there.NEITZEL, D.: The Committee action should have been Accept. The two definitions, as added, are each used in only

one sub-division. The NEC Style Manual requires this type of definition to be placed within the respective sub-divisionnot in Article 100.





70E-38The committee action should have been to Accept in Principle and to relocate the definition of

"conductor, bare" from Article 100 of the existing NFPA 70E-2009 to Article 130, where the term appears numeroustimes in the context of the descriptions in exisiting Table 130.7(C)(9).

The term "bare...conductort" exists many places in Table 130.7(C)(9). A definition is needed



DROBNICK, D.: The Committee action should have been Reject. These definitions do not comply with Section 2.2.2.1of the NEC Style Manual (2003), which requires that a term be used in two or more articles before a definition isprovided in Article 100. (Bare Conductor, not found within the document using Find function)(Proposal 70E-63) at the ROP stage.

NEITZEL, D.: The Committee action should have been Reject. These definitions do not comply with Section 2.2.2.1of the NEC Style Manual (2003), which requires that a term be used in two or more articles before a definition isprovided in Article 100. (Bare Conductor is not found within the document using Find function)





70E-39Recommend relocating the definition of “Conductor, Covered” from Article 100 of the existing NFPA

70E-2009 to Article 130, where the term appears in 130.1(A), FPN No. 3.Add to 130.1(A)(3), FPN No. 3:“…high-resistance grounding of low voltage and 5 kV (nominal) systems, current limitation, and specification of

covered bus or conductors within equipment are techniques available to reduce the hazard of the system.”)The term “covered conductor” (bus) exists 130.1. A definition is needed. It is very important to retain

the distinction that a “covered conductor” is not the same as an “insulated conductor.”The additional “or conductors” to FPN No. 3 was discussed on Hamer’s Explanation of Negative to the action on

Proposal 70E-39.

The committee accepts retaining the definition of "conductor, covered". The committee accepts in principle the revisionto the last sentence of Fine Print Note No. 3 to 130.1(A)(3) to read:Proven designs such as arc-resistant switchgear, remote racking (insertion or removal), remote opening and closing of

switching devices, high-resistance grounding of low-voltage and 5 kV (nominal) systems, current limitation, andspecification of covered bus or covered conductors within equipment are techniques available to reduce the hazard ofthe systemThe committee does not accept locating the definition in Article 130.

Although the term is currently used in only Article 130, it is a general term and does not have adefinition that is unique to a specific article in the standard. Therefore retaining the definition in Article 100 isappropriate.


DROBNICK, D.: The Committee action should have been Accept. The two definitions as added are each used in onlyone sub-division. The NEC Style Manual requires this type of definition to be placed within that respective sub-divisionnot in Article 100. Additionally, the Committee could have chosen to place the terms into Article 100 and use areference pointer to the sub-division to inform the user that each definition is located there.NEITZEL, D.: The Committee action should have been Accept. The two definitions, as added, are each used in only

one sub-division. The NEC Style Manual requires this type of definition to be placed within the respective sub-divisionnot in Article 100.





70E-39The committee action should have been to Accept in Principle and to relocate the definition of

"Conductor, Covered" from Article 100 of the existing NFPA 70E-2009 to Article 130, where the term appears in130.1(A), FPN No. 3.Also, per Mr. Hamer's negative ballot comment on Proposal 70E-39, add "or conductors" in 130.1(A)(3) FPN No. 3 as

follows:"...high-resistance grounding of low voltage and 5 kV (nominal) systems, current limitation, and specification of covered

bus or conductors within equipment are techniques available to reduce the hazard of the system."The term "covered conductor" (bus) exists in 130.1. A definition is needed. It is important to retain the

distinction that a "covered conductor" is not the same as an "insulated conductor:The additional "or conductors" to FPN No. 3 was discussed on Hamer's Explanation of Negative to the action on

Proposal 70E-39.



DROBNICK, D.: The Committee action should have been Reject. These definitions do not comply with Section 2.2.2.1of the NEC Style Manual (2003), which requires that a term be used in two or more articles before a definition isprovided in Article 100. (Covered Conductor, not found within the document using Find function)Proposal 70E-63) at the ROP stage.NEITZEL, D.: The Committee action should have been Reject. These definitions do not comply with Section 2.2.2.1

of the NEC Style Manual (2003), which requires that a term be used in two or more articles before a definition isprovided in Article 100. (Covered Conductor is not found within the document using Find function)





70E-40Recommend reversing the action to accept this proposal and to retain the definition of “Conductor,

Insulated” in Article 100 as it exists in NFPA 70E-2009.A definition is needed. It is very important to retain the distinction that a “covered conductor” is not the

same as an “insulated conductor.”See Hamer’s Explanation of Negative to the action on Proposal 70E-40.


DROBNICK, D.: The Committee action should have been Reject. These definitions do not comply with Section 2.2.2.1of the NEC Style Manual (2003), which requires that a term be used in two or more articles before a definition isprovided in Article 100. (Insulated Conductor, only found within the document in a term that has been deleted)(Proposal 70E-63) at the ROP stage.NEITZEL, D.: Should be Reject (R). The term "insulated conductor" is not used in the standard, therefore a definition

is not needed. Placement of this definition in Article 100 does not comply with Section 2.2.2.1 of the NEC Style Manual(2003), which requires that a term be used in two or more articles before a definition is provided in Article 100.


_______________________________________________________________________________________________70E-32 Log #293 EEW-AAA


70E-40The committee action should have been to Reject this proposal and to retain the definition of

"Conductor, Insulated" in Article 100 as it exists in NFPA 70E-2009.A definition is needed. It is important to retain the distinction that a "covered conductor" is not hte

same as an "insulated conductor."See Mr. Hamer's Explanation of Negative to the action on Proposal 70E-40.


NEITZEL, D.: See my Explanation of Negative on Comment 70E-31 (Log #251).





70E-43The committee should accept this proposal in part.

The committee should accept the definition and reject the fine print note. The definition is accurate andneeds to be included, while the FPN is not mandatory anyway and that seems to be causing more concern than thedefinition.

The proposal limits the defined term to only certain physiological effects.



_______________________________________________________________________________________________70E-34 Log #169 EEW-AAA


70E-49The Proposal should have been Accepted in Principle and revised as follows

Enclosed. Surrounded by a case, housing, fence, or wall(s) that prevents persons from accidentally contactingenergized conductors and circuit parts.

While it may be nice to be able conform to the Glossary of terms, it is also important to retainconsistency through out the document. Mr. Hamer is correct in pointing this out. The 70E committee has gone to greatlengths to address wording and consistency. Acceptance of the Proposal as submitted takes a step back from progressmade.

The recommendation is rejected so that the NFPA 70E definition of "enclosed" is consistentwith the definition of "enclosed" in the 2011 NEC.


BARRIOS, L.: The committee action should have been Accept in Principle referring to Comment 70E-35. Refer to mynegative ballot comment on Comment 70E-35.NEITZEL, D.: This should have been Accept in Principle (APR) and refer to 70E-35 for substantiation.





70E-49Modify to read:

Surrounded by a case, housing, fence, or wall(s) that prevents persons from accidentally contactingenergized electrical conductors or circuit parts.

Change proposed is to be consistent with the remainder of the Standard where this phrase is used.



BARRIOS, L.: The final recorded committee action is not clear. The Committee action is recorded as a "Reject";however, the Committee action also records changes to the submitter's recommendation. During Committeedeliberations on this comment, an Accept in Principle was recorded with the committee changing "or" to "and" as noted.However, this comment was reopened after initially receiving a solid majority, and the committee completely reverseditself with a straight Reject of the comment. I believe what we are seeing is a combination of both actions. The correctaction should have been to Accept in Principle so that the phrase "energized electrical conductors and circuit parts", aswas so painstakingly executed throughout the Standard by the Words & Phrases Task Group during the last cycle, isused consistently throughout the Standard. If it means that the NEC definition must be changed, then this can beaddressed by the next NEC revision cycle.NEITZEL, D.: This should have been Accept (A). Including the words "electrical conductors and circuit" makes this

definition consistent with terminology used throughout NFPA 70E of "energized conductors and circuit parts".


_______________________________________________________________________________________________70E-36 Log #343 EEW-AAA


70E-49The committee action should have been to Accept in Principle and to modify the proposal as

follows:Surrounded by a case, housing, fence, or wall(s) that prevents persons from accidentally contacting

energized electrical conductors or circuit parts. [70, 2008]The phrase “electrical conductors or circuit” was added in order to provide consistency with how these

terms are used throughout the Standard.



BARRIOS, L.: See my negative ballot comment on Comment 70E-35.NEITZEL, D.: This should have been Accept (A) and refer to 70E-35 for substantiation.




_______________________________________________________________________________________________Mike Doherty, Infrastructure Health & Safety Association / Rep. CSA Z462 Technical Committee

70E-55The committee action for Proposal 70E-55 should have been Accept in Part. Do not delete the

definition of “Flame Resistant” as proposed by the submitter, but accept the part of the proposal to use the term “ArcRated” in place of “Flame Resistant or FR throughout the standard and delete “FR” where it is used with the term “ArcRated”. The two exceptions for deleting the terms “Flame Resistant” and “FR” are in the definition of “Flame Resistant(FR)” and in the a proposed new definition for the term “Arc Rated”: A flame resistant (FR) material forwhich an arc rating has been determined.

This comment is submitted by the full CSA Z462 Workplace Electrical Safety Technical Committee.The definition of the term “Flame Resistant (FR)” should be maintained since the term and the abbreviation “FR” are

widely used for protective clothing manufactured for and used by electricians and electrical workers. Clothing willusually be labeled both with the Arc Rating and also with the “FR” designation. Providing users with the definition of bothArc Rating and Flame Resistant (FR) will avoid confusion. The term “Arc Rated” needs to be defined separately from“Arc Rating” and the information that all Arc Rated materials are also flame resistant needs to be provided since manyusers of Arc Rated clothing or PPE work in an environment which has both an arc flash hazard and a flash fire hazard.

The definition (Flame Resistant) does not comply with Section 2.2.2.1 of the NEC Style Manual(2003 Edition), which requires that a term be used in two or more articles before a definition is provided in Article 100. Itis the intent of the committee based on its ROP actions to change the term to "arc-rated".


BARRIOS, L.: The CSA Z462 committee had the right idea - to change "FR" or "Flame Resistant" to the proper term of"AR" or "Arc Rated" throughout the document, but to retain the definition of Flame Resistant for at least one morerevision cycle of the Standard. Pointing out the differences between flame resistant and arc rated is important for usersof the Standard. Wholesale deletion of the term and its definition, which has been a key term in the Standards for over10 years, may raise more questions then deleting the term resolves. The committee statement for rejecting thiscomment is unsubstantiated, because in other actions taken by the committee, the committee acknowledged that NFPA70E definitions cannot always appear in two or more Articles like the NEC in order to place the definition in Article 100.





70E-55Retain the definitions for both “Arc Rating” and “Flame Resistant” as the definitions exist in NFPA

70E-2009, which means reversing the Committee Meeting Action on this proposal and others associated with it.The proposal should have been rejected. The term is used and is needed for the Standard. Broad

deletion of such a frequently used and understood term in the Standard may have unintended consequences.“Arc-rated” is simply a compound adjective applied to describe a flame-resistant material that meets the ASTM F 1506test requirements.



BARRIOS, L.: See my negative ballot comment on Comment 70E-37.


_______________________________________________________________________________________________70E-39 Log #294 EEW-AAA


70E-55The committee action should have been to Accept in Principle. The definition of "flame-resistant

(FR)" should be retained and not deleted this cycle. A task group should be appointed to verify that the submitter'sproposal to replace all references to flame-resistant or "FR" with arc rated is appropriate.

Broad deletion/replacement by NFPA staff of such a frequently used and understood term in theStandard may have unintended consequences. During the ROP meeting, the committee discovered two exampleswhere replacing FR with arc-rated was not appropriate (associated with proposals 70E-349 and 70E-354). There maybe other examples where direct replacement is not appropriate.







_______________________________________________________________________________________________Rodney J. West, Square D Company/Schneider Electric

70E-55The committee should continue to accept this proposal.

In addition, the committee should add the following informational note to the Article 100 definition of Arc Rating:Informational Note: An Arc Rating on clothing or equipment indicates that it has been tested for exposure to an

electrical arc. While Flame-Resistant (FR) clothing and equipment prevents, terminates, or inhibits combustion, it maynot have been tested for exposure to an electrical arc. See 130.8 for information on Personal and other ProtectiveEquipment.

While we agree with this proposed change of FR to AR, we also recognize that the term FR has beentaught to many users of the standard and is frequently used in practice. The Informational Note will help users of thestandard to bridge the change from FR to AR by clarifying the difference between the two terms. The suggestedInformational Note, which by definition is explanatory material, is based both on the current edition of NFPA 70E and thesubstantiation submitted with proposal 70E-55.

Revise the recommendation to read:Informational Note No. 1: Arc-rated clothing or equipment indicates that it has been tested for exposure to an electric

arc. Flame-Resistant (FR) clothing without an arc rating has not been tested for exposure to an electric arc.The committee action meets the intent of the recommendation and places it as the first

informational note to the definition of arc-rating.



_______________________________________________________________________________________________70E-41 Log #158 EEW-AAA


70E-20Continue to accept in principle with modifications as follows:

Incident Energy Analysis. A component of an arc flash hazard analysis, A study used to predict the incident energy ofan arc flash for a specified set of conditions.

The TCC note clearly supports the assertion of Mr. Hickman that clarification is needed to eliminateconfusion.The proposed definition, as seen in the committee action, must be further modified for clarity and usability. It is

imperative that the user of this standard understand that all applicable requirements in 130.7 must be enforced. Wemust provide clarity for the user of the standard so they understand that an “incident energy analysis” is but onecomponent of an “arc flash hazard analysis.”It should be noted that the proposed modification in this comment is not new material. In accordance with the NFPA

consensus process, the above suggested text has had public review in the ROP in the comment on affirmative by Mr.Hickman.







The addition of the word Intentional does not add clarity and may lead to confusion. By adding theword Intentional it could be construed to mean there is a difference between Working On and entering the ProhibitedApproach Boundary.The same requirements apply to regardless whether the contact is intentional or unintentional. This is hard enough

without adding this confusion.

The term “intentionally” makes the definition accurate and understandable without addingsubjectivity. A person could come into contact with energized conductors or circuit parts inadvertently when they are notworking on the parts.


NEITZEL, D.: This comment should have been Accept. The addition of the word "intentional" will add confusion.Crossing the Prohibited Approach Boundary, by definition, is the same as making contact with an exposed energizedelectrical conductor or circuit part. The same requirements apply regardless of whether the contact is intentional orunintentional.PACE, D.: This comment should have been an accept. The addition of the word "intentional" will add confusion. Any

time the prohibited approach boundary is crossed is the same as touching the energized uninsulated conductor. Thesame requirements apply regardless of whether the contact is intentional or unintentional. By adding this word anothercondition or type of work has been established with no separate requirements other than those of crossing theprohibited approach boundary.SAPORITA, V.: Acceptance of the original proposal, which adds the word “intentionally” will actually reduce safety. It

seems to infer that there is a difference between “working on” and entering the “prohibited approach boundary”.TIEDE, T.: The comment to reject proposal 70E-73 should have been accepted. Addition of the word “intentional” is

not necessary and may create confusion. Any work inside the prohibited approach boundary is considered the same asmaking contact with live parts.


CARPENTER, T.: The committee action to reject is correct. Further in the definition, it clearly states that "workingon" includes diagnostic and repair. Both of these obviously require intent to touch.GRAY, B.: Continue to reject. I disagree that requirements are the same for both working on and protecting from

unintentional contact with energized components. Doing live-line bare hand work is an accepted practice in 130.2(C)(3),while protecting from shock hazards while working within the RAB is designed to prevent unintentional contact. Ascurrently written, neither the definition of "Working on" or "Boundary, Prohibited Approach" recognize the unintentionalcontact event.WIDUP, R.: Agree with committee action - the term "intentionally" adds clarity to the term "working on" and

differentiates the term from incidental contact. One does not typically "unintentionally" work on something.





With all due respect for my friend Bobby adding the words creates a conflict with the definition ofProhibited Approach Boundary.



NEITZEL, D.: See my explanation of negative vote on Comment 70E-42.PACE, D.: See my explanation of negative vote on Comment 70E-42.SAPORITA, V.: Acceptance of the original proposal, which adds the word “intentionally” will actually reduce safety. It

seems to infer that there is a difference between “working on” and entering the “prohibited approach boundary”.TIEDE, T.: The comment to reject proposal 70E-73 should have been accepted. Addition of the word “intentional” is

not necessary and may create confusion. Any work inside the prohibited approach boundary is considered the same asmaking contact with live parts.


CARPENTER, T.: See my Comment on Affirmative on Comment 70E-42 (Log #170).GRAY, B.: See my affirmative comment in 70E-42.

_______________________________________________________________________________________________70E-44 Log #172 EEW-AAA


70E-77This Proposal should have been Accepted in Principle in Part.

Accept the deletion of “not qualified to” and the revision of “work” to “working”. Reject the deletion of the last sentencebut delete the word “unqualified” from the last sentence.

I agree the requirements should apply to both qualified and unqualified employees. Removal of the lastsentence creates a large void in protecting employees from hazards presented by existing installations that are notcovered by this standard. However, tasks that are covered by this standard that may expose employees to electricalhazards from existing installations outside the scope of this document are and should be covered by this standard. Thelast sentence provides protection to employees for those cases.

Comment 70E-51 adds more clarity and simplification to the document by deleting all but thefirst sentence. See the committee action taken on Comment 70E-51.






70E-76The Technical Correlating Committee advises that Article Scope statements are the responsibility

of the Technical Correlating Committee and the Technical Correlating Committee “Accepts” the committee action.The Technical Correlating Committee directs that the committee clarify the committee action on this proposal to comply

with the NEC Style Manual. Specifically, the proposed text has been removed from Article 110 and moved to newArticle 105 without providing a suggested rewrite of Article 110 or providing a scope and introduction for revised Article110.In addition, the Technical Correlating Committee notes that a title is required for this new Article.The Technical Correlating Committee also directs that the action taken on this proposal be correlated with the action

taken on Proposal 70E-77.This is a direction from the Technical Correlating Committee on National Electrical Code® in


In response to the Technical Correlating Committee concerns:#1: Article 110 as shown in the ROP draft is the intended result of relocating former Sections 110.1 through 110.4 to

new Article 105.#2: A scope was not included for Article 110 to be consistent with Articles 120 and 130 which also do not have scope

sections.#3: The title of Article 105 “Application of Safety Related Work Practices” is shown in the committee action on Proposal

70E-76#4: The committee action on Proposal 70E-77 has been incorporated into new Section 105.1



_______________________________________________________________________________________________70E-46 Log #171 EEW-AAA


70E-76Continue to Accept In Principle but retain the first sentence in 105.3.

There is a difference between the first (deleted) sentence and second sentence of this section. Inorder for the employee to be able to implement the requirements of Chapter 1 they must first know what they are. Anemployer could implement safe work practices that do not meet all of the requirements of Chapter 1. With the wordingbeing suggested and accepted by the committee there is no requirement to implement the requirements of Chapter 1.This does not provide protection to the people in the field. It dilutes it.



CARPENTER, T.: The committee action should have been to accept. By allowing the deletion of this sentence, wehave removed the employee's responsibility to work safely in accordance with the requirements of Chapter 1, unless hehas been trained on them by the employer. What if the employer's training misses something? With the revisedwording, the employee would not then be accountable to meet the requirement.






correlated with the action taken on Proposal 70E-76.See the Technical Correlating Committee Note on Proposal 70E-76.





_______________________________________________________________________________________________70E-48 Log #107 EEW-AAA

_______________________________________________________________________________________________John Luke, The ESCO Group


105.1 Scope. Chapter 1 covers electrical safety-related work practices and procedures for employees who areexposed to an electrical hazard in workplaces covered in the scope of this standard. Electric circuits and equipment notincluded in the scope of this standard might present a hazard to employees working near within the limited approachboundary or the arc flash boundary of energized electrical conductors or circuit parts. such facilities.

Removing the word "near" and adding the limited and arc flash boundaries will give the users of thisdocument guidance for electrical hazards not covered in the scope of this standard.








This change does not improve safety or the communications of the hazards. It simply requires somesort of documentation that a meeting was held. If documentation is required then the communications should associatedwith the communicating the hazards. The 2008 language should be retained and more appropriate language beconsidered in the next cycle.

The requirement to document communication of hazards requires little additional resource butprovides some evidence that the discussion did occur.


WILMER, K.: This comment should have been accepted. NFPA 70E should not require documentation of meetingsbetween host employers and contractors. Host employers should be allowed to determine when documentation isrequired.


_______________________________________________________________________________________________70E-50 Log #295 EEW-AAA


70E-77The committee action should have been to reject this proposal.

Deleting the second sentence as proposed now renders the preceding sentence meaningless andunnecessary. What remains is the statement "Electric circuits and equipment not included in the standard might presenta hazard to employees working near such facilities." If that is the case, then the scope of the standard should addressthese hazards.






_______________________________________________________________________________________________The Technical Correlating Committee directs that the phrase “electrical practices” be revised to “electrical

safety-related work practices” to correlate with wording used throughout the document.Louis Barrios, Shell Projects & Technology

70E-77The committee action should have been to Accept in Principle with the entire 110.1 modified as

follows: “Chapter 1 covers electrical practices and procedures for employees who are exposed to an electrical hazard inworkplaces covered in the scope of this standard.”

This modified version retains the first sentence in 110.1 and deletes the second two to address thesubmitters concerns. This statement can easily be correlated with the action taken on proposal 70E-76 as directed bythe TCC by changing the section number from 110.1 to the new 105.1.






70E-91This Proposal should have been accepted.

While I agree that some training is better performed on the job, the committee statement still does notaddress the concern that the complexity of electrical safety has reached a point where classroom training is required.The wording in the proposal does not prohibit or limit the employer’s flexibility for specific training. I train several hundredpeople a year on electrical safety and my experience is that most are not knowledgeable on the basics of electricalsafety. This is being propagated from one generation of electricians to the next because there is no mechanism in placeto break the cycle. The current wording would allow only on the job training to be used. Electrical safety has reached apoint where it cannot be performed to an acceptable level with only on the job training. The only way new advances inelectrical safety can be disseminated effectively is through classroom training.

The committee reaffirms its action and statement on Proposal 70E-91.


HALE, L.: Classroom training is important, allowing for an either / or, just provides the opportunity to continue badhabits. With the requirement of refresher training every 3 years, this proposal should have been accepted.PACE, D.: This comment should have been an accept. The Committee statement on Proposal 70E-91 states "while

other training is better suited to a classroom" yet the committee does not require classroom training. Many jurisdictionsrequire classroom training to renew a electricians license to help assure that the current requirements created by thechanging of NEC every 3 years is communicated. Electrical safety can no longer be relegated to only "on-the-job"training because of the complexity of electrical safety work practices. Requiring classroom training does not reduce theemployers "flexibility" in training for specific tasks. It helps assure electricians are training appropriately. Not requiringclassroom training diminishes the safety of people exposed to electrical hazards. People who do not understand therequirements, or who do not agree with them and make a decision to not follow them, will pass this on to futuregenerations if there is no classroom, or formal training to correct this. All of have heard "I have been doing it this way for30 years and I'm not going to change now". This standard has to make sure this does not continue.


CARPENTER, T.: The committee action is correct. Employers need to be able to create the required training inwhatever manner makes the most sense for their situation, without having an arbitrary requirement placed on them.



_______________________________________________________________________________________________Palmer L. Hickman, National Joint Apprentice & Training Committee

70E-79Continue to reject Proposal 70E-79. This will remove the words "specific identified" from the 110.2

text that was relocated into 105.2.Adding the words "specific identified" in the committee action that relocated 110.2 into 105.2 (as

pointed out in the committee statement on Proposal 70E-76) creates a conflicting action between 70E-76 and 70E-79.The committee action to reject Proposal 70E-79 rejected adding that phrase. Equally important, it appears thatadequate technical substantiation has not been provided to add that phrase into what is now 105.2. The substantiationprovided in the committee action that added "specific identified" and caused the conflicting action did not address theaddition of that phrase. The recommendation and subsequent committee action appeared to be an editorial relocationfrom 110.2 to 105.2. However, the recommendation and subsequent committee action contained technical changes thatdo not have adequate technical substantiation.



_______________________________________________________________________________________________70E-54 Log #371 EEW-AAA

_______________________________________________________________________________________________Michael J. Johnston, National Electrical Contractors Association


(f) The employer shall determine, through regular supervision and or through inspections conducted on at least anannual basis that each employee is complying with safety-related work practices required by this standard.

eplacing “and” with “or” will stay consistent with the language in 110.2(D)(3)(a), Retraining, and sendthe same message to the users of this standard.







70E-80It was the action of the Technical Correlating Committee that this proposal be correlated with the

action taken on Proposal 70E-76.See the Technical Correlating Committee Note on Proposal 70E-76.


The committee accepts the direction of the Technical Correlating Committee to correlate theactions of Proposals 70E-76 & 70E-80. The text deleted in the action on Proposal 70E-80 is also deleted in therelocated text in Proposal 70E-76.



_______________________________________________________________________________________________70E-56 Log #109 EEW-AAA

_______________________________________________________________________________________________Daryld Ray Crow, DRC Consulting, Ltd.


The employer shall provide the safety-related work practices and shall train the employee who shall then implementthem.As a minimum, the employer shall provide and train employees on the safety-related work practices addressed in

Chapter 1. Employees shall implement the safety–related work practices required by their employer.The current text in NFPA 70E requires implementation and training on the safety-related work

practices addressed in Chapter 1. Deleting the first sentence as proposed creates confusion. Without the first sentencethere is no guidance on what minimum safe work practices should be provided and implemented.

The recommendation is overly restrictive as it limits the training to only the safety-related workpractices covered in NFPA 70E. The recommendation in Proposal 70E-80 provides the necessary clarity as to theemployer and employee responsibilities for safety-related work practices.


HALE, L.: This proposal should have been accepted as it adds clarity to what training is required.PACE, D.: This comment should have been an accept. The wording accepted in Proposal 70E-80 is so vague that it

has no meaning and provides no clarity at all. It does not require a minimum requirement. The safe work practicesprovided in 70E should be the minimum. The wording proposed in this Comment provides the clarity on what safe workpractices that should be provided and trained on.






The employer shall provide the safety-related work practices and shall train the employee who shall then implementthem. The safety related work practices contained in Chapter 1 shall be implemented by employees. The employer shallprovide the safety-related work practices and shall train the employee who shall then implement them.

The current text in NFPA 70E adds clarity and references that all work practices in chapter 1 shall beimplemented. Deleting the first sentence as proposed creates confusion. Without the first sentence there is no guidanceon what safe work practices should provided and implemented.



PACE, D.: See my explanation of negative vote on Comment 70E-56.


_______________________________________________________________________________________________70E-58 Log #173 EEW-AAA


70E-80This Proposal should have been rejected.

There is a difference between the first sentence and second sentence of this section. In order for theemployee to be able to implement the requirements of Chapter 1 they must first know what they are. An employer couldimplement safe work practices that do not meet all of the requirements of Chapter 1. With the wording being suggestedand accepted by the committee there is no requirement to implement the requirements of Chapter 1. This does notprovide protection to the people in the field. It dilutes it.



CARPENTER, T.: See my Explanation of Negative on Comment 70E-46 (Log #171).PACE, D.: See my explanation of negative vote on Comment 70E-56.




_______________________________________________________________________________________________Thomas A. Carpenter, ATA

70E-76Do not delete the following text: "The safety related work practices contained in Chapter 1 shall be

implemented by the employees."By removing this sentence, we have removed the employee's responsibility to work safely in

accordance with the Chapter 1 requirements, unless he is trained on them by the employer. What if the employer'straining misses something? With the revised wording, the employee is not required to meet the requirement.



CARPENTER, T.: See my Explanation of Negative on Comment 70E-46 (Log #171).


_______________________________________________________________________________________________70E-60 Log #218 EEW-AAA


70E-80Do not delete the following text: "The safety related work practices contained in Chapter 1 shall be

implemented by the employees."I agree that the two sentences appear to be redundant. However, by removing this sentence, we have

removed the employee's responsibility to work safely in accordance with the Chapter 1 requirements, unless he istrained on them by the employer. What if the employer's training misses something? With the revised wording, theemployee is not required to meet the requirement.









action taken on Proposal 70E-89 because the text in Proposal 70E-89 is different than the text in this proposal.This is a direction from the Technical Correlating Committee on National Electrical Code® in


The correlated committee actions on Proposals 70E-83 and 70E-89 should read as follows:110.1(C) Documentation. There shall be a documented meeting between the host employer and the contract employer.

The committee accepts the direction of the Technical Correlating Committee (TCC) to correlatethe actions on Proposals 70E-83 & 70E-89. The committee statement on Proposal 70E-83 should have recognized thatthe action to "accept in principle in part" was met by the action taken on Proposal 70E-89. The committee action on thiscomment clarifies the actions for the TCC.



_______________________________________________________________________________________________70E-62 Log #49 EEW-AAA

_______________________________________________________________________________________________Kathleen Wilmer, Duke Energy

70E-83Committee action should be Reject.

The standard should not require documentation of meetings between host employers and contractors.Employers should be allowed to determine if documentation is necessary.



WILMER, K.: See my Explanation of Negative on Comment 70E-49 (Log #174).











_______________________________________________________________________________________________70E-64 Log #219 EEW-AAA


70E-84The committee action should have been to accept the proposal and delete the second part of the

sentence as recommended.The current wording requires the host employer to "assume" what hazards the contract employer will

or won't recognize. The proposed wording would have corrected this.

The committee reaffirms its action and statement on Proposal 70E-84. The phrase that hasbeen recommended to be deleted is needed to provide clarity on the host employer's responsibility.


CARPENTER, T.: The committee action should have been to accept. The current wording requires the hostemployer to "assume" what hazards the contract employer will or won't recognize. Assumptions lead to missed hazardsand danger to the employees.NEITZEL, D.: This should be Accept (A) which would then Accept (A) Proposal 70E-84. The current NFPA 70E,

110.5(A)(1)(a) language requires the host employer to presume what the contract employer and employee would orwould not recognize. The current wording requires the host employer to “assume” what hazards the contract employerwill or won’t recognize. By deleting the second part of (a), “and that might not be recognized by the contract employer orits employees” clarifies that the host employer will inform the contract employer of all “Known hazards that are coveredby this standard, that are related to the contract employer’s work” without exception or presumptions.


WIDUP, R.: Agree with committee action - we don't want the host employer to withhold information on hazards thatare known to the host employer but may be unknown to the contract employer.




70E-86Accept Proposal 70E-86 in Principle with the following text:

b. Information about the host employer's installation that the contract employer needs to make the assessmentsrequired by Chapter 1 such as the available fault current and upstream overcurrent protective device opening time,including its condition of maintenance.

This recommendation is intended to enhance clarity and usability. Although the intent of this provisionis explained in the preamble of OSHA's proposed rewrite of 29 CFR Part 1926 Subpart V and 1910.269 published in theFederal Register on June 15, 2005, the intent of these provisions is unclear in the context of their inclusion in NFPA70E. It has been my experience that both host and contract employers are seeking clarity on what this provision isintending that they are to provide each other, especially in light of the fact that the 2012 edition appears that it will againadditionally require a documented meeting [proposed 110.1(C)]. This recommendation is an attempt to provide suchinsight. Also, see explanation of negative on Proposal 70E-86.

Hazard identification will be addressed in the disclosure requirements of new Section110.1(A)(1). Creating a list of what is needed for information increases the risk of omission.Such information may include available fault current, clearing time of OCPDs, and condition of OCPDs.


HICKMAN, P.: The last sentence of the committee statement seems to support at least an Accept in Principle on therecommendation as an informational note if not as a requirement. As written, the provision offers no insight into whatinformation the host employer is to provide to the contract employer. The requirement went into 70E without anyexplanation of what this information was intended to be. The recommendation offering information “such as” was anattempt to provide insight into what information a contract employer needs to make the assessments required byChapter 1. The committee statement recognizes this concept.


_______________________________________________________________________________________________70E-66 Log #50 EEW-AAA

















_______________________________________________________________________________________________70E-68 Log #21 EEW-AAA



action taken on Proposal 70E-83 because the text in Proposal 70E-83 is different than the text in this proposal.This is a direction from the Technical Correlating Committee on National Electrical Code® in





_______________________________________________________________________________________________70E-69 Log #51 EEW-AAA

















_______________________________________________________________________________________________70E-71 Log #180 EEW-AAA


70E-88See my comment on 70E-87.

See my comment on 70E-87.

The comment is rejected based on Section 4.4.5 of the Regulations Governing CommitteeProjects covering the required content of public comments. Referring to comments on other proposals does not providethe committee with a direct recommendation and related substantiation.



_______________________________________________________________________________________________70E-72 Log #190 EEW-AAA


70E-89See my comment on 70E-87.

See my comment on 70E-87.








The training required by this section shall be classroom or and on-the-job type, or a combinationof the two. The degree of training provided shall be determined by the risk to the employee.

Both class room and on-the-job training are important. One element of electrical safety training mustbe classroom training. NFPA 70E requirements change once every three years. This document represents “the leadingedge thinking” on electrical safe work practices. On-the-job training only will not ensure that the latest electrical safework practices are addressed.The committee action during the ROP meeting should have been accept.



HALE, L.: See my Explanation of Negative on Comment 70E-52 (Log #175).PACE, D.: See my explanation of negative vote on Comment 70E-52.


_______________________________________________________________________________________________70E-74 Log #53 EEW-AAA



Employers should not be required arbitrarily to train employees on Automatic External Defibrillator use.There is no requirement that employers must have AED units. Many employers rely on local emergency squads toprovide that service. Employers who do not have AEDs should not be required to train their employees on them.

According to the American Heart Association (AHA), survival rates as high as 74% are possibleif treatment and defibrillation is performed in the first 3 minutes. In contrast survival rates are only 5% where no AEDprograms have been established to provide prompt CPR and defibrillation. ("CPR statistics" American HeartAssociation). Additional training on AED use is minimal investment.


CARPENTER, T.: The committee action should have been to accept. There is no requirement that AEDs beprovided in the workplace. As such, employers should not be required to train employees on AEDs if they don't havethem available.NEITZEL, D.: The committee action should have been Accept. There is no requirement that an Automatic External

Defibrillator (AED) be provided in the workplace, although it is a good idea to have them available. As such, employersshould not be required to train employees on the proper use of an AED if they don't have them available.WILMER, K.: This comment should have been accepted. Employers should not be required arbitrarily to train

employees on Automatic External Defibrillator use. There is no requirement that employers must have AED units.Many employers rely on local emergency squads to provide that service. Employers who do not have AEDs should notbe required to train their employees on them.





70E-93Revise the committee action as follows:

Employees exposed to electrical hazards and those responsible for taking action in case of emergency shall be trainedin methods of release of victims form contact with exposed energized electrical conductors or circuit parts.

See the explanations of negative for Proposal 70E-115 in the ROP which substantiates thisrecommendation.



HITTEL, M.: The action should be reject. The submitter did not provide substantiation.


_______________________________________________________________________________________________70E-76 Log #106 EEW-AAA



(C) Emergency Procedures. Employees responsible for taking action in case of emergency exposed to shock hazardsand those trained to respond to emergencies shall be trained in methods of release of victims from contact with exposedenergized electrical conductors or circuit parts.

Requiring both employees exposed to shock hazards and emergency responders to be trained in themethods of release, will ensure the safety of electrical workers and the responders of emergencies when electricalhazards are present.



HITTEL, M.: The action should be reject. The original proposal 70E-93 that was accepted resolves long-standingconfusion in the standard as it is the personnel that delivers the emergency response services that shall be trained. It ispointless that the person who is being shocked and cannot let go knows how to safely employ methods of release ofvictims when that person IS the victim that this requirement is all about.






Employees exposed to shock hazards and those employees responsible for taking actionin case of emergency shall be trained in methods of release of victims from contact with exposed energized electricalconductors or circuit parts. Employees shall be regularly instructed in methods of first aid and emergency procedures,such as approved methods of resuscitation, if their duties warrant such training. Training of employees in approvedmethods of resuscitation, including cardiopulmonary resuscitation and automatic external defibrillator (AED) use, shallbe certified by the employer annually.

All employees exposed to a shock hazard need to be trained in how to release a person fromenergized parts. The wording in Proposal 70E-93 implies that electricians that are exposed to shock hazards do notneed to be trained in how to release a person from energized electrical conductors or circuit parts.

The committee accepts the revision to the first sentence of the recommendation and rejects the recommendation todelete the words "if their duties warrant such training".

The committee intends that this requirement apply only to those employees who areresponsible for performing the emergency and first aid procedures.


HITTEL, M.: See my Explanation of Negative on Comment 70E-76 (Log #106).


_______________________________________________________________________________________________70E-78 Log #118 EEW-AAA


70E-93The committee action on Proposal 70E-93 should have been “Accepted in Principle in Part.” The

four words that were deleted in the first sentence, i.e. “exposed to shock hazards” should have been retained and thenew wording added as follows for the first sentence.110.6 (c) Emergency Procedures. Employees exposed to shock hazards and those responsible for taking action in

case of emergency shall be trained in methods of release of victims from contact with exposed energized electricalconductors or circuit parts.

While the CSA Z462 Technical Committee agrees that those responsible for taking action in the eventof an emergency should be trained, we conclude that this provision applies primarily workers exposed to electricalhazards. In most cases the person that will take action in the case of an emergency will be another electrical worker.



HITTEL, M.: The action should be reject. The statement in the submitter's substation "In most cases the person thatwill take action in the case of an emergency will be another electrical worker" is not accurate and no data is submitted tojustify this statement. In fact, a VAST MANY electricians work without another electrician accompanying them.




_______________________________________________________________________________________________Keith Fager, Bayer CropScience

70E-93This proposal should be Accepted in Principal in Part and the text revised to read as follows.

Employees exposed to shock hazards and those responsible for taking action in case of emergency shall be trained inmethods of release of victims from contact with exposed energized electrical conductors or circuit parts. Employeesshall be regularly instructed in methods of first aid and emergency procedures, such as approved methods ofresuscitation, if their duties warrant such training. Training of employees in approved methods of resuscitation, includingcardiopulmonary resuscitation, shall be certified by the employer annually.

The proposal text could be interpreted to require method of release training for emergency personnelonly and not all electricians. When two electricians are working together, neither is specifically designated asresponsible for taking emergency action but both should be trained in methods of release and other emergencyservices. The word “exposed” is unnecessary. The energized conductor or circuit part may not necessarily be exposedif a worker has inadvertently reached into an area where the energized conductor or part is not visible.



HITTEL, M.: The action should be reject. The original form of Proposal 70E-93 clearly requires ANYONERESPONSIBLE for executing such methods to be trained in those methods. If two electricians are working together, theone designated to be the "standby observer/helper" MUST be trained in those methods. If those two switch roles, thenthe other MUST be also trained in those methods.


_______________________________________________________________________________________________70E-80 Log #159 EEW-AAA


70E-93Reject this proposal.

The action by the committee to accept in part proposal 70E-93 is a significant step backward in safety.The accepted text will permit employers to do nothing, no training will occur. The person responsible may be identified

as the local EMT in the township. The action by the committee infers that it is acceptable in a shock situation to leave aperson in contact with energized parts while the “person responsible for taking action in case of emergency” issummoned. ALL employees that are exposed to shock hazards must be trained in methods of release. An employee inthis situation will react to save a co-worker. Without proper training this rescue attempt may place more than one life indanger.

The committee reaffirms its action on Proposal 70E-93 as modified by its action on Comment70E-77.






70E-93This Proposal should have been Accepted in Principle in Part with wording of the first sentence as

follows;“Employees exposed to shock hazards and those responsible for taking action in case of emergency shall be trained in

methods of release of victims from contact with exposed energized electrical conductors or circuit parts.”Reject the remainder of the Proposal.

This change requires for both emergency personnel and the other electricians to be trained in methodsof release. This addresses the concern of the submitter and those who still want the electricians trained in methods ofrelease.



HITTEL, M.: The action should be reject. The language accepted from proposal 70E-93 allows the employer toassess the risks and design their First-Aid / Emergency Response Program unique to their situation. A program that isbased upon one type of model (e.g. where 2 electricians are present for every task) must not be the basis for a genericprescriptive rule.


_______________________________________________________________________________________________70E-82 Log #177 EEW-AAA


70E-94This Proposal should have “Accepted in Principle”. The submitter is correct that the employer

cannot certify this kind of training. The sentence should be revised to read as follows:“Employers shall provide certified Ttraining of for employees in approved methods of resuscitation, including

cardiopulmonary resuscitation and automatic external defibrillator (AED) use, shall be certified by the employer.”The submitter is correct the employer is not a certifying body but can provide employees the training

from a certified body.

The recommendation does not provide additional clarity to the certified training requirement.


PACE, D.: This comment should have been an accept. The proposed wording would have clarified the requirement.The employer cannot certify employees in CPR unless the employer has been certified to provide such training, whichsome are but not all. I am sure it is not the intent to require the employer to become certified in all cases. The proposedwording as stated will mean that is what will need to happen.






Employers should not be required arbitrarily to train employees on Automatic External Defibrillator use.There is no requirement that employers have AED units. Many employers rely on local emergency squads to providethat service. Employers who do not have AEDs should not be required to train their employees on them.





_______________________________________________________________________________________________70E-84 Log #369 EEW-AAA



Training of the employee in approved methods of resuscitation, including cardiopulmonary resuscitation, shall becertified by the employer annually an authorized provider and documented by the employer on an annual basis.

The intent of the submitter is to eliminate the confusion that the employer typically does not certify thistype of training. Contractors (employer) rely on third party providers to certify individuals in this training. Some samplesof authorized providers are American Red Cross, American Heart Association and other similar entities.

The recommended text is unclear as to who is responsible for authorizing the provider.








(C) Emergency Procedures. Employees responsible for taking action in case of emergencyexposed to shock hazardsand those trained to respond to emergencies shall be trained in methods of release of the victim from contact withexposed energized electrical conductors or circuit parts.

Requiring both the employee exposed to shock hazards and emergency responders to be trained inthe methods of release, will ensure the safety of electrical workers and the responders of emergencies when electricalhazards are present.





_______________________________________________________________________________________________70E-86 Log #387 EEW-AAA

_______________________________________________________________________________________________Louis A. Barrios, Shell Projects & Technology

70E-93The committee action should have been Accept in Principle, in Part. The NFPA 70E-2009 text is

revised as follows:“Employees exposed to shock hazards and those responsible for taking action in case of emergency shall be trained in

methods of release of victims from contact with exposed energized conductors or circuit parts.”Do not accept the addition of “emergency treatment of burns, etc.” per the committee action.

Training in methods of release for persons exposed to shock hazards is retained. The submitter didnot provide adequate substantiation to remove this from the Standard.



HITTEL, M.: The action should be reject. The proposal did include substantiation stating "Employees 'exposed toshock' will not be the ones who need the training regarding rescue".




_______________________________________________________________________________________________Larry Ayer, Bizcom Electric

70E-93The committee should reject the proposal.

It would not be appropriate to accept the revisions to the first sentence. This new text would limit thenumber of people trained in the methods of release. Job site personnel may change on a daily basis for a variety ofreasons such as sicknesses or vacations. Certainly, situations would then be created when a shock event occurs,where non-trained personnel may be left without a person trained in emergency response. All workers exposed toshock hazards should be trained.

The committee reaffirms its action on Proposal 70E-93 as modified by its action on Comment70E-77.



HITTEL, M.: The submitters' substantiation actually supports the original language passed during the proposal stage.An approach that says "we'll train all the electricians and trust that they are available and execute properly" versus aprocess where the need for these specialized services are proactively identified and addressed during pre-task planningand built into the system.

_______________________________________________________________________________________________70E-88 Log #22 EEW-AAA


70E-97The Technical Correlating Committee directs that this proposal be reconsidered and correlated with

the action taken on Proposal 70E-98.This is a direction from the Technical Correlating Committee on National Electrical Code® in


The resultant text from the committee actions on Proposals 70E-97 and 70E-98 is to read:An employee who is undergoing on the job training for the purpose of obtaining skills and knowledge necessary to be

considered a qualified person and who, in the course of such training, has demonstrated an ability to perform specificduties safely at his or her level of training and who is under direct supervision of a qualified person for the performanceof those specific duties.

The committee accepts the direction of the Technical Correlating Committee to correlate theactions of proposals 70E-97 & 70E-98. Proposal 70E-97 was incorrectly identified in the submitter's recommendation asthird level subdivision (b) instead of the correct third level subdivision (c). This error is noted in the committee statement.The committee action on this comment combines the actions of both proposals for clarity.



HITTEL, M.: This language contemplates what the "intentions" of an employer or a worker may be and would thus beunenforceable. Further, it is irrelevant if a worker has intentions it to get his journeyman card or not.










BARRIOS, L.: The Committee Statement should refer to the action and statement on Comment 70E-88 and notComment 70E-89.

_______________________________________________________________________________________________70E-90 Log #220 EEW-AAA


70E-100The committee action should have been to reject the proposal.

The substantiation does not provide any evidence of a safety issue, it only quotes an OSHArequirement. It is the job of this committee to determine what we believe to be electrical safety requirements, not tore-quote OSHA requirements. If we are going to mimic OSHA, why not just delete the existing contents of the standardand replace with one line stating, "Follow OSHA electrical safety requirements." If we don't agree with OSHA, we shouldsay so and use this as justification in a request to get the OSHA requirements changed. Also, section 110.7(H) alreadyrequires auditing of the electrical safety program. Now we are mandating an annual supervisor inspection and theauditing.

Proposal 70E-100 was submitted by the Article 110 Task Group to address NFPA staffcomments regarding annual inspections and adds clarity to the requirement. The committee action on Comment70E-91 modifies the action taken on Proposal 70E-100.







110.6(D)(1)(f) The employer shall determine, through regular supervision and or through inspections conducted on atleast an annual basis that each employee is complying with the safety-related work practices required by this standard.

The above comment is consistent with the current section 110.6(D)(3)(a) of NFPA 70E-2009.Requiring inspection annually is unreasonable, and the replacement of “and” with “or” gives the employer the option.


PACE, D.: NFPA 70E should meet or exceed the requirements of OSHA. 1910.269(a)(2)(iii) states "The employershall determine, through regular supervision and through inspections conducted on at least an annual basis, that eachemployee is complying with the safety-related work practices required by this section. " 70E should match thisrequirement not reduce it.


_______________________________________________________________________________________________70E-92 Log #296 EEW-AAA


70E-100The committee action should have been Accept in Principle, with the proposal modified as follows:

"110.6(D)(1)(f) the employer shall determine, through regular supervision and or through inspections conducted on atleast an annual basis that each employee is complying with safety-related work practices required by this standard."

The above comment is consistent with the current section 11 0.6(0)(3)(a) of NFPA 70E-2009.Requiring inspectionannually is unreasonable, and the replacement of "and" with "or" gives the employer the option.



HITTEL, M.: The action should be Accept. The comment is suggesting an action that was Accepted in Comment70E-91.PACE, D.: See my explanation of negative vote on Comment 70E-91.


HICKMAN, P.: The action on this comment should have been to Accept.




70E-100The committee action should have been to Reject.

110.6(D)(1) provides the training requirements for qualified persons. The submitter’s proposal to addsupervision and inspection requirements do not belong in 110.6(D)(1). Retraining as a result of supervision or annualinspections is already addressed in 110.6(D)(3) and auditing electrical safety program compliance is already addressedin 110.7(H).




_______________________________________________________________________________________________70E-94 Log #404 EEW-AAA

_______________________________________________________________________________________________Peter R. Walsh, Mersen

70E-100This proposal should be rejected.

The OSHA reference cited as substantiation pertains to only utility companies as per OSHA scope.The 70E standard applies much more generally. I agree with TC Member Carpenter’s explanation of his negative vote.




_______________________________________________________________________________________________70E-95 Log #189 EEW-AAA



The submitter is proposing to adopt a requirement found in OSHA 1910.269 related to regularsupervision and inspections. The regulation 1910.269 does not apply to most employers who are covered by the Scopeof 70E. This requirement should not be enforced on those employers.








The submitter is proposing to adopt a requirement found in OSHA 1910.269 to regular supervision andinspections. The regulation 1910.269 does not apply to most employers who are covered by the Scope of 70E. Thisrequirement should not be enforced on those employers.




_______________________________________________________________________________________________70E-97 Log #54 EEW-AAA



The submitter is proposing to adopt a requirement found in OSHA 1910.269 related to regularsupervision and inspections. The regulation 1910.269 does not apply to most employers who are covered by the Scopeof 70E. This requirement should not be enforced on those employers








(f) The employer shall determine, through regular supervision and or through inspections conducted on at least anannual basis that each employee is complying with the safety-related work practices required by this standard.

Removing "and" and replacing with "or" will stay consistent with the language in 110.2(D)(3)(a).Retraining, and send the same message to the users of this standard.






_______________________________________________________________________________________________70E-99 Log #336 EEW-AAA

_______________________________________________________________________________________________Daleep C. Mohla, DCM Electrical Consulting Services, Inc.

70E-100This proposal should be rejected as it exclusively applies to the installation covered by 1910.269

mostly utility installations which are specifically excluded in NFPA 70E scopeAs pointed in a negative ballot, this requirement is essentially covered in the existing 110.6(D)(3)(a)

which require retraining if the supervision or annual inspections determine the employee is not complying with the safetyrelated work practices. Acceptance of this proposal will create a conflict with 110.6(D)(30(a) because this proposalrequires supervision and annual inspections.As recommended in the proposal, this requirement will apply to every worker at every facility covered by 70E scope .

The paragraph quoted from §1910.269(a)(1)(iii) in the substantiation means that each employee who is covered by§1910.269 employers must determine on an annual basis that each employee is following the safety-related workpractices required by §1910.269. The scope of §1910.269 (from paragraph (a)(1)) limits the application of thisrequirement. Thus, it does not apply to every employee, but to every employee who performs work that is covered by§1910.269.There is no such requirements in subpart S which is the primary scope covered by NFPA 70E.Work covered by 1910.269 which generally applies to the Utility and similar installations is specifically excluded in the

scope of the NFPA 70E.








NFPA 70E should not arbitrarily require that employers retrain employees every 3 years. Employersshould be allowed to determine the frequency of training necessary for their employees.

Without direction from this standard as to the frequency of training, it becomes an arbitrarydecision on the part of the employer as to when the retraining should occur. This could result in unreasonable intervalsbetween training of employees. Based on the substantiation the committee understands this comment is addressed toProposal 70E-104.


COOK, C.: NFPA-70E should not arbitrarily require that employers retrain employees every 3 years. Employersshould be allowed to determine the frequency of training necessary for their employees.HITTEL, M.: The action should be accept. NFPA 70E is on a three revision cycle. In this context, the requirement is

already contained in 110.6 (D)(3) (b) where it states that retraining is required "If new technology, new types ofequipment, or changes in procedures necessitate the use of safety-related practices that are different from those thatthe employee would normally use." If the revision introduces any of these triggers (as is the justification in thesubstantiation from Proposal 70E-104), retraining is already required by the existing language.


_______________________________________________________________________________________________70E-101 Log #55 EEW-AAA


70E-103See action should be Reject.

NFPA 70E should not arbitrarily require that employers retrain employees every three years.Employers should be allowed to determine the frequency of training necessary for their employees.



COOK, C.: See my Explanation of Negative on Comment 70E-100 (Log #201).HITTEL, M.: See my Explanation of Negative on Comment 70E-100 (Log #201).






NFPA 70E should not arbitrarily require that employers retrain employees every three years.Employers should be allowed to determine the frequency of training necessary for their employees.

Without direction from this standard as to the frequency of training, it becomes an arbitrarydecision on the part of the employer as to when the retraining should occur. This could result in unreasonable intervalsbetween training of employees.


COOK, C.: See my Explanation of Negative on Comment 70E-100 (Log #201).HITTEL, M.: See my Explanation of Negative on Comment 70E-100 (Log #201).WILMER, K.: This comment should have been accepted. NFPA 70E should not arbitrarily require that employers

retrain employees every three years. Employers should be allowed to determine frequency of training necessary fortheir employees.


_______________________________________________________________________________________________70E-103 Log #160 EEW-AAA


70E-104Continue to accept the proposal.

Adding a requirement for retraining at three year intervals is NOT a burden on employers.NFPA 70E is on a three year revision cycle. As the requirements of this standard are revised, employees who are

required to implement these safe work practices (see 2009 NFPA 70E 110.3) must be aware of revisions affectingsafety in the workplace. NFPA 70E mandates that employees implement “safety related work practices.” NFPA 70Emust also mandate that these employees be provided with the necessary training. This must include retraining. Thethree year window is perfectly suited to allow employers to retrain in any areas necessary as well as on revisions to thestandard.


COOK, C.: NFPA-70E should not arbitrarily require that employers retrain employees every 3 years. Employersshould be allowed to determine the frequency of training necessary for their employees. It's presumptuous for thecommittee to believe that a three-year training cycle is not a burden on employers.HITTEL, M.: The action should be reject. This standard extends administrative burden when we add redundant

requirements for managers and consultants to parse and interpret. Also the committee Statement is inaccurate as thecurrent language has triggers adequate for training that would not permit "unreasonable intervals".WILMER, K.: This comment should have been rejected. NFPA 70E should not arbitrarily require that employers

retrain employees every three years. Employers should be allowed to determine frequency of training necessary fortheir employees.






NFPA 70E should not arbitrarily require that employers retrain employees every 3 years. Employersshould be allowed to determine the frequency of training necessary for their employees.



COOK, C.: See my Explanation of Negative on Comment 70E-100 (Log #201).HITTEL, M.: See my Explanation of Negative on Comment 70E-100 (Log #201).WILMER, K.: See my Explanation of Negative on Comment 70E-102 (Log #56).


_______________________________________________________________________________________________70E-105 Log #71 EEW-AAA



NFPA 70E should not require employers to document "content of training."

The substantiation does not indicate why the standard should not require documentation on thecontent of training. It is necessary for the employer to know what training an employee has received. Content of thetraining can be documented by the employer in determining the qualifications of employees.


WILMER, K.: This comment should have been accepted. NFPA 70E should not require employers to document"content of training". I agree with Mr. Hamer in comment 70E-107 that the term "content" should be replaced by"description".






NFPA 70E should not require employers to document "content of training."





_______________________________________________________________________________________________70E-107 Log #255 EEW-AAA


70E-105Revise as follows:

The documentation shall contain the content a description of the training, each employee’s name, and dates of training.Including the “content” of the training in the records could be interpreted as meaning training materials,

presentations, tests, videos, etc. A brief description of the training should satisfy the submitter’s intent.

The term "content" requires more comprehensive and detailed documentation than is requiredby a course "description".


BARRIOS, L.: Maintaining the content of training as a documentation record is an overly restrictive requirement. Adescription of the training, consisting of more than just a title, should be adequate.GRAY, B.: The action should be to accept the proposed change. The phrase "content" is ambiguous and

unenforceable. The proposed replacement word "description" better describes the intent of TC that only the topicscovered need to be maintained in retrievable records.HITTEL, M.: The action should be accept. As stated in the comment, the term "content" at a minimum could be

interpreted to mean a LARGE amount of detail to be retained within each employees records. A description of thetraining in each employees records with the detail documented in a SINGLE place for reference is a more acceptableburden on employers.WILMER, K.: This comment should have been accepted. The standard should require that documentation of training

contains a "description" of the training, not the content of training.


WIDUP, R.: Agree with committee action - the word "content" helps to assure there is adequate documentation of thetraining.




70E-105The committee action should have been to Accept in Principle.

Replace “the content of the training” with “a description of the training.”Documenting the content of the training as suggested by the submitter could be interpreted as

requiring all training materials, presentations, handouts, books, etc., which could be considered the content of thetraining. A description of the training, as proposed above should be sufficient and meet the submitter’s intent.



BARRIOS, L.: Maintaining the content of training as a documentation record is an overly restrictive requirement. Adescription of the training, consisting of more than just a title, should be adequate.GRAY, B.: See my negative comment on 70E-107.HITTEL, M.: See my Explanation of Negative on Comment 70E-107 (Log #255).WILMER, K.: See my Explanation of Negative on Comment 70E-107 (Log #255).


_______________________________________________________________________________________________70E-109 Log #389 EEW-AAA


70E-106The committee action should continue to be Reject. However, the committee statement conflicts

with the action taken.The committee should clarify its statement.

The committee action to Reject this proposal retains the FPN which states, “Employment records thatindicate that an employee has received the required training are an acceptable means for meeting this requirement.”However, the committee statement indicates “The recommended action is not consistent with OSHA requirements.Employee records may not necessarily demonstrate proficiency and that is conveyed with the current wording in theinformational note.”



BARRIOS, L.: The committee failed to clarify the conflict between the action taken and committee statement asrequested by the submitter.HICKMAN, P.: We agree with the submitter of comment 70E-109 that the committee should clarify its statement on

proposal 70E-101. The action to accept comment 70E-109 without an accompanying committee statement did not clearthis up.




70E-118This Proposal should have been Accepted.

The Committee has not addressed the concerns submitted with the Proposal. The present wording isvague and unenforceable. Routine work has not been defined and neither has “some tasks”. Removing 110.3(G)(3)does not remove a requirement for a job briefing as it is required by 110.3(G)(1). The changes made a as result ofProposal 70E-119 further dilutes the requirement for a job briefing. If the task is normal work and the person is qualifiedthen there is no need for a job briefing, 110.3(G)(3) needs to be removed to clarify the intent is to require a job briefingwhen a person is exposed to an electrical hazard.

The current requirement as modified by the committee action on Proposal 70E-119 is clear andthere are many routine tasks with a comparatively low level of complexity and risk that can be adequately addressedthrough a brief discussion.


SAPORITA, V.: NEMA supports deleting the allowance to skip the job briefing for routine work. Safety would beimproved if a briefing were always required.


_______________________________________________________________________________________________70E-111 Log #24 EEW-AAA


70E-113The Technical Correlating Committee directs that the committee clarify the action on this proposal,

and that further consideration be given to the comments expressed in the voting.This is a direction from the Technical Correlating Committee on National Electrical Code® in


The committee action is clarified in its action on Comment 70E-112.







(F) Hazard/Risk Evaluation Procedure. An electrical safety program shall identify a hazard/risk evaluation procedure tobe used limited Approach and before work is started within the arc flash boundaries of energized electrical conductorsand circuit parts operating at 50 volts or more or where an electrical hazard exists.

The revision improves clarity to the users of this standard.

Revise the comment recommendation to read:An electrical safety program shall identify a hazard/risk evaluation procedure

to be used before work is started within the Limited Approach Boundary or and before work is started within the arc flashboundary Arc Flash Boundary of energized electrical conductors…

The revision improves clarity and meets the intent of the recommendation.





_______________________________________________________________________________________________The Technical Correlating Committee directs that this comment be reported as “Accept in Principle”, as

the language in Comment 70E-113 is different from that resulting from committee action on Comment 70E-112.Mike Doherty, Infrastructure Health & Safety Association / Rep. CSA Z462 Technical Committee

70E-112Proposal 70E-112 should have been accepted in principle. Section 110.7(F) should be revised as

follows:110.7(F) Hazard/Risk Evalutaion Hazard Identification and Risk Assessment Procedure:An electrical safety program shall identify a hazard/risk assessment include a hazard identification and a risk

assessment procedure to be used before work is started within the Limited Approach Boundary of energized electricalconductors and circuit parts operating at 50 volts or more or where an electrical hazard existsThe procedure shall identify the hazard/risk process that shall be used by employees used to evaluate the tasks before

work is started process to be used by the employee before work is started to identify hazards and assess risks, includingpotential risk mitigation strategies.FPN No. 1: The Hazard/Risk Evalutaion Hazard Identification and Risk Assessment procedure may include identifying

when a second person could be required and the training and equipment that person should have.FPN No. 2: For an example of a Hazard/Risk Analysis Evaluation Hazard Identification and Risk Assessment

Procedure Flow Chart, see Annex F.FPN No. 3: For an example of a Hazard/Risk Evalutaion Hazard Identification and Risk Assessment Procedure, see

Annex F.The submitter of 70E-112 is trying to clarify the difference between hazard and risk. As defined in

international standards such as “ISO Guide 51 – Safety Aspects – Guidelines for their inclusion in standards,” the termshazard and risk are not the same and therefore must be identified separately:· A hazard is a potential source of harm· Risk is the combination of the probability of occurrence of harm and the severity of that harm.As outlined in International standards such as “ISO 31000 – Risk Management – Principles and Guidelines,” hazards

are identified and risks are assessed. Risk assessment includes analyzing and evaluating the risk level to determine ifthe risk is tolerable or if risk mitigation treatment is required.Accepting the submitter’s proposal in principle with the recommended modifications will clarify the intent of section

110.7(F) and will bring NFPA 70E in line with internationally accepted terminology regarding hazards and risk.Accepting the submitter’s proposal will also harmonize the NFPA 70E Technical Committee action with the action

taken on Proposal 70E-519 that replaced Annex F with material that aligns with the above mentioned internationalstandards.Note: the FPN revisions are necessary to correlate to the revisions in the body of the text and should not be considered

“new material.”

The committee understands that the action on this comment is modified by the committeeaction on Comment 70E-112.


HICKMAN, P.: We are concerned that this change in terminology did not occur globally throughout the standard,including as it relates to Table 130.7(C)(9).





70E-126The committee action should have been to accept in principle with the following action:

The committee directs that all references in the document to Annex F be revised to correlate with the new title of AnnexF that was created by the committee action on 70E-519.

This action is necessary to correlate with the action taken on 70E-519 in order to provide clarity to theuser of the document.

The committee understands that the Comment is directed to Proposal 70E-519 and is seekingcorrelation on the new title of Annex F wherever used in the standard. The committee directs staff to make thenecessary correlation.



_______________________________________________________________________________________________70E-115 Log #74 EEW-AAA

_______________________________________________________________________________________________The Technical Correlating Committee directs that the recommended text be revised for clarity as follows:

The briefing shall cover such subjects as the information on the energized electrical work permit, if required, hazardsassociated with the job, work procedures involved, special precautions, energy source controls, and personal protectiveequipment requirements, and the information on the energized electrical work permit, if required.

Palmer L. Hickman, National Joint Apprentice & Training Committee70E-115

Revise the committee action as follows:"The briefing shall cover such subjects as the information on the energized electrical work permit, hazards associated

with the job..."This recommendation is intended to clarify that the information on the energized electrical work permit

is to be covered during the job briefing.

Revise the recommendation to read:The briefing shall cover such subjects as the information on the energized electrical work permit, if required, hazardsassociated with the job, work procedures involved, special precautions, energy source controls, and personal protectiveequipment requirements.

The committee understands that the submitter's intent is to accept in principle therecommendation in Proposal 70E-115 with the revisions shown in the recommendation of this comment. The committeeaction revises the comment recommendation by adding the words "if required" based on the fact that not all workrequires an electrical work permit (EWP).





_______________________________________________________________________________________________Jerry E. Rivera, National Electrical Contractors Association


General. Before starting each job the employee competent person in charge shall conduct a job briefing with theemployees involved.

The term competent person would make the committees intent more consistent with other consensusstandard language and OSHA definitions. This would enhance the user understanding of what is expected in terms ofqualification for conducting the jobsite briefing and the responsibilities to workers safety.

One who is capable of identifying existing and predictablehazards in the surroundings or working conditions that are unsanitary, hazardous, or dangerous to employees and whohas authorization to take prompt corrective measures to eliminate them.

This inclusion of the term competent person in this instance without a new definition does notenhance clarity.



_______________________________________________________________________________________________70E-117 Log #76 EEW-AAA


70E-119Reject Proposal 70E-119.

The revised text is vague and less protective. See the explanation of negative on Proposal 70E-119.

The proposal supports and is consistent with 110.6(D)(1)(a) which states that “a person can beconsidered qualified with respect to certain equipment and methods but still unqualified for others.”







The language in the current 110.7(H) was adequate and gave employers the flexibility to design theirown audit programs. NFPA 70E should not specify the content of the audits.

The accepted proposal adds a requirement to audit field work and requires an audit every threeyears. The substantiation does not support that the requirement be lessened.


BARRIOS, L.: See my negative ballot comment on Comment 70E-120.WILMER, K.: This comment should have been accepted. The language in the current 110.7(H) was adequate and

gave employers the flexibility to design their own audit programs. NFPA 70E should not specify the content of the audits.


_______________________________________________________________________________________________70E-119 Log #188 EEW-AAA



The language in the current 110.7(H) was adequate and gave employers the flexibility to design theirown audit programs. NFPA 70E should not specify the content of the audits.



BARRIOS, L.: See my negative ballot comment on Comment 70E-120. Also, the committee statement should refer tothe action and statement on Comment 70E-118 and not Comment 70E-119.HICKMAN, P.: We continue to be concerned that text deleted in proposal 70E-119 reduces the level of safety in the

workplace. Even qualified workers need to go over the hazards of the job before commencing work, especially as therequirement is written. The conditions where “a more extensive discussion” is required indicate that these should not beconsidered “routine work.”WILMER, K.: See my Explanation of Negative on Comment 70E-118 (Log #57).





70E-122Accept the Committee Meeting Action on the proposal “in principle and in part:”

(1) The electrical safety program shall be audited to help ensure that the principles andprocedures of the electrical safety program are still in compliance with the latest requirements and regulations. Thefrequency of the audit shall not exceed three years. The frequency of audit shall be determined by the employer, basedon the complexity of the procedures and the type of work being covered.(2) Auditing of field work shall be performed to help assure that the requirements contained in the

procedures of the electrical safety program are being followed. Where the auditing determines that the principles andprocedures of the electrical safety program are not being followed, the appropriate revisions to the training program orrevisions to the procedures shall be made.

The employer should not be restricted to a set schedule for audits, which may be inappropriate for thesituation. The audit schedule should be based on the “… complexity of the procedures and the type of work beingcovered...” according to the existing NFPA 70E-2009 requirements.

The committee action on the proposal is correct (shall not exceed three years) and does notprohibit auditing more often.


BARRIOS, L.: The committee should have accepted this recommendation. As noted in the submitter's substantiationand in accordance with the current edition of the Standard, the audit schedule should be based on the "complexity of theprocedures and the type of work being covered...".WILMER, K.: This comment should have been accepted. Employers should be allowed to determine the frequency

of their audits.





70E-122Accept the Committee Meeting Action on the proposal "in principle and in part"

(H) Electrical Safety Auditing.(1) Electrical Safety Program. The electrical safety program shall be audited to help ensure that the principles and

procedures of the electrical safety program are still in compliance with the latest requirements and regulations. Thefrequency of the audit shall not exceed three years. The frequency of audit shall be determined by the employer basedon the complexity of the procedures and the type of work being covered .(2) Field Work. Auditing of field work shall be performed to help assure that the requirements contained in the

procedures of the electrical safety program are being followed. Where the auditing determines that the principles andprocedures of the electrical safety program are not being followed, the appropriate revisions to the training program orrevisions to the procedures shall be made.

The employer should not be restricted to a set schedule for audits, which may be inappropriate for thesituation. The audit schedule should be based on the " ... complexity of the procedures and the type of work beingcovered ... • according to the existing NFPA 70E-200S requirements.



BARRIOS, L.: See my negative ballot comment on Comment 70E-120.WILMER, K.: See my Explanation of Negative on Comment 70E-120 (Log #256).





70E-122This proposal should have been accepted in part to read as follows:

The electrical safety program shall be audited to help ensure that the principles andprocedures of the electrical safety program are still in compliance. with the latest requirements and regulations. Thefrequency of the audit shall not exceed three years.

As mentioned in Terry Tiede’s affirmative voting comment, it is unclear what is meant by the term “withthe latest requirements and regulations”. The prepositional phrase “with the latest requirements and regulations” shouldbe eliminated. If the committee concludes that a descriptive phrase is needed, it could use the phrase “with thisstandard”.

110.7(H)(1) The electrical safety program shall be audited to help ensure verify that the principals and procedures ofthe electrical safety program are still in compliance with the latest requirements and regulations this standard.110.7(H)(2) Auditing of Field work shall be audited performed to verify help ensure that the requirements…”

The committee accepts the grammatical comment in principle but contends that “ thisstandard”, as suggested in the substantiation, is the more appropriate language. This action incorporates the committeeaction on Comment 70E-123.



_______________________________________________________________________________________________70E-123 Log #346 EEW-AAA


70E-122The committee should continue to accept the proposal in principle with the following changes:

Modify the committee action in 110.7(H)(1) as shown: “The electrical safety program shall be audited to verify helpensure that the principles…”Modify the committee action in 110.7(H)(2) as shown: “Auditing of Field work shall be audited performed to verify help

ensure that the requirements…”Audits cannot “ensure” or “assure” compliance but are conducted to “verify” compliance. 110.7(H)(2)

was modified grammatically to change from passive to active voice and to make the statement parallel to 110.7(H)(1).






70E-129The committee action should have been to Reject this proposal.

While the submitter’s intent was to eliminate some redundancy in the Standard’s requirementsbetween Article 110 and Article 130, what has been created is unorganized confusion in Article 130. Additionalredundancy within Article 130 that did not exist before has also been created with the proposed change.

The proposal improves the document and does not create additional redundancy. Proposal70E-127 recommended fine print notes that may have addressed the submitter’s concerns. The committee reaffirms theacceptance of Proposal 70E-129.



_______________________________________________________________________________________________70E-125 Log #39 EEW-AAA

_______________________________________________________________________________________________Drake A. Drobnick, Saline, MI

70E-131, 70E-190The requirements for establishing an electrically safe work condition in Proposals 70E-131 (Log

#273) and 70E-190 (Log #471) are contradictory. Adding Conditions 2 and 3 from Proposal 70E-190 (Log #471) intoProposal 70E-131 (Log #273) would remedy this discrepancy.

Document clarity.

The committee recognizes that certain work tasks may be performed within the arc flashboundary without the necessity to establish an electrically safe work condition.






70E-131Accept Proposal 70E-131 in Principle as follows:

(1) Energized Electrical Conductors and Circuit Parts – Safe Work ConditionBefore an employee works within the Limited Approach Boundary or within the arc flash boundary, energized electrical

conductors and circuit parts to which an employee might be exposed shall be put into an electrically safe work condition,unless work on energized components can be justified according to 130.1.

This proposal should have been modified to address the arc flash hazard as indicated by Mr. Pace inhis explanation of negative for Proposal 70E-131 in the ROP. The general requirements that immediately precede thisprovision being discussed (130.3(A) General [2009 edition numbering]) require that safe work practices be used toprotect against electrical hazards (defined to include contact or equipment failure and exposure to shock, flash andblast).

The committee reaffirms its action on Proposal 70E-131. While safe work practices arenecessary to protect against electrical hazards it is not always required to establish an electrically safe work conditionbefore entering the arc flash boundary. See the committee action and statement on Comment 70E-164.



_______________________________________________________________________________________________70E-127 Log #215 EEW-AAA

_______________________________________________________________________________________________William K. Shinn, e-Hazard Management, LLC


Before an employee works within the Limited Approach Boundary, energized electrical conductors and circuit parts towhich an employee might be exposed shall be put into an electrically safe work condition, unless work on energizedcomponents can be justified according to 130.1 130.2(A).

The reference to 130.1 is from NFPA 70E-2009. 130.2(A) is the current reference.

The committee recognizes that this change will be implemented by NFPA staff. Renumberingas directed by the committee is a staff function.






70E-133Reject this proposal (and revise Proposal 70E-190, addressed separately).

Note the applicable definition:“ A state in which an electrical conductor or circuit part has been disconnected from

energized parts, locked/tagged in accordance with established standards, tested to ensure the absence of voltage, andgrounded if determined necessary.”The context of this definition is protection of personnel from shock. The addition of a requirement for placing

conductors in an electrically safe work condition when a person is within the arc flash protection boundary was notjustified by the proposal’s substantiation. An agreed basis for determining an arc flash protection boundary (a distancefrom a prospective arc source) has not been established as a requirement in NFPA 70E, so the newly-proposedrequired text is unenforceable. IEEE Std 1584 is only one of several methods that can be used to determine the arcflash protection boundary, which can vary widely based on a number of parameters and assumptions. By contrast, theshock protection boundary distance (in the case of this section, the Limited Approach Boundary) is well defined by Table130.2(C).

The committee concludes that while safe work practices are necessary to protect againstelectrical hazards it is not always required to establish an electrically safe work condition before entering the arc flashboundary. See the committee action and statement on Comment 70E-164.



_______________________________________________________________________________________________70E-129 Log #298 EEW-AAA


70E-133The committee should have rejected this proposal.

Note the applicable definition;"Electrically Safe Work Condition. A state in which an electrical conductor or circuit part has been disconnected from

energized parts, locked/tagged in accordance with established standards, tested to ensure the absence of voltage, andgrounded if determined necessary."The context of this definition is protection of personnel from shock. The addition of a requirement for placing

conductors in an electrically safe work condition when a person is within the arc flash protection boundary was notjustified by the proposal's substantiation.

The committee concludes that while safe work practices are necessary to protect againstelectrical hazards it is not always required to establish an electrically safe work condition before entering the arc flashboundary. See the committee action and statement on Comment 70E-164.






70E-135Insert into last sentence before (a): "The authority having jurisdiction will ensure that an Electrical

Hazard Analysis has been completed in accordance with this section."This proposal clarifies which party has the prime responsibility for ensuring compliance with this

section of the standard. The Submitter understands that the acceptance of this proposal would place it into Article 130.

The employer is required to train and implement safety related work practices. The committeedoes not want to identify who is responsible for these tasks as the responsibility could vary depending on the situation.


DROBNICK, D.: The Committee action should have been Accept. An AHJ for purposes of the 70E standard can bedefined as the property owner or his designee. In a sub-contractor relationship the owner or his designee assumes therole of “Host” or controlling employer and is required to follow the mandatory requirements of the standard. Performingan electrical hazard analysis is one of those requirements.GRAY, B.: Contrary to the committee statement for rejecting this comment, the Committee has already identified who

is responsible for the task through the definition of Authority Having Jurisdiction in Article 100. What the committee hasfailed to do is define the limitation and scope of those responsibilities in a mandatory rule.




_______________________________________________________________________________________________The Technical Correlating Committee directs that first and second level subdivisions in 110.9(C) be

revised to comply with the NEC Style Manual as follows:(C) GFCI Protection.(1) General. Employees shall be provided with GFCI protection where required by applicable state, federal or local

codes and standards. Listed cord sets or devices incorporating listed ground-fault circuit-interrupter protection forpersonnel identified for portable use shall be permitted.(2) Outdoors. GFCI protection shall be provided when an employee is outdoors and operating or using cord and plug

connected equipment supplied by 125 volt, 15-, 20-, or 30-ampere circuits. Where employees working outdoors operateor use equipment supplied by other than 125 volt, 15-, 20-, or 30-ampere circuits, an assured equipment groundingconductor program shall be implemented.

Daryld Ray Crow, DRC Consulting, Ltd.70E-147

Delete text as follows:Employees shall be provided with GFCI protection where required by applicable state, federal or

local codes and standards. Listed cord sets or devices incorporating listed ground-fault circuit-interrupter protection forpersonnel identified for portable use shall be permitted.(1) Devices GFCI protection devices shall be tested per manufacturer’s instructions.(2) Outdoors. GFCI

Delete 110.9(C)(1) [new 110.4(C)(1)]. This statement exists in new 110.4(D)

Revise the recommendation of Proposal 70E-147 to read:Employees shall be provided with GFCI protection where required by applicable state, federal or

local codes and standards. Listed cord sets or devices incorporating listed ground-fault circuit-interrupter protection forpersonnel identified for portable use shall be permitted.(1) Devices GFCI protection devices shall be tested per manufacturer’s instructions.(2) Outdoors. GFCI

The revisions are made to comply with the NEC Manual of Style.








The proposal added a requirement that already exists in the NEG. The Accept in Principle actionrevised the wording to remove the NEG installation requirements. However, the wording now only requires safety (I.e.requiring a GFGI) when mandated by government bodies. It should be the committee's responsibility to require what issafe regardless of what a state, local, etc. body requires.Also, the committee action created 110.4(C)(1) which duplicates 110.4 (D).

The proposal clarifies and emphasizes the need for personnel safety when working outdoorsand does not conflict with the requirements in the NEC.



_______________________________________________________________________________________________70E-133 Log #222 EEW-AAA


70E-146The committee action should have been to accept the proposal.

Telling the user to "test per manufacturer's instructions" is not adequate in all cases. What if themanufacturer has no instructions - does the user not have to do anything? What if the manufacturer requires monthly oreven weekly testing? Isn't this overkill for devices that may not be used for years at a time? The proposal providedguidance to the user for these type issues and actually would increase safety for the devices that fail between their lasttest and use.

By accepting this comment, the standard will conflict with both OSHA and NEC requirements touse listed equipment in accordance with the instructions that are included as part of the product listing and labeling.






70E-147Revise text to read as follows: Employees shall be provided with GFCI

protection where required by applicable state, federal or local codes and standards. Listed cord sets or devicesincorporating listed ground-fault circuit-interrupter protection for personnel, identified for portable use, shall be permitted.

GFCI protection devices shall be tested per manufacturer’s instructions.GFCI protection shall be provided when an employee is outdoors and operating or using cord and plug

connected equipment supplied by 125 volt, 15-, 20-, or 30-ampere circuits. Where employees working outdoors operateor use equipment supplied by other than 125 volt, 15-, 20-, or 30-ampere circuits, an assured equipment groundingconductor program shall be implemented.

See Mr. Hamer’s Comment on Affirmative in the ROP.








70E-147The committee action should continue to be Accept in Principle, but revise the committee

recommendation as follows:Employees shall be provided with GFCI protection where required by applicable state, federal or

local codes and standards. Listed cord sets or devices incorporating listed ground-fault circuit-interrupterprotection for personnel identified for portable use shall be permitted. GFCI protection devices shall be tested per

manufacturer’s instructions.(1) Devices GFCI protection devices shall be tested per manufacturer’s instructions.(2) Outdoors. GFCI protection shall be provided when an employee is outdoorsand operating or using cord and plug connected equipment supplied by 125volt, 15-, 20-, or 30-ampere circuits. Where employees working outdoorsoperate or use equipment supplied by other than 125 volt, 15-, 20-, or 30-ampere circuits, an assured equipment

grounding conductor program shall be implemented.The committee added the concept of GFCI protection “outdoors” in the proposed changes to 110.9(C

). This is not consistent with NEC Article 590.6 and sets up correlation issues with the NEC. The proposed changesabove removes the concept of “outdoors” and deletes the assured equipment grounding conductor program because itis already adequately and more appropriately addressed in NEC 590.6.



BARRIOS, L.: The submitter's recommendation in Comment 70E-135 is the "cleaner" option to satisfy therecommendations in Proposal 70E-147, while not conflicting with existing requirements in NEC Article 590.6 Also, therequirement for an assured equipment grounding conductor program precludes the use of low voltage lighting and tools,typically operating at 12V. Because of the committee action taken on Comment 70E-135, the committee willunnecessarily require an assured equipment grounding program when using LV products outdoors because theyoperate at other than "125 volt, 15-, 20- or 30-ampere circuits."





70E-151The committee action to Accept in Principle is correct. However, the wording used should be

revised as follows:. Before excavation starts and where there exists reasonable

possibility of contacting electrical or utility lines or equipment, the employer shall take the necessary steps to contact theappropriate owners or authorities to identify and mark the location of the electrical lines or equipment. AWhen it hasbeen determined that a reasonable possibility for contacting electrical lines or equipment exists, a hazard analysis shallbe performed to identify the appropriate safe work practices that shall be utilized during excavation.

Delete the words “or utility” as they do not match the article title or the requirement to identify and markthe location of.Revise the last sentence to make it clear that a hazard analysis is only required if the reasonable possibility of

contacting electrical lines or equipment exists. As it is now worded, a hazard analysis is required for all excavations.



_______________________________________________________________________________________________70E-137 Log #77 EEW-AAA



See the explanation of negatives on Proposal 70E-154.


HITTEL, M.: The action should be reject. The comment does not provide substantiation. The explanation ofnegative does not provide any information that justifies the reversal of the committee action at the proposal stage.




_______________________________________________________________________________________________Danny Liggett, The DuPont Company, Inc.

70E-154This Proposal should have been rejected.

If the electrical energy is not under control then an Electrically Safe Work Condition has not beenestablished. Control of energy is the identification of the energy sources, the method to isolate the energy and then howthe isolation will be controlled. Not all energy isolating devices are capable of being locked unless additional steps aretaken. If these devices are not secured either by a lock or other means then the energy is not under control.


HITTEL, M.: The action should be reject. The original proposal intended to improve clarity by deleting a sentencethat uses terms in an odd context that, when interpreted, does not really add much value to the user and may confusethe issues.


_______________________________________________________________________________________________70E-139 Log #151 EEW-AAA


70E-155The committee action should be to reject Proposal 70E-155 and retain the original text.

Three Two forms of hazardous electrical energy control shall be permitted: individual employee control, simplelockout/tagout, and complex lockout/tagout. For the individual employee control and the simplelockout/tagout, the qualified person in charge shall have overall responsibilityFPN: For an example of a lockout/tagout procedure, see Annex G.

No substantiation was provided other than the text does not harmonize with OSHA 1910.333(b)(2).This method has been used safely and without incident at our facility for years. The most frequent application is atmotor control centers when the electricians are tightening connections after an infrared scan of the equipment orperforming similar maintenance and adjustments on the starter components. The disconnecting means is in the MCCstarter cubicle and under exclusive control of the qualified person performing the work. OSHA uses the phrase“exclusive control” in 1910.147(a)(2)(iii)(A) in describing an acceptable means of energy control for plug and cordconnected equipment, yet lockout devices for plugs are readily available.

The committee reaffirms its decision to accept Proposal 70E-155. The Individual QualifiedEmployee Control Procedure does not provide adequate safeguards and control to prevent injury. The condition orisolation status of the equipment can change within the one-shift duration allowed by 120.2(C )(2), exposing anemployee who may return to the work site.


HITTEL, M.: The action should be accept. The committee statement contemplates a situation where a worker leavesthe work area and returns to a condition where the status of the system that was being worked on has changed.Current lockout rules would require the employee to re-verify the status of the lock-out before returning to work by therequirement in OSHA 1910.147(d)(6).






See my comment on ProposaI70E-158.



HITTEL, M.: The action should be accept. Exclusive control is a well established term in both OSHA and ANSIstandards. 1910.147(a)(2)(iii)(A) states "Work on cord and plug connected electric equipment for which exposure to thehazards of unexpected energization or start up of the equipment is controlled by the unplugging of the equipment fromthe energy source and by the plug being under the exclusive control of the employee performing the servicing ormaintenance." Further, the term is used in OSHA 1910.147(c)(4)(i). Also, ANSI Z244.1 part 5.4.3.1 states: "ExclusivePersonal Control. The user shall provide a means of exclusive personal control to prevent exposure to the hazardousenergy. Examples include...proximity to control devices." Lastly, the submitter has not provided substantiation that thisallowance has caused even ONE injury.


_______________________________________________________________________________________________70E-141 Log #149 EEW-AAA


70E-158The action should have been to reject this proposal and retain the original text.

No substantiation was provided other than the text does not seem to comply with OSHA1910.333(b)(2). This method has been used safely and without incident at our facility for years. The most frequentapplication is at motor control centers when the electricians are tightening connections after an infrared scan of theequipment or performing similar maintenance and adjustments on the starter components. The disconnecting means isin the MCC starter cubicle and under exclusive control of the qualified person performing the work. OSHA uses thephrase “exclusive control” for cord and plug connected equipment with no requirement for a lock and tag(1910.147(a)(2)(iii)(A) yet locking devices for plugs are readily available.








70E-157The action should have been to reject this proposal and retain the original text from the 2009

edition.No substantiation was provided other than the text does not seem to comply with OSHA 1910.333(b).

This method has been used safely and without incident at our facility for years. The most frequent application is atmotor control centers when the electricians are tightening connections after an infrared scan of the equipment orperforming similar maintenance and adjustments on the starter components. The disconnecting means is in the MCCstarter cubicle and under exclusive control of the qualified person performing the work. OSHA uses the phrase“exclusive control” for cord and plug connected equipment with no requirement for a lock and tag (1910.147(a)(2)(iii)(A)yet locking devices for plugs are readily available.

The committee reaffirms its decision to accept Proposal 70E-158 and to accept in principleProposal 70E-157. See the committee action and statement on Comment 70E-141.




_______________________________________________________________________________________________70E-143 Log #225 EEW-AAA



No substantiation was given that the existing "Individual Employee Control" allowance is unsafe or hascaused any injury. The only substantiation is that it is not recognized by OSHA. It is the job of this committee todetermine what we believe to be electrical safety requirements, not to re-quote OSHA requirements. If we are going tomimic OSHA, why not just delete the existing contents of the standard and replace with one line stating, "Follow OSHAelectrical safety requirements.". If we don't agree with OSHA, we should say so and use this as justification in a requestto get the OSHA requirements changed.









edition.No substantiation was provided other than the text does not harmonize with OSHA 1910.333(b)(2).

This method has been used safely and without incident at our facility for years. The most frequent application is atmotor control centers when the electricians are tightening connections after an infrared scan of the equipment orperforming similar maintenance and adjustments on the starter components. The disconnecting means is in the MCCstarter cubicle and under exclusive control of the qualified person performing the work. OSHA uses the phrase“exclusive control” in 1910.147(a)(2)(iii)(A) in describing an acceptable means of energy control for plug and cordconnected equipment, yet lockout devices for plugs are readily available.





_______________________________________________________________________________________________70E-145 Log #148 EEW-AAA



edition.This change is not editorial in nature. It is eliminating the individual qualified employee control

procedure.

The action taken by Proposal 70E-159 alone does not delete the Simple Lockout/TagoutProcedure, but only the first sentence which is redundant to the standard and therefore unnecessary.








See my comment on ProposaI 70E-158.





_______________________________________________________________________________________________70E-147 Log #227 EEW-AAA



See my comment on Proposal 70E-158.









The primary responsibility for a complex lockout/tagout may lie with a supervisor/manager levelemployee, who may not be "qualified."

The committee understands that the submitter’s comment addresses Proposal 70E-162 andnot 70E-161 as stated.


NEITZEL, D.: The substantiation for Comment 70E-148 is not true because the requirement of NFPA 70E120.2(D)(3) is applicable to the person applying the electrical lockout not the person authorizing it. OSHA 29 CFR1910.333(b)(2)(iv) requires the person to be "qualified" to perform an electrical lockout. Since NFPA 70E is the standardfor electrical safety the lockout requirements should reflect electrical lockout requirements for a "qualified" person asspecified by OSHA. The use of the term "authorized" is not consistent with OSHA requirements for electrical lockout.Proposal 70E-162 should be Accept (A) in order to be in compliance with the OSHA 29 CFR 1910.333(b)(2)(iv)requirement. If it is not then 70E is in violation of OSHA Federal law.


_______________________________________________________________________________________________70E-149 Log #392 EEW-AAA



As stated in Mr. Hittel’s and Mr. Hamer’s ROP ballot comments, the term “authorized employee” is welldefined in OSHA 1910.147(b) and is the correct term to use in NFPA 70E. As noted in Mr. Hamer’s ballot comment, thecommittee should consider adding the 1910.147 definition of “authorized employee” to Article 120.


NEITZEL, D.: The substantiation for Comment 70E-149 is true however OSHA 29 CFR 1910.333(b)(2)(iv) requiresthe person to be "qualified" to perform an electrical lockout. Since NFPA 70E is the standard for electrical safety thelockout requirements should reflect electrical lockout requirements for a "qualified" person as specified by OSHA. Theuse of the term "authorized" is not consistent with OSHA requirements for electrical lockout. Proposal 70E-162 shouldbe Accept (A) in order to be in compliance with the OSHA 29 CFR 1910.333(b)(2)(iv) requirement. If it is not then 70E isin violation of OSHA Federal law.






See the explanation of negatives on Proposal 70E-167.

The committee does not necessarily agree with all of the submitter’s substantiation.



_______________________________________________________________________________________________70E-151 Log #229 EEW-AAA




The committee reaffirms its decision to accept Proposal 70E-172. The Individual QualifiedEmployee Control Procedure does not provide adequate safeguards and control to prevent injury. The condition orisolation status of the equipment can change within the one-shift duration allowed by Section 120.2(C )(2), exposing anemployee who may return to the work site.








edition.No substantiation was provided other than the text does not harmonize with OSHA 1910.333(b)(2).

This method has been used safely and without incident at our facility for years. The most frequent application is atmotor control centers when the electricians are tightening connections after an infrared scan of the equipment orperforming similar maintenance and adjustments on the starter components. The disconnecting means is in the MCCstarter cubicle and under exclusive control of the qualified person performing the work. OSHA uses the phrase“exclusive control” in 1910.147(a)(2)(iii)(A) in describing an acceptable means of energy control for plug and cordconnected equipment, yet lockout devices for plugs are readily available.





_______________________________________________________________________________________________70E-153 Log #209 EEW-AAA



The Committee statement helps to make my case for acceptance of this proposal. It is idealistic toassume that the Electrically Safe Work Condition may encompass the entire work area. Unitization and circuitsegregation does not exist in all equipment nor is it required by any standard. Performing a lockout on one circuit maynot isolate all of the components in the work area or in one piece of equipment. Understanding what has been placed inan Electrically Safe Work Condition and what has not is critical to electrical safety. Testing for the absence of voltage isthe method used to understand the boundary of the Electrically Safe Work Condition. Assuring that all personnelinvolved in the task understand the boundary of the Electrically Safe Work Condition is vital. In one large industrialcompany as much 50% of the incidents and injuries were due to the person migrating outside the Electrically Safe WorkCondition.






70E-176Change the wording of the Committee Meeting Action to:

The procedure shall identify steps to be taken when the job or task requiringlockout/tagout is completed. Before electric circuits or equipment are reenergized, appropriate tests and visualinspections shall be conducted to verify that all tools, mechanical restraints and electrical jumpers, temporaryshort-circuits shunts, and temporary protective grounding equipment have been removed, so that the circuits andequipment are in a condition to be safely energized.

The proposed text change more accurately represents the intent of the proposal. When equipment is“released for return to service” in the context of this section on lockout/tagout, “short circuits” are not removed, but“temporary short-circuits shunts” would be.

The committee reaffirms its action on Proposal 70E-176 and the use of the terms "temporaryprotective grounding equipment" and "short circuits" is correct.



_______________________________________________________________________________________________70E-155 Log #299 EEW-AAA


70E-176The committee action should have been Accept in Principle, with the committee action changed to

the following:(m) Release for Return to Service. The procedure shall identify steps 10 be taken when the job or task requiring

lockout/tagout is completed. Before electric circuits or equipment are reenergized, appropriate tests and visualinspections shall be conducted to verify that all tools, mechanical restraints and electrical jumpers, temporaryshorts-circuits shunts, and temporary protective grounding equipment have been removed, so that the circuits andequipment are in a condition to be safely energized.

The proposed text change more accurately represents the intent of the proposal. When equipment is"released for return to service" in the context of this section on lockout/tagout, "short circuits" are not removed, but"temporary short-circuits shunts" would be.







70E-186Add an additional last sentence to the committee action as follows:

All requirements of this article shall apply whether a shock hazard analysis is completed or if Table 130.8(C)(15)(1) andTable 130.8(C)(16) are utilized.

This comment is intended to reinforce the fact that a shock hazard analysis is required even whenTable 130.7(C)(9) is used to select PPE for shock. Also, see comment on affirmative for Proposal 70E-186 in the ROP.

The intent of this new requirement is to clarify for the user that the rest of the article applies ifTables 130.7(C)(9) and 130.7(C)(10) are used. Existing Section 130.1 addresses shock protection and is part of thisarticle. The submitter's recommendation does not add clarity.


BARRIOS, L.: There are a few issues with the committee action taken on proposal 70E-186, which added a new 130.1entitled "General" that this and other comments attempted to address. First of all, even though the title of this newsection is "General" the content applies specifically to arc flash hazards analysis. It is not "general" requirements andtherefore this information should not be located at the beginning of Article 130. Also as currently written, the new 130.1implies that Article 130 only applies to arc flash hazards. This comment attempted to correct the issues with the new130.1 by adding provisions for shock protection since Article 130 applies to both shock and arc flash protection.HICKMAN, P.: We disagree that justification for work in 130.1 addresses shock protection. We submit that it address

justification as it relates to when an electrically safe work condition must be established. The recommendation was tomake it clear that a shock hazard analysis is required even when shock protection was selected as provided for in Table130.7(C)(9). This was to parallel the logic that was used that placed the requirement that all of Article 130 applies evenwhen the tables are used to select arc flash PPE. The same is the case for shock PPE. All of the shock-relatedrequirements apply even if Table 130.7(C)(9) is used to determine shock protection.NEITZEL, D.: The Committee action should have been Accept in Principle and reword 130.1(A) General as follows:

"Energized electrical conductors and circuit parts to which an employee might be exposed shall be put into anelectrically safe work condition before an employee works within the Limited Approach Boundary and Arc FlashProtection Boundary of those conductors or parts, whether the hazards are calculated or Table 130.7(C)(9) and (C)(10)are used." By doing this all concerns are met for the shock and arc flash hazards which are addressed in Article 130.PACE, D.: This comment should have been an accept. The committee is incorrect in stating that 130.1 already

addresses the shock hazard. It does not. The wording that has been accepted does not address the fact that a shockhazards analysis is still required even when Table 130.7(C)(9) is used to select PPE for shock hazards. This wordingleaves the impression that the arc flash hazard is all that is covered or is important.


BOWMAN, W.: It is not suggested in this comment vote that the committee intends for a balaclava be required forHRC 1 from the task tables.





Mr. Hamer is correct is stating that this leaves the reader with the impression that the Article onlycovers Arc Flash. The proposed new text would be more appropriate at the end 130.5 which addresses the arc flashhazard.



BARRIOS, L.: As stated in my negative ballot comment in Comment 70E-156, this new 130.1 that addresses arc flashprotection only, is out of place, does not address "general" requirements as the title implies, is redundant torequirements later in Article 130 and should not have been accepted.NEITZEL, D.: See my explanation of negative vote on Comment 70E-156.PACE, D.: See my explanation of negative vote on Comment 70E-156.



_______________________________________________________________________________________________70E-158 Log #260 EEW-AAA


70E-186Reject the change made by this proposal.

The committee’s action to insert a new 130.1 with the text amended by the Committee Meeting Actionnow implies that Article 130 only applies to arc-flash hazards, which is not the case. Article 130 deals with both theshock hazard and the arc-flash hazard.



BARRIOS, L.: See my negative ballot comment on Comment 70E-157.NEITZEL, D.: See my explanation of negative vote on Comment 70E-156.PACE, D.: See my explanation of negative vote on Comment 70E-156.







The committee's action to insert a new 130.1 with the text amended by the Committee Meeting Actionnow implies that Article 130 only applies to arc-flash hazardds, which is not the case. Article 130 deals with both theshock hazard and the arc-flash hazard.



BARRIOS, L.: See my negative ballot comment on Comment 70E-157.NEITZEL, D.: See my explanation of negative vote on Comment 70E-156.PACE, D.: See my explanation of negative vote on Comment 70E-156.






70E-190Add a new exception to Section 130.1(A) to read:

Exception: Where a disconnecting means or isolating element that has been properly installed and maintained isoperated, opened, closed, removed or inserted to achieve an electrically safe work condition for connected equipment orto return connected equipment to service that has been placed in an electrically safe work condition, the equipmentsupplying the disconnecting means or isolating element shall not be required to be placed in an electrically safe workcondition provided a risk assessment is performed and does not identify unacceptable risks for the task.

The recommended exception clarifies for the user of the standard that it is not necessary whenestablishing an electrically safe work condition to open the next upstream device in order to de-energize equipment thatcontains a disconnecting means or isolating element.


PACE, D.: This comment should have been a reject. The proposed new exception only states the obvious and addsconfusion for the reader. The process of establishing an electrically safe work condition includes removing power at thesource, an action that is clearly done with the device energized, otherwise there would be no need to remove the power.Readers of this exception are not going to understand why it was created, nor how to apply it.


BARRIOS, L.: This exception was created by the committee in order to address concern #3 in my Comment 70E-168.Because of the actions taken by the committee on proposal 70E-190 and on comment 70E-164, one would be requiredto establish an electrically safe work condition on equipment such as circuit breakers and other disconnecting meansused to establish an electrical safe work condition for connected equipment. This exception makes it clear that this isnot required as long as the criteria stated in the exception are met.HICKMAN, P.: We understand that the term “properly installed” means installed in accordance with the NEC.

_______________________________________________________________________________________________70E-160 Log #206 EEW-AAA


70E-190Add new text to read as follows:

Informational Note #2: See exceptions listed in 130.2 (B)(3)130.2 requires the following: Energized electrical conductors and circuit parts to which an employee

might be exposed shall be put into an electrically safe work condition …..The informative note #2 should be added to direct one to the exceptions.

The recommended informational note does not provide additional clarity.







Energized electrical conductors and circuit parts to which an employee might be exposed when performing repair workshall be put into an electrically safe work condition if any of the following conditions exist:(1)The employee is within the Limited Approach Boundary.(2)The employee is within the Arc Flash Boundary.(3)The employee interacts with equipment where conductors or circuit parts are not exposed, but an increased risk of

arc flash hazard exists.(1) The current text does not allow for testing or visual observation. Circuits are usually energized

when testing.(2) When walking inside a large industrial substation or switchyard a person will be in the arc flash boundary but not

doing any repair work. The person must be in the proper arc rated PPE. It is not practical to de-energize a wholeswitchyard to walk thru it while taking transformer temperature readings. Another example is an electrical rectifier stationat an aluminum smelter or a large rolling mill motor control room. Personnel are constantly within an arc flash boundarybut not interacting with the equipment in these areas. I am sure many examples from many different industries could belisted for this category.(3) As currently written it would be impossible for an employee to create an electrically safe work condition because

they would have to interact with the disconnect switch or breaker by the act of opening the device in order to create theelectrically safe work condition.

This requirement is not limited to performing repair work only. See the committee action onComment 70E-163 and the committee action and statement on Comment 70E-164.


HALE, L.: This comment should have been accepted as it adds clarity to the situation. I however do agree with70E-159A, CC #9, 70E-292 and 70E-163 as providing clarity.





70E-187The Proposal should have been an Accept in Principle with the wording revised to state "Simply

walking through an area that has energized electrical equipment does not constitute work and Arc Flash PPE is notrequired if the energized electrical equipment is not being worked on and has no exposed energized conductors orcircuit parts."

There is still a need for the guidance requested by the original proposal. This revision would haveprovided the necessary clarification requested by the proposer and cleared up the committee concern that was the basisfor the rejection. Also, if Section 130.1(A) is not the proper location for this guidance, then I am okay with moving it toanother section such as the new 130.2(A).



HICKMAN, P.: See our explanations of negative on Comments 70E-292 and 163.




_______________________________________________________________________________________________The Technical Correlating Committee recognizes that the action on Comment 70E-164 is modified by the

action on Comment 70E-163.Thomas A. Carpenter, ATA

70E-190The Accept in Principle re-wording should have been as follows: 130.2 Electrically Safe Working

Conditions. Energized electrical conductors and circuit parts to which an employee might be exposed shall be put intoan electrically safe work condition before an employee performs work if any of the following conditions exist:

The original wording required an electrically safe work condition "before an employee works".However, this revision left out the work requirement so that an electrically safe work condition is required any time theemployee meets the specified conditions, whether work is being performed on not. This was not part of the originalproposal and no justification for this change was provided. Even the Committee Statement justifying the change talksabout "conditions that required justification for energized work."


HICKMAN, P.: First, we are concerned that the accepted recommendation was to 130.2 as those requirements are in130.1. Second, the text accepted reduces clarity and creates confusion. The phrase “before an employee performswork” is essentially any time an employee is “on the clock” or in any way “working.” A workers’ presence wouldconstitute work. Therefore, the text added by this requirement is at best stating the obvious with the downside ofcreating confusion that someone would misunderstand what “performs work” means.HITTEL, M.: The action should be reject. The committee action should not include arc flash hazard in this section.

This section has always been about shock protection where the requirements are objective and easily understood. Thesecond condition for the proposed change is VERY subjective. The actions taken in the last two cycles have seriouslywatered down the requirements focused on electric shock protection. The arc flash hazard may or may not exist basedupon a risk assessment process and are specific to the equipment and task and must be evaluated to determine when itis appropriate to de-energize rather than prescriptively required for vague circumstances. The proposal expands thepermitting requirements to levels that are disproportionate to the benefits gained.NEITZEL, D.: I agree with the negative comment made by David Pace and restate it here: "This comment should

have been a reject. Proposal 70E-190 should have been accepted as proposed. The action taken on Proposal 70E-190and the resulting action taken in the Comment stage on multiple comments has left the wording confusing. The wordingaccepted by the Committee now allows a person to be within the arc flash boundary of exposed energized conductorswithout a requirement to establish an Electrically Safe Work Condition. I disagree with the committee statement that theElectrically Safe Work Condition is primarily associated with the shock hazard. It is associated with removing electricalhazards an employee is exposed to, arc flash or shock. The committee further states that if a person is wearing arc flashPPE then there is no reason to remove the hazard. The position should be to remove the hazard first and then if notfeasible, as required in OSHA 1910.333(a)(1), to then apply the safe work practices. The changes leave this standard inconflict OSHA and has diluted electrical safety. The requirements should apply anytime someone is exposed to thehazards, whether they are performing "work" or not, the definition of which, by the way, can be different from one personto the next.”PACE, D.: This comment should have been a reject. Proposal 70E-190 should have been accepted as proposed.

The action taken on Proposal 70E-190 and the resulting action taken in the Comment stage on multiple comments hasleft the wording confusing. The wording accepted by the Committee now allows a person to be within the arc flashboundary of exposed energized conductors without a requirement to establish an Electrically Safe Work Condition. Idisagree with the committee statement that the Electrically Safe Work Condition is primarily associated with the shockhazard. It is associated with removing electrical hazards an employee is exposed to, arc flash or shock. The committeefurther states that if a person is wearing arc flash PPE then there is no reason to remove the hazard. The positionshould be to remove the hazard first and then if not feasible, as required in OSHA 1910.333(a)(1), to then apply the safework practices. The changes leaves this standard in conflict OSHA and has diluted electrical safety. The requirementsshould apply anytime someone is exposed to the hazards, whether they are performing "work" or not, the definition ofwhich, by the way, can be different from one person to the next.

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Report on Comments – June 2011 NFPA 70EWALLIS, D.: I am abstaining in accordance with my agency’s policy requiring abstentions on technical issues.

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70E-190Revise the proposal that was “Accepted in Principle” as follows

Energized electrical conductors and circuit parts to which an employeemight be exposed shall be put into an electrically safe work condition if any either of the following conditions exist:(1) The employee is within the Limited Approach Boundary.(2) The employee is within the Arc Flash Boundary.(3) (2) The employee interacts with equipment where conductors or circuit parts are not exposed, but an increased risk

of injury from an arc flash hazard exists and inadequate personal protective equipment is selected for the task.Informational Note: See definition of arc flash hazard in Article 100.

The accepted wording should be revised. An “Electrically Safe Working Condition” is primarilyassociated with the shock hazard. If a person is wearing arc-rated PPE for the applicable incident energy and is withinthe Arc Flash Protection Boundary, there is no reason for the parts to be put in an electrically safe working condition.Adding a requirement to require placing equipment in an electrically safe working condition for all work within the ArcFlash Protection Boundary will actually dilute the effort to address shock hazards and prevent shock injuries andelectrocutions. An agreed basis for determining an arc flash protection boundary (a distance from a prospective arcsource) has not been established as a requirement in NFPA 70E, so the newly-proposed requirement is unenforceableand ambiguous. IEEE Std 1584 is only one of several methods that can be used to determine the arc flash protectionboundary, which can vary widely based on a number of parameters, assumptions, or the chosen calculation method. Bycontrast, the shock protection boundary distance (in the case of this section, the Limited Approach Boundary) is welldefined by Table 130.2(C).

The committee accepts the recommendation to revise the text as shown. The committee does not accept addition of"inadequate personal protective equipment is selected for the task. In addition, the committee deletes the InformationalNote. The committee action on this recommendation reads:Energized electrical conductors and circuit parts to which an employee might be exposed shall be put into an

electrically safe work condition before an employee works within the Limited Approach Boundary of those conductors orparts if any either of the following conditions in 130.1(A)(1) through 130.1(A)(3) exist:(1) The employee is within the Limited Approach Boundary.(2) The employee is within the Arc Flash Boundary.(32) The employee interacts with equipment where conductors or circuit parts are not exposed, but an increased risk of

injury from an exposure to an arc flash hazard exists.Informational Note: See definition of arc flash hazard in Article 100.

The intent of the recommendation is met in the committee action. The committee deletes theInformational Note as it is not necessary to point the user of the standard to Article 100 repeatedly. The additional textat the end of list item 2 does not provide additional clarity. The committee does not agree that the reference to PPE isrelated to this section.


HITTEL, M.: The action should be reject. The committee action should not include arc flash hazard in this section.This section has always been about shock protection where the requirements are objective and easily understood. Thesecond condition for the proposed change is VERY subjective. The actions taken in the last two cycles have seriouslywatered down the requirements focused on electric shock protection. The arc flash hazard may or may not exist basedupon a risk assessment process and are specific to the equipment and task and must be evaluated to determine when itis appropriate to de-energize rather than prescriptively required for vague circumstances. In any case, the language isvery confusing and is redundant. I suggest that the committee intended revision should read: "Energized electricalconductors and circuit parts to which an employee might be exposed shall be put into an electrically safe work conditionbefore:(1) The employee crosses the Limited Approach Boundary.(2) The employee interacts with equipment where conductors or circuit parts are not exposed, but an increased risk ofinjury from an exposure greater than 40 cal/cm2 arc flash hazard exists.

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Report on Comments – June 2011 NFPA 70ENEITZEL, D.: See my explanation of negative vote on Comment 70E-163.PACE, D.: See my explanation of negative vote on Comment 70E-163.


BARRIOS, L.: I'm voting with the committee because of the tremendous collaborative effort taken during the ROCmeeting to address concerns with the action taken on proposal 70E-190. A cleaner action would have been to rejectproposal 70E-190 in the first place for all of the reasons stated in Comment 70E-168. The submitter's recommendationsin Comment 70E-164 attempted to address these issues; however, the committee's actions made during the ROCmeeting resulted in a very confusing requirement even for the most experienced with the Standard, and resulted in theneed for a complex exception as presented in Comment 70E-159a. By definition, establishing an electrically safe workcondition is centered around minimizing the risk of shock. As we have seen the past couple of revision cycles, simplyintroducing language to apply the same requirements for persons conducting work within the Arc Flash Boundary is notas simple as the submitters intend. We in the committee need to think about this in a whole new way in order to keepthe requirements clear and concise. The proposed actions on Comment 70E-164 are not clear and concise. If youbreak the requirement into its two parts: 1) the recommendation requires energized electrical conductors and circuitparts to which an employee might be exposed to be placed in an electrically safe work condition before an employeeworks within the Limited Approach Boundary if an employee is within the Limited Approach Boundary, and 2) therecommendation requires energized electrical conductors and circuit parts to which an employee might be exposed tobe placed in an electrically safe work condition before an employee works within the Limited Approach Boundary if anemployee interacts with equipment where the conductors or circuit parts are not exposed, but an increased risk of arcflash injury exists. Neither one of the statements now makes sense. For example, part 2 doesn't even apply becausean individual will never work within the Limited Approach Boundary if the circuit parts are not exposed.WIDUP, R.: Agree with committee action of accepting in principle in part. The text as re-written provides the needed

clarity to the 70E.

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70E-190The panel action should have been to Reject this proposal.

This section is associated with shock hazards. If personnel are wearing arc-rated PPE for theapplicable incident energy and is within the Arc Flash Protection Boundary, there is no reason for the parts to be put inan electrically safe work condition.

This section addresses shock and arc flash hazards. See the committee action on Comment70E-163 and the committee action and statement on Comment 70E-164.


HITTEL, M.: The action should be accept. The committee action should not include arc flash hazard in this section.This section has always been about shock protection where the requirements are objective and easily understood. Thesecond condition for the proposed change is VERY subjective. The actions taken in the last two cycles have seriouslywatered down the requirements focused on electric shock protection. The arc flash hazard may or may not exist basedupon a risk assessment process and are specific to the equipment and task and must be evaluated to determine when itis appropriate to de-energize rather than prescriptively required for vague circumstances.NEITZEL, D.: See my explanation of negative vote on Comment 70E-163.PACE, D.: See my explanation of negative vote on Comment 70E-163.


BARRIOS, L.: See my affirmative ballot comment on Comment 70E-164.

_______________________________________________________________________________________________70E-166 Log #331 EEW-AAA


70E-190The committee should reject the proposal.

Support the comments by Mr. Hamer.

The committee reaffirms its action on Proposal 70E-190 as modified by the committee actionson Comments 70E-163 and 70E-164. The committee action on Comment 70E-164 increases the clarity of this section.


HITTEL, M.: See my Explanation of Negative on Comment 70E-165 (Log #301).NEITZEL, D.: See my explanation of negative vote on Comment 70E-163.PACE, D.: See my explanation of negative vote on Comment 70E-163.


BARRIOS, L.: See my affirmative ballot comment on Comment 70E-164.

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70E-189The panel action should have been to Accept this proposal.

The committee action on proposal 70E-190 does not meet the intent of the submitter. The submitterwas attempting to clarify that an electrically safe work condition shall be established “before” an employee works withinthe Limited Approach Boundary. The committee action on 70E-190 requires an electrically safe work condition to beestablished when the employee “is within” the Limited Approach Boundary.



HITTEL, M.: See my Explanation of Negative on Comment 70E-165 (Log #301).NEITZEL, D.: See my explanation of negative vote on Comment 70E-163.PACE, D.: See my explanation of negative vote on Comment 70E-163.


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70E-190The panel action should have been to Reject this proposal.

While the intent of reducing/eliminating both the shock hazard and arc flash hazard by establishing anelectrically safe work condition is reasonable, the committee action on proposal 70E-190 is flawed in a few areas.1. The addition of an informational note to refer to Article 100 to see the definition of arc flash hazard is superfluous

and unnecessary. The Standard already contains too many informational notes to refer to Article 100 for definitions.2. The proposed 130.1(A)(3) is also redundant and sets up a potential unnecessary requirement. Someone interacting

with conductors or circuit parts that are not exposed and creating an increased risk of arc flash may be inside the arcflash protection boundary or outside the arc flash protection boundary. If they are within the arc flash protectionboundary, then they are already covered by 130.1(A)(2). The committee action in 130.1(A)(3) is suggesting that even ifsomeone is outside of the arc flash protection boundary (regardless of the distance), an electrically safe work conditionmust be established for persons interacting with equipment where an arc flash hazard may exist.3. The proposed 130.1(A)(2) mandates establishing an electrically safe work condition for persons entering the Arc

Flash Protection Boundary. Per Article 120, an electrically safe work condition requires 6 steps to be taken. 120.1(2)requires disconnect devices to be opened for each source in order to de-energize power to the equipment to be workedon. In many cases, the act of disconnecting power creates an arc flash protection boundary because it requiresindividuals to closely interact with equipment in a manner that may increase the likelihood of an arc flash event. In orderto satisfy this new requirement in 130.1(A)(2), the next upstream device will need to be opened in order to de-energizethe bus that contains the circuit breaker that must be opened to establish an electrically safe work condition on theequipment to be worked on. I hope you can see the dilemma.4.120.1(5) requires the use of adequately rated voltage detector to test each phase conductor or circuit part to verify

they are deenergized. An employee may be working within the Arc Flash Protection Boundary created by interactingwith equipment not having exposed conductors or circuit parts. In such a case, an electrically safe work conditioncannot be met because the individual is unable to use rated voltage detectors to verify the circuit has beende-energized.5. Another short coming of the proposed change is the wording requires establishing an electrically safe work condition

when an employee “is within the Limited Approach Boundary” or “is within the Arc Flash Boundary”. As suggested inproposal 70E-189, an electrically safe work condition should be established before an employee enters these areas.

Some of the concerns of the submitter are met by other actions. The committee has acceptedin principle in part the action for Proposal 70E-190. See the committee action on Comment 70E-163 and the committeeaction and statement on Comment 70E-164. The informational note has been deleted by the action on Comment70E-164. The potential redundancy has been addressed by the action on Comment 70E-164.


HICKMAN, P.: The committee action should have been an accept in principle as indicated by the phrase “the concernsof the submitter are met by other actions” in the committee statement to reject.HITTEL, M.: The action should be accept. The committee action should not include arc flash hazard in this section.

This section has always been about shock protection where the requirements are objective and easily understood. Thesecond condition for the proposed change is VERY subjective. The actions taken in the last two cycles have seriouslywatered down the requirements focused on electric shock protection. The arc flash hazard may or may not exist basedupon a risk assessment process and are specific to the equipment and task and must be evaluated to determine when itis appropriate to de-energize rather than prescriptively required for vague circumstances. The proposal expands thepermitting requirements to levels that are disproportionate to the benefits gained.


BARRIOS, L.: While the committee made a valiant effort to address the submitter's concerns in its actions onComments 70E-164 and 70E-159a, what is left for the user of the Standard is a very complex set of requirements forestablishing an electrically safe work condition. Refer to my additional affirmative ballot comments on Comment

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Report on Comments – June 2011 NFPA 70E70E-164.

_______________________________________________________________________________________________70E-169 Log #359 EEW-AAA


70E-191The committee action should have been to Accept proposal 70E-191.Energized work shall be permitted where the employer can demonstrate that de-energizing

introduces additional hazards or increased hazards risk.The committee statement did not address the submitter’s substantiation. The proposer is brining up a

valid issue with the appropriate use of terminology. The committee statement did not refute the claim that the standarduses this term inappropriately. As stated, the TC is saying that the term is consistently used incorrectly.The submitter of 70E-191 is trying to clarify the difference between hazard and risk. As defined in internationalstandards such as “ISO Guide 51 – Safety Aspects – Guidelines for their inclusion in standards” and “ISO 31000 – RiskManagement – Principles and Guidelines,” the terms hazard and risk are not the same and therefore must be identifiedseparately:• A hazard is a potential source of harm.• Risk is the combination of the likelihood of occurrence of harm and the severity of that harm.In line with the above there may be one or more (i.e. additional) hazards, but hazards do not increase, rather, the risk

associated with the hazard(s) can increase (or decrease).Accepting the submitter’s proposal will bring NFPA 70E in line with internationally accepted terminology regarding

hazards and risk.Accepting the submitter’s proposal will also harmonize the NFPA 70E Technical Committee action with the action

taken on Proposal 70E-519 that replaced Annex F with material that aligns with the above mentioned internationalstandards.

Revise the recommendation to read:Energized work shall be permitted where the employer can demonstrate that de-energizing

introduces additional hazards or increased hazards risk.The committee deletes the second occurrence of the term "hazards" and this action meets the

intent of the recommendation.


HICKMAN, P.: We are concerned that this change in terminology did not occur globally throughout the standard,including as it relates to Table 130.7(C)(9).


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_______________________________________________________________________________________________Louis A. Barrios, Shell Global Solutions

70E-191The committee action should have been to Accept this proposal.

The submitter is correct. “Risk” is the correct term to use in this case. Risk includes the elements oflikelihood that an event will occur and the consequences of that event. In the context of 130.1(A)(1), deenergizing acircuit may increase the likelihood of an event or the consequence, however the hazards remain unchanged – shock,arc flash, etc.



_______________________________________________________________________________________________70E-171 Log #80 EEW-AAA



The change is not editorial and adequate technical substantiation has not been provided. Also, seeexplanation for Proposal 70E-193 in the ROP.

The committee concludes that "50 volts" is the appropriate terminology.



_______________________________________________________________________________________________70E-172 Log #262 EEW-AAA



Energized electrical conductors and circuit parts that operate at less than 50 volts to ground,or 50 volts conductor to conductor, shall not be required to be deenergized where the capacity of the source and anyovercurrent protection between the energy source and the worker are considered and it is determined that there will beno increased exposure to electrical burns or to explosion due to electric arcs.

The accepted proposal should have been “Accepted in Principle.” A voltage 50 volts or more - either“conductor-to-conductor“ or “conductor to ground” - could present a shock hazard.

The committee concludes that "50 volts" is the appropriate terminology. The use of "50 volts"alone covers both scenarios offered by the submitter.



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70E-194The committee action should have been to Accept in Principle proposal 70E-194 with the following

action:FPN No. 1: Examples of increased or additional hazards or increased risk include, but are not limited to, interruption of

life support equipment, deactivation of emergency alarm systems, and shutdown of hazardous location ventilationequipment.

The committee statement did not address the submitter’s substantiation. The proposer is brining up avalid issue with the appropriate use of terminology. The committee statement did not refute the claim that the standarduses this term inappropriately. As stated, the TC is saying that the term is consistently used incorrectly.The submitter of 70E-194 is trying to clarify the difference between hazard and risk. As defined in internationalstandards such as “ISO Guide 51 – Safety Aspects – Guidelines for their inclusion in standards” and “ISO 31000 – RiskManagement – Principles and Guidelines,” the terms hazard and risk are not the same and therefore must be identifiedseparately:• A hazard is a potential source of harm.• Risk is the combination of the likelihood of occurrence of harm and the severity of that harm.

In line with the above there may be one or more (i.e. additional) hazards, but hazards do not increase, rather, the riskassociated with the hazard(s) can increase (or decrease).Accepting the submitter’s proposal will bring NFPA 70E in line with internationally accepted terminology regarding




HICKMAN, P.: See our explanation of negative on Comment 70E-169.


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_______________________________________________________________________________________________Steven J. Abbott, Stark Safety Consultants

70E-198Revisetext as follows:

130.1(B) Energized Electrical Work Permit Justification.(1) Where Required. When working on energized electrical conductors or circuit parts that are not pleased in an

electrically safe work condition (i.e., for the reasons of increased or additional hazards or infeasibility per 130.1), work tobe performed shall be considered energized electrical work and shall be performed by written Permit justification only.(2) Elements of Work Permit Justification. The energized electrical work Permit Justification shall include, but not be

limited to, the following items.(1) A description of the circuit and equipment to be worked on and their location.(2) Justification for why the work must be performed in an energized condition (130.1).(3) A description of the safe work practices to be employed [110.8(B)].(4) Results of the shock hazard analysis [110.8(B)(1)(a)].(5) Determination of shock protection boundaries [130.2(B) and Table 130.2(C)].(6) Results of the arc flash hazard analysis (130.3).(7) The arc flash protection boundary [130.3(A)].(8) The necessary personal protective equipment to safely perform the assigned task [130.3(B), 130.7(C)(9), and Table

130.7(C)(9)].(9) Means employed to restrict the access of unqualified persons from the work area [110.8(A)(2)].(10) Evidence of completion of a job briefing, including a discussion of any job-specific hazards [110.7(G)].(11) Energized work approval (authorizing or responsible management, safety officer, or owner, etc.) signature(s).(3) Exemptions to Work Permit Justification. Work performed within the Limited Approach Boundary of energized

electrical conductors or circuit parts by qualified persons related to tasks such as testing, troubleshooting, voltagemeasure, etc., shall be permitted to be performed without an written energized electrical work Permit justification,provided appropriate safe work practices and personal protective equipment in accordance with Chapter 1 are providedand used. If the purpose of crossing the Limited Approach Boundary is only for visual inspection and the RestrictedApproach Boundary will not be crossed, then a written energized electrical work Permit justification shall not be required.

The intent of the submitter is to eliminate the confusion and misconception that the word Permit givethe qualified person permission to work energized. Replacing “Permit” with “Justification” would be more in line with theterminology in 130.1 Justification of work. My response to the Committee comment; “Authorization” just as “Permit” stillconveys the meaning that someone can give “permission” to do energized work regardless of 130.1.

The term "permit" is intended to identify a written document. "Justification" is a component ofthe permit process. A permit does not override infeasibility or greater hazard thresholds when it is justified by theemployer in accordance with 130.1.



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The revised language will significantly expand the tasks for which energized work permits are needed.All work within the limited approach boundary or arc flash boundary will require a work permit. Previously, permits wererequired when “working on” conductors, which was defined as coming in contact. The new requirement could beinterpreted as requiring work permits for operating switches and other tasks where no conductors are exposed.

The submitter's substantiation indicating that permits are required where conductors are notexposed is incorrect.


BARRIOS, L.: As noted in the submitter's substantiation, the committee's action on proposal 70E-199, and on thesubsequent comments will significantly expand the tasks for which energized electrical work permits are required.Industrial facilities have successfully used the energized electrical work permit, which is typically in addition to a normalwork permit, as a deterrent for "working on" or within the prohibited approach boundary. We are concerned that theeffectiveness of the energized electrical work permit will be reduced by requiring it for most tasks that an electrician willperform. Also, to require site management authorization for all these tasks is anticipated to become very onerouswithout significantly improving existing electrical safe work practices. An industrial exemption, similar to those found inthe National Electrical Code, may be required as a result of the actions taken this cycle.HITTEL, M.: The action should be accept. The permitting requirement has always been focused on "working on" and

should remain so. This action expand the permitting requirements to levels disproportionate to the benefits gained. Inaddition, the original committee action statement, as stated in my original ROP Ballot, is inaccurate as this is NOT aclarification of permit requirements; it is a change without appropriate substantiation. It changed from "working on" to"within the limited approach boundary or arc flash boundary of exposed." This action will lessen the effectiveness of thepermitting requirement.PACE, D.: See my explanation of negative vote on Comment 70E-183.


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(1) When Required. When working within the limited approach boundary or the flash boundary of exposed onenergized electrical conductors or circuit parts that are not placed in an electrically safe work condition within theprohibited approach boundary (i.e., for the reasons of increased or additional hazards or infeasibility per 130.1), work tobe performed shall be considered energized electrical work and shall be performed by written permit only.

The revision improves clarity to the users of this standard.

The committee does not agree that permits should only be required when working within theprohibited approach boundary.


BARRIOS, L.: See my negative ballot comment on Comment 70E-175.PACE, D.: See my explanation of negative vote on Comment 70E-183.


_______________________________________________________________________________________________70E-177 Log #198 EEW-AAA



The revised language will significantly expand the tasks for which energized work permits are needed.All work within the limited approach boundary or arc flash boundary will require a work permit. Previously, permits wererequired when "working on" conductors, which was defined as coming in contact. The new requirement could beinterpreted as requiring work permits for operating switches and other tasks where no conductors are exposed.



BARRIOS, L.: See my negative ballot comment on Comment 70E-175.HITTEL, M.: See my Explanation of Negative on Comment 70E-175 (Log #58).PACE, D.: See my explanation of negative vote on Comment 70E-183.


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When working within the Limited Approach Boundary or the arc flash boundary of exposed energized electricalconductors and circuit parts that are not placed in an electrically safe work condition (i.e., for the reasons of increased oradditional hazards or infeasibility per 130.1 130.2(A), work to be performed shall be considered energized electricalwork and shall be performed by written permit only.

The reference to 130.1 is from NFPA 70E-2009. 130.2(A) is the current reference.

Renumbering is a NFPA staff function.



_______________________________________________________________________________________________70E-179 Log #233 EEW-AAA



The provided substantiation goes to great length in describing how a hazard is determined, but doesnot provide justification as to why a work permit is required for those hazards. Electrical hazards exist everywhere, so dowe require a work permit for everything? With the way the standard will now read, we will need a permit to plug in ourcoffee maker since, according to Table 130.2(C), the limited approach boundary for 120V is 3 ft. 6 in. The substantiationalso references the committee action to Comment 70E-403 for the 2009 standard which changed "live" to "energizedelectrical conductors or circuit". However, the committee action to Comment 70E-404 for the 2009 standard revised thewording to what is now in the standard. In the Committee Statement to Comment 70E-404 for the 2009 standard, itstates, "In addition, the committee understands that this action modifies the action taken on Comment 70E·403." Thevote on this was 24 Affirmative, 1 Negative, and 1 Abstain, which clearly indicates the existing wording was intended.





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70E-199Reject this proposal and its associated Committee Meeting Action.

The Committee Meeting Action introduces requirements for work within the Limited ApproachBoundary that have not been substantiated. The levels of protection should be as follows: a) when working within theLimited Approach Boundary, a person must be qualified, b) when working within the Restricted Approach Boundary, aqualified person must use shock protection, c) when working within the Prohibited Approach Boundary, except aspermitted by the Standard, an Energized Electrical Work Permit is required that includes management approval. TheCommittee Meeting Action also introduced unsubstantiated requirements for work within the “arc flash boundary.” If aworker is wearing arc-rated PPE for the applicable incident energy and is within the Arc Flash Protection Boundary,there is no reason to require a written permit. An agreed basis for determining an arc flash protection boundary (adistance from a prospective arc source) has not been established as a requirement in NFPA 70E, so thenewly-proposed requirement is unenforceable and ambiguous. IEEE Std 1584 is only one of several methods that canbe used to determine the arc flash protection boundary, which can vary widely based on a number of parameters,assumptions, or the chosen calculation method. By contrast, the shock protection boundary distance (in the case of thissection, the Limited Approach Boundary) is well defined by Table 130.2(C).





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The Committee Meeting Action introduces permit requirements for work within the Limited ApproachBoundary that have not been substantiated. The levels of protection should be as follows: a) when working within theLimited Approach Boundary, a person must be qualified, b) when working within the Restricted Approach Boundary, aqualified person must use shock protection, c) when working within the Prohibited Approach Boundary, except aspermitted by the Standard, an Energized Electrical Work Permit is required that includes management approval. TheCommittee Meeting Action also introduced unsubstantiated requirements for work within the "arc flash boundary." If aworker is wearing arcrated PPE for the applicable incident energy and is within the Arc Flash Protection Boundary, thereis no reason to require a written permit.





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The proposed action has unintended consequences and reduces clarity.For example, the proposed wording requires an energized work permit to turn off a 30 Ampere safety switch, open the

cover and replace a fuse. As written in the 2009 edition, once the switch has been turned “off” and the absence ofvoltage has been confirmed at the fuse clips, the work is no longer considered energized and no energized electricalwork permit is required. However, with the proposed wording, a permit will be required for any work within the shockand arc flash boundaries. In this example, even with the switch in the “off” position, the line side of the switch isenergized and the cover is open – meaning both the shock and arc flash boundaries exist. While it is clear that safeelectrical work practices are necessary to replace a fuse, is it the intent of the committee to require an energizedelectrical work permit to replace a fuse? If not, the wording as written in the 2009 edition is clearer and should remainunchanged.



BARRIOS, L.: See my negative ballot comment on Comment 70E-175.HITTEL, M.: See my Explanation of Negative on Comment 70E-175 (Log #58).PACE, D.: See my explanation of negative vote on Comment 70E-183.TIEDE, T.: We continue to have concerns about clarity with the new language as expressed in the substantiation of

comment 70E-182. The existing text as shown in 130.1(B)(1) - {2009 edition} is clear and correct.


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As stated in Mr. Hittel’s negative ballot comment, the term “working on” was carefully selected in thelast cycle to require an energized electrical work permit when employees were in direct contact with exposed energizedparts (either with their body or with tools). It is this direct contact work that poses an elevated risk that should require ahigher level of authorization provided by the energized electrical work permit. The energized electrical work permit,which requires site management approval, should be used as a deterrent for what may be considered the mosthazardous work – when physically coming in contact with exposed, energized conductors and circuit parts. What thecommittee has done is reduced the effectiveness of the energized electrical work permit by requiring it for most tasksthat an electrician will perform. By the committee action, the act of establishing an electrical safe work condition will nowrequire an energized electrical work permit because the act of operating disconnecting means to deenergize equipmenttypically requires workers to be in the arc flash protection boundary. I don’t think it is the intent of the committee tomandate energized electrical work permits for establishing an electrically safe work condition. Previous editions of theStandard have required escalating levels of protective measures based on the perceived risk of the task. 1) Whenworking within the Limited Approach Boundary, a person must be qualified. 2) When working within the RestrictedApproach Boundary, a qualified person must use shock protection. 3) When working within the Prohibited ApproachBoundary, except as permitted by the Standard, an energized electrical work permit is required that includesmanagement approval. The committee action has now disrupted this escalation in protective measures by requiring anenergized electrical permit any time an employee may be in the Limited Approach Boundary or Arc Flash ProtectionBoundary.



BARRIOS, L.: See my negative ballot comment on Comment 70E-175.HITTEL, M.: See my Explanation of Negative on Comment 70E-175 (Log #58).PACE, D.: This Comment should have been accepted. I agree with the comments made by Mr. Barrios in his

substantiation. The Committee has not addressed the concerns of the many people who have commented on Proposal70E-199. Nor has the Committee provided any substantiation to justify this change.


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70E-201Revise the committee action to read as follows:

(4) Results of the shock hazard analysisa. The limited approach boundaryb. The restricted approach boundaryc. The prohibited approach boundaryd. The necessary shock personal and other protective equipment to safely perform the assigned task

(5) Results of the arc flash hazard analysisa. The arc flash boundaryb. The necessary arc flash personal and other protective equipment to safely perform the assigned taskc. The available incident energy or Hazard Risk Category

***Renumber the remaining list items***Adding additional clarity to the committee action will increase usability and retain the original intent of

the requirement by clarifying shock protection requirements. Also, see comment on affirmative for Proposal 70E-201 inthe ROP.

1. Accept the recommendation with the following revisions to item (5) as follows:(5) Results of the arc flash hazard analysis

a. The available incident energy or Hazard/Risk Categoryb. The necessary arc flash personal and other protective equipment to safely perform the assigned taskc. The arc flash boundary

2. Revise Annex J- to reflect the changes resulting from the revisions to 130.1(B)(2).The revisions to (5) provide a more logical order. The revisions to Annex J provide correlation

with the revised requirements for the energized work permit.



BARRIOS, L.: As currently written, the recommendation does not include reference to the applicable sections numbersfor each item, which is available in the 2009 edition of the Standard. Since this is editorial in nature, NFPA staff isrequested to include the applicable reference numbers for items (4) and (5).DROBNICK, D.: Revise the committee action to read as follows:

(4) Results of the shock hazard analysisx. Voltage exposurea. The limited approach boundaryb. The restricted approach boundaryc. The prohibited approach boundaryd. The necessary shock personal and other protective equipment to safely perform the assigned task work(5) Results of the arc flash hazard analysisa. The arc flash boundaryb. The necessary arc flash personal and other protective equipment to safely perform the assigned taskc. work based upon the available incident energy within the equipment or Hazard Risk Category associated with the task

Corrections were made to add missing concepts and provide clarity. Finding the voltage exposure level is the first stepin a Shock Hazard Analysis.

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_______________________________________________________________________________________________Timothy Crnko, Cooper Bussmann


d. Overcurrent protective device(s) used for arc flash hazard analysis condition of maintenance.The arc flash hazard analysis is dependent on the condition of maintenance of the overcurrent

protective device providing the protection and therefore should be added.

The recommendation in the comment does not align with the recommendation in the originalproposal and is unclear as to intent.



_______________________________________________________________________________________________70E-186 Log #3 EEW-AAA


70E-201Remove the words "or Hazard Risk Category" from c. of the accepted proposal.

The committee has made great strides in this cycle in our attempt to distinctly separate analysismethods from the use of the task tables. Associating the words Hazard Risk Category (a task based term) within thecontext of arc flash hazard analysis concepts will create additional public confusion.

The committee concludes that "Hazard/Risk Category" is necessary on the permit when the"table" method is used.



_______________________________________________________________________________________________70E-187 Log #40 EEW-AAA



Insert the words "associated with the task" after "Hazard Risk Category" in Subsection (6)c.Hazard risk category is a task based term. Aids in document clarity.

Hazard/Risk Category is always associated with a task. The additional text does not addclarity.



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70E-204Accept the proposal.

The Energized Electrical Work Permit should only be applicable to work within the ProhibitedApproach Boundary. Even though the term “exposed” was added to qualify the Arc Flash Protection Boundary inProposal 70E-199, the committee’s changes can reduce the effectiveness of the Energized Electrical Work Permit atpreventing “hot work”. To paraphrase the Standard, the levels of protection are as follows: a) when working within theLimited Approach Boundary, a person must be qualified, b) when working within the Restricted Approach Boundary, aqualified person must use shock protection, c) when working within the Prohibited Approach Boundary, except aspermitted by the Standard, an Energized Electrical Work Permit is required that includes management approval. Alsosee my comments on Proposal 70E-199. The Committee Statement did not adequately address or refute Mr. Barrios’substantiation.

The permit is required within the Limited Approach Boundary and the Arc Flash Boundarybased on the committee's action on Comment 70E-175, Therefore, the exemptions can only be applied to the LimitedApproach Boundary and Arc Flash Boundary. The exemptions must be consistent with the requirements for having apermit.


BARRIOS, L.: See my negative ballot comment on Comment 70E-175.PACE, D.: See my comment of negative vote on Comment 70E-183.


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The Energized Electrical Work Permit should only be applicable to work within the ProhibitedApproach Boundary. Even though the term "exposed" was added to qualify the Arc Flash Protection Boundary inProposaI 70E-199, the committee's changes can reduce the effectiveness of the Energized Electrical Work Permit atpreventing "hot work". To paraphrase the Standard, the levels of protection are as follows: a) when working within theLimited Approach Boundary, a person must be qualified, b) when working within the Restricted Approach Boundary, aqualified person must use shock protection, c) when working within the Prohibited Approach Boundary, except aspermitted by the Standard, an Energized Electrical Work Permit is required that includes management approval. Alsosee my comments on Proposal 70E-199. The Committee Statement did not adequately address or refute Mr. Barrios'substantiation.





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As stated in Mr. Hittel’s negative ballot comment on proposal 70E-199, the term “working on” wascarefully selected in the last cycle to require an energized electrical work permit when employees were in direct contactwith exposed energized parts (either with their body or with tools). It is this direct contact work that poses an elevatedrisk that should require a higher level of authorization provided by the energized electrical work permit. The energizedelectrical work permit, which requires site management approval, should be used as a deterrent for what may beconsidered the most hazardous work – when physically coming in contact with exposed, energized conductors andcircuit parts. What the committee has done is reduced the effectiveness of the energized electrical work permit byrequiring it for most tasks that an electrician will perform. By the committee action, the act of establishing an electricalsafe work condition will now require an energized electrical work permit because the act of operating disconnectingmeans to deenergize equipment typically requires workers to be in the arc flash protection boundary. I don’t think it isthe intent of the committee to mandate energized electrical work permits for establishing an electrically safe workcondition. Previous editions of the Standard have required escalating levels of protective measures based on theperceived risk of the task. 1) When working within the Limited Approach Boundary, a person must be qualified. 2)When working within the Restricted Approach Boundary, a qualified person must use shock protection. 3) Whenworking within the Prohibited Approach Boundary, except as permitted by the Standard, an energized electrical workpermit is required that includes management approval. The committee action has now disrupted this escalation inprotective measures by requiring an energized electrical permit any time an employee may be in the Limited ApproachBoundary or Arc Flash Protection Boundary.





_______________________________________________________________________________________________70E-191 Log #397 EEW-AAA



See explanation on my comment to proposal 70E-204.





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_______________________________________________________________________________________________Lee R. Hale, Alcoa/Lee Hale Consulting / Rep. Aluminum Association

70E-190Revise text as follows:

Energized electrical conductors and circuit parts to which an employee might be exposed when working shall be putinto an electrically safe work condition if any of the following conditions exist:(1) The employee is within the Limited Approach Boundary.(2) The employee is within the Arc Flash Boundary.(3) The employee interacts with equipment where conductors or circuit parts are not exposed, but an increased risk of

arc flash hazard exists.The current text would require a qualified person to de-energize the equipment (for instance a

substation) if they were just walking through the substation and were within the Arc Flash Boundary, I do not believe thiswas the intent of the committee nor is it feasible.

The committee actions on Comments 70E-163 and 70E-164 meet the intent of therecommendation to add "when working".


HICKMAN, P.: See our explanation of negative on Comments 70E-163.PACE, D.: See my comment of negative vote on Comment 70E-163.


HALE, L.: I can accept the committee action as meeting the intent of the submitter.

_______________________________________________________________________________________________70E-193 Log #25 EEW-AAA





The Committee notes the referenced proposal is intended to be 70E-206. The Committeereaffirms its actions taken on both Proposals 70E-206 and 70E-207 and actions will be correlated. The committeeacknowledges that a statement should have been included in its action on Proposal 70E-207 indicating that the actionwas modified by its action on Proposal 70E-206. Additionally, references to Tables will reflect new citations inaccordance with actions taken on Proposal 70E-186.



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70E-214Revise committee action as follows:

(1) The qualified person complies with both a and ba. The qualified person is insulated or guarded from the energized electrical conductors or circuit parts operating at

50 volts or moreb. No uninsulated part of the qualified person's body crosses the Prohibited Approach Boundary set forth in Table

130.2(C).The wording accepted appears tohave the unintended consequence of deleting an additional level of

safety. The text proposed here is intended to meet the intent of the submitter of the proposal and maintain the samelevel of protection. Also, see explanation of negative for Proposal 70E-232 in the ROP.

The committee concludes that the proposed language change could be misinterpreted to meanthe employee is not required to use rubber insulating gloves or rubber insulating gloves and sleeves until the employeeis within the prohibited approach boundary. The restricted approach boundary is the distance qualified persons mustuse for shock protection and the current language adds clarity to the users of this standard.


HICKMAN, P.: We continue to be concerned that eliminating the text referencing the Prohibited Approach Boundaryand related protection reduces the level of protection provided for in this provision.NEITZEL, D.: I agree with the negative comments by P. Hickman and D. Pace, and restate their concerns - This

Comment should have been accepted. The commenter's proposed language provides clarity as to the intent. Thelanguage accepted by the Committee has removed a vital requirement. I am concerned that eliminating the textreferencing the Prohibited Approach Boundary and related protection reduces the level of protection provided for in thisprovision.PACE, D.: This Comment should have been accepted. The commenter's proposed language provided clarity as to the

intent. The language accepted by the Committee has removed a vital requirement.

SAPORITA, V.: The existing 2009 edition text is confusing, but the proposal doesn’t remedy that confusion. Existingtext describes the qualified person as both insulated/guarded and yet he or she has uninsulated body parts at the sametime. Yet, removal of the phrase “and no uninsulated part of the qualified person’s body crosses the ProhibitedApproach Boundary set forth in Table 130.2(C)” will reduce safety by removing the emphasis for all parts of the bodythat need to be insulated or guarded, such as the shoulder, or back of the head.WALLIS, D.: I am abstaining in accordance with my agency’s policy requiring abstentions on technical issues.

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70E-210The committee should have accepted this proposal.

The submitter makes a very valid point about the accuracy implied by decimal places for fractions ofmillimeters. The committee should really reconsider this action and develop some sort of basis for the need for the typeof accuracy implied by the current table values. I recommend that we maintain the feet-inches for the conversion inparentheses, but put the metric values in meters, tenths of meters or straight integer centimeters for lengths less than0.1 meters.



_______________________________________________________________________________________________70E-197 Log #353 EEW-AAA


70E-214aCorrelate the metric/imperial conversions in the new Table 130.4(C)(2) with the distances in Table

130.4(C)(1) (formerly Table 130.3(C)(2)).Examples:Table 130.4(C)(1) lists 3.05 m as 10 ft 0 in; whereas Table 130.4(C)(2) lists 3.0 m as 10 ft 0 inTable 130.4(C)(1) lists 1.07 m as 3 ft 6 in; whereas Table 130.4(C)(2) lists 1.0 m as 3 ft 6 in. in column 3 and as 3 ft 2

in. in columns 4 and 5The metric/imperial conversions do not correlate between Table 130.4(C)(1) and Table 130.4(C)(2),

which can potentially create confusion for the user of the document.

The committee action on Comment 70E-196 is to accept the use of hard conversions.



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70E-214aThe committee action to Accept 70E-214a is correct.

This comment is submitted by the full CSA Z462 Workplace Electrical Safety Technical Committee.The IEEE paper from the 2009 Electrical Safety Workshop which was referenced in the Proposal 70E-214a with this

comment to ensure that the one negative voter has access to the substantiation for the new Table 130.2(C)(2).Note: Supporting material is available for review at NFPA Headquarters.



_______________________________________________________________________________________________70E-199 Log #96 EEW-AAA


70E-222Accept Proposal 70E-222 in Principle. Revise the first sentence of 130.3 to read as follows:

An arc flash hazard analysis shall determine the Arc Flash boundary, the incident energy or Hazard/Risk Category,and the appropriate levels of PPE either by matching the arc rating of arc rated garments (clothing) to meet or exceedthe incident energy analysis or by matching the Hazard/Risk Category from Table 130.7(C)(9) with the protectiveclothing and personal protective equipment in Table 130.7(C)(10).

The action should be additionally modified to reflect all of what is addressed by 130.3. Consider that130.3 does not only determine PPE by incident energy calculation but rather determines PPE by either incident energyor HRC. In addition, 130.3 determines three things; (A) boundary, (B) PPE, and (C) the labeling information. See alsothe comment on affirmative on Proposal 70E-222 in the ROP.

Revise existing Exception No. 2 (2009 edition) to read:Exception: The requirements of 130.7(C)(9) and 130.7(C)(10) shall be permitted to be used in lieu of a detailed

determining the incident energy at the working distance analysis .The committee action meets the intent of the recommendation and clarifies that the exception

provides an alternative to determining the incident energy at the working distance.



HICKMAN, P.: We agree with the recommendation in the substantiation for this comment that a proposal to the 2014NEC on this topic from the NFPA 70E Technical Committee would be in order and would likely be persuasive to NECPanel 1.

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70E-219The action should have been to accept in principle in part. The text should be inserted before

Exception No. 1 and should read as follows. A new Exception No. 3 should be added after Exception No. 2.The arc flash hazard analysis for a facility shall be performed by a Professional Electrical Engineer or by a Qualified

Person under the supervision of a Professional Electrical Engineer registered in the state in which the facility is locatedwhere the analysis takes place, and the Engineer shall not be an employee of or affiliated with and electrical equipmentmanufacturer.Exception No. 3: The person conducting or supervising the study shall not be required to be a registered professional

electrical engineer if the applicable state registration laws provide exemptions to persons working for a privatecorporation or other business entity and the person meets the requirements for the exemption.

Most, if not all, states require that persons performing or advertising to perform engineering servicesbe registered in that state. This is the case for both states in which I’m registered. Some state registration laws haveexemption provisions for engineers working only for a private company which is why Exception No. 3 is needed. Thereis no justification to exclude employees of electrical equipment manufacturers if they meet the qualification andregistration requirements.

The committee reaffirms its action and statement on Proposal 70E-219. Enforcement ofrequirements covering professional engineers' scope of activities is the responsibility of entities that regulate theprofession.



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The intent of the submitter is commendable. It would be ideal if an incident energy analysis wereperformed before any justified electrical work is even considered, on any equipment in any occupancy. However, this isvirtually impossible unless the installation standard (the NEC) were to mandate that a survey take place when theequipment is installed. Even if we were fortunate enough to get such a requirement starting tomorrow, we would stillhave millions of occupancies without a survey.The present text of this section works. No substantiation was provided that a problem exists. The action of the

committee to accept this proposal may result in extreme confusion and may result in the elimination of the hazard riskcategory tables. The existing exception permits the use of the tables in lieu of a detailed incident energy analysis. Theaction by the committee to accept this proposal may create confusion. The text in the draft requires that an arc flashhazardanalysis determine three separate items as follows: (1) the Arc Flash Protection Boundary, (2) the incident energy at theworking distance, and (3) the personal protective equipment that people within the Arc Flash Protection Boundary shalluse.The existing exception permitting the use of the tables clearly covers items (1) and (3) as listed above. However many

individuals will interpret new item (2) listed above as a mandate for an energy level at a given distance regardless ofwhether a study is performed or the tables are applied. There is already a buzz in the industry that this new requirementwill undermine the use of the hazard risk category tables.The present text of the first sentence of this section (as seen below) works. The text clearly requires that the analysis

determine “the personal protective equipment that people within the Arc Flash Protection Boundary shall use.”” 130.3 Arc Flash Hazard Analysis. An arc flash hazard analysis shall determine the Arc Flash Protection Boundary andthe personal protective equipment that people within the Arc Flash Protection Boundary shall use.”………….The additional text suggested by this proposal does not enhance the existing requirement, nor does it provide clarity or

usability. The additional text simply creates confusion.The committee has created a potentially serious conflict within this section. The parent text as modified by this

proposal requires the arc flash hazard analysis to determine “the incident energy at the working distance.” Thedetermination of “the incident energy at the working distance” is impossible without an incident energy analysis.

The committee continues to accept Proposal 70E-222. The committee action on Comment70E-199 addresses the concerns expressed in the substantiation.



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_______________________________________________________________________________________________John M. Weber, Kone, Inc.

70E-222Revise the wording of 130.3 Exception No. 2 as follows: The requirements of 130.7(C)(9),

130.7(C)(10) and 130.7(C)(11) shall be permitted to be used in lieu of a detailed incident energy analysis arc flashhazard analysis.

The addition of the words “the incident energy at the working distance” presents a problem with thewording of Exception No. 2. Left alone, the exception could be construed to only apply to the words added by theacceptance of 70E-222, leaving the requirement for an arc flash hazard analysis to determine the Arc Flash ProtectionBoundary and the personal protective equipment that people within the boundary must use. That precludes use of thetables, rendering them useless.



DROBNICK, D.: The Committee action should have been Accept. The action on Comment 199 does not address thesubmitter’s concern. The submitter’s use of the term arc flash hazard analysis is correct in light of the removal of the“default” boundary and the inclusion of the arc flash boundary within the task tables.


_______________________________________________________________________________________________70E-203 Log #265 EEW-AAA



. An arc flash hazard analysis shall determine the Arc Flash Protection Boundary. ,the incident energy at the working distance, and the The analysis, which includes the methods of 130.3(B), shall beused to determine the protective clothing and personal protective equipment that people for use within the Arc FlashProtection Boundary shall use.

This proposal should be revised as shown above, as the proposal wording would not permit Sections130.7(C)(9), 130.7(C)(10), and 130.7(C)(11) to be used as presently permitted by 130.3(B)(2). An “Incident EnergyAnalysis,” by the very nature of arc behavior, is only a rough estimate of incident energy. The proposed addedrequirement to determine the “incident energy at the working distance” should not supersede the ability to use Sections130.7(C)(9), 130.7(C)(10), and 130.7(C)(11), which is an equally valid methodology for determining the PPE required fora task.The above comment offers proposed wording for the existing first sentence of 130.3 that reflects the intent of this

section, and was included in the Explanation of Negative by Mr. Hamer so it would have public review during thecomment period and not be considered new information.




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70E-222The committee action should have been to Accept in Principle with the proposed text modified as

follows:130.3 Arc Flash Hazard Analysis. An arc flash hazard analysis shall determine the Arc Flash Protection Boundary. the

incident energy at the working distance, and the The analysis which includes the methods of 130.3(8) shall be used todetermine the protective clothing and personal protective equipment that people for use within the Arc FlashProtection Boundary shall use.

This proposal should be revised as shown above, as the proposal wording would not permit Sections130. 7(C)(9),130. 7(C)(10), and 130.7(C)(11) to be used as presently permitted by 130.3(B)(2). An "Incident EnergyAnalysis," by the very nature of arc behavior, is only a rough estimate of incident energy. The proposed addedrequirement to determine the "incident energy at the working distance" should not supersede the ability to use Sections130. 7(C)(9), 130.7(C)(10), and 130.7(C)(11), which is an equally valid methodology for determining the PPE requiredfor a task.The above comment offers proposed wording for the existing first sentence of 130.3 that reflects the intent of this

section, and was included in the Explanation of Negative by Mr. Hamer so it would have public review during thecomment period and not be considered new information.




_______________________________________________________________________________________________70E-205 Log #351 EEW-AAA



The committee action introduces language that may be interpreted as eliminating the permitted us ofTables 130.7(C )(9), 130.7(C )(10), and 130.7(C )(11) from determining the appropriate PPE for the task.




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_______________________________________________________________________________________________Vincent J. Saporita, Cooper Bussmann

70E-222Modify the accepted text to read:

An arc flash hazard analysis shall include 130.3(1), 130.3(2)) and (130.3(3), or130.3(4)(1) Arc Flash Protection Boundary(2) Personal Protective Equipment that people within the Arc Flash Protection Boundary shall use(3) Incident Energy at the working distance(4) Hazard/Risk Category

As accepted by the committee, the text would require an incident energy calculation even when the"table method" (130.7(C)(9), 130.7(C)(10), & 130.7(C)(11)) is utilized. The suggested wording in this comment wouldallow the "table method" to continue to be used.We need to allow the table method for those situations where the worker does not have access/ability to calculate the

precise incident energy. The practical result of not allowing the use of the "table method" is that some workers will gowithout any PPE, subjecting themselves to potential horrific injuries or death. It is much preferred to allow the worker todress according to the "table method" than to have the worker with no PPE at all.




_______________________________________________________________________________________________70E-207 Log #370 EEW-AAA


70E-222Delete text as follows:

An arc flash hazard analysis shall determine the Arc Flash Protection Boundary, the incident energy at the workingdistance and the personal protective equipment that people within the Arc Flash Protection Boundary shall use.

This action could render the use of table 130.7(C)(9) useless. The newly inserted language should bedeleted or reworded to ensure that both methods are available for use.




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_______________________________________________________________________________________________Edward Jacobson, Los Alamos, NM

70E-217The action should have been accept in principle.

Whether 70E-223 is finally approved or not, the substantiation presented for this proposal is valid.




_______________________________________________________________________________________________70E-209 Log #413 EEW-AAA


70E-219The action to reject is correct.

P.E. registration or licensure does not automatically qualify one to perform AFHA. It is conceivable thata competent and knowledgeable electrician or technician or industrial hygienist could be the most qualified person toperform an AFHA for a specific work situation. Who has the most at stake, someone in an office several states distant,registered in several states, or those in the facility where the work is located?Accurate data collection and evaluation and commercial considerations that might negatively affect worker safety are

all valid concerns, but they cannot be effectively addressed by the proposed requirements.



_______________________________________________________________________________________________70E-210 Log #414 EEW-AAA


70E-221The action on the proposal should have been accept.

Although it could be assumed that the required allowance of the added sentence is not prohibited, theaddition of the sentence does add clarity.

The committee reaffirms its action and statement on Proposal 70E-221. The substantiationdoes not provide justification to add the recommendation of Proposal 70E-221.



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70E-333The committee action should have been to accept in principle Proposal 70E-333 with the following

action:1. Revise 130.3 to require an arc flash hazard analysis without referencing a specific method as follows:

An arc flash hazard analysis shall determine the Arc Flash Protection Boundaryand the personal protective equipment that people within the Arc Flash Protection Boundary shall use. The arc flashhazard analysis shall be updated when a major modification or renovation takes place. It shall be reviewed periodically,not to exceed five years, to account for changes in the electrical distribution system that could affect the results of thearc flash hazard analysis. The arc flash hazard analysis shall take into consideration the design of the overcurrentprotective device and its opening time, including its condition of maintenance.

Where it has been determined that work will be performed within the Arc Flash Protection Boundary identifiedby 130.3(A), one of the following methods shall be used for the selection of protective clothing and other personalprotective equipment: arc flash protective clothing and other personal protective equipment that meets the requirementsof 130.7 shall be used.The personal protective clothing and equipment shall be based on the working distance of the employee’s face andchest areas from a prospective arc source, while performing a specific task. Additional protective clothing andequipment shall be used for parts of the employee’s body that are closer than the working distance.FPN: For information on methods to estimate incident energy or determine appropriate PPE see Annex D and H.(1) Incident Energy Analysis. The incident energy analysis shall determine, and the employer shall document, the

incident energy exposure of the worker (in calories per square centimeter). The incident energy exposure level shall bebased on the working distance of the employee’s face and chest areas from a prospective arc source for the specifictask to be performed. Arc-Rated FR clothing and other personal protective equipment (PPE) shall be used by theemployee based on the incident energy exposure associated with the specific task. Recognizing that incident energyincreases as the distance from the arc flash decreases, additional PPE shall be used for any parts of the body that arecloser than the distance at which the incident energy was determined.FPN: For information on estimating the incident energy, see Annex D.(2) Hazard/Risk Categories. The requirements of 130.7(C)(9), 130.7(C)(10), and 130.7(C)(11) shall be permitted to be

used for the selection and use of personal and other protective equipment.2. Move sections 130.7(C)(9), 130.7(C)(10) and 130.7(C)(11) and Tables 130.7(C)(9), 130.7(C)(10) and 130.7(C)(11)

into Annex D as proposed below or the revised Annex H and re-title Annex H accordingly.

Annex D summarizes calculation methods available for calculating arc flash boundary and incidentenergy. Annex D also includes the hazard/risk category method of selecting electrical hazard personal protectiveequipment. It is important to investigate the limitations of any methods to be used. The limitations of calculation methodssummarized in Annex D are described in Table D.1.

FPN: Any use of mandatory language in this section only indicates that users of this method cannot selectively useparts of the method and ignore other parts, it does not impose a requirement on users of this document to use thismethod. The hazard/risk category method is designed to be used in whole, not in part.

Where selected in lieu of the incident energy analysis of 130.3(B)(1), Table 130.7(C)(9) shall be When using this

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Report on Comments – June 2011 NFPA 70Emethod, Table D.X1 is used to determine the hazard/risk category and requirements for the use of rubber insulatinggloves and insulated and insulating hand tools for a task. The assumed maximum short-circuit current capacities andmaximum fault clearing times for various tasks are listed in the notes to Table 130.7(C)(9) D.X1. Do not use this methodfor tasks not listed, or for power systems with greater than the assumed maximum short circuit current capacity or withlonger than the assumed maximum fault clearing times, an arc flash hazard analysis shall be required in accordancewith 130.3.FPN No. 1: The work tasks and protective equipment identified in Table 130.7(C)(9) D.X1 were identified by a task

group and the protective clothing and equipment selected was based on the collective experience of the task group. Theprotective clothing and equipment is generally based on determination of estimated exposure levels.In several cases where the risk of an arc flash incident is considered low, very low, or extremely low by the task group,the hazard/risk category number has been reduced by 1, 2, or 3 numbers, respectively. The collective experience of thetask group is that in most cases closed doors do not provide enough protection to eliminate the need for PPE forinstances where the state of the equipment is known to readily change (e.g., doors open or closed, rack in or rack out).The premise used by the Task Group is considered to be reasonable, based on the consensus judgment of the fullNFPA 70E Technical Committee.FPN No. 2: Both larger and smaller available short-circuit currents could result in higher 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 forthe overcurrent protective device, arc flash energies could also increase.FPN No. 3: Energized electrical conductors or circuit parts that operate at less than 50 volts may need to be

deenergized 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 sourceoperating at less than 50 volts increases exposure to electrical burns or to explosion from an electric arc.FPN No. 4: See 130.1(B)(2)(6) for requirements on documenting the available short-circuit current and fault clearing

time.

Once the Hazard/Risk Category has beenidentified from Table 130.7(C)(9) (including associated notes) and the requirements of 130.7(C)(9), Table 130.7(C)(10)shall be used to determine the required PPE for the task. Table 130.7(C)(10) D.X2 lists the requirements for protectiveclothing and other protective equipment based on Hazard/Risk Category numbers 0 through 4. This clothing andequipment shall be used when working within the Arc Flash Protection Boundary.Once the Hazard/Risk Category has been identified in Table D.X1 by following the method indicated in D.X1, Table

D.X2 is used to determine the PPE for the task(s). The protective clothing and other protective equipment forHazard/Risk Category numbers 0 through 4 listed in Table D.X2 is based on the requirements of this standard. Thisstandard requires that such clothing and equipment be used when working within the Arc Flash Protection Boundary(see 130.7(C)(1)).FPN No. 1: See Annex H for a suggested simplified approach to ensure adequate PPE for electrical workers within

facilities with large and diverse electrical systems.FPN No. 2: The PPE requirements of listed in this section are is intended to protect a person from arc flash and shock

hazards. While some situations could result in burns to the skin, even with the protection described in Table130.7(C)(10) D.X2, burn injury should be reduced and survivable. Due to the explosive effect of some arc events,physical trauma injuries could occur. The PPE requirements of listed in this section do not address protection againstphysical trauma other than exposure to the thermal effects of an arc flash.

Notes:1. See Table 130.7(C)(11) D.X3. Arc rating for a garment or system of garments is expressed in cal/cm2.2. If the use of rubber insulating gloves with leather protectors are required indicated by Table 130.7(C)(9) D.X1,

additional leather or arc-rated gloves are not required necessary. The combination of rubber insulating gloves withleather protectors satisfies the arc flash protection requirements of 130.7 within the limits of Table D.X2 (e.g. up to 40

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Report on Comments – June 2011 NFPA 70Ecalories/cm2).

Table 130.7(C)(11) lists examples of protective clothing systems and typical characteristics, including the degree ofprotection, for various clothing. The protective clothing selected for the corresponding Hazard/Risk Category numberdetermined from Table 130.7(C)(9) (including associated notes) and the requirements of 130.7(C)(9) shall have an arcrating of at least the value listed in the last column of Table 130.7(C)(11).Table D.X3 lists examples of protective clothing systems and typical characteristics, including the degree of protection,

for various clothing. In order to comply with the requirements of this document the protective clothing selected for thecorresponding Hazard/Risk Category number determined from Table D.X1, by following the method indicated in D.X1,must have an arc rating of at least the value listed in the last column of Table D.X3.FPN: The arc rating for a particular clothing system can be obtained from the FR clothing manufacturer.

3. Editorial changes made to sections referencing sections 130.7(C)(9), 130.7(C)(10) and 130.7(C)(11) and Tables130.7(C)(9), 130.7(C)(10) and 130.7(C)(11) as follows:

.FPN No. 2: See Table 130.7(C)(9) D.X1 for examples of activities that could pose an arc flash hazard.

(8) The necessary personal protective equipment to safely perform the assigned task [130.3(B) and 130.7(C)130.7(C)(9), and Table 130.7(C)(9).]

FPN: Table 130.7(C)(9) provides further information on identifying D.X1 provides guidance to identify tasks whererubber insulating gloves are required.

Exception No. 1: Nonmelting, flammable (non-FR) materials shall be permitted to be used as underlayers to FR clothing,as described in 130.7(C)(14), and also shall be permitted to be used for Hazard/Risk Category 0 as described in Table130.7(C)(10).

The use of Table H.1 is suggested as a simplified approach to provide minimum personal protective equipment forelectrical workers within facilities with large and diverse electrical systems. The clothing listed in Table H.1 fulfills theminimum FR clothing requirements of Table 130.7(C)(9) and Table 130.7(C)(10). The clothing systems listed in thistable should be used with the other PPE appropriate for the Hazard/Risk Category. The notesat the bottom of Table 130.7(C)(9) must apply as shown in that table. The notes associated with the use of Table D.X1also apply to the use of this table.The use of Table H.1 is suggested as a simplified approach to provide minimum personal protective equipment forelectrical workers within facilities with large and diverse electrical systems. The clothing listed in Table H.1 is derivedfrom the Hazard/Risk Category method of Table D.X1 and Table D.X2. The clothing systems listed in this table shouldbe used with the other PPE appropriate for the Hazard/Risk Category listed in Table D.X2. The notes associated withthe use of Table D.X1 also apply to the use of this table.

All Hazard/Risk Category 1, 2 and 2* tasks listed in Table 130.7(C)(9)b

a Note other PPE required for the specific tasks listed in Tables 130.7(C)(9) D.X1 and 130.7(C)(10) D.X2, which includearc-rated face shields or arc flash suit hoods, FR hardhat liners, safety glasses or safety goggles, hard hat, hearingprotection, leather gloves, voltage-rated gloves, and voltage-rated tools. Arc rating for a garment is expressed incal/cm2.b The assumed short-circuit current capacities and fault clearing times for various tasks are listed in the text and notes

to Table 130.7(C)(9) D.X1. Do not use this method for tasks not listed, or for power systems with greater than theassumed short-circuit capacity or with longer than the assumed fault clearing times, an arc flash hazard analysis shallbe required in accordance with 130.3.

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Report on Comments – June 2011 NFPA 70E130.7(C)(5), Table 130.7(C)(10) Table D.X2, 130.7(C)(13)(a), 130.7(C)(16)

The technical committee’s statement that “The committee disagrees that Tables 130.7(C)(9), (10) and(11) belong in an Annex simply because calculation methods exist in Annex D” does not address the submitter’ssubstantiation.Proposal 70E-333 did not seek to place the H/RC method in an annex ‘ various calculation methods

are found in an annex.’ The proposal sought to , or in this case,the only specific method found in the body of the document. As stated in the substantiation: “The standard shouldspecify the outcome of a method rather than a method.” Since the technical committee has in the past included somecalculation methods in an annex, rather than delete the H/RC method entirely it would be appropriate to include ahazard/risk category method in an annex.As the 70E technical committee has acknowledged, the H/RC method is only one of many possible methods. However,as noted by Mr. Pace in his negative ballot comment “By having the Tables in the body of the text places moreemphasis on using the Table and sends the signal that using the Tables is the preferred method. Moving the Tables toan Annex is the appropriate approach.”The submitter’s substantiation further indicated that the hazard/risk category method is not a transparently scientific

method and that the reduction in levels of PPE employed in the method is not based on accepted risk managementprinciples found in ANSI Z10 or ISO 31000. These serious flaws in the H/RC method were not addressed by thetechnical committee in the committee statement. These issues must sooner or later be addressed by the technicalcommittee. Placing the H/RC method in an annex – a non-mandatory part of the standard – would be an appropriateinterim step that the technical committee could take in that direction.

The committee disagrees that the Tables belong in an Annex and reaffirms the action to rejectProposal 70E-333. Annex material is informational only. The standard provides two methods for determining PPE anddoes not establish a hierarchy of choice.



HITTEL, M.: We've moved calculation methods to Annexes while leaving the tables in the body of the standard. Thismay give the user the impression that they are the preferred method.

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70E-229The action on the proposal should be reject.

The action on the proposal should be reject for the reasons given in the two Explanations of Negative.The proposal’s Substantiation does not provide important data, such as the impedance of the transformer involved.Also, a lineman working on a pole-mounted transformer would have been performing work specifically not covered byNFPA 70E, as stated in 90.2 Scope (B) Not Covered (5) electric utility installations.

The minimum transformer size and level of voltage at which an arc-flash hazard exists has notbeen scientifically validated. Using a general set of parameters to exempt all systems from having to be assessed is nota prudent approach.


GRAY, B.: See my negative comment to 70E-217.HITTEL, M.: The action should be accept. The original proposal 70E-229 did not provide appropriate substantiation.

The arc flash boundary is set based upon the onset of a 2nd degree burn and not a 1st degree burn.STALLCUP, J.: The reason for a negative vote for the comment is that I do not feel it corresponds to the IEEE 1584,

Clause 4.2.


BOWMAN, W.: There have been no documented cases with details that have occurred in the last 12 years of anincident that has been presented to the committee of significant arc flash burns from 240 V or less circuits fed fromtransformers rated less than 125 kVA.

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_______________________________________________________________________________________________The Technical Correlating Committee recognizes that this comment and the associated action address

Proposal 70E-244.Drake A. Drobnick, Saline, MI

70E-223Delete the phrase "for each work task" from the accepted proposal.

The existing language adequately describes the methods to be used for selecting PPE when workingwithin the Arc Flash Boundary.



BARRIOS, L.: Comment 70E-213 actually applies to Proposal 70E-244.DROBNICK, D.: The recommendation and substantiation for Comments 70E-213 and 70E-241 are reversed. The text

shown below is how the comments were submitted. I agree with the Committee action on both comments as it appearsin the ballot.

70E-213 Log #4(130.3 Exception No.1)Submitter: Drake A. Drobnick, Saline, MIComment on Proposal: 70E-223Recommendation: Rather than renumber, delete current Exception #2.Substantiation: This exception is a duplication of 130.3(B) (2) where the concept is currently appropriately placed.

70E-241 Log #5(130.3B)Submitter: Drake A. Drobnick, Saline, MIComment on Proposal: 70E-244Recommendation: Delete the phrase "for each work task" from the accepted proposal.Substantiation: The existing language adequately describes the methods to be used for selecting PPE when workingwithin the Arc Flash Boundary.

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70E-223, 70E-227The committee action on 70E-223 should have been Reject; and the committee action on 70E-227

should have been Accept.130.3 Exception No. 1: An arc flash hazard analysis shall not be required where all of the following conditions exist:(1) The circuit is rated 240 volts or less.(2) The circuit is supplied by one transformer.(3) The transformer supplying the circuit is rated less than 125 kVA.Exception No. 1: An arc flash hazard analysis shall not be required for equipment below 240 V unless it involves at

least one 125 kVA or larger low impedance transformer in its immediate power supply (see IEEE 1584 Clause 4.2).This comment is submitted by the full CSA Z462 Workplace Electrical Safety Technical Committee.

Both 70E-223 and 70E-227 recognize that Exception No. 1 is an incorrect and potentially misleading translation of IEEE1584-02 Clause 4.2 paragraph 5, which states: “Equipment below 240 V need not be considered unless it involves atleast one 125 kVA or larger low-impedance transformer in its immediate power supply.” Proposal 70E-223 seeks tocorrect the statement and locate the statement in an informational note. Proposal 70E-227 seeks to correct thestatement and leave it as a normative exception.The CSA Z462 Technical Committee feels that since the requirement to perform an arc flash hazard analysis is stated

in mandatory language then any exception to the requirement is more properly stated in the document as an exceptionin normative language rather than as a non-mandatory informational note.



GRAY, B.: See my negative comment to 70E-217.HITTEL, M.: See my Explanation of Negative on Comment 70E-212 (Log #426).STALLCUP, J.: See my Explanation of Negative on Comment 70E-212 (Log #426).


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70E-217The committee action should have been to accept the proposal.

The committee statement that the Exception was deleted by Proposal 70E-223 is correct. However, aFPN was added by this same Proposal that states that some situations exist that may not require an arc flash hazardanalysis, which is basically what the exception stated. The purpose of this Proposal was to provide guidance on whatshould be done in this event. The need for guidance still exists, but not was given by rejecting this Proposal. Sincerequirements can not be included in FPNs, the correct action to Proposal 70E-223 should have been to reject or toaccept in principle and reword the exception to what is now in the FPN. Then this Proposal should have been acceptedor accepted in principle with proper rewording so that the required guidance for this situation is provided.



GRAY, B.: See my negative comment to 70E-217.HITTEL, M.: See my Explanation of Negative on Comment 70E-212 (Log #426).


_______________________________________________________________________________________________70E-216 Log #236 EEW-AAA

_______________________________________________________________________________________________The Technical Correlating Committee directs that 130.3 Exception No.1 be revised to eliminate

requirements that were contained within the informational note. The text should be revised as follows:An arc flash hazard analysis may not be necessary for some three-phase systems rated less than 240 volts. See IEEE

1584 for more information regarding arc flash hazards for three-phase systems rated less than 240 volts.Thomas A. Carpenter, ATA

70E-223The committee action should have been to reject the proposal or, at best, accepted in principle and

make the Informational Note an Exception.New Article 130.5 (formerly 130.3) requires an arc flash hazard analysis unless the tables are used

(Exception). However, the new 130.5, IN #5 states that some an arc flash hazard analysis "may not be necessary forsome three phase systems. The NEC Style Manual does not allow Informational Notes to give requirements. As such, Idon't think they can give exceptions to requirements either.



CARPENTER, T.: The committee action should have been to accept this comment and thereby reject Proposal70E-223. As it will now exist, the standard gives a requirement to perform an analysis and then allows an exception tothis requirement in an Informational Note. The TCC needs to look at this to see if it meets the NEC Style Manual, i.e.can an exception to a requirement be given in an IN.GRAY, B.: See my negative comment to 70E-217.HITTEL, M.: See my Explanation of Negative on Comment 70E-212 (Log #426).


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70E-223Reject the change of this proposal. See Comment on Proposal 70E-224 for wording.

An fact to consider is that arcs are extremely difficult to sustain on low-capacity systems rated 120volts to ground (i.e., the normal context of a 120/240 volt, or a “240 volt” single-phase system; or a 208Y/120 voltthree-phase system). Experience in the field has validated this fact. The wording of the exception could be improved(see my comment submitted for Proposal 70E-224 and the Explanation of Negative by Mr. Hamer) so it would apply onlyto systems rated at or below 120 volts, nominal, to ground. The deletion of this exception would create confusion. In theextreme, without the present exception or a similar exception, an arc flash hazard analysis would be required even forwork on a residential, single-phase, 120/240 volt panelboard.



GRAY, B.: This comment should be accepted. By deleting the exception in its entirety, the TC has implemented asituation where a mandate to estimate the incident energy exposure when no recognized method, based on empiricaldata to perform the mandate, exists. If existing wording contains an error, the error should be corrected, but not byeliminating a technical basis for the employer to use to make educated decisions on when an arc flash hazard exists. Ifthis isn't corrected, the risk is present that an arbitrary threshold is established by an employer that exposes a worker toan actual arc flash hazard. The TC needs to provide technical guidance to the industry, not leave them confused andquestioning the technical credibility of the document.HITTEL, M.: See my Explanation of Negative on Comment 70E-212 (Log #426).


_______________________________________________________________________________________________70E-218 Log #267 EEW-AAA


70E-224Accept this proposal, as submitted.

The Committee Statement essentially asked for tests to prove a negative (i.e., that arcing faults don’thappen on low-capacity 120 volt systems). The Committee did not submit any testing or substantiation for Proposal70E-223 to justify deleting the present exception in the 2009 Edition. In the Explanation of Negative published in theROP, a request was made during the Public Comment period to document any actual sustained arcs within installedequipment that have been experienced on low-capacity (less than 10 kA available short circuit current) systems rated ator below 120 volts, nominal, to ground. The Committee should review any responses to this request in making itsdecision. Also, see the substantiation included with the original proposal.





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See my comments for Proposals 70E-223 and 70E-224.





_______________________________________________________________________________________________70E-220 Log #305 EEW-AAA



A fact to consider is that arcs are extremely difficult to sustain on low-capacity systems rated 120 voltsto ground (i.e., the normal context of a 120/240 volt, or a "240 volt" single-phase system; or a 208Y/120 volt three-phasesystem).Experience in the field has validated this fact. The wording of the exception could be improved so it would apply only to

systems rated at or below 120 volts, nominal, to ground. The deletion of this exception would create confusion. In theextreme, without the present exception or a similar exception, an arc flash hazard analysis would be required even forwork on a residential, single-phase, 120/240 volt panelboard.





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70E-224The committee should have accepted this proposal in Principle and in Part. The original text from

NFPA 70E-2009 is modified below.Exception No. 1: An arc flash hazard analysis shall not be required where all of the following conditions exist:(1) The circuit is rated less than 240 volts or less(2) The circuit is supplied by one transformer.(3) The transformer supplying the circuit is rated tess than 125kVA

The proposed change brings the exception more in line with IEEE 1584, which was mis-quoted in the2009 editon of Standards. See additional comments on the API comment to Proposal 70E-223.





_______________________________________________________________________________________________70E-222 Log #307 EEW-AAA



See APRI comments on Proposals 70E-223 and 70E-224.





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The proposal should be rejected due to inadequate substantiation.Support the comments by both Mr. Hamer and Mr. Hiltel.It is not clear what will be deleted - Exception No.1 in its entirety or only Exception No.1 (3).If all of Exception No.1 is deleted then there would be a requirement to complete an analysis on every circuit above 50

volts. This requirement would be burdensome and unnecessary.If Exception No.1(3) is deleted then the requirement to complete an analysis on 240 volts or less circuit with a

transformer rated greater than 125 kVA is eliminated.Deleting Exception No. 1 would also bring into question the validity of Table 130.7(C)(9) - Panelboards or other

equipment rated 240 V and below note 1.





_______________________________________________________________________________________________70E-224 Log #332 EEW-AAA



The proposal should be rejected due to inadequate substantiation. Support the comments by both Mr.Hamer and Mr. Hittel.





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70E-224The action should have been to accept in principle.

The information provided in the substantiation would be a useful addition to NFPA 70E, perhaps inAnnex D. The Committee statement that “sufficient testing has not been conducted” should be addressed. Stage sometests for all to observe first-hand what happens when properly-protected 112.5kVA transformers having variousimpedances have their 208 output leads shorted together and when one or more leads are shorted to ground.



GRAY, B.: See my negative comment to 70E-217.


_______________________________________________________________________________________________70E-226 Log #418 EEW-AAA



The committee action should have been to Reject and have the revised wording continue to be anexception. If the existing language contains an error as the submitter states, then the error should be corrected and theexception should remain.An important point to consider is that arcs are extremely difficult to sustain on low-capacity systems rated 120 volts to

ground and this exception is useful to folks that have no need for the details to perform their work safely.Since the committee added the wording into the 2009 edition, it is obvious that the committee recognized a benefit of

adding this exception. In order to accurately convey the committee’s intent of adding the exception, the errors can, andshould, be corrected, but not removed entirely to a fine print note.





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This proposal should be accepted as it corrects the errors that exist in 130.3 Exception No. 1 bycorrelating the information with IEEE 1584. The submitter correctly states the needed corrections and the committee’scontinued referral to action on proposal 70E-223 does not correct or rectify a problem but throws the baby out with thebath water so to speak. Let’s correct and maintain the useful exception and not add another meaningless FPN.



GRAY, B.: See my negative comment to 70E-217.


_______________________________________________________________________________________________70E-228 Log #420 EEW-AAA



The submitter uses a personal experience with a first degree burn as substantiation to change theexisting language; however, neither the standards for arc flash hazard calculations, nor this standard, attempt to protectanyone from a first degree burn. The submitter’s experience was regarding an arc burn but not an arc flash as isconsidered for this standard.Accepting this proposal without true substantiation for the change is not in keeping with the committee’s position that

adequate substantiation must be presented.





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70E-232Accept Proposal 70E-232 in Part by deleting the word "detailed."

The submitter of Proposal 70E-232 was attempting to make a necessary clarification in Exception 2.Deleting the word "detailed" will enhance clarity and usability by eliminating ambiguity by the use of a term that isundefined and unclear as to its intent, without negatively impacting the text that remains. Also, see comment onaffirmative for Proposal 70E-232 in the ROP.




_______________________________________________________________________________________________70E-230 Log #11 EEW-AAA

_______________________________________________________________________________________________

Danny Liggett, DuPont Company70E-234

Revise Exception No. 2 of 130.3 to read as followsException No. 2: The requirements of 130.7(C)(9), 130.7(C)(10), and 130.7(C)(11) shall be permitted to be used in lieu

of a detailed incident energy analysis only where the conditions outlined in the notes of the respective table are met. Allfacilities built after January 1, 2012 will be required to have a detailed arc flash hazard analysis.

The exception is a loophole that is being abused and endangering electricians. Employers are usingthis exception to avoid performing a detained arc flash hazard analysis. The table 130.7(C)(9) is not being appliedcorrectly. In one example, an employer has used the table which indicates requiring only 8 cal/cm2 arc flash protection.A detailed analysis determined the incident energy was over 40 cal/cm2. This kind of abuse will continue until a limit isset on how long this exception can be used.

NFPA 70E is a work practices standard. Part of the recommendation of Proposal 70E-234 iswithin the purview of the National Electrical Code as it invokes installation requirements. The committee points out thatthe visibility of the table notes has been greatly increased by the Committee Action on Proposal 70E-331 whichincorporates the notes into the table.



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70E-234Continue to reject the proposal.

The intent of the submitter is commendable. However, this type of requirement is not within thepurview of the NFPA 70E Technical Committee. The proposed text seeks to mandate that all facilities built after January1, 2012, have a detailed arc flash analysis. This is an installation requirement directly tied to new facilities. This type ofrequirement belongs in the installation standard, the NEC.I support this concept and agree with the submitter that this type of marking requirement is necessary. I suggest that

the NFPA 70E technical committee develop a proposal for the 2014 NEC for submission by the chairman in the name ofthe committee.



_______________________________________________________________________________________________70E-232 Log #211 EEW-AAA


70E-234This Proposal should have been Accepted in Principle in Part. The Principle being adding an

exception for single family residences. The Part being not accepting the revision of the first sentence.Electricians will continue to be injured by arc flash until a line is drawn in the sand and employers are

forced to complete an arc flash hazard analysis (see 130.5) using tools such as IEEE 1584. The recommended effectivedate has no more influence or authority than the effective date of NFPA 70E. It is a national consensus standard andhas no authority but has a great deal of influence. We can’t wait until we have a perfect formula. Yes, a specific examplewas given where electricians were and continue to be put at risk because an arc flash analysis is not being performed.Now that the concept of an exception for single family residences has had public review, if we need an exception thenadd one. In their 2006 paper Cawley and Homce showed that approx. 1800 people a year are injured from electricalburns. That number is probably half of what is occurring because too many of the injuries are reported as burns and notelectrical burns. Some estimate that approx. 4500 people a year are injured as a result of arc flashes. The most effectivetime to calculate the incident energy and arc flash boundary is while it is being designed. Steps can be taken to mitigatethe arc flash hazard at that time versus trying “fix it in the field”. There are a lot of reasons not to do it. But I have onegood one to do it. Reduce the number of electrical arc flash burn injuries.




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70E-234Continue to reject this proposal.

See the Explanation of Negatives in the ROP.



_______________________________________________________________________________________________70E-234 Log #308 EEW-AAA


70E-234Continue to reject this proposal.

This proposal should be "rejected." The state-of-the-art of the calculation methods used to calculateincident energy has not matured to the point where it can be stated that the analysis can be made definitively and withprecision. In fact, this may never be the case due to the random behavior of arcs. The added requirement for an "arcflash hazard analysis" after 2012 may actually result in a false sense of security and a less safe work place because thecalculation method is undefined and is more likely undefinable. This proposal seems to drive the employer to a zero riskenvironment, and the only way to do this is to work in a world without electricity. For example, the hazard may be high(in case of of unpredictable equipment failure) but the frequency of the event (risk) is extremely low. See Article130.7(C)(9), FPN No. 1. This judgment and experience of the Technical Committee has stood the test of time throughusage of the hazard/risk approach for various tasks since the introduction of the approach in the 2000 edition. Nospecific incidents are cited in the substantiation that electricians have been endangered by the use of Table 130.7(C)(9).



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70E-234This proposal should continue to be rejected.

The submitter has based this proposal solely on the misapplication of the tables. In other actions, theCommittee has made significant improvements to usability of the tables. The hazard/risk category table approach, whenproperly applied by a qualified person, provides needed information for certain users of the standard.We agree with the significant enforcement concerns expressed in voting comments related to installations in “all

facilities built after January 1, 2012.” This proposal is outside the scope of the document and should continue to berejected.



_______________________________________________________________________________________________70E-236 Log #421 EEW-AAA


70E-234The committee should have accepted this proposal in part and revise Exception No. 2 of 130.3 to

read as follows:Exception No. 2: The requirements of 130.7(C)(9), 130.7(C)(10), and 130.7(C)(11) shall be permitted to be used in lieuof a detailed incident energy analysis only where the conditions outlined in the notes of the respective table are met.The remainder of the proposed text should be rejected.

The argument over the date after which all facilities should have arc flash hazard calculations needs tobe addressed separately and not lose the value of the proposed added text. The recommended accept in part capturesthe needed wording for clarity.

The notes to Table 130.7(C)(9) have been incorporated into the body of the table through thecommittee action on Proposal 70E-331.



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70E-236Accept the proposal, as modified in the Explanation of Negative by Mr. Hamer.

See the Explanation of Negative by Mr. Hamer.

Arc flash boundaries are contained in Table 130.7(C)(9) and that portion of 130.3(A) has beendeleted by the committee action on Proposal 70E-237.



_______________________________________________________________________________________________70E-238 Log #271 EEW-AAA



See the associated comment for Proposal 70E-236. The text of this section should not be deleted.See my comment on Proposal 70E-236. IEEE Std 1584 is only one of many methods that can be used to determine theArc Flash Protection Boundary and it is misleading to list the additional proposed information in the notes of Table130.7(C)(9).

The fundamentals used to create the arc flash boundaries in Table 130.7(C)(9) are widelyaccepted in the industry and are inherent to the calculation methods in IEEE 1584.



_______________________________________________________________________________________________70E-239 Log #27 EEW-AAA


70E-240The Technical Correlating Committee directs that the committee clarify the action on this proposal

with respect to the action taken on Proposal 70E-237.This is a direction from the Technical Correlating Committee on National Electrical Code® in


The committee accepts the direction to reconsider its action on Proposal 70E-240 and theaction should have been to accept the recommendation in principle in part for correlation with its action on Proposal70E-237.



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The original recommendation and its substantiation do not match. The proposal says to delete theFPN, while the substantiation says to relocate it. The committee action of "Accept" does not match to the committeestatement that says, "The committee does not agree with the substantiation that it should be relocated to Article 100.See committee action on ProposaI70E-195." The action on Proposal 70E-195 was to accept moving the FPN from 130.1to 130.3, which doesn't delete it or move it to Article 100. Since neither the recommendation nor its substantiation wereperformed, the action on this proposal should have been Reject.

The committee action on Proposal 70E-195 to relocate the fine print note to Section 130.3provides more clarity.



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_______________________________________________________________________________________________The Technical Correlating Committee recognizes that this comment and the associated action address

Proposal 70E-223.Drake A. Drobnick, Saline, MI

70E-244Rather than renumber, delete current Exception #2.

This exception is a duplication of 130.3(B)(2) where the concept is currently appropriately placed.

The committee does not concur with the substantiation that this exception is a duplication andunnecessary.



DROBNICK, D.: The recommendation and substantiation for Comments 70E-213 and 70E-241 are reversed. The textshown below is how the comments were submitted. I agree with the Committee action on both comments as it appearsin the ballot.

70E-213 Log #4(130.3 Exception No.1)Submitter: Drake A. Drobnick, Saline, MIComment on Proposal: 70E-223Recommendation: Rather than renumber, delete current Exception #2.Substantiation: This exception is a duplication of 130.3(B) (2) where the concept is currently appropriately placed.

70E-241 Log #5(130.3B)Submitter: Drake A. Drobnick, Saline, MIComment on Proposal: 70E-244Recommendation: Delete the phrase "for each work task" from the accepted proposal.Substantiation: The existing language adequately describes the methods to be used for selecting PPE when workingwithin the Arc Flash Boundary.

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70E-245The committee action on 70E-245 should have been Reject.

Delete the following from 130.3(B) as suggested by 70E-245:The requirements of 130.7 shall apply regardless of the method used to select the equipment

Adding the last sentence in 130.3(B) as proposed may confuse users that Tables 130.7(C)(9) and130.7(C)(10) apply equally to persons who need to determine PPE when performing an incident energy analysis...andthis is not the case.Further, the committee action taken on 70E-186 satisfies the intent of the submitter.



_______________________________________________________________________________________________70E-243 Log #272 EEW-AAA


70E-244Reject the proposal to add the wording. Retain the original text.

The additional wording “…for each work task:” actually introduces confusion rather than improvingclarity.



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70E-244The proposal should have been accepted in principle with the following change .

Change the accepted wording from “… protective equipment for each task” with “…. protective equipment for eachelectrical equipment

Allowing either B(1) or B(2) for each task can result in two different levels of PPE on the sameequipment if two different tasks are being performed on the same electrical equipment. One based on incident energyanalysis and one based HRC. Substantiation clearly indicated and referenced different equipment and not differenttasks on the same electrical equipment. Only one of the methods 130.3(B)(1) or 130.3(B)(2) should be permitted for oneelectrical equipment.

The additional wording for each task has been deleted by the committee action on Comment70E-288.



_______________________________________________________________________________________________70E-245 Log #373 EEW-AAA

_______________________________________________________________________________________________Palmer L. Hickman, NJATC

70E-245Revise 130.3(B) as follows:

"Where it has been determined that work will be performed within the Arc Flash Protection Boundary identified by130.5(A), one of the following methods shall be used for the selection of protective clothing and other personalprotective equipment. . ."

This recommendation is intended to be editorial housekeeping to correlate with the committee actionon Proposal 70E-331 that placed the AFB in a column in Table 130.7(C)(9) [now Table 130.8(C)(15)(1) in the ROPdraft]. The literal wording of 130.3(B) [now 130.5(B) in the ROP draft] does not recognize that the AFB can now bedetermined either by 130.3(A) [now 130.5(A) in the ROP draft] or in the new vertical column in Table 130.7(C)(9) [nowTable 130.8(C)(15)(1) in the ROP draft].



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70E-244The committee action should have Rejected this proposal.

The addition of the phrase “or each task” at the end of 130.3(B) does not accomplish what thesubmitter intends. In fact it may introduce more confusion. The proposed language can be interpreted as requiring anincident energy analysis for each task. This is certainly not the case. Incident energy analyses are conducted based onelectrical system and equipment design and operation parameters with typical distances from prospective arc flashes.The job briefing is used to identify other hazards specifically related to the tasks.



_______________________________________________________________________________________________70E-247 Log #84 EEW-AAA


70E-247Revise the committee action by replacing the word "guidance" with "information."

The information provided in the Informative Annex is intended as information rather than guidance.Also, see P. Hickman comment on affirmative on Proposal 70E-247.



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The committee statement, "Use of the "table method" is necessary in many instances where the workerdoes not have access to the results of a detailed incident energy analysis." does not consider that the "table method"requires two pieces of information that the same worker would most likely also not have access to without some sort ofanalysis. Those two pieces of information are the upstream device clearing time and the available short circuit current.Surely the committee is not advocating use of the table without consideration of these two values. The "detailedanalysis" referred to only requires a simple spreadsheet calculation once the two pieces of information cited above areknown. The most difficult part of the analysis is obtaining the field data from which to determine those two bits ofinformation.The only task sections in Table 130.7(C)(9) that do not require this information, and can, therefore, be directly applied

are:● NEMA E2 (fused contactor) Motor Starters, 2.3 kV Through 7.2 kV● Metal Clad Switchgear, 1 kV Through 38 kV● Arc-Resistant Switchgear Type 1 or 2 (for clearing times of <0.5 sec with a perspective fault current not to exceed the

arc resistant rating of the equipment)● Other Equipment 1 kV Through 38 kVAll others require screening using the two pieces of information for comparison to the limits set by the notes to the

table. One cannot follow Section 130.3(B)(2) and as it stands and comply with Section 130.3(C) which requires analysisto complete.

The committee continues to recognize that the “table method” is an option for performingjustified energized work in many instances where an incident energy analysis has not been performed. Many electricalsystems in use do not have an incident energy analysis performed. The tables provide the installer/maintainer with theability to determine necessary PPE for justified energized work.



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70E-260Revise the committee action on Proposal 70E-260 to read:

(C ) Equipment Labeling.Electrical equipment such as switchboards, panelboards, industrial control panels, meter socket enclosures, and motor

control centers that are in other than dwelling units, that and are likely to require examination, adjustment, servicing, ormaintenance while energized shall be field marked with a label containing all the following information:(1) At least one of the following:a. Available incident energy and the corresponding working distance.b. Minimum arc rating of clothing.c. Required level of PPE.d. Highest Hazard/Risk Category (HRC) for the equipment .(2) Nominal system voltage(3) Arc flash boundaryException: Labels applied prior to are acceptable if they contain the available incident energy or

required level of PPE.The method of calculating and data to support the information for the label shall be documented.

This committee action incorporates revisions from multiple comments in one action for clarity. Thecomments are: 70E-249, 70E-251 and 70E-252.


CARPENTER, T.: The committee action should have been to reject this comment and accept in principle Comment70E-268 with the addition of the grandfathering exception. The labeling requirements as now specified by theacceptance of this comment will be confusing, could require putting information on a label that has no value, and couldset up an employee to not wear proper PPE. Under section (1), one of items a - d must be on the label. If an incidentenergy calculation has been done, item a is easy, makes sense and has value. However, if an incident energycalculation has not been performed, item a is not available and, as such, can not be used - which leaves one of items b -d as a requirement. Item b requires the label to provide the minimum arc rating of clothing - what good is that whenmany tasks may require higher levels of protection. As a minimum, this is misleading. At worst, it could lead someoneto perform work on the equipment with extremely inadequate PPE. Item c requires the label to provide the requiredlevel of PPE. What is this? Many tasks require different levels of PPE, so which one should go on the label? Or shouldthey all go on the label? Item d requires the highest HRC for the equipment. Like items b and c, what value is this, whenthe task to be performed may only need a significantly lower HRC. Again, this is confusing to the employee installingthe label and the one trying to use it.DROBNICK, D.: I agree that adding the corresponding working distance to the available incident energy is correct.

Items b, c, and d should be deleted for the following reasons.b. “Minimum arc rating of clothing” is not descriptive. Is it associated with calculated incident energy on a piece of

equipment or a Hazard/Risk Category level associated with a task?c. “Required level of PPE” This undefined term is usually misinterpreted to mean placing an HRC level on the label.d. “Highest Hazard/Risk Category (HRC) for the equipment” HRC’s are associated with the combination of a specific

task on a class of equipment. Incident energy is calculated for a piece of equipment. Additionally, asking an employeeto wear an HRC 4 ensemble to perform a HRC 0 task is overly restrictive.Adding these three new terms will create additional public confusion and labeling inconsistency within the body of the

standard’s users.Add changes to Exception: Dated labels…..level of PPE until their five year expiration date.HICKMAN, P.: We are voting negative as the exception indicates that old labels “are acceptable” if the label contains

the level of PPE or the incident energy. There is no assurance that the label will not contain values that are no longervalid. Those “grandfathered” values may be based provisions of an edition of 70E that were superseded by a morecurrent edition of 70E as is the case when a new edition is issued by NFPA Standards Council. Note from the committeestatement on comment 70E-1 that NFPA Standards Council has indicated that “…NFPA codes and standards are

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Report on Comments – June 2011 NFPA 70Evoluntary and users who adopt or use voluntary codes and standards can decide when and how to implement their use.”Accordingly, it would appear that the decision to “grandfather” a label or how to address the question of how to addressexisting labels can be decided by those that adopt or use them. There is no need to “grandfather” labels in an exceptionwhen it has been clarified that “…users who adopt or use voluntary codes and standards can decide when and how toimplement their use.” It would appear that this decision can be left up to individual companies or facilities themselves asto which rules to follow and when.


HALE, L.: The committee is correct, this is the information the electricians in the field need to make an informeddecision and provides a grand fathering date.TIEDE, T.: We believe the portion of the new requirement that states: “Exception: Labels applied prior to September

30, 2011 are acceptable if they contain the available incident energy or required level of PPE” Is not necessary. It isclear that any task (including labeling of equipment) is subject to the requirements that are in effect on the date the taskis performed.

_______________________________________________________________________________________________70E-249 Log #6 EEW-AAA


70E-260Add a reference to working distance after incident energy on the equipment label.

The Committee accepted this reference in Proposal 70E-222 as part of the requirements of an ArcFlash Hazard Analysis. While a "working distance" is alluded to in the definition of Incident Energy, documenting thisimportant information on the label would help the Qualified Person understand the reference point where the incidentenergy was calculated.

See the committee action on Comment 70E-248a (Log #CC7).



_______________________________________________________________________________________________70E-250 Log #41 EEW-AAA


70E-260Add the following Informational Note:

See Annex Q for sample labels.Document clarity.

Based on the committee action on Comment 70E-430 to reject Proposal 70E-537 (proposedAnnnex Q), this cross-reference is not needed.



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70E-256Committee action should have been Accept in Principle in Part.

NFPA 70E has no grandfathering clause. Changing the required content of equipment labels willrequire relabeling for employers. That is a significant burden to employers, many of whom just spent considerable timeand money labeling equipment since the last revision of 70E. Any revisions to 130.3(C) should include this statement"130.3(C)(1)(b), 130.3(C)(2), 130.3(C)(3), and 130.3(C)(4) apply only to labels installed after the effective date of thestandards."

The intent of the recommendation is met by the committee action on Committee Comment70E-248a (Log #CC7).



_______________________________________________________________________________________________70E-252 Log #60 EEW-AAA



NFPA 70E has no grandfathering clause. Changing the required content of equipment labels willrequire relabeling for employers. That is a significant burden to employers, many of whom just spent considerable timeand money labeling equipment since the last revision of 70E. Any revisions to 130.3(C) should include this statement"130.3(C)(1)(b), 130.3(C)(2), 130.3(C)(3), and 130.3(C)(4) apply only to labels installed after the effective date of thestandards."




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NFPA 70E has no grandfathering clause. Changing the required content of equipment labels willrequire relabeling for employers. That is a significant burden to employers, many of whom just spent considerable timeand money labeling equipment since the last revision of 70E. Any revision to 130.3(C) should include this statement“130.3(C)(1))(b), 130.3(C)(2), 130.3(C)(3), and 130.3(C)(4) apply only to labels installed after the effective date of thestandard.”




_______________________________________________________________________________________________70E-254 Log #62 EEW-AAA



NFPA 70E has no grandfathering clause. Changing the required content of equipment labels willrequire relabeling for employers. That is a significant burden to employers, many of whom just spent considerable timeand money labeling equipment since the last revision of 70E. Any revisions to 130.3(C) should include this statement:"130.3(C)(1)(b), 13.3(C)(2), 130.3(C)(3), and 130.3(C)(4) apply only to labels installed after the effective date of thestandards."




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The committee states that the action on Proposal 70E-260 meets the intent of the recommendation,however, it is not clearly stated in either proposal whether or not the labels will have to be changed on a 5 year cycleeven if the incident energy levels remain the same. It appears that the employer will have to change all labels andredate them every 5 years regardless of any change in the hazards. This does not seem reasonable for a largeindustrial facility. Our site requires over 400 labels. It is one thing to require that the arc flash assessment be updatedevery five years and quite another to require changing labels every 5 years when the only revision is the date. A hard orelectronic copy of the report, or both, can be dated and retained for audit purposes.

See the committee action on Comment 70E-248a (Log #CC7).



_______________________________________________________________________________________________70E-256 Log #138 EEW-AAA


70E-260The committee action should have been to accept this proposal as it was submitted. The text

revisions included in this proposal and those submitted in Proposal 70E-255 should be accepted for paragraph130.3(C). The paragraph should read as follows.Electrical equipment such as switchboards, panelboards, industrial control panels, meter socket enclosures and motor

control centers that are likely to require examination, adjustment, servicing or maintenance while energized shall at aminimum be field marked with a label containing the available incident energy or required level of PPE.

This proposal suggested text changes to clarify which equipment required labels warning of the arcflash hazard. It did not address the label content at all. Revisions to the label content were added by the committeebased on other proposals. If the additional information is required to be on the label there needs to be a “grandfatherclause” included, otherwise employers will be changing labels every 3 or 5 years to comply with either the revision cycleof the standard if other label changes are made or the required arc flash study update if the study date is required on thelabel. Our facility requires over 400 labels so it is no small task to relabel equipment. The additional label informationincluded by the committee does not add to the safety of the worker. Listing the date is proposed for auditing purposes,not worker safety. The nominal system voltage is known by qualified workers by definition and is readily available fromother sources. Qualified workers at our site assume they will be crossing the arc flash boundary when working onequipment and are wearing the appropriate level of PPE when they approach the equipment for troubleshooting, rackingbreakers and starters in/out, or placing the equipment in an electrically safe condition. Adding the arc flash boundary tothe label will not change their work practices or improve their safety.

The committee concludes that adding "at a minimum" to the requirement does not provideadditional clarity.



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The committee action included addressing this proposal as part of Proposal 70E-260. The actions onProposals 70E-255 and 70E-260 change the revised text proposed in 70E-259.

The committee reaffirms the action to accept in principle Proposal 70E-260. The intent of therecommendation in Proposal 70E-259 is met in the action of the Committee Comment 70E-248a (Log #CC7).



_______________________________________________________________________________________________70E-258 Log #140 EEW-AAA



The committee action included addressing this proposal as part of Proposal 70E-260. The proposaladds a requirement to include the voltage potential, the incident energy level, and the required PPE. By definition, aqualified person should be able to determine the voltages present. The requirement for posting incident energy and thePPE required seems to be in conflict with the committee’s statement in Proposal 70E-261.

The committee continues to include nominal system voltage on the label. See the committeeaction on Comment 70E-248a (Log #CC7).



_______________________________________________________________________________________________70E-259 Log #141 EEW-AAA


70E-255The committee action should have been to accept this proposal. The text revisions included in this

proposal and those submitted in Proposal 70E-260 should be accepted for paragraph 130.3(C).The committee action included addressing this proposal as part of Proposal 70E-260. The proposal

defines the minimum requirements for the label and allows the addition of information as required by each employer’selectrical safety program.

The intent of the recommendation has been met in Committee Comment Number 70E-248a(Log #CC7).



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The committee action included addressing this proposal as part of Proposal 70E-260. Requiring thearc flash boundary to be on the label does not necessarily add to the worker’s safety when they wear arc-rated clothingfor their normal work clothes. I have interviewed our electricians and they assume they will cross the arc flash boundaryregardless of the distance calculated and posted.

The committee concludes that including the arc flash boundary on the label provides thequalified person with important information on a distance where an arc flash hazard exists.



_______________________________________________________________________________________________70E-261 Log #143 EEW-AAA



The committee action included addressing this proposal as part of Proposal 70E-260. If the additionalinformation is required to be on the label there needs to be a “grandfather clause” included, otherwise employers maybe changing labels every 3 years to comply with the revision cycle of the standard if new information is required on thelabel. Our facility requires over 400 labels so it is no small task to relabel equipment. The added label informationincluded in the proposal does nothing to improve the safety of the worker. The nominal system voltage is known byqualified workers by definition. Qualified workers at our site assume they will be crossing the arc flash boundary whenworking on equipment and are wearing the appropriate level of PPE when they approach the equipment fortroubleshooting, racking breakers and starters in/out, or placing the equipment in an electrically safe condition. Addingthe arc flash boundary to the label will not change their work practices or improve their safety. This proposal includesthe requirement that incident energy and required PPE be included on the label and the committee specifically statedthat it does not intend to allow both incident energy and level of PPE (Proposal 70E-261).

The committee reaffirms acceptance in principle of Proposal 70E-253. See the committeeaction on Committee Comment 70E-248a (Log #CC7). which may address some of the concerns expressed in thesubstantiation.



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70E-252The Committee action should have been to reject this proposal.

It is not clearly stated in the proposal whether or not the labels will have to be changed on a 5 yearcycle even if the incident energy levels remain the same. It appears that the employer will have to change all labels andredate them every 5 years regardless of any change in the hazards. This does not seem reasonable for a largeindustrial facility. Our site requires over 400 labels. It is one thing to require that the arc flash assessment be updatedevery five years and quite another to require changing labels every 5 years when the only revision is the date. A hard orelectronic copy of the report, or both, can be dated and retained for audit purposes.

The committee notes that acceptance of this comment only addresses the date of theevaluation accepted by the committee action in Proposal 70E-252.



_______________________________________________________________________________________________70E-263 Log #186 EEW-AAA



NFPA 70E has no grandfathering clause. Changing the required content of equipment labels willrequire relabeling for employers. That is a significant burden to employers, many of whom just spent considerable timeand money labeling equipment since the last revision of 70E. Any revision to 130.3(C) should include this statement"130.3(C)(1)(b), 130.3(C)(2), 130.3(C)(3), and 130.3(C)(4) apply only to labels installed after the effective date of thestandard."



HICKMAN, P.: See our explanation of negative on comment 70E-248a.


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70E-256See my comment on Proposal 70E-260.





_______________________________________________________________________________________________70E-265 Log #196 EEW-AAA







_______________________________________________________________________________________________70E-266 Log #197 EEW-AAA







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Equipment Labeling ….(1) At lease one of the following:a. Available incident energy at ___ inchesb. Minimum arc rating of PPEc. PPE Category(2) Arc flash boundary(3) Nominal system voltage(4) Limited Approach Boundary(5) Restricted Approach Boundary(6) Prohibited Approach Boundary(7) Equipment identification(8) Date of arc flash hazard analysis

1. Incident energy is at a specific distance.2. Stating a PPE category after the incident energy is known does not include consideration of risk. Many companies

use specific PPE categories of PPE. Stating a PPE category that a company has supplied for use by employees doesnot include risk.3.Shock information should be included on signage to align with the NEC labeling requirements. One should not ignore

the shock hazard and only be concerned with the flash hazard. The labeling should include both shock and flashinformation.

The committee accepts the change to "at least one of the following". The committee accepts in principle the addition ofdistance in (1)(a). The committee accepts in principle adding "PPE Category". The committee rejects adding limitedapproach boundary, restricted approach boundary, and prohibited approach boundary. See the committee action onCommittee Comment 70E-248a (Log #CC7).

The recommendation to include shock boundaries does not add clarity as nominal systemvoltage is listed on the label.


HICKMAN, P.: We disagree with the action and committee statement. Simply knowing the system voltage does notclarify what the shock boundaries are or the distance at which shock protection is required.


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70E-260The committee action sets up a conflict within the standard and needs to be changed as follows:

Where a detailed incident energy analysis has been performed, Eelectrical equipment suchas switchboards, panelboards, industrial control panels, meter socket enclosures and motor control centers that arelikely to require examination, adjustment, servicing or maintenance while energized shall be field marked with a labelcontaining all the following information:(1) Only one of the following:a. Available incident energyb. Minimum arc rating of clothing(2) Date of arc flash hazard analysis(3) Nominal system voltage(4) Arc flash boundaryWhere a detailed incident energy analysis has not been performed (as allowed by the exception to 130.5), electrical

equipment such as switchboards. panelboards, industrial control panels. meter socket enclosures and motor controlcenters that are likely to require examination, adjustment, servicing or maintenance while energized shall be fieldmarked with a label identifying that an arc flash hazard exists and to consult aR!2ropriate supervision for PPErequirements.

The standard clearly allows for the use of Tables 130.8(C)(15) and 130.8(C)(16) in lieu of performing adetailed incident energy analysis. However, the action taken on this proposal requires information to be placed on alabel that can only be obtained by performing a detailed incident energy analysis which, in effect, rules out using thetables. (1) a requires an analysis to determine the available incident energy, while (1) b cannot be specified since thetables require different arc ratings of clothing depending on the action being performed. (4) also cannot be specifiedsince the tables require different boundaries depending on the action being performed.

Labeling is important regardless of how the information was determined. Consultation withappropriate supervision is not appropriate for the label. The committee does not want to add "where a detailed incidentenergy analysis has been performed."


CARPENTER, T.: The committee action should have been to accept this comment "in principle" with the addition of agrandfathering exception. The labeling requirements as now specified by Committee Comment 70E-248a (Log #CC7)will be confusing, could require putting information on a label that has no value and could set up an employee to notwear the proper PPE. Under section (1), one of items a - d must be on the label. If an incident energy calculation hasbeen done, item a is easy, makes sense and has value. However, if an incident energy calculation has not beenperformed, item a is not available and, as such, can not be used - which leaves one of items b - d as a requirement.Item b requires the label to provide the minimum arc rating of clothing - what good is that when many tasks may requirehigher levels of protection. As a minimum, this is misleading. At worst, it could lead someone to perform work on theequipment with extremely inadequate PPE. Item c requires the label to provide the required level of PPE. What is this?Many tasks require different levels of PPE, so which one should go on the label? Or should they all go on the label?Item d requires the highest HRC for the equipment. Like items b and c, what value is this, when the task to beperformed may only need a significantly lower HRC. Again, this is confusing to the employee installing the label and theone trying to use it.


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We recognize that properly labeled equipment can provide valuable information when maintainedunder qualified engineering supervision; however, there are several issues with the proposed wording even within asupervised environment.First, isn’t it understood that the “Minimum arc rating of clothing” should be equal to or higher than the “Available

incident energy”? Was the intent of the committee to say “Hazard/Risk Category (HRC)” instead of saying “Minimum arcrating of clothing”?Second, the word “only” in (1) is too restrictive and should be eliminated. By removing the word “only” the standard will

permit a single labeling method to be used throughout a company’s electrical safety program. For example, suppose anengineer conducts an analysis and determines an Incident Energy value of 7 cal/cm^2. The company chooses toinclude that value on the label along with a “CATEGORY 2” marking which can enhance the understanding for theelectrical worker. Two different methods exist to arrive at the level of PPE; however, it is confusing for electrical workersto require two different labeling methods which could co-exist in the same facility. By simply removing the word “only”the standard would permit a common label format.Third, the committee unfortunately did not address an inaccuracy in the submitter’s substantiation. NEC 110.16

specifically excludes “dwelling occupancies”, putting it in conflict with the proposed language. Is it the committee’s intentthat labeling be required in all dwellings?This proposal creates too many additional issues and should be rejected.

The committee reaffirms the inclusion of additional label requirements. The submitter'sconcerns may be addressed by the actions taken in Committee Comment 70E-248a (Log #CC7). Dwelling units areexcluded from the labeling requirement for consistency with NEC Section 110.16.



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70E-260Add the following additional text:

(4) Arc flash boundaryAny label installed prior to the effective date of the standard shall not be required to provide this information unless a

label is replaced due to damage or label is found to be in error. As part of the five year periodic review of the arc flashhazard analysis all labels not providing all information required shall be replaced with labels providing the requiredinformation.

This would give employers a more reasonable amount of time implement the new labeling requirementbut would bring all into compliance in approximately five years.

The committee accepts in principle the provision for "grandfathering" of existing labels. The committee does not acceptthe portion of the recommendation of updating labels as part of the five year review.

The intent of the recommendation to permit the use of existing labels is met by the committeeaction on Committee Comment 70E-248a (Log #CC7). The substantiation does not support the necessity of replacingthe label as part of the five year review.


HICKMAN, P.: See our explanation of negative on comment 70E-248a.


_______________________________________________________________________________________________70E-271 Log #333 EEW-AAA


70E-252Delete the date of evaluation from the committee action: 130.3(C) Equipment Labeling. Equipment

shall be field marked with a label containing the available incident energy or required level of PPE and date ofevaluation.

The committee revision which includes the requirement for the date of the arc flash hazard analysis tobe included on the label is an unnecessary burden on the employer to replace all labels that do not contain the date ofthe analysis. This information is available on request from the employer and therefore it is not necessary to be on thelabel.



HICKMAN, P.: We do not necessarily agree with the substantiation provided by the submitter.

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70E-260Delete 130,3(C)(2) of the committee revision: (2) Date of arc flash hazard analysis

The committee revision which includes the requirement for the date of the arc flash hazard analysis tobe included on the label is an unnecessary burden on the employer to replace all labels that do not contain the date ofthe analysis. This information is available on request from the employer and therefore it is not necessary to be on thelabel.



HICKMAN, P.: We do not necessarily agree with the substantiation provided by the submitter.

_______________________________________________________________________________________________70E-273 Log #405 EEW-AAA


70E-260The original proposal should have been accepted as submitted.

The additional requirements added by the committee without the proper submittal procedure should berejected. This new ad-hoc requirement will disrupt the orderly labeling process. It will make current labels obsolete withinsufficient notice. Safety people will hesitate in the future about investing in Arc Flash Hazard Analysis calculationsbecause the labels could be obsoleted without due code making processes.

The committee disagrees with the submitter's substantiation. The revisions to the labelingrequirement in the ROP stage have had adequate public review through the NFPA consensus process. See CommitteeComment 70E-248a (Log #CC7).



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70E-266I support the TC Committee’s “Accept in Part” with this proposal.

The requirement for keeping documentation for verification is correctly discarded.



HICKMAN, P.: We do not necessarily agree with the substantiation provided by the submitter and submit that it isinadequate substantiation for a comment as required by the regulations Governing Committee Projects.

_______________________________________________________________________________________________70E-275 Log #430 EEW-AAA


70E-260The committee should continue to Accept in Principle this proposal with the following change in the

committee action:Change“(1) Only one of the following:a. Available incident energyb. Minimum arc rating of clothing”To:“(1) Available incident energy or the minimum arc rating of clothing”.

The present committee action is awkward because it states “field marked with a label containing all ofthe following information”, and item number one is “ only one of the following”. This is better accomplished by stating“Available incident energy or the minimum arc rating of clothing”.




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_______________________________________________________________________________________________John McQuilkin, GE

70E-260Add new text as follows:

Informational Note: It is inappropriate to provide arc-flash hazard results/labels for system locations having fault dutieshigher than their overcurrent protective device’s momentary, interrupting, or withstand ratings, or the bus’ withstandrating, as greater hazard caused by failing equipment can exist.Informational Note: Overdutied overcurrent protective devices whose calculated fault duties are greater than their

momentary, interrupting, or withstand ratings, may fail closed while trying to open for a fault. Therefore, it is not possibleto calculate arc-flash results using the opening time of those protective devices, as the opening time needed by theequations is not provided by their manufacturer when they are applied above their rating.

See ROP 70E-497 and its latest ROC.

The committee concludes that an informational note related to overdutied protective devices isnot necessary. Engineering judgment is an important part of performing an incident energy analysis. It is not the intent ofthe committee to address work practices associated with installations that do not comply with NEC requirements.Applying an overcurrent protective device outside of its listing is contrary to 110.3(B) and 110.9 of the NEC as well asapplicable OSHA standard 1910.303(b)(4).



_______________________________________________________________________________________________70E-277 Log #407 EEW-AAA


70E-268The Informational Note should reflect the current revision of this standard, ANSI Z535.4-2007.

Draft mistakenly deleted "(or most current edition)" and left the outdated 1998 edition.

The committee action on Comment 70E-278 deletes the fine print note accepted by thecommittee action on Proposal 70E-268.



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The proposed Informational Note does not improve the usability of the standard.The existing marking requirement in NEC 110.16 is to warn of the hazard. As such, ANSI Z535.4 is appropriately

referenced in the NEC as in Informational Note. Review the NEC 2008 Handbook for an example of an ANSI Z535.4compliant label that meets the requirement of NEC 110.16.The labeling requirement in NFPA 70E is informational in nature. It complements the NEC 110.16 marking

requirement and contains information that is site and application specific. Therefore it does not necessarily have tocomply with the format requirements of ANSI Z535.4.In order for a label to comply with ANSI 535.4 it must include a properly formatted safety alert symbol, require selection

of one of four specific signal words (Danger, Warning, Caution, Notice), conform with the color schemes defined byANSI Z535.1, conform with the letter style, font and size, it must have specific message panel arrangements, etc.These formatting requirements may not be appropriate for field applied labels that are informational in nature.Taking the existing FPN located in NEC 110.16 and simply duplicating it in NFPA 70E will have unintended

consequences and will cause confusion about format requirements for arc flash information labels. This proposalshould be rejected.



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_______________________________________________________________________________________________Alan Manche, Square D Company/Schneider Electric

70E-235This proposal should have been accepted in principal:

Exception No. 3: Where the electrical system and associated arc flash hazard analysis is maintained under qualifiedengineering supervision, a new arc flash hazard incident energy analysis shall not be required where the equipment hasbeen field marked with a label containing the available incident energy or required level of PPE.(C) Equipment Labeling. Equipment shall be field marked with a label containing the available incident energy or

required level of PPEWhile at first glance the original proposal could be interpreted to mean that equipment labeling has

been removed, that is not the intent of the submitter or the true outcome of the proposal. In fact, the intent of thisproposal is to encourage field labeling only in situations where the labels add value to the electrical worker. If labels areapplied in uncontrolled environments the data is questionable at best and inaccurate at worst. If the information on thelabel can not be trusted, then the label has little or no value and possibly puts electrical workers at risk.The original proposal stated that “…a new arc flash hazard analysis shall not be required where the equipment has

been field marked with a label …”. However, because the field marking label contains information related to an incidentenergy analysis it would be more accurate to say “…a new incident analysis shall not be required where the equipmenthas been field marked with a label…”This exception is analogous to the existing 130.3 Exception No. 2 which allows the Tables to be used in lieu of an

incident energy analysis.Once accepted, the net result of this proposal would be to require a new analysis unless either (1) the tables are used

per the existing exception or (2) the equipment contains a field applied label indicating that an analysis has already beencompleted.This proposal lets electrical workers realize the potential benefits of field markings when they are located on equipment

in controlled environments. In addition, this proposal eliminates the present wording which mandates field applied labelsin all situations – including those where no controls exist to ensure that the information is accurate and up to date.It is recognized that the proposed changes to the content of the labels, as outlined in proposal 70E-260, will need to be

included in the newly proposed exception.

The committee rejects inclusion of an exception. As written, the proposed exception wouldexclude an installation from "a new arc flash incident energy analysis" simply because it has been field marked with alabel. The committee continues to include equipment labeling requirements. Arc flash hazard analysis updating isaddressed in 130.3.


TIEDE, T.: We continue to support the concept introduced in proposal 70E-235. The intent of the proposal andassociated comment 70E-279 is to encourage field marking in situations where the labels add value. It is recognizedthat there are facilities where qualified workers will be contracted to perform repairs (which includes equipment marking)yet they may never return after completion of the job. In these locations the information on the label that is left behindwill not be reviewed, audited or updated. Not only does such a label have little or no value, it possibly puts futureelectrical workers at risk. In addition, the committee statement indicates that even equipment that has been fieldmarked with a label is still subject to a new arc flash incident energy analysis. This is confusing as it was ourunderstanding that this is one of the primary values that labeling (in controlled environments) adds.


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70E-294Committee action should have been Reject.

The committee has not provided evidence that hearing protection is required for all employees anytime they are within the arc flash boundary. This will result in requiring hearing protection at very low risk situationswhen there is, in reality, no danger of overexposure to noise. EEI understands that the Technical Committee cannotquantify the level at which hearing protection is required. That is not an excuse for requiring it at all times.

The committee reaffirms the action taken on Proposal 70E-294. The evidence presented to thecommittee in Proposal 70E-391 during the 2009 revision cycle provided compelling evidence that hearing protection isneeded to protect workers from the sound levels that occur within the arc flash boundary.


HITTEL, M.: The appropriate action is accept. The action taken has additional risks that outweigh the potentialbenefits. The impact of this action is to protect against a possible hazard while reducing the alertness of the workerwhich elevates the overall risk.WILMER, K.: This comment should have been accepted. The committee has not provided evidence that hearing

protection is required for all employees any time they are within the arc flash boundary. This will result in requiringhearing protection at very low risk situations where there is, in reality, no danger of overexposure to noise. EEIunderstands that the technical committee cannot quantify the lower threshold for hearing protection but requiring it at alltimes is unnecessary.


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_______________________________________________________________________________________________Mark Rucker, Toyota Motor Mfg., Kentucky, Inc.


Section 130.3(C)(5) Hearing Protection. Employees shall wear hearing protection whenever within the arc flashboundary. underneath a flash suit hood or face shield,(Must also reconcile with Table 130.8(C)(16).)

First, the need for hearing protection at all arc flash levels is not substantiated by the proposers. Is itthe contention of the 70E Committee that switching a motor in a motor control center with covers on or reading a panelmeter while operating a meter switch (Category 0 tasks according to Table 130.8(C)(15)(1)) carries a real risk ofpermanently damaging the operator’s hearing?The lack of substantiation leads to a second problem, are ear canal inserts sufficient protection? The proposers cite

Annex K.4, ““The sounds associated with these [arc blast] pressures can exceed 160 dB.” OSHA standard1910.95(b)(2) Table G-1 reads, “Exposure to impulsive or impact noise should not exceed 140 dB peak sound pressurelevel.”(*) One ear canal insert in this writer’s possession is rated 30 dBA Noise Reduction ration (NRR). In OSHAdocument “Methods for Estimating HPD Attenuation (App IV:C)” the following statement is made, ”OSHA's experienceand the published scientific literature have shown that laboratory-obtained real ear attenuation for HPDs [HearingProtective Devices] can seldom be achieved in the workplace. To adjust for workplace conditions, OSHA stronglyrecommends applying a 50% correction factor when estimating field attenuation.”This means that under the condition cited by the proposer, 160dB or more sound levels, that ear canal inserts are

inadequate: 160dB – (30 NRR x 50%) = 145dB, which exceeds the 140dB limit set by OSHA. Of course the calculationof sound pressure levels with NRR is not this simple, plus we don’t know the effects of noise attenuation by the flash suithood or face shield, etc. One NIOSH study of impulse noise abatement at firing ranges(**) found peak noise levelsof150dB, which they corresponded to A-weighted levels of 122 dBA. The study also notes the difficulties with thesemeasurements: “spectral distribution of the impulse waveform is critical,” “Impulse noise behaves differently … becauseof the reverberation…,” etc.Third, the proposer cites no cases of permanent hearing loss due to arc flash events of any level.In the absence of substantiation and with the unknown adequacy of the protection required, I ask the committee to not

place unnecessary burden on workers to wear hearing protection when arc flash hazards are low, and instead tie its useto when arc-rated PPE is required (Category 1 and above). Also, investigation by third parties into the damaging effectsof low and high level arc flash events on hearing and how to properly protect workers should be encouraged by thecommittee.




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70E-260Revise the committee action in 130.3(C)(1)(b) by replacing "Minimum arc rating of clothing" with

"HRC."Providing the minimum arc rating of clothing as either available incident energy or minimum arc rating

of clothing is essentially providing the same information on this part of the label. One would need to at least meetincident energy available with an arc rating for the protective equipment. This would provide the information necessaryif incident energy calculations are performed for the selection of protective clothing. Providing the HRC in "b." wouldprovide the information necessary to select the protective equipment necesasry when incident energy calculations arenot performed.




_______________________________________________________________________________________________70E-283 Log #100 EEW-AAA


70E-271aAdd the words "or are flash boundary" after Limited Approach Boundary.

Document clarity.

The committee accepts the recommendation for correlation with the committee action onProposal 70E-199.



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70E-275aThe committee should continue to Reject this proposal.

The proposal, which was correctly rejected by the committee, would require establishing an electricallysafe work condition for any work within the Limited Approach Boundary of an uninsulated overhead line. Thisrequirement does not distinguish if the work within the Limited Approach Boundary is being performed by an unqualifiedperson performing non electrical work in close proximity to an uninsulated overhead line or is being performed byqualified line crews using insulated live line tools, insulated bucket trucks and insulated linemen’s gloves and sleevesand using special precautionary techniques for working on overhead lines. The proposed requirement can beinterpreted as requiring to deenergize an entire overhead line and to place it in an electrically safe work condition inorder to open a fused cutout (disconnect switch) with a voltage rated hotstick from an insulated bucket truck in order tode-energize a circuit tapped off the overhead line. The new embedded requirements in this section, which wassupposed to be a simple re-ordering of the sections, places undue restrictions on persons trained and familiar withworking on overhead lines and should continue to be rejected.



_______________________________________________________________________________________________70E-285 Log #97 EEW-AAA


70E-276Relocate 130.6 after 130.7.

Since much of the document is already being renumbered and relocated, relocate 130.6 so that it islocated after 130.7 [these are the section numbers from the ROP Draft] and renumber accordingly so that "Work Withinthe LAB of Uninsulated Overhead Lines" is located after "Other Precautions for Personnel Activities" for usability.

The committee relocates the recommendation as the last section of Article 130.The committee action meets the intent of the recommendation.



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_______________________________________________________________________________________________The Technical Correlating Committee modifies the title of this section for compliance with the NEC style

manual and for clarity. The Technical Correlating Committee directs that this section be titled as follows:“Work Within the Limited Approach Boundary of Uninsulated Overhead Lines”

Thomas A. Carpenter, ATA70E-276

The committee action should have been to reject the proposal.The title of this section is "130.6 (formerly 130.5) Work Within the Limited Approach Boundary of

Uninsulated Overhead Lines." The requirement being added is to have a qualified person determine if the lines areinsulated for the voltage the lines are operating at. This section is for uninsulated lines, so what is the qualified personchecking for since there is no insulation to check?

Some overhead lines contain a protective covering that is not rated for the operating voltage.This new requirement mandates that a qualified person must determine if the overhead lines are insulated for theoperating voltage.


BARRIOS, L.: The submitter makes a valid point that the placement of the new requirement to have a qualified personverify the insulation level appears to be incorrect since it is in the uninsulated overhead lines section of the Standard.CARPENTER, T.: The committee action should have been to accept this comment. We are setting up confusion

within the document when requiring the checking of insulation ratings when there is no insulation to check (hence thetitle ... Uninsulated Overhead Lines). The concern discussed during the meeting was that some lines have a weathercovering that can be confused with insulation. If this is truly the driver for this change, then the addition to the standardshould require the verification that any line covering be verified to be either an insulation system or a weather cover sothat appropriate safety measures can be used.GRAY, B.: The action should be to accept. The submitter is correct. If the lines are uninsulated, either bare or

covered, there is no reason to expose a qualified worker to a hazard unnecessarily. If there is a need to perform thistask, the requirement should be placed elsewhere in the document, not under the section dealing with uninsulatedconductors.NEITZEL, D.: I agree with the negative comments expressed by L. Barrios, T. Carpenter, and B. Gray and restate

them here - “The submitter makes a valid point that the placement of the new requirement to have a qualified personverify the insulation level appears to be incorrect since it is in the uninsulated overhead lines section of the Standard.”“The committee action should have been to accept this comment. We are setting up confusion within the document

when requiring the checking of insulation ratings when there is no insulation to check (hence the title ... UninsulatedOverhead Lines). The concern discussed during the meeting was that some lines have a weather covering that can beconfused with insulation. If this is truly the driver for this change, then the addition to the standard should require theverification that any line covering be verified to be either an insulation system or a weather cover so that appropriatesafety measures can be used.”“The action should be to accept. The submitter is correct. If the lines are uninsulated, either bare or covered, there is

no reason to expose a qualified worker to a hazard unnecessarily. If there is a need to perform this task, the requirementshould be placed elsewhere in the document, not under the section dealing with uninsulated conductors.”


HICKMAN, P.: The word “Uninsulated” should have been removed from the title for this section as discussed at theROC meeting. The requirements that follow should not include information that is not covered in the section.

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70E-276Suggest “Accepting in Principle” and rewording to improve grammar:

(B) A qualified person shall determine if the overhead electrical lines are insulated for the lines’ operating voltage thelines are operating at.

Editorial for grammar.



_______________________________________________________________________________________________70E-288 Log #321 EEW-AAA



I agree with Mr. Hamer the added text adds confusion to an already confusing process. TheCommittee statement in 70E-245 clearly states the Committee does not support combining of the two methods forselection of arc flash PPE.



HICKMAN, P.: We do not necessarily agree with the substantiation provided by the submitter and note that there wasnot a committee statement to Proposal 70E-245.

_______________________________________________________________________________________________70E-289 Log #432 EEW-AAA


70E-276The committee action should be Accept in Principle with the following modifications:

“(B) A qualified person shall determine if the overhead electrical lines are insulated for the voltage at which the linesare operating at.”

The proposed change is editorial and is suggested to improve grammar.




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70E-260Delete 130.5(C)(2).Date of the arc flash analysis.

There already is a requirement in 130.5 of the Draft for the arc flash analysis to be reviewed andupdated every 5 years. Requiring a date on each label will setup a situation where there will be labels with differentdates unless all of the labels are changed as conditions change. There is also a requirement in 130.5(C) for supportingdata for the analysis. If there is a question whether the information on an un-dated label is still accurate then thesupporting data can be checked. Having labels in the field with different dates will cause confusion. There is nojustification to require both.



HALE, L.: Requiring a date on the label will just add confusion, the committee action is correct.HICKMAN, P.: We do not necessarily agree with the substantiation provided by the submitter and note that 130.3 does

not require than an arc flash analysis be updated every 5 years.

_______________________________________________________________________________________________70E-291 Log #361 EEW-AAA


70E-283The committee action should have been to Accept in Part proposal 70E-283 with the following

action:(I) Anticipating Failure. When there is evidence that electric equipment could fail and injure employees, the electric

equipment shall be deenergized unless the employer can demonstrate that deenergizing introduces additional hazardsor increased hazards risk or is infeasible because of equipment design or operational limitation. Until the equipment isdeenergized or repaired, employees shall be protected from hazards associated with the impending failure of theequipment.

The submitter of 70E-283 is trying to clarify the difference between hazard and risk. As defined ininternational standards such as “ISO Guide 51 – Safety Aspects – Guidelines for their inclusion in standards” and “ISO31000 – Risk Management – Principles and Guidelines,” the terms hazard and risk are not the same and therefore mustbe identified separately:• A hazard is a potential source of harm.• Risk is the combination of the likelihood of occurrence of harm and the severity of that harm.In line with the above there may be one or more (i.e. additional) hazards, but hazards do not increase, rather, the risk

associated with the hazard(s) can increase (or decrease).Accepting the submitter’s proposal will bring NFPA 70E in line with internationally accepted terminology regarding





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70E-288The concept of this proposal should be changed to read as an exception and be added after the

FPN No.2 to 130.7(A):Exception: Enclosed and labeled equipment rated 600 volts and below that is in a normal operating condition shall not

require the use of personal and other protective equipment.Informational Note: Opening and closing a switching device that is applied within its published voltage,

continuous-current, and short-circuit ratings is considered a normal operating condition. An activity such as insertion orremoval of a starter or a circuit breaker from its cubicle, or opening enclosure doors or removing covers that expose liveparts, is not a normal operating condition.

See Mr. Hamer’s Comment on Affirmative in the ROP, which includes the above wording.

The committee accepts in principle the inclusion of a new Informational Note No. 2 to read:It is the collective experience of the Technical Committee on Electrical Safety in the Workplace that normal operation

of enclosed electrical equipment, operating at 600 volts or less, that has been properly installed and maintained byqualified persons is not likely to expose the employee to an electrical hazard.Relocate Informational Note No. 2 in the current text as Informational Note No. 3.

The recommendation to add the exception is rejected.The revised informational note meets the intent of the recommendation. The recommendation

to add the exception is rejected because the decision on whether to use personal protective equipment for any task isthe responsibility of the employer.


HITTEL, M.: The action should be accept. The language proposed by this comment gives detail and explanatorymaterial that is necessary to give context.NEITZEL, D.: I agree with the negative vote and comment by D. Pace. I also believe that the Committee statement

on Proposal 70E-288 is correct and that the Committee action on Comment 70E-292 is incorrect. This action will leadworkers to believe that no hazard exists and that PPE and/or protective clothing is not needed when operatingequipment. Unless this is verified by a hazard analysis it is just a guess and we should not provide protection, or in thiscase no protection, on a guess. Our purpose as a Technical Committee is to provide the best protection possible forworkers and not provide loop-holes for them to get around the requirements to protect themselves or for employers toprotect their employees.PACE, D.: This Comment should have been rejected. The Committee statement on Proposal 70E-288 is the

appropriate approach. This language will lead people to believe that arc flash PPE is not required in places where itshould be. To say that in every case that meets the wording in the committee action for this comment that the condition"is not likely to expose the employee to an electrical hazard" is wrong. It is not possible to describe a set of conditionsfor equipment that will be true in all cases. Equipment age, manufacturing defects, operating history, as examplespresent risks not mentioned in the committee action. The point is that in all cases a hazards analysis must beperformed in order to determine the hazards, and the risk, or likelihood that a person may be exposed to them. Theresults of this analysis is then used to determine if protective measures are required, and if so, what those are.


CARPENTER, T.: I am okay with the addition of a new IN. However, I am concerned that the 600V limitation sets upa conflict within the document. This new note is almost exactly like the last sentence in the existing note (FPN No. 1 in2009) under the definition of Arc Flash Hazard, except the existing note does not have the 600V disclaimer. As such, inone place we are saying that all electrical equipment that has been properly installed, etc. is not likely to be a hazardand in another place we are saying that only 600V and less equipment is not likely to be a hazard. The two notes needto be consistent, that is - delete the 600/v disclaimer in the new note so that the two notes match each other.HICKMAN, P.: We understand that the term “properly installed” means installed in accordance with the NEC. We

understand that the term “properly maintained” means maintained in accordance with manufacturers’ instructions or

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Report on Comments – June 2011 NFPA 70Econsensus standards. We understand that the term “normal operation” does not include manually reenergizing a circuituntil it has been determined that the equipment and circuit can be safely energized and that the repetitive manualreclosing of circuit breakers or reenergizing circuits through replaced fuses is prohibited.WIDUP, R.: Agree with committee action - this is an important informational note that helps add clarity and reduces

confusion for employees in the workplace who may or may not understand the interpretation and implications of the 70Erequirements.

_______________________________________________________________________________________________70E-293 Log #323 EEW-AAA



If electrical equipment is not maintained then it will not operate correctly or in timely manner. Thisimpacts the safety of personnel who have to interact with the electrical equipment. This requirement needs to be addedto Chapter 1 to reinforce the need for the requirements for Chapter 2. There is no requirement in Chapter 2 to performmaintenance on electrical equipment. The electrical equipment being referred to in the Proposal is the same electricalequipment mentioned in 205.1.

Locate the recommendation in Proposal 70E-287 as Section 205.3 General Maintenance Requirements. RelocateSection 205.3 in the ROP Draft to be 205.4 with the title "Overcurrent Protective Devices". Renumber remainder ofArticle 205 accordingly.Revise the first sentence of the recommendation to read:Electrical equipment shall be maintained in accordance with manufacturer's instructions or industry consensus

standards in good condition to reduce or eliminate the risk of failure and the subsequent exposure of employees toelectrical hazards. This requirement shall include the equipment environment, operation, components, attachments,extensions, and associated auxiliary equipment

This provision is more appropriately located in Article 205 and has been revised to includemandatory text and for clarity.


PACE, D.: This Comment should have been Accepted in Principle as revised by the Committee but not relocated toArticle 205. It should have been placed in Article 130 as suggested. There are no requirements in Chapter 1 thatequipment be maintained. Maintaining equipment is a safety related work practice. The way 90.3 is worded it can leada person to assume that Chapter 2 is not related to Chapter 1 and is not required. The vast majority of readers only useChapter 1. Putting a pointer in Chapter 1 to proper maintenance will direct the reader to Chapter 2 and make it clearthat proper maintenance is required.


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_______________________________________________________________________________________________Alan Manche, Square D Company/Schneider Electric

70E-288This proposal should have been accepted in principle and revised as follows:

130.6(L) Normal Operating Condition. The normal operation of 50-600 Volt enclosed equipment does not expose usersto a shock or arc flash hazard.Operation, Normal. Operation of enclosed electrical equipment that has not been altered and has been properly

installed, rated, and maintained. For purposes of this definition, altered equipment includes equipment with coversremoved to expose bare energized conductors or circuit parts or when work is being performed on or in the equipment.

The submitter’s intent is on target and plausible even if it needs adjustment, however, the committeehas not acted to address the submitter’s intent. Based on the voting comments of Mr. Weber and Mr. Hamer, theyrecognize the issue the submitter is attempting to address.NFPA 70E currently recognizes “routine opening and closing of circuits” in paragraph 130.6(J). FPN 1 found in the

definition of Arc Flash Hazard also recognizes that under normal operating conditions, enclosed energized equipmentthat has been properly installed and maintained does not pose an arc flash hazard.NFPA 70E currently fails to recognize that an unqualified person can and do interact safely with electrical systems.Examples include1) The lights being turned on in the office by office personnel using breakers marked “swd” in a panelboard2) The factory or warehouse worker turning on high bay lights using “HID” rated breakers as the “light switch” for that

facility3) The machine shop worker using a start-stop switch to toggle the power to a piece of equipment multiple times a day.4) The factory worker turning the safety-switch off on the control panel in order to bring the production line to a halt to

address a mechanical safety situation.5) HVAC maintenance person (electrically unqualified) that turns the “disconnect” off (breaker or switch) in order to

clean the coils, check the refrigerant, change the filter, etc. NFPA 70E may drive the owner of the HVAC company toinstruct his/her employees to keep the power “on” because the technicians are not electrically qualified. This may resultin unnecessary exposure to hazards such as rotating fans, etc.Numerous examples can be added to this list and supports a concern that without recognizing normal operating

conditions for unqualified persons, further safety issues may be created and an unnecessary burden is placed onbusiness without any safety basis.




HICKMAN, P.: See our explanation of affirmative on comment 70E-292.

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70E-289, 70E-290The technical committee actions for Proposals 70E-289 and 70E-290 should have been Accept in

Part with the following action:The committee accepts the part of the proposal to add a new sentence referencing a new PPE table:130.7(A) General. Employees working in areas where electrical hazards are present shall be provided with, and shalluse, protective equipment that is designed and constructed for the specific part of the body to be protected and for thework to be performed. A summary of the personal protective equipment required by this standard for electrical hazardsis found in Table 130.7(A).The committee accepts the part of the proposal identified in the proposal submission as “Option 3.”The committee correlates the action on this proposal with actions taken on 70E-294 and 70E-377.

This comment is submitted by the full CSA Z462 Workplace Electrical Safety Technical Committee.Problem: Finding information in the document regarding the selection of PPE for shock or arc flash protection can be

difficult as the information cannot be found in one location, nor is the information on PPE laid out in the document in alinear fashion. Many users of the NFPA 70E “reverse engineer” Table 130.7(C)(10) to acquire an arc flash PPE listrather than go section by section through the document. This practice is incorrect and inappropriate (Seehttp://www.nfpa.org/publicColumn.asp?categoryID=&itemID=40828&src=NFPAJournal)Solution: A table that lists all PPE requirements found in the document. The table does not establish any new

requirements; it simply provides a quick reference for users of the document to find the appropriate sections of thedocument when identifying PPE requirements.The CSA Z462 Workplace Electrical Safety Technical Committee feels that the committee statement that the

recommendation does not provide additional clarity is incorrect for the reasons stated.The CSA Z462 Workplace Electrical Safety Technical Committee feels that the Comment on Affirmative by Ms. Wilmer

that the material is appropriate for an Annex, but not as a requirement in the 70E standard is inaccurate as the materialdoes not establish any new requirements.

The committee continues to reject Proposals 70E-289 and 70E-290. This concept wasaccepted and is better suited as reference material in Annex H as revised by the action taken on Proposal 70E-522a.



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1 70E Log #124 Tbl 130.7(A) Rec A2011 ROC

Table 130.7(A) Personal Protective Equipment for Electrical Hazards

Shock Hazard Personal Protective Equipment Applicable Section(s)

Rubber insulating gloves; and Leather protectors (unless the requirements of ASTM F 496 are met)

130.7(C)6(a)

Rubber insulating sleeves (as needed) 130.7(C)6(a)

Class G or E hard hat (as needed) 130.7(C)3

Safety glasses or goggles (as needed) 130.7(C)4

Dielectric overshoes (as needed) 130.7(C)7

Arc Flash Hazard Personal Protective Equipment Applicable Section(s)

Incident Energy Exposures up to and including 1.2 calories/cm2

Clothing: non-melting or untreated natural fiber long sleeve shirt and long pants or coverall

130.7(C)1; 130.7(C)12(d)

Gloves: leather 130.7(C)6(b); 130.7(C)13(c)

Hard hat: class G or E 130.7(C)3

Faceshield: covers the face, neck and chin 130.7(C)3

Safety glasses or goggles 130.7(C)4; 130.7(C)13(b)

Hearing protection 130.7(C)x [See TC action on 70E-294]

Shoes or boots: heavy duty leather (as needed) 130.7(C)13(d)

Incident Energy Exposures > 1.2 calories/cm2

Clothing: arc-rated clothing system with an arc rating appropriate to the anticipated incident energy exposure

130.7(C)1; 130.7(C)2; 130.7(C)5; 130.7(C)12(d)

Clothing underlayers (when used): Arc-rated or non-melting untreated natural fiber

130.7(C)(12)(c); 130.7(C)14; 130.7(C)(15)

Gloves:

Exposures > 1.2 calories/cm and 8 calories/cm2: Heavy duty leather gloves (e.g. > 12 oz/yd2)

Exposures > 8 calories/cm2: Rubber insulating gloves with their leather protectors; or

Arc-rated gloves

130.7(C)6(b); 130.7(C)13(c)

Hard hat: class G or E 130.7(C)1; 130.7(C)3

Face shield:

Exposures > 1.2 calories/cm and 12 calories/cm2: Arc-rated faceshield that covers the face, neck and chin and an arc-rated

balaclava or an arc-rated arc flash suit hood

Exposures > 12 calories/cm2: Arc-rated arc flash suit hood

130.7(C)1; 130.7(C)3; 130.7(C)13(a); 130.7(C)13(b)

[See TC action on 70E-377]



Shoes or boots:

Exposures 4 calories/cm2: Heavy duty leather work shoes or boots (as needed)

Exposures > 4 calories/cm2: Heavy duty leather work shoes or boots

130.7(C)13(d)




The submitter has not provided substantiation that hearing protection is required for work at 50V. Justbecause there was documentation submitted that applied to the inclusion of the requirement in the tables for the 2009edition, does not means it applies generically. Where is the documentation that there is a noise hazard for the lowercategory arc flash scenarios?





_______________________________________________________________________________________________70E-297 Log #63 EEW-AAA



The committee has not provided evidence that hearing protection is required for all employees anytime they are within the arc flash boundary. This will result in requiring hearing protection at very low risk situations whenthere is, in reality, no danger of overexposure to noise. EEI understands that the Technical Committee cannot quantifythe level at which hearing protection is required. That is not an excuse for requiring it at all times.





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70E-294Reject the proposal in its entirety.

TC Committee Member Hittel’s comment is correct. This is no substantiation of the threshold ofhearing damage for an arc flash. There should be some research into prior injuries that could have been preventedbefore making this requirement.Many people have experienced an arc flash without permanent hearing loss. Overuse of PPE, like hearing protection,

can create additional hazards, such as not hearing a sudden verbal warning from a co-worker.





_______________________________________________________________________________________________70E-299 Log #423 EEW-AAA



Acceptance of this proposal is presenting another puzzle to the public with regards to the concussiveeffects of an arc blast. There is currently no method for determining the effect of arc flash explosion on hearing. Thestandards for assessing the need for hearing protection are based on decibel levels over time. It is inappropriate for thecommittee to set arbitrary levels without a method for validating these levels. The submitter has not providedsubstantiation for the requirements for hearing protection. There is no evidence that supports a one time noise exposurefrom an arc flash event produces any permanent hearing loss. This change will result in requiring hearing protection atvery low risk situations when there is, in reality, no danger of overexposure to noise.





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Acceptance of this proposal is presenting another puzzle to the public with regards to the concussiveeffects of an arc blast. There is currently no method for determining the effect of arc flash explosion on hearing. Thestandards for assessing the need for hearing protection are based on decibel levels over time. It is inappropriate for thecommittee to set arbitrary levels without a method for validating these levels. The submitter has not providedsubstantiation for the requirements for hearing protection. There is no evidence that supports a one time noise exposurefrom an arc flash event produces any permanent hearing loss. This change will result in requiring hearing protection atvery low risk situations when there is, in reality, no danger of overexposure to noise.





_______________________________________________________________________________________________70E-301 Log #276 EEW-AAA


70E-299Reject the proposal and restore the existing FPN, with the following editorial changes.

FPN: Such clothing can be provided as an arc-rated flash suit jacket and arc-rated flash suit pants, shirts and pants, oras coveralls, or as a combination of jacket and pants, or, for increased protection, as coveralls with jacket and pants.Various weight fabrics are available. Generally, the higher degree of protection is provided by heavier weight fabricsand/or by layering combinations of one or more layers of FR arc-rated clothing. In some cases, one or more layers of FRarc-rated clothing are worn over flammable, non-melting clothing.

The FPN is intended to be informational and provides good information for the user on FR clothing.(“FR clothing’ should be changed to “arc-rated” clothing in the FPN).

The committee reaffirms the committee action on Proposal 70E-299 and the deleted fine printnote is not needed because this information is already contained within the requirements of the standard.



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70E-300The Technical Correlating Committee directs the committee to correlate the action taken on this

proposal with the actions taken on Proposals 70E-372 and 70E-373.This is a direction from the Technical Correlating Committee on National Electrical Code® in


The committee accepts the direction of the Technical Correlating Committee to correlate theaction taken on Proposal 70E-300 with the action taken on Proposals 70E-372 & 70E-373. The committeeacknowledges that the action on Proposal 70E-300, 70E-372 and 70E-373 did not correlate, the action on Proposal70E-300 should have been to "accept in principle".



_______________________________________________________________________________________________70E-303 Log #394 EEW-AAA


70E-302Add a new first sentence to read as follows:

EH rates shoes shall be worn when individuals are working on energized electrical equipment or if a shock hazardexists where wearing them does not create an unsafe condition such as a person being a static electricity ignition sourcein hazardous locations.

Wearing EH rated shoes provides an additional level of safety at minimal cost. Section 130.4(C) [draft}still requires primary shock protection such as rubber gloves if the hands cross the RAB.

Add a new informational note as follows:EH (Electrical Hazard) shoes meeting ASTM F2413 can provide a secondary source of electric shock protection underdry conditions.

The committee rejects the recommendation to require EH shoes. The committee has includedan informational note to inform users of the standard of the additional benefits of EH footwear where used.


PACE, D.: This comment should have been an accept. Type EH shoes are currently required my many majoremployers in the US and is required in most areas of Canada. Most shoes worn by electrical people are already typeEH. Adding this requirement adds a level of safety and is not a burden on employers as most are already incompliance.


HICKMAN, P.: EH (Electrical Hazard) should be revised as Electrical Hazard (EH).

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70E-304The committee statement should have been to “The committee actions on Proposals 70E-305 and

70E-383 meets the intent of the recommendation.In the ROP Proposal 70E-304 was Accepted in Principle with the committee statement “The committee

action on Proposal 70E-305 meets the intent of the recommendation.” However, Proposal 70E-305 did not include theaddition of the following three standards to the Table 130.7(C)(8) as proposed in 70E-304:

Arc Flash Barriers:

In fact, these three standards were added to 130.7(F) by the committee action on Proposal 70E-383 so the committeestatement needs to include its action on 70E-383.



_______________________________________________________________________________________________70E-305 Log #383 EEW-AAA

_______________________________________________________________________________________________Hugh Hoagland, IV, ArcWear.com


***Insert Table here***

The committee accepted my proposal in principle and cited that Log #305 met my intent. This is notcomplete. I added some new standards which are not in Log #305. Please consider these additional standards as theyrelate to shock and arc flash and are not currently listed in the standard but are very useful in shock and arc flashprotection.Items underlined (as in my original proposal) are NEW and should be considered. I do support updating the year

numbers. I would also suggest we add a line above to indicate that these years are acceptable or the most currentversion of the standard. I have updated one other standard which came out since the ROP. ASTM F1506 has a 2010revision date which allowed for disposable arc rated garments for dirty applications.

The committee action on Proposal 70E-383 meets the intent of the recommendation. Thecommittee action on Proposal 70E-383 adds the reference documents to the proper table.



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1 70E_L383_Tbl_A2011ROC_R

Subject Number and Title

Head protection ANSI Z89.1, Requirements for Protective Headwear for Industrial Workers, 2003 2009

Gloves ASTM D 120, Standard Specification for Rubber Insulating Gloves, 2002a (R 2006) 2009

Sleeves ASTM D 1051, Standard Specification for Rubber Insulating Sleeves, 2007 2008

Gloves and Sleeves ASTM F 496, Standard Specification for In-Service Care of Insulating Gloves and Sleeves, 2006 2008

Footwear ASTM F 1117, Standard Specification for Dielectric Overshoe Footwear, 2003 (R2008)

ASTM F1116 - 03(2008) Standard Test Method for Determining Dielectric Strength of Dielectric Footwear

ASTM F 2412, Standard Test Methods for Foot Protection, 2005

ASTM F 2413, Standard Specification for Performance Requirements for Foot Protection, 2005 2008

Apparel ASTM F 1506, Standard Performance Specification for Textile Material for Wearing Apparel for Use by Electrical Workers Exposed to Momentary Electric Arc and Related Thermal Hazards, 2002a 2010

Face protective products

ASTM F 2178, Standard Test Method for Determining the Arc Rating and Standard Specification for Face Protective Products, 2006 2008

Fall protection ASTM F 887, Standard Specifications for Personal Climbing Equipment, 2005ae1

Dielectric Body Protection

ASTM F2677 Standard Specification for Electrically Insulating Aprons, 2008a

2 70E_L383_Tbl_A2011ROC_R

Dielectric Barriers ASTM D1048 Standard Specification for Rubber Insulating Blanket, 2005

ASTM F1742 - 03e1 Standard Specification for PVC Insulating Sheeting

Arc Flash Barriers ASTM F2676 Standard Test Method for Determining the Protective Performance of an Arc Protective Blanket for Electric Arc Hazards, 2009

ASTM F2522 - 05 Standard Test Method for Determining the Protective Performance of a Shield Attached on Live Line Tools or on Racking Rods for Electric Arc Hazards




***Insert Table 130.2(C) here

From http://www.nist.gov/ts/wmd/metric/upload/sd10final.pdf3.5 Soft conversion. A soft conversion is the process of changing a measurement from inch-pound units to equivalent

metric units within acceptable measurement tolerances without changing the physical configuration of the item.3.6 Hard conversion. A hard conversion is the process of changing a measurement from inch-pound units to

non-equivalent metric units which necessitates physical configuration changes of the item outside those permitted byestablished measurement tolerances. The term “hard conversion” is in general use in the United States, although it istechnically incorrect when applied to specific items because no “conversion” takes place. Instead, a new metric itemrequiring a new part identification is created to eventually replace the inch-pound version of the item. The new item isoften referred to as being in “hard metric.”

Where the actual measured size of a product is not the same as the nominal size, trade size 12designators shall be used rather than dimensions. Trade practices shall be followed in all cases.

Where material is extracted from another standard, the context of the original materialshall not be compromised or violated. Any editing of the extracted text shall be confined to making the style consistentwith that of the NEC.

Where industry practice is to express units in inch-pound units, the inclusion of SI unitsshall not be required.

Where hard conversion to SI would have a negative impact on safety.The conversion from inch-pound units to SI units shall be permitted to be an

approximate conversion.See Annex C for information on standard conversions.

For dimensions less than 1 m, the SI unit shall be expressed as mm. For dimensions from 1 m to lessthen 1 km, the SI units shall be expressed in m. For dimensions of 1 km or greater, the SI units shall be expressed askm.

See the committee action on Comment 70E-196.



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1 70E_L384_Tbl 130.2(C)_A2011ROC_R

Table 130.2(C) - Approach Boundaries to Energized Electrical Conductors or Circuit Parts for Shock Protection (All dimensions are distance from energized electrical conductor or circuit part to employee.)

(1) (2) (3) (4) (5)

Nominal System Voltage Range, Phase to Phase2

Limited Approach Boundary1 Restricted Approach Boundary1, Includes Inadvertent Movement Adder

Prohibited Approach Boundary1

Exposed Movable Conductor3

Exposed Fixed Circuit Part

Less than 50 Not specified Not specified Not specified Not specified

50 to 300 3.0 m (10 ft 0 in) 1 m (3 ft 6 in) Avoid contact Avoid contact

301 to 750 3.0 m (10 ft 0 in) 1 m (3 ft 6 in) 0.3 m (1 ft 0 in) 2.5 cm (0 ft 1 in)

15.1 kV to 36 kV Etc. Etc. Etc. Etc.

36.1 kV to 46 kV

46.1 kV to 72.5 kV

72.6 kV to 121 kV

138 kV to 145 kV

161 kV to 169 kV

230 kV to 242 kV

345 kV to 362 kV

500 kV to 550 kV

765 kV to 800 kV



70E-319Revise the last sentence of 130.7(C)(9) as follows: "The Hazard/Risk Category, protective

clothing..."See comment on affirmative for Proposal 70E-319 in the ROP.

The committee understands that the recommendation is to revise the next to the last sentencein the committee action to Informational Note No. 1 in Proposal 70E-319.



_______________________________________________________________________________________________70E-308 Log #239 EEW-AAA


70E-319If the original note is going to be broken apart, it should be done in such a manner as the original

information and intent remains. One suggestion is to break it into three pieces as shown below.Informational Note No.1: The hazard/risk category, work tasks, and protective equipment identified in Table

130.8(C)(15){1) were identified by a task group, and the hazard/risk category, protective clothing, and equipmentselected were based on the collective experience of the task group. The protective clothing and equipment are generallybased on determination of estimated exposure levels.In several cases, where the risk of an arc flash incident is considered low, very low, or extremely low by the task group,

the hazard/risk category number has been reduced by 1, 2, or 3 numbers, respectively.Informational Note No.2: The collective experience of the task group is that in most cases closed doors do not provide

enough protection to eliminate the need for PPE for instances where the state of the equipment is known to readilychange (e.g., doors open or closed, rack in or rack out). The premise used by the Task Group is considered to bereasonable, based on the consensus judgment of the full NFPA 70E Technical Committee.Informational Note No.3: The premise used by the Task Group in developing the criteria discussed in Informational

Note No.1 and Informational Note No.2 above is considered to be reasonable. based on the consensus judgment of thefull NFPA 70E Technical Committee.

Breaking the original note into two pieces as was done by the committee action on this proposalremoved some very relevant information from being applicable to Note 1 as it was only included with Note 2.

The committee action on Comment 70E-307 modifies the recommendation for InformationalNote No. 2.


HICKMAN, P.: We reaffirm the concern expressed in the balloting on proposal 70E-319 that it is unclear what taskgroup is being referred to in informational notes 2 and 3.


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70E-319Accept the editorial additions by the Committee Meeting Action associated with “Hazard/Risk

Category.” Do not accept the proposal to separate and create a second FPN. Keep the present FPN No. 1 as a singleFPN.

The existing FPN No. 1 describes what the task group did in originally creating the table and shouldnot be segregated into two separate FPNs.

The committee rejects the recommendation to consolidate the information into a single note.The committee action on Comment 70E-308 provides further clarity for the information

expressed in the informational notes. The committee does not concur that consolidation of the material into a singlenote provides more clarity.


HICKMAN, P.: This comment should have been accepted. Acceptance would have prevented the ambiguity createdby the committee action accepted in proposal 70E-319 and comment 70E-308.


_______________________________________________________________________________________________70E-310 Log #374 EEW-AAA

_______________________________________________________________________________________________Palmer L. Hickman, NJATC

70E-319Accept Proposal 70E-319 in Principle but modify the committee action by restoring all of the

content into one informational note rather than into two.While I do not necessarily have a specific issue with having two informational notes rather than one to

explain the origin of the protection in the HRC table, Informational Note 2 begins awkwardly by stating “The collectiveexperience of the task group is that. . .” It is unclear what task group the informational note is referring to. Restoring thisinformation back into one note would enhance clarity and usability.



HICKMAN, P.: See our explanation of negative on comment 70E-309.


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70E-319The committee action should continue to be Accept in Principle with the following modifications to

the committee action:Add the following sentence to the new FPN 1:“The premise used by the Task Group is considered to be reasonable, based on the consensus judgment of the full

NFPA 70E Technical Committee.”The committee action separated FPN No 1 into FPN No 1 and a new FPN No 2 in order to place

emphasis on the level of protection closed doors provided (or don’t provide) during arc flash events. The problem isthat the last sentence of the old FPN No 1 (and new FPN No 2) applied to the whole FPN. Now that the FPN’s havebeen split, the last sentence in FPN No 2 now must be repeated in FPN No 1.



HICKMAN, P.: This comment should have been accepted. See our explanation of negative on comment 70E-309.


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70E-337The committee action on ROP 70E-337 should have been Accept.

FPN No. 1: The work tasks and protective equipment identified in Table 130.7(C)(9) were identified by a task groupand the protective clothing and equipment selected was based on the collective experience of the task group. Theprotective clothing and equipment is generally based on determination of estimated exposure levels. In several caseswhere the risk of an arc flash incident is considered low, very low, or extremely low by the task group, the hazard/riskcategory number has been reduced by 1, 2, or 3 numbers, respectively. The collective experience of the task group isthat in most cases closed doors do not provide enough protection to eliminate the need for PPE for instances where thestate of the equipment is known to readily change (e.g., doors open or closed, rack in or rack out). A reduction in thehazard/risk category number is based on the assumption that the equipment is properly installed and maintained (seeArc Flash Hazard definition FPN No. 1). The premise used by the Task Group is considered to be reasonable, based onthe consensus judgment of the full NFPA 70E Technical Committee.

****Insert Table 130.7(C)(9) Here****

The committee statement rejecting the proposed addition to Section 130.7(C)(9) FPN No. 1 was asfollows:“There are multiple factors that are included in performing the risk assessment and it is not possible to enumerate all ofthe factors in this fine print note.”There may be multiple factors included in performing a risk assessment, however, proper installation and maintenancewere important enough risk factors that the Technical Committee included them in FPN No. 1 of the definition of ArcFlash Hazard:“Arc Flash Hazard. A dangerous condition associated with the possible release of energy caused by an electric arc.FPN No. 1: An arc flash hazard may exist when energized electrical conductors or circuit parts are exposed or whenthey are within equipment in a guarded or enclosed condition, provided a person is interacting with the equipment insuch a manner that could cause an electric arc. Under normal operating conditions, enclosed energized equipment thathas been properly installed and maintained is not likely to pose an arc flash hazard.”The importance of maintenance to risk reduction is also mentioned in 130.3 Exception No. 2 FPN No. 1:“FPN No. 1: Improper or inadequate maintenance can result in increased opening time of the overcurrent protectivedevice, thus increasing the incident energy.”Including this new sentence will harmonize with this practice and must be articulated for the protection of the workerusing the hazard/risk category method.

The committee reaffirms rejection of Proposal 70E-337. There are multiple factors including butnot limited to installation and maintenance in performing the risk assessment. It is the responsibility of qualified personsperforming a hazard risk evaluation to consider all factors associated with the installation. The committee also notes thatproper installation and maintenance is required for overcurrent protective devices in Section 130.3.



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70E_L127_Rec_ROC_A2011

Table 130.7(C)(9) Hazard/Risk Category Classifications and Use of Rubber Insulating Gloves and Insulated and Insulating Hand Tools

Tasks Performed on Energized Equipment Hazard/Risk

Category

Rubber Insulating

Gloves

Insulated and

Insulating Hand Tools

Panelboards or Other Equipment Rated 240 V and Below Parameters:

Maximum of 25 kA short circuit current available; maximum of 0.03 sec (2 cycle) fault clearing time; minimum 18 in. working distance

Potential Incident Energy using above parameters: 1.3 calories/ cm2 Potential Arc Flash Boundary using above parameters: 19 inches

-- -- --

Perform infrared thermography and other non-contact inspections outside the restricted approach boundary

0 N N

Circuit breaker (CB) or fused-switch operation with covers on 0 N N

CB or fused-switch operation with covers off 0 N N

Work on exposed energized electrical conductors and circuit parts, including voltage testing

1 Y Y

Remove/install CBs or fused switches 1 Y Y

Removal of bolted covers (to expose bare energized electrical conductors and circuit parts)

1 N N

Opening hinged covers (to expose bare energized electrical conductors and circuit parts)

0 N N

Work on exposed energized electrical conductors and circuit parts of utilization equipment fed directly by a branch circuit of the panelboard

1 Y Y

Panelboards or Switchboards Rated >240 V and up to 600 V (with molded case or insulated case circuit breakers) Parameters:

Maximum of 25 kA short circuit current available; Maximum of 0.03 sec (2 cycle) fault clearing time; Minimum 18 in. working distance


-- -- --


1 N N

CB or fused-switch operation with covers on 0 N N

CB or fused-switch operation with covers off 1 Y N


2* Y Y

Work on exposed energized electrical conductors and circuit parts of utilization equipment fed directly by a branch circuit of the panelboard or switchboard

2* Y Y

600 V Class Motor Control Centers (MCCs) Parameters:



-- -- --


1 N N

CB, fused-switch, or starter operation with enclosure doors closed 0 N N

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



Category

Rubber Insulating

Gloves

Insulated and


CB, fused-switch, or starter operation with enclosure doors open 1 N N


2* Y Y

Work on control circuits with exposed energized electrical conductors and circuit parts 120 V or below, exposed

0 Y Y

Work on control circuits with exposed energized electrical conductors and circuit parts greater than 120 V, exposed

2* Y Y

Application of safety grounds after voltage test 2* Y N


2* Y Y



Potential Incident energy using above parameters: 46.1 calories/ cm2 Arc Flash Protection Boundary using above parameters: 165 inches

Insertion or removal of individual starter “buckets” from MCC 4 Y N

Removal of bolted covers (to expose bare, energized electrical conductors and circuit parts)

4 N N

Opening hinged covers (to expose bare, energized electrical conductors and circuit parts)

1 N N

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

Maximum of 35 kA short circuit current available; Maximum of up to 0.5 sec (30 cycle) fault clearing time; Minimum 18 in. working distance

Potential Incident Energy using above parameters: 52.5 calories/ cm2 Potential Arc Flash Protection using above parameters: 233 inches

-- -- --


2 N N

CB or fused-switch operation with enclosure doors closed 0 N N


CB or fused-switch operation with enclosure doors open 1 N N


2* Y Y


0 Y Y


2* Y Y

Insertion or removal (racking) of CBs from cubicles, doors open or closed 4 N N



4 N N

Opening of hinged covers (to expose bare energized electrical conductors and circuit parts)

2 N N

Other 600 V Class (277 V through 600 V, nominal) Equipment Parameters:

Maximum of 65 kA short circuit current available; Maximum of 0.03 sec (2 cycle) fault clearing time; Minimum 18 in. working distance (except as

-- -- --



Category

Rubber Insulating

Gloves

Insulated and


indicated) Potential Incident Energy using above parameters: 7.1 calories/ cm2 Potential Arc Flash Boundary using above parameters: 53 inches

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


2* N N

Opening to hinged covers (to expose bare energized electrical conductors and circuit parts)

1 N N


2* Y Y


Revenue meters (kW-h at primary voltage and current) — — —

Insertion or removal 2* Y N

Cable trough or tray cover removal or installation 1 N N

Miscellaneous equipment cover removal or installation 1 N N

Work on energized electrical conductors and circuit parts, including voltage testing 2* Y Y


Insertion of or removal of plug-in devices into or from busways 2* N N

NEMA E2 (fused contactor) motor starters, 2.3 to 7.2 kV Parameters:

Maximum of 35kA short circuit current available; Maximum of up to 0.2 sec (12 cycle) fault clearing time; Minimum 36 in. working distance

Potential Incident energy using above parameters: 41 calories/ cm2 Potential Arc Flash Protection using above parameters: 422 inches


3 N N

Contactor operation with enclosure doors closed 0 N N


Contactor operation with enclosure doors open 2* N N


4 Y Y


0 Y Y


3 Y Y

Insertion or removal (racking) of starters from cubicles, doors open or closed 4 N N

Application of safety grounds after voltage test 3 Y N


4 N N


3 N N

Insertion or removal (racking) of starters from cubicles of arc-resistant construction, tested in accordance with IEEE C37.20.7, doors closed only

0 N N

Metal-clad switchgear, 1 to 38 kV Parameters:




Category

Rubber Insulating

Gloves

Insulated and


Incident energy using above parameters: 41 calories/ cm2 Arc Flash Protection using above parameters: 422 inches


3 N N

CB operation with enclosure doors closed 2 N N


CB operation with enclosure doors open 4 N N


4 Y Y


2 Y Y


4 Y Y




4 N N


3 N N

Opening of voltage transformer or control power transformer compartments 4 N N

Arc-resistant switchgear Type 1 or 2 (for clearing times of less than 0.5 s, with a protective fault current not to exceed the arc-resistant rating of the equipment) Parameters:



CB operation with enclosure door closed 0 N N

Insertion or removal (racking) of CBs from cubicles, doors closed 0 N N

Insertion or removal of CBs from cubicles with door open 4 N N

Work on control circuits with energized conductors and circuit parts 120 V or below, exposed

2 Y Y

Insertion or removal (racking) of ground and test device with door closed 0 N N

Insertion or removal (racking) of voltage transformers on or off the bus, door closed

0 N N

Other equipment 1 to 38 kV Parameters:



Metal-enclosed interrupter switchgear, fused or unfused — — —

Switch operation of arc-resistant type construction, tested in accordance with IEEE C37.20.7, doors closed only

0 N N

Switch operation, doors closed 2 N N

Work on exposed energized electrical conductors and circuit parts, including 4 Y Y



Category

Rubber Insulating

Gloves

Insulated and


voltage testing


4 N N


3 N N

Outdoor disconnect switch operation (hookstick operated) 3 Y Y

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

Insulated cable examination, in manhole or other confined space 4 Y N

Insulated cable examination, in open area 2 Y N

General Notes (applicable to the entire table):

(a) Rubber insulating gloves are gloves rated for the maximum line-to-line voltage upon which work will be done.

(b) Insulated and insulating hand tools are tools rated and tested for the maximum line-to-line voltage upon which work will be done, and are manufactured and tested in accordance with ASTM F 1505, Standard Specification for Insulated and Insulating Hand Tools.

(c) Y = yes (required), N = no (not required).

(d) For systems rated less than 1000 volts, the fault currents and upstream protective device clearing times are based on an 18 in. working distance the Incident Energy and the Arc Flash Boundary values were determined using the IEEE 1584 method, a working distance of 18 inches, and the parameters specified in each section. For Panelboards and MCC equipment the arc gap used was 25 mm. For Switchgear the arc gap used was 32 mm. The protective device type was 0 (other) and the ground type was ungrounded for all equipment.

All calculated values have been rounded up to the nearest whole number.

(e) For systems rated 1 kV and greater, the Hazard/Risk Categories are based on a 36 in. working distance the Incident Energy and the Arc Flash Boundary was determined by using the IEEE 1584 method and the following information:

A maximum fault clearing time of 0.2 seconds was selected by adding the typical maximum total clearing time of the circuit breaker to an estimated value for relay operation. This coincides with the IEEE 1584 values of 0.18 second operating time and 0.08 tripping time rounded off.

A maximum 35kA short circuit current was selected to coincide with the required minimum arc rating of the clothing specified for Hazard/Risk Category 4.

Working distance used was (909mm) 36”, the arc gap was (455mm) 6”, the protective device type 0 (other) and the ground type was ungrounded for all calculations.


(f) For equipment protected by upstream current limiting fuses with arcing fault current in their current limiting range (1⁄2 cycle fault clearing time or less), the hazard/risk category required may be reduced by one number. Specific Notes (as referenced in the table): 1. Maximum of 25 kA short circuit current available; maximum of 0.03 sec (2 cycle) fault clearing time. 2. Maximum of 65 kA short circuit current available; maximum of 0.03 sec (2 cycle) fault clearing time. 3. Maximum of 42 kA short circuit current available; maximum of 0.33 sec (20 cycle) fault clearing time. 4. Maximum of 35 kA short circuit current available; maximum of up to 0.5 sec (30 cycle) fault clearing time.



70E-338This Proposal should have been accepted.

More consideration should be given to this recommendation. The more information employers areprovided the better decisions they can make in protecting their employees.

The committee reaffirms its action on Proposal 70E-338. The submitter has not provided anyadditional substantiation to support changing the H/R categories for these tasks.


PACE, D.: This Comment should have been Accepted. Providing information to employers allows them to makebetter decisions.


_______________________________________________________________________________________________70E-314 Log #339 EEW-AAA


70E-336This proposal should be accepted and table 130.7( C) (9) should be revised as recommended in

proposal 70E -317The statement by the TC that the current text provides recognition of the risk assessment element that

is a component of the tasks included in the tables is vague without any defensible basis. There is no technicaljustification provided by TC to support reduction of protection when risk of arc flash incident is considered low, very low,or extremely low. If there is actual data to support this then same reduction should be allowed when incident energy iscalculated. It should be clearly indicated where such reduction has been made in the table and why? What factors wereconsidered in establishing this reduction has not been explained. What level of reduction can be made when incidentenergy is calculated for the same equipment?Risk= Frequency x consequences and reduction of frequency does not reduce the consequences. The consequence

will be the same when a low probability event occurs. Arc flash hazard, incident energy, is based on arcing current andovercurrent device clearing time. These do not change whether the arc flash incident is low, very low or extremely low.The protective clothing and equipment is based on exposure level not on probability of incident By this approach we areunder protecting the worker exposed to a possible arc flash incident.

The committee reaffirms rejection of Proposal 70E-336. The current text provides recognition ofthe risk assessment element that is a component of the tasks included in the tables.



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70E-338The Committee Action on the proposal to should have been Accept in Part with the accepted “Part”

being that only tasks in Table 130.7(C)(9) which had the associated HRC level reduced by 3 numbers are changed to anHRC level reduction of 2 numbers. Tasks reduced by 1 and 2 numbers are not modified. In Proposal 70E-338,essentially all tasks for which there had been a reduction of the HRC level by 1, 2 or 3 numbers were changed byadding +1 to the HRC level. In the attached modified Table 130.7(C)(9), this moderated approach results in nine tasksfor which the HRC level had been reduced the 3 numbers being modified by +1 number instead of the 41 tasks forwhich the HRC had been increased by +1 number in the initial proposal 70E-338. Of the nine tasks for which the HRClevel has been increased by +1, seven of these are HRC 0 tasks increased to HRC 1 and two are HRC 1 tasksincreased to HRC 2. Several HRC0 tasks involving “CB or fused switch or starter operation with enclosure doorsclosed” and “Reading a panel meter while operating a meter switch” and “Work on control circuits with energizedelectrical conductors and circuit parts 120 V or below, exposed” listed under 600V Class Switchgear, NEMA E2 MotorStarters, 2.3 kV to 7.2 kV, and Metal Clad Switchgear, 1 kV to 38 kV have not been modified from HRC 0 due to thenature of these tasks. In the current 2009 Edition Table 130.7(C)(9), these tasks have had their HRC level reduced by 4numbers, i.e. reduced from HRC 4 to HRC 0.The FPN text would be modified as previously proposed:

130.7(C)(9) FPN No. 1: The work tasks and protective equipment identified in Table 130.7(C)(9) were identified by atask group and the protective clothing and equipment selected was based on the collective experience of the task group.The protective clothing and equipment is generally based on determination of estimated exposure levels.In several cases where the risk of an arc flash incident is considered low, or very low, or extremely low by the task

group, the hazard/risk category number has been reduced by 1 or 2, 2, or 3 numbers, respectively. The collectiveexperience of the task group is that in most cases closed doors do not provide enough protection to eliminate the needfor PPE for instances where the state of the equipment is known to readily change (e.g., doors open or closed, rack in orrack out). The premise used by the Task Group is considered to be reasonable, based on the consensus judgment ofthe full NFPA 70E Technical Committee.Modify Table 130.7(C)(9) as follows:

****Insert Table 130.7(C)(9) Here****

The Committee Statement indicated a lacking in the substantiation for Proposal 70E-338. First, itneeds to be stated that there is no technical justification for reducing the HRC level by 3 numbers. This reduction of 3numbers has been based on a judgment that the risk of an arc flash incident is extremely low, but the risk of an arc flashis not zero, and the incident energy level of an arc flash is not reduced regardless of the extremely low level of risk ofoccurrence of an arc flash incident. As further substantiation, regarding the IEEE paper that was submitted withProposal 70E-338 (and is resubmitted with this comment), the specific cases cited for worker injury in arc flash incidentdue to selection of clothing based NFPA 70E Table 130.7(C)(9), the following arc flash incidents from the paper arenoted.Incident 17A (Date of incident is 2006 so the 2004 Edition of NFPA 70E is applicable): The worker used HRC1protection per NFPA 70E, 2004 Edition, for 600V Class Switchgear. The task was “Fused switch operation withenclosure doors open.” The incident energy was determined to be 26 cal/cm2 which falls well within expected exposureincident energy based on Note 5 (2004 Edition) short circuit current maximum of 35 kA and the clearing time maximumof 30 cycles.For Incident 17A, all footnote conditions for Table 130.7(C)(9) in NFPA 70E, 2004 Edition were met in selecting HRC1

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of 4 70E_Log #128_Rec A2011 ROC


Tasks Performed on Energized Equipment Hazard/ Risk

Category

Rubber Insulating

Gloves

Insulated and


Panelboards or Other Equipment Rated 240 V and Below — Note 1 Perform infrared thermography and other non-contact inspections outside the restricted approach boundary

0

N

N

Circuit breaker (CB) or fused switch operation with covers on 0 N N CB or fused switch operation with covers off 0 N N Work on energized electrical conductors and circuit parts, including voltage testing

1 Y Y

Remove/install CBs or fused switches 1 Y Y Removal of bolted covers (to expose bare, energized electrical conductors and circuit parts)

1 N N


0 N N

Work on energized electrical conductors and circuit parts of utilization equipment fed directly by a branch circuit of the panelboard

1

Y

Y

Panelboards or Switchboards Rated >240 V and up to 600 V (with molded case or insulated case circuit breakers) — Note 1


1

N

N

CB or fused switch operation with covers on 0 N N CB or fused switch operation with covers off 1 Y N Work on energized electrical conductors and circuit parts, including voltage testing

2* Y Y

Work on energized electrical conductors and circuit parts of utilization equipment fed directly by a branch circuit of the panelboard or switchboard

2*

Y

Y


600 V Class Motor Control Centers (MCCs) — Note 2 (except as indicated)


1 N

N

CB or fused switch or starter operation with enclosure doors closed 0 N N Reading a panel meter while operating a meter switch 0 N N CB or fused switch or starter operation with enclosure doors open 2 N N Work on energized electrical conductors and circuit parts, including voltage testing

2* Y Y

Work on control circuits with energized electrical conductors and circuit parts 120 V or below, exposed

0 Y Y

Work on control circuits with energized electrical conductors and circuit parts >120 V, exposed

2* Y Y

Insertion or removal of individual starter “buckets” from MCC — Note 3

4 Y N

Application of safety grounds, after voltage test 2* Y N Removal of bolted covers (to expose bare, energized electrical conductors and circuit parts) — Note 3

4

N N

Opening hinged covers (to expose bare, energized electrical conductors and circuit parts) — Note 3

1 2 N N

Work on energized electrical conductors and circuit parts of utilization equipment fed directly by a branch circuit of the motor control center

2*

Y

Y

600 V Class Switchgear (with power circuit breakers or fused switches) — Notes 4


2

N

N

CB or fused switch operation with enclosure doors closed 0 N N Reading a panel meter while operating a meter switch 0 N N CB or fused switch operation with enclosure doors open 1 2 N N Work on energized electrical conductors and circuit parts, including voltage testing

2* Y Y


0 Y Y


2* Y Y

Insertion or removal (racking) of CBs from cubicles, doors open or closed]

4

N N

Application of safety grounds, after voltage test 2* Y N Removal of bolted covers (to expose bare, energized electrical conductors and circuit parts)

4

N N


2 N N


Other 600 V Class (277 V through 600 V, nominal) Equipment — Note 2 (except as indicated)

Lighting or small power transformers (600 V, maximum) — — — Removal of bolted covers (to expose bare, energized electrical conductors and circuit parts)

2* N N


1 N N

Work on energized electrical conductors and circuit parts, including voltage testing

2* Y Y

Application of safety grounds, after voltage test 2* Y N Revenue meters (kW-hour, at primary voltage and current) Insertion or removal

2* Y N

Cable trough or tray cover removal or installation 1 N N Miscellaneous equipment cover removal or installation 1 N N Work on energized electrical conductors and circuit parts, including voltage testing

2* Y Y

Application of safety grounds, after voltage test 2* Y N Insertion or removal of plug-in devices into or from busways 2* Y N NEMA E2 (fused contactor) Motor Starters, 2.3 kV Through 7.2 kV Perform infrared thermography and other non-contact inspections outside the restricted approach boundary

3

N

N

Contactor operation with enclosure doors closed 0 1 N N Reading a panel meter while operating a meter switch 0 N N Contactor operation with enclosure doors open 2* N N Work on energized electrical conductors and circuit parts, including voltage testing

4

Y Y


0 Y Y


3 Y Y

Insertion or removal (racking) of starters from cubicles, doors open or closed

4

N N

Application of safety grounds, after voltage test 3 Y N Removal of bolted covers (to expose bare, energized electrical conductors and circuit parts)

4 N N


3 N N


0 1 N

N


Metal Clad Switchgear, 1 kV Through 38 kV Perform infrared thermography and other non-contact inspections outside the restricted approach boundary

3

N

N

CB operation with enclosure doors closed 2 N N Reading a panel meter while operating a meter switch 0 N N CB operation with enclosure doors open 4 N N Work on energized electrical conductors and circuit parts, including voltage testing

4 Y Y


2 Y Y


4 Y Y

Insertion or removal (racking) of CBs from cubicles, doors open or closed

4 N N

Application of safety grounds, after voltage test 4 Y N Removal of bolted covers (to expose bare, energized electrical conductors and circuit parts)

4 N N


3 N N

Opening voltage transformer or control power transformer compartments 4 N N Arc Resistant Switchgear Type 1 or 2 (For clearing times of <0.5 sec with a perspective fault current not to exceed the Arc Resistant rating of the equipment)

CB operation with enclosure door closed 0 1 N N Insertion or removal (racking) of CBs from cubicles, doors closed 0 1 N N Insertion or removal of CBs from cubicles with door open 4 N N Work on control circuits with energized electrical conductors and circuit parts 120 V or below, exposed

2 Y Y

Insertion or removal (racking) of ground and test device with door closed 0 1 N N Insertion or removal (racking) of voltage transformers on or off the bus door closed

0 1 N N

Other Equipment 1 kV Through 38 kV Metal-enclosed interrupter switchgear, fused or unfused Switch operation of arc-resistant type construction, tested in accordance with IEEE C37.20.7, doors closed only

0 1 N

N

Switch operation, doors closed 2 N N Work on energized electrical conductors and circuit parts, including voltage testing

4 Y Y


4 N N


3 N N

Outdoor disconnect switch operation (hookstick operated) 3 Y Y Outdoor disconnect switch operation (gang-operated, from grade)

2 Y

N

Insulated cable examination, in manhole or other confined space 4 Y N Insulated cable examination, in open area 2 Y N

Report on Comments – June 2011 NFPA 70EPPE, but the actual exposure required HRC4 PPE. The practice of reducing the HRC level by 3 numbers caused theworker’s burn injuries to be more severe.As additional substantiation, it is important to note that out that seven HRC0 tasks increased to HRC1, six of these tasksinvolve arc resistant gear. Arc resistant gear is tested with doors closed for ignition of a specific test fabric positioned inproximity of the gear. This fabric ignition test represents an exposure in the range 4 cal/cm2. Consequently, workerswith an HRC0 level of protection will receive burns to their unprotected skin, i.e. face and hands in the event of an arcflash. These six HRC0 tasks involving arc resistant gear have been increased to HRC1 to avoid face and hand burninjuries.Note: Supporting material is available for review at NFPA Headquarters.

See the committee action and statement on Comment 70E-313. Additionally, see thecommittee action and statement on Comment 70E-340.


PACE, D.: See my comment on Comment 70E-313.


_______________________________________________________________________________________________70E-316 Log #325 EEW-AAA


70E-333This Proposal should have been Accepted in Part. Accept moving the recommended sections and

tables to an Annex as submitted. Reject the remainder of the proposal.Having these Tables within the body of the text implies they are mandatory. The methods for

calculating the arc flash hazard are in an Annex and thus the impression is they are not required. By moving the Tablesto an Annex will provide a balanced emphasis on the methods that can be used. If the Tables are not mandatory thenthey should not be in the body of the text but in an Annex. Section 3.3.6.1 of the Regulations Governing CommitteeProjects states “Nonmandatory provisions shall be located in an appendix or annex, footnote, or fine-print note and arenot to be considered a part of the requirements of a standard.”



PACE, D.: This Comment should have been Accepted. The information should be relocated to the Annex asrecommended. The Committee states that a hierarchy has not been established. However, by allowing the Tables toremain within the body of the text, it has established a hierarchy. The Table method becomes the preferred method andthe wording in 90.3 reinforces this perception. It is inappropriate for the Committee to hold one method above theothers.


200Printed on 1/19/2011




The action will require use of balaclava for Hazard Risk Category 2 work. Use of hard hat and faceshield alone will not be allowed. Hard hat and face shield have been known to provide adequate protection alone.Requiring the use of a balaclava under the hard hat for this work is unnecessary. HRC 2* should be retained soemployees can continue to wear hard hat and face shield alone for HRC2 and hard hat/face shield/balaclava for higherrisk HRC 2* work.

The committee notes that the action on Proposal 70E-335 was to reject. The substantiation isinconsistent with the intent of Proposal 70E-335.



BARRIOS, L.: The action taken on this comment is unclear. The committee statement acknowledges thesubstantiation is not consistent with the action taken on proposal 70E-335. It appears that the submitter has incorrectlyreferenced proposal 70E-335. Therefore the proper action on this comment probably should have been to rejectbecause the submitter's recommendation was unclear.HICKMAN, P.: We not necessarily agree with all of the substantiation of the submitter.

_______________________________________________________________________________________________70E-318 Log #29 EEW-AAA


70E-320It was the action of the Technical Correlating Committee that the action taken on this proposal be



The committee accepts the direction of the Technical Correlating Committee to correlate theactions on Proposals 70E-320 and 70E-331. Correlation is achieved through the actions on Comments 70E-329 and70E-341.



201Printed on 1/19/2011



70E-272Reject the proposed change.

The operation of “racking” does not expose workers to a shock hazard, but only to an arc-flash hazard,and the requirement to use insulating rubber gloves is the wrong application of the PPE. Either arc-rated gloves, orinsulating rubber gloves with leather protectors could be used to afford the protection.


PACE, D.: This comment should have been a reject. If a fault occurs while racking, current will flow through anyconductor that is available. If current flows through a conductor, and a person is in contact with that conductor, theybecome a parallel path for the current. If the fault current is high enough, the person can be exposed to significantshock hazards. Step and touch potential protection is addressed in several places in the 70E standard and this isanother area where it should be. The belief that a person would not be exposed to shock hazards in this case isincorrect.


HICKMAN, P.: We not necessarily agree with all of the substantiation of the submitter.

_______________________________________________________________________________________________70E-320 Log #277 EEW-AAA


70E-308This proposal should have been “Accepted in Part.”

The heading should read: “Panelboards, Switchboards, or Other Equipment Rated >240 V and up to 600 V (withmolded ease or insulated case circuit breakers) – Note 1”

Accept the part to add “Other Equipment,” since the category may apply to equipment that is fed bybranch circuits. Do not accept the deletion of “(with molded ease or insulated case circuit breakers),” since it is importantto distinguish these type of devices, which tend to be current-limiting or introduce significant arc impedance during theinterruption process, from other types of protective devices applied at voltages greater than 240 volts and up to 600volts. For “Panelboards or Other Equipment Rated 240 V and Below,” it is not important to designate “molded case orinsulated case circuit breakers” for that category.

The committee reaffirms acceptance of Proposal 70E-308. The type of device used is limited bythe amount of available short circuit current and clearing time. Other current limiting devices such as fuses with aclearing time as listed the table would be permitted.



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70E-309Reject the proposal and restore the original content. The Committee Statement should not refer to

the action on Proposal 70E-331 as meeting the intent. This statement is too vague.Annex Table D.9.2 is informative and not a requirement. There are calculation techniques other than

IEEE Std 1584. Table 130.7(C)(9) is presently used for applications 2.3 kV through 38 kV (i.e., operating voltages lowerthan 5 kV and greater than 15 kV) and these voltage ratings are common and valid, and the tables are now being usedsuccessfully for these applications. There was no evidence or substantiation submitted to the contrary in the proposal.The committee unnecessarily constrained the application of this existing category without justification.

The committee reaffirms the inclusion of specific notes to limit available short circuit current andclearing times. The submitter did not provide technical substantiation to allow higher values or no limits of available shortcircuit current or longer clearing times.


BARRIOS, L.: One of the submitter's concerns not addressed by the committee's statement is the reduction in the38kV limit in MV switchgear voltage ratings to 15kV, which was one of the recommended changes in proposal 70E-309.


_______________________________________________________________________________________________70E-322 Log #279 EEW-AAA


70E-315Accept the proposal to make the heading an note read:

Panelboards or Other Equipment Rated 240 V and Below - Notes 1 and 55. For < 10 kA short-circuit current available, the hazard/risk category may be reduced by one number.

This proposal should be accepted, with correction to the original proposed note of the “less than”symbol before 10 kA. See my comment on Proposal 70E-224 for substantiation of this comment.

The recommendation is in conflict with information contained in the standard relative to incidentenergy levels at less than 10 kA.



BARRIOS, L.: The committee statement is vague and does not adequately address the submitter's recommendation.

203Printed on 1/19/2011



70E-316Delete the word “temporary” that was inserted by the Committee Meeting Action.

Add the following definition to Article 100, Definitions, from ASTM F 855-04: “Devices installed temporarily on de-energized electric power circuits for the purposes of potential equalization and toconduct a short circuit current for a specified duration (time).”

The addition of “temporary” by the Committee Meeting Action is redundant and should be deleted.The added definition was included in Mr. Hamer’s Comment on Affirmative, included with the ROP.

The addition of a new definition does not provide additional clarity or usability. The word“temporary” is added to differentiate between permanent grounding of the system and temporary protective grounds.



_______________________________________________________________________________________________70E-324 Log #64 EEW-AAA


70E-331Committee action should have been Accept in Part.

EEI supports the concept of the tables but there are number of technical issues. The tables list taskswith HRC = 0 and Arc Flash Boundary equals zero inches. HRC = 0 means there are PPE requirements for this workinside the arc flash boundary. But arc flash boundary equals zero has no meaning. These tasks should be deleted fromthe table. The table should include an explanation of the expectation when arc flash boundary is less than arms’ length.Does that mean you need protection for the hands but not the torso? Does that mean that hearing protection and headprotection is not required since the head is outside the arc flash boundary? The table includes requirements forequipment that is above 15 kv. But the IEEE 1584 method is known not to be accurate above 15 kv. The table shouldinclude a note indicating that calculations above 15 kv may not be accurate or delete all tasks above 15 kv.

The recommendation does not provide specific recommended text. The comment does notcomply with 4.4.5 of the NFPA Regulations Governing Committee Projects. See the committee action on Comment70E-342.



204Printed on 1/19/2011



70E-320Reject the proposal.. Restore the table’s content for this section to that of the 2009 Edition.

Table 130.7(C)(9) is now being used successfully for applications through 38 kV and these voltageratings are common and valid for Table 130.7(C)(9). There was no evidence submitted in the substantiation to thecontrary. IEEE Std 1584 is not well developed enough even at 15 kV to designate the proposed fault-current andclearing time values as requirements, and it is not the only method for calculating incident energy. No justification byfield experience for this change has been submitted. Reduction to the values of the proposed notes 5 and 6 would makethe table virtually unusable for these equipment applications, where Table 130.7(C)(9) has been used safely since itsintroduction in prior editions of NFPA 70E. Also see my Public Comment for Proposal 70E-309.



BARRIOS, L.: One of the submitter's concerns not addressed by the committee's statement is the reduction in the38kV limit in MV switchgear voltage ratings to 15kV, which was one of the recommended changes in proposal 70E-309.


_______________________________________________________________________________________________70E-326 Log #283 EEW-AAA



The calculation procedures to determine the incident energy are in a constantly changing environment,and the proposal only includes IEEE Std 1584 methodology, which is only one approach. The proposal adds verydetailed and precise information to the table which would lead the user to the conclusion that the procedure for arc-flashincident energy calculation is proven science. It is not.




205Printed on 1/19/2011



70E-331Reject the Committee Meeting Action and, as an alternative to the added columns, include the

following as documented by Mr. Hamer in his “Explanation of Negative” in the printed ROP.Add a sentence to the end of the present text of Section 130.7(C)(9), above the present FPN No. 1:“… It shall be permitted to determine the Arc Flash Protection Boundary by one or more calculation methods. The

calculation and method(s) used for the determination of the Arc Flash Protection Boundary (or boundaries) shall bedocumented.”

The proposed additional columns for the arc flash boundary should be rejected. Procedures forarc-flash incident energy calculation are not agreed, may have widely varying results and inaccuracies due to therandom behavior of arcing faults and laboratory-based measurements, and a single determination method has not beenaccepted for inclusion as a requirement in the standard. To add the proposed new columns within Table 130.7(C)(9)would complicate the issue and give a false impression that the table’s Hazard / Risk Categories are based entirely onIEEE Std 1584 calculations, which is not true. The Arc Flash Protection Boundary could be determined by one of manycalculation methods, including but not limited to IEEE Std 1584 or other methods in Annex D. The proposed alternativein the above comment satisfies the need for defining the Arc Flash Protection Boundary (or boundaries).

The committee reaffirms the action taken on Proposal 70E-331. The submitter did not providedadequate technical substantiation to remove maximum available short circuit current, overcurrent protective deviceclearing times, and arc flash boundaries from the table. See the committee action on Comment 70E-340. The committeerejects the additional text at the end of Section 130.7(C)(9). If calculations are performed, the HRC tables are notapplicable. See the committee action on Comment 70E-326. The intent of the submitter in respect to documentation hasbeen met by the Committee action on Comment 70E-248a (Log #CC7).



206Printed on 1/19/2011



70E-308This proposal should have been "Accepted in Part."

The heading should read: "Panelboards, Switchboards, or Other Equipment Rated >240 V and up to 600 V (withmolded case or insulated case circuit breakers) - Note 1"

Accept the part to add "Other Equipment," since the category may apply to equipment that is fed bybranch circuits. Do not accept the deletion of "(with molded case or insulated case circuit breakers)," since it isimportant to distinguish these type of devices, which tend to be current-limiting or introduce significant arc impedanceduring the interruption process from other types of protective devices applied at voltages greater than 240 volts and upto 600 volts. For "Panelboards or other equipment Rated 240 V and below," it is not important to designate "moldedcase or insulated case circuit breakers" for that category.

The committee reaffirms acceptance of proposal 70E-308. The type of device used is limited bythe amount of available short circuit current and clearing time. Other current limiting devices such as fuses with aclearing time as listed the table would be permitted.



HICKMAN, P.: We believe that a portion of the committee statement requires clarification. The committee statementindicates that “other current limiting devices…would be permitted.” Since molded case circuit breakers were included inthe text that was deleted one could conclude that the committee considers molded case circuit breakers to be currentlimiting devices. We do not necessarily believe that molded case circuit breakers are listed as being current limitingovercurrent protective devices.

207Printed on 1/19/2011



70E-320The committee action should have been to Accept in Part.

Accept the change from 38kV to 15kV. Do not accept the addition of Notes 5 and 6. Do not accept the increase inhazard risk catgory for the tasks "contractor operation with enclosure doors closed" and "contractor operation withenclosure doors open."

Increasing the HRC for contractor operation with enclosure doors closed establishes a requirementwhereby persons walking through a substation without interacting with equipment will be required to wear HRC 3 level ofprotection. This is not reasonable, and the substantiation was not provided to demonstrate that the risk of this taskwarrants that level of PPE. The submitter based both increases to HRC levels in the NEMA E2 motor starters sectionpurely on IEEE 1584 calculation methods without fully substantiating the likelihood that an event could occur.

The committee rejects the portion of the recommendation to reduce the voltage level from 38 kV to 15 kV.The submitter has not provided additional technical substantiation to support reducing the

voltage level from 38 kV to 15 kV.



208Printed on 1/19/2011




I am not sure how much more substantiation is needed when information is provided based on testingand presented by personnel who are extremely knowledgeable in the field. This is a Note not a requirement. Mr.Hickman is correct in stating this information should not be ignored. Adding this note will allow employers to make betterdecisions in protecting their employees.

Until the research is complete, the field studies & substantiation does not support the changesto HRC categories for all levels of equipment recommended by the submitter.


NEITZEL, D.: I agree with the negative vote and comment by D. Pace. Tom Neal is an expert in the field of arc flashresearch and we, as a Technical Committee, should not totally ignore what he has proposed. I believe that hissubstantiation supports his proposal. Comment 70E-330 should have been accepted. Why should we, as a TC, denyadditional protection when there is a proven increased hazard?PACE, D.: This comment should have been an accept. Research in this area will probably never be complete, and

certainly not in our lifetime. If we wait until it is "complete", we will be waiting decades and in the process many peoplewill have been exposed to hazards, some injured or killed, all while following the guidance in the 70E document, whichin some cases is found to be flawed. The existing guidance in 70E is many years old and it should be no surprise thatwith new research and information that the guidance should change. This has been seen in several areas and willcontinue as our understanding of the hazards improves. The people making these recommendations are of the mostknowledgeable people there are. They certainly are more knowledgeable than the majority of those on the committee.If they recommend a change, they are doing it because there is a serious concern for the guidance as written and thecommittee should listen to them.


209Printed on 1/19/2011



70E-317The proposal should be accepted in principle with the following change Under 600 V Class

Switchgear, retain HRC 2 for Infrared inspection

Technical committee has not provided any justification or technical data to support the rejectionstatement that lower level of protection is acceptable when doors are closed or covers are in place for equipment that isnot tested or listed as arc resistant. TC has not explained why lower level of PPE requirements is acceptable when thistable is used. There is no similar reduction provided when incident energy is calculated. Since reduced level ofprotection with doors closed or covers in place is permeated throughout the table, changes in the table have to becomprehensive based on technical substantiation provided in the proposal. TC statement that the substantiation doesnot support the comprehensive changes to the HRC category is insufficient to support the rejection.Risk= Frequency x consequences. Therefore, for a defined limit of risk, the more serious the consequences, the lower

the tolerable frequency of occurrence. PPE is based on consequences and not on frequencyIt is irrelevant to consider reduced level of protection if TC considers frequency is low. Consequence will be the same

when a low probability fault occurs. TC has not provided how a lower level of protection will be able to protect the workerwhen a lower probability event occurs. Unless equipment is tested for arc fault with covers or doors closed, doors arenot tested to provide protection against an arcing fault.Discussions with UL indicates that in most UL standards for industrial or distribution equipment, only short circuit

(bolted fault) withstand testing is required For this type of fault, the properly secured enclosure door normally providessome limited protection to those who may be in close proximity to the equipment. However, UL standards do not requiretests with simulated internal arcing faults. Equipment may be tested to the requirements of IEEE C37.20.7, in whichcase it bears an additional UL Classification mark. The effects of an arc flash and arc blast due to an internal arcingfault could cause a casualty hazard, in addition to a thermal hazard, to those in close proximity to the equipment.

The substantiation does not support the changes to HRC categories for all levels of equipmentrecommended by the submitter.


PACE, D.: See my explanation of negative vote for Comment 70E-330.


_______________________________________________________________________________________________70E-332 Log #356 EEW-AAA


70E-347aRevise the title of Table 130.8(C)(15)(1) (formerly Table 130.7(C)(9)) as follows:

Table 130.8(C)(15)(1) Hazard/Risk Category Classifications and Use of Rubber Insulating Gloves and Insulated andInsulating Hand Tools – ac Equipment

Title of Table 130.8(C)(15)(1) should include the term “ac Equipment” to correlate with action taken onProposal 70E-347a to add new Table 130.8(C)(15)(2) Hazard/Risk Category Classifications and Use of RubberInsulating Gloves and Insulated and Insulating Hand Tools — dc Equipment



210Printed on 1/19/2011



70E-325Modify the recommendation in Proposal 70E-325 by deleting "Remove/install CB's or fused

switches 2* YY."In addition, delete "Remove/install CB's or fused switches 1YY under the "Panelboards and Other Equipment Rated

240V and Below" category.See explanation of negative for Proposal 70E-325 in the ROP. The text that is proposed to be deleted

in this comment is redundant as it is already covered by existing text.

The existing tasks provide clarity and usability.


HICKMAN, P.: We reaffirm our position that the added text is redundant as installing and removing circuit breakers isworking on energized parts in Table 130.7(C)(9).


211Printed on 1/19/2011


_______________________________________________________________________________________________Larry Ayer, Bizcom Electric

70E-326The committee should reconsider their action and accept the entire proposal

It is not technically accurate to continue to allow switchboards to remain in the first two equipmentcategories in the Hazard/Risk Tables.Switchboards that are found in electrical distribution systems are typically rated 1,200 amp or greater. This size of

equipment requires similar size overcurrent protection. The 130.7(C)(9) Tables continue to use 25 kA @ 2 cycle torepresent typical fault current and clearing times of overcurrent devices for the first two equipment categories. While theTables are not to be used in situations in which the actual clearing times and fault current fall outside of theseparameters, the 70E committee should strive to accurately portray real world conditions that cover a majority ofapplications.A graph is attached which shows the relationship between incident energy to fault current for 400A and 800A o.c.

devices. You should be able to discern from the chart that the 25kA @ 2 cycle parameter is adequate for lower ampacityequipment such as disconnects and panelboards, but the same parameter is not adequate for higher ampacityswitchboards which typically incorporate 800A and larger devices. Switchboard equipment should be moved to themotor control center category as specified in this proposal which uses 65kA @ 2 cycle.

****Insert Graph Here****

In addition, many of the tasks in the motor control center category such as reading a panel meter, working on controlcircuits, and applying temporary protective grounding equipment apply to switchboard equipment as well.Note: Supporting Material is available for review at NFPA headquarters.

Delete “Switchboards” from the second part of Table 130.7(C)(9) and relocate “Switchboards” to “600 V ClassSwitchgear (with power circuit breakers or fused switches) and 600 V Class Switchboards” Remove "switchboard" fromthe last task in the "Panelboards or Switchboards Rated >240V and up to 600V" equipment category.

The committee action meets the intent of the recommendation.


NEITZEL, D.: I agree with the negative vote and comment by V. Saporita, and restate it here: "Moving Switchboardsto the Switchgear portion of the table is incorrect and the Committee should have Rejected this comment. Switchboardsare built to the UL 891 Standard and Switchgear is built to the UL 1558 Standard. UL 891 products are used inapplications very similar to Panelboards and should remain in the same area of the Table, and with the samerequirements."SAPORITA, V.: Moving Switchboards to the Switchgear portion of the table is incorrect and the Committee should

have Rejected this comment. Switchboards are built to the UL 891 Standard and Switchgear is built to the UL 1558Standard. UL 891 products are used in applications very similar to Panelboards and should remain in the same area ofthe Table, and with the same requirements.TIEDE, T.: More study is needed to determine if the proposed changes are needed with respect to location of

switchboard equipment in the tables. The commenter suggested that switchboard equipment should be moved to themotor control center category. The committee action moved switchboard equipment to the 600 V class switchgearcategory. Perhaps a separate category for switchboard equipment is what is actually needed. Without furtherinvestigation the committee action may have unforeseen and unintended consequences.


212Printed on 1/19/2011


_______________________________________________________________________________________________Chad Kennedy, Square D Company/Schneider Electric


In consideration of the ROP voting comment by P. Hamer, the operation of circuit breaker or fusedswitch/fuse truck “racking” does not expose workers to a shock hazard and adding the requirement to use insulatingrubber gloves is the wrong application of the PPE. In addition, the proposal would only apply to 600V switchgear andthus is not consistent with PPE for racking of 1kV-38kV devices or racking of devices in arc resistant switchgear.Further, no technical substantiation was submitted to validate the need for additional shock protection for employeeswho are outside the limited approach boundary.


PACE, D.: See my explanation of negative vote for Comment 70E-319.


_______________________________________________________________________________________________70E-336 Log #393 EEW-AAA


70E-331Delete text to read as follows:

Arc Flash Boundary600V Class Motor Control Centers(MCC’s) (3) 0 N N 65kA @ 0.03 sec (2 Cycle) 0600V Class Switchgear - (with power circuit breakers or fused switches) 0 N N 35kA @ 0.5 sec (30 Cycle) (4) 0

The Arc Flash Boundary for operation of a switch or circuit breaker with the doors closed for the abovenon- arc-resistant construction equipment should not be shown as zero. Data does not exist for this statement. Therehave been many cases where the doors have blown open during a fault in non-arc-resistant design equipment. An arcflash boundary should exist unless the equipment is arc-resistant rated equipment. UL rated equipment that is not of thearc-resistant design is only tested with a bolted fault not an arcing fault.

The committee action on Comment 70E-340 has deleted the columns containing maximumavailable short circuit current, clearing times, and arc flash boundaries.



213Printed on 1/19/2011



70E-330The committee should have accepted the proposal.

The committee statement, "The use of Table 130.7(C)(9) and the Hazard Risk Category method isnecessary for venues in which a complete study of all incident energy values has not been completed." fails to recognizethe fact that some sort of analysis is necessary just to obtain the information required to screen if the table can be usedor not - short circuit current and upstream device clearing time.Several years of trying to differentiate or equivocate the use of the table method with that of the analysis method has

proven that a simple requirement that the incident energy be calculated is the best tact to take. Confusion exists as it isnow, and the proposed insertion of information contained in other proposals for the table, such as additional columns ofinformation, will only make things worse.It is time to face the fact that the table is no longer a viable tool that can be used with any degree of confidence since

there appears to be no repeatable technical process used in its development or in the proposed additions. Lets doeveryone a favor and drop it now before it becomes so unwieldy and unmanageable.

The committee continues to recognize that the “table method” is an option for performingjustified energized work in many instances where an incident energy analysis has not been performed. Many electricalsystems in use do not have an incident energy analysis performed. The tables provide the installer/maintainer with theability to determine necessary PPE for justified energized work.



_______________________________________________________________________________________________70E-338 Log #425 EEW-AAA


70E-331The committee should have rejected the proposal.

After several years of dealing with the confusion in the work force about why there is a differentrequirement for certain tasks that are also calculated to have a higher arc flash incident energy than the table allowedPPE, it has become more of a liability than aid. Simply requiring the calculation as is already part of section 130.3(B)(1)without the allowance of the table values will make the presentation of requirements more meaningful to the worker andto those who enforce the requirements.The recommended changes in this and other proposals accepted by the committee will only serve to complicate the

matter even more. There is too much information being placed in a table for it to be a simple tool and this practice drivesus away from the desired engineering solution to arc flash analysis.

See the committee action and statement on Comment 70E-327. These tables are applicableonly when incident energy calculations are not performed.



214Printed on 1/19/2011



70E-334Change HRC 0 to HRC 1 in the following locations:

- Perform infrared thermography and other non-contact inspections outside the restricted approach boundary- CB or fused switch operation with covers off- Opening hinged covers (to expose bare energized electrical conductors and circuit parts)

- Opening hinged covers (to expose bare energized electrical conductors and circuit parts)

- Work on control circuits with energized electrical conductors and circuit parts 120 V or below, exposed

-Work on control circuits with energized electrical conductors and circuit parts 120 V or below, exposed

- Work on control circuits with energized electrical conductors and circuit parts 120 V or below, exposed

Also, change the AFPB to 55 in. for the following task (due to the assocaited clearing time and available fault currentassociated with the equipment):

- Work on control circuits with energized electrical conductors and circuits parts 120 V or below, exposedWhile the debate continues whether there is a need for arc-rated clothing when covers are on

equipment and covers are closed, 130.7(C)(5) requires all parts of the body to be protected with FR when inside theAFPB. This comment is intended to requrie FR where the AFPB is a greater distance than where the calculation of heatenergy was done (18 in . for systems rated less than 1000 volts and 36 in. for systems 1 kV and greater) and there isnot "protection" provided by the enclosure. Flammable clothing should not be worn (as permitted by HRC 0) in thesecases. Also see P. Hickman Affirmative Comment on Proposal 70E-334.For the second recommendation, the AFPB should be changed from 15 to 55 in. due to the associated claring time and

available fault current associated with the equipment.

The committee recognizes that flammable clothing is not permitted within the arc flashboundary, however the arc flash boundary is based on the equipment class and not necessarily on the task itself.


HICKMAN, P.: The committee action to allow flammable clothing inside the arc flash boundary is in conflict with130.7(C)(1) and (5) especially in light of the fact that the committee statement indicates that “the committee recognizesthat flammable clothing is not permitted inside the arc flash boundary…. In pointing out that the arc flash boundaryincluded in the equipment heading in Table 130.7(C)(9) in the 2012 edition of 70E is based on the equipment classrather than on the task itself, it would seem to follow that “to be determined (TBD)” or “analysis required (AR)” shouldreplace the HRC for these tasks since one could only select PPE once the arc flash boundary is determined by acalculation to determine where 1.2 calories per square centimeters is encountered. If flammable clothing is outside thatcalculated value then flammable clothing could be worn. If clothing is inside that calculated arc flash boundary then130.7(C)(1) and (5) would necessitate that the clothing be arc rated. The arc flash boundary and HRC need to bedetermined on a case by case basis since there is no arc flash boundary for the task in table 130.7(C)(9). Note that thecommittee added clarification that “all requirements of this article shall apply for both an incident energy analysis or if thetables are used in lieu of an incident energy analysis” in its action on Proposal 70E-186. The action taken on thiscomment conflicts with the existing requirements of 130.7(C)(1) and (5) as well with the action taken on Proposal70E-186.

215Printed on 1/19/2011

Report on Comments – June 2011 NFPA 70ENEITZEL, D.: I agree with the negative vote and comment by P. Hickman, and restate it here: "The committee action

to allow flammable clothing inside the arc flash boundary is in conflict with 130.7(C)(1) and (5) especially in light of thefact that the committee statement indicates that “the committee recognizes that flammable clothing is not permittedinside the arc flash boundary…. In pointing out that the arc flash boundary included in the equipment heading in Table130.7(C)(9) in the 2012 edition of 70E is based on the equipment class rather than on the task itself, it would seem tofollow that “to be determined (TBD)” or “analysis required (AR)”should replace the HRC for these tasks since one couldonly select PPE once the arc flash boundary is determined by a calculation to determine where 1.2 calories per squarecentimeters is encountered." If worker is outside the calculated arc flash boundary then flammable clothing could beworn. If the worker is inside that calculated arc flash boundary, then 130.7(C)(1) and (5) would necessitate that theirclothing be arc rated. "The arc flash boundary and HRC need to be determined on a case by case basis since there isno arc flash boundary for the task in table 130.7(C)(9). Note that the committee added clarification that “all requirementsof this article shall apply for both an incident energy analysis or if the tables are used in lieu of an incident energyanalysis” in its action on Proposal 70E-186. The action taken on this comment conflicts with the existing requirements of130.7 (C)(1) and (5) as well with the action taken on Proposal 70E-186.


216Printed on 1/19/2011


_______________________________________________________________________________________________The Technical Correlating Committee directs that the new note to the table that addresses the

determination of an arc flash boundary for power systems from 1 kV to 38 kV be modified as follows: Replace (455 mm)with (153 mm) for correlation with the calculation methods.

Mike Doherty, Infrastructure Health & Safety Association / Rep. CSA Z462 Technical Committee70E-323, 70E-331

The action on 70E-323 should have been Accept in Principle rather than Accept in Principle andPart with the following Committee Statement:1. The committee Accepts the relocation of the maximum short circuit current, fault clearing time and working distance

parameters from the notes into the header of the appropriate section of Table 130.7(C)(9).2. The committee accepts including an estimation of incident energy and arc flash protection boundary in the header of

each section based on the parameters for that section.3. The committee notes that the action on this proposal will be modified by the action on Proposal 70E-331.The action on 70E-331 should have been Accept in Principle and Part with the following committee statement:1. The committee Accepts in Principle the relocation of the available short circuit currents and clearing times from the

“Specific Notes” to the body of the document, but relocates the information in the header of the appropriate Tablesection.2. The committee deletes the existing “Specific Notes” in Table 130.7(C)(9).3. The committee Accepts in Principle the added limitations for available short circuit current and clearing time where

they are missing in the existing table, but locates the information in the header of the appropriate Table section.4. The committee Accepts in Principle and Part the addition of Arc Flash Boundaries in the Table, but locates the

information in the header of the appropriate Table section.5. The committee adds a note at the end of the table to explain how the arc flash boundary and incident energy

estimations were determined:6. The committee retains and relocates the information in note (d) regarding the 18 inch working distance for systems

rated less than 1000V to ensure correlation with note (e) which retains the working distance information for electricalsystems rated 1 kV and greater.

****Insert Table 130.7(C)(9) Log #125 Here****

The Technical Committee action on Proposal 70E-331 that creates a new column for available shortcircuit currents and clearing times and a new column for the arc flash protection boundary will potentially be confusing tousers of the document. Placing the available short circuit currents and clearing times in each row opposite each taskand associated hazard/risk category implies that the H/RC value is directly related to these available short circuitcurrents and clearing times. As indicated in Section 130.7(C)(9) FPN No. 1, this is clearly incorrect. The H/RC valuesare often arrived at using risk reduction factors, as explained in the aforementioned reference.Proposal 70E-323 sought to place the available short circuit currents and clearing times in the header for each table

section, where the Note that references available short circuit currents and clearing times currently resides. Locatingthe information in the header provides a clear separation between the parameters that permit the use of the table fromthe H/RC values.The committee rationale for excluding the proposed incident energy information in Table 130.7(C)(9) is because the

Table is hazard/risk based and not exclusively based on incident energy. A key word in the committee statement is“exclusively.” While H/RC values are not based exclusively on incident energy, it was used as a basis by the task forcethat created the tables in the initial selection of the level of personal protective equipment. This is clearly stated inSection 130.7(C)(9) FPN No. 1: “The protective clothing and equipment is generally based on determination ofestimated exposure levels.”

217Printed on 1/19/2011

1 NFPA 70E Log #125 Rec A2011 ROC



Category

Rubber Insulating

Gloves

Insulated and





-- -- --


0 N N




1 Y Y



1 N N


0 N N


1 Y Y




-- -- --


1 N N




2* Y Y


2* Y Y




-- -- --


1 N N






Category

Rubber Insulating

Gloves

Insulated and




2* Y Y


0 Y Y


2* Y Y



2* Y Y






4 N N


1 N N




-- -- --


2 N N





2* Y Y


0 Y Y


2* Y Y




4 N N


2 N N

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




Category

Rubber Insulating

Gloves

Insulated and


Parameters: Maximum of 65 kA short circuit current available; Maximum of 0.03 sec (2 cycle) fault clearing time; Minimum 18 in. working distance (except as indicated)




2* N N


1 N N


2* Y Y













3 N N





4 Y Y


0 Y Y


3 Y Y




4 N N


3 N N




Category

Rubber Insulating

Gloves

Insulated and



0 N N





3 N N





4 Y Y


2 Y Y


4 Y Y




4 N N


3 N N









2 Y Y



0 N N


Maximum of 35kA short circuit current available; Maximum of up to 0.2 sec (12




Category

Rubber Insulating

Gloves

Insulated and


cycle) fault clearing time; Minimum 36 in. working distance Potential Incident energy using above parameters: 41 calories/ cm2 Potential Arc Flash Protection using above parameters: 422 inches



0 N N



4 Y Y


4 N N


3 N N
















(f) For equipment protected by upstream current limiting fuses with arcing fault current in their current limiting range (1⁄2 cycle fault clearing time or less), the hazard/risk category required may be reduced by one number. Specific Notes (as referenced in the table): 1. Maximum of 25 kA short circuit current available; maximum of 0.03 sec (2 cycle) fault clearing time.


2. Maximum of 65 kA short circuit current available; maximum of 0.03 sec (2 cycle) fault clearing time. 3. Maximum of 42 kA short circuit current available; maximum of 0.33 sec (20 cycle) fault clearing time. 4. Maximum of 35 kA short circuit current available; maximum of up to 0.5 sec (30 cycle) fault clearing time.

Report on Comments – June 2011 NFPA 70EPlacing incident energy estimation along with arc flash boundary in the header of each Table section provides the user

of the document with information that enables them to make informed safety related work practice decisions and PPEchoices.The ballot comment that “calculation procedures to determine the incident energy are in a constantly changing

environment, and the proposal only includes IEEE Std 1584-2002 methodology, which is only one approach” is notgermane. Engineering and health and safety decisions must be made using the best information available at the time.To delay engineering and health and safety decisions while waiting for a perfect methodology would be negligent. Theballot comment that adding very detailed and precise information to the table would lead the user to the conclusion thatthe procedure for arc-flash incident energy calculation is proven science is inaccurate and misleading. Not including thebest information available in the Table has led many to conclude that the Table is proven science, which it clearly is not.

The committee accepts in part the following components of the recommendation and notes that these modifications areto be made to Table 130.8(C)(15)(1) as shown in the ROP Draft.The committee continues to accept the deletion of the specific notes and the relocation of maximum available short

circuit current values, maximum clearing times and minimum working distances in the body of the table.The committee also continues to accept the inclusion of maximum available short circuit current values and maximum

clearing times where they were missing.The committee places the information on maximum available short circuit current values, maximum clearing times, and

minimum working distance in each equipment header.The committee accepts the placement of arc flash boundaries in each equipment header. The text prefacing the arc

flash boundary in each header shall read: Potential arc flash boundary with exposed energized conductors or circuitparts using above parameters; xx inches.The committee deletes the incident energy information from the equipment headers.The committee accepts splitting the 600V Class MCCs into separate header items as shown in the recommendation.The committee deletes Notes 5 and 6 to Table 130.8(C)(15)(1) in the ROP Draft.The committee rejects the remainder of the recommendation.

The committee rejects the inclusion of incident energy values. The submitter did not provideadequate technical substantiation to include the incident energy values. Table 130.7(C)(9) is hazard/risk based and notexclusively based on incident energy.


NEITZEL, D.: See my explanation of negative vote on comment 70E-339.


BARRIOS, L.: The committee action on Comment 70E-340 appears to be a reasonable compromise on a number ofconcerns raised by committee members.

218Printed on 1/19/2011



70E-320This proposal should have been accepted in principle in part (APP).

(1) The committee should continue to accept in principle the submitters’ suggestion to add maximum levels of ASCCand clearing times that were missing. However the values suggested in proposal 70E-331 should continue to be used.(2) The committee should continue to reject the suggestion to increase HRC levels.(3) The committee should continue to reject the reduction in voltage levels from 38kV to 15kV.

This comment is submitted in an effort to address the note from the TCC directing the committee tocorrelate the action on this proposal with the action taken on proposal 70E-331.The TCC requested this correlation due to the fact that an action to accept in principle (as taken on this proposal) infers

that all of the submitters’ suggestions were accepted in some form. However, the 70E technical committee did notaccept all of the proposed revisions in proposal 70E-320.The addition of maximum ASCC vales and clearing times as suggested in this proposal have been accepted in

principle by the action taken on proposal 70E-331. The committee has chosen to use the values that were proposed andsubstantiated in proposal 70E-331. See proposal 70E-331.The committee did not accept an increase to the HRC levels. The committee statement and action to reject proposal

70E-317 substantiates this rejection. See proposal 70E-317.The submitter has not provided adequate substantiation to reduce the maximum voltage level for Other Equipment

from 38 kV to 15 kV.



_______________________________________________________________________________________________70E-342 Log #434 EEW-AAA


70E-331The committee action should continue to be Accept in Principle with the committee action modified

as follows:Change where the Flash Protection Boundary indicates “0” in the new table to “N/A”, meaning not applicable.

Indicating a flash protection boundary of 0 inches, when an HRC level is also indicated will createdconfusion when using the modified tables. Changing the “0” to “N/A” indicating “not applicable” should clear up thisconfusion. An alternative is to leave the Flash Protection Boundary in these cases blank. Also, the preferred method ofdisplaying the data , as shown in the ROP draft is by equipment voltage and type and not by task.

The committee action on Comment 70E-340 deletes the column containing arc flashboundaries.


BARRIOS, L.: Adding a new Note 10 that does not provide clear guidance to the user does not add clarity to theStandard, especially when the committee has attempted to reduce the number of notes to the table.


219Printed on 1/19/2011



70E-331Committee action should have been Accept in Part.

EEI supports the concept of the tables but there are number of technical issues. The tables list taskswith HRC = 0 and Arc Flash Boundary equals zero inches. HRC = 0 means there are PPE requirements for this workinside the arc flash boundary. But arc flash boundary equals zero has no meaning. These tasks should be deleted fromthe table. The table should include an explanation of the expectation when arc flash boundary is less than arms' length.Does that mean you need protection for the hands but not the torso? Does that mean that hearing protection and headprotection is not required since the head is outside the arc flash boundary? The table includes requirements forequipment that is above 15 kv. But the IEEE 1584 method is known not to be accurate above 15 kv. The table shouldinclude a note indicating that calculations above 15 kv may not be accurate or delete all tasks above 15 kv.

The recommendation does not provide specific recommended text. The comment does notcomply with 4.4.5 of the NFPA Regulations Governing Committee Projects. See the committee action on Comment70E-342.



220Printed on 1/19/2011



70E-322The Committee Action on the proposal should have been Accept in Principle with the “Principle”

being that only the indicated HRC3 and HRC4 tasks that are noted with 3* (3-star) and 4*(4-star) in the attachedmodified Table 130.7(C)(9) have been noted for PPE with an increased arc rating. These indicated tasks involve arcflash hazards inside an equipment enclosure. The following note is added to Table 130.7(C)(10) regarding HRC3* andHRC4*:Note 11: Hazard/Risk Category 3* indicates the arc flash hazard is inside an equipment enclosure. Because the

protective performance of arc rated clothing decreases when subjected to an arc flash exposure in an enclosure, thetotal clothing system consisting of FR shirt and pants and/or FR coveralls and/or arc flash coat and pants and hood shallhave a minimum arc rating of 50 for Hazard/Risk Category 3*.Note 12. Hazard/Risk Category 4* indicates the arc flash hazard is inside an equipment enclosure. Because the

protective performance of arc rated clothing decreases when subjected to an arc flash exposure in an enclosure, thetotal clothing system consisting of FR shirt and pants and/or FR coveralls and/or arc flash coat and pants and hood shallhave a minimum arc rating of 80 for Hazard/Risk Category 4*.

Additionally, the “Accept in Principle” includes the following added text in Annex D section D.5.2 for those whodetermine incident energy for arc flash hazards which involve conductors in an equipment enclosure:

The estimated incident energy for an arc in a cubic box (20 in. on each side, open on oneend) is given in the following equation. This equation is applicable to arc flashes emanating from within switchgear,motor control centers, or other electrical equipment enclosures. For arc flash exposures which involve an enclosure, the“effective” arc rating of clothing is decreased from its stated value due to the increased proportion of convective energyin these types of exposures. For arc rated clothing with an arc rating up to 15, multiply the stated arc rating by 0.8 todetermine the “effective” arc rating. For arc rated clothing or an arc flash suit with an arc rating above 15, multiply thestated arc rating by 0.5 to determine the “effective” arc rating. Use the “effective” arc rating when selecting protectiveclothing or an arc flash suit for the determined incident energy value."

The added note “g” for Table 130.7(C)(9) in Proposal 70E-322 should be modified as follows to be consistent withproposed notes 11 and 12 above: \"General Notes (g) If the task involves an arc flash hazard within an enclosure, the Hazard/Risk Category 3 and 4 tasks

are designated with 3* and 4* respectively. The arc rating of clothing is known to decrease when the arc flash eventoccurs in an enclosure due to the higher proportion of convective energy created in this equipment configuration. Thisnote applies to all tasks listed in Table 130.7(C)(9) in which the arc flash hazard is in an enclosure.”

See also attached modified Table 130.7(C)(9).

Proposal 70E-322 would have added the following note to Table 130.7(C)(9), “If the task involves anarc flash hazard within an enclosure, add one number to the hazard/risk category number. The arc rating of clothing isknown to decrease when the arc flash event occurs in an enclosure due to the higher proportion of convective energycreated in this equipment configuration. This note applies to all tasks listed in Table 130.7(C)(9) in which the arc flashhazard is in an enclosure.” This would have made it necessary for the users of Table 130.7(C)(9) to determine if theirarc flash hazard was inside an equipment enclosure. This comment assists the users of Table 130.7(C)(9) by indicatingwith a Hazard/Risk Category 3* and 4* which tasks involve an arc flash hazard which is inside an equipment enclosure,and therefore the tasks where protective clothing with an increased arc rating is to be selected. The original proposalcontained the following three pieces of essential information:(1) The arc rating of clothing is known to decrease when the arc flash event occurs in an enclosure and the supporting

information indicated the “effective” arc rating was approximately 50% of the determined arc rating.(2) The Hazard/Risk Category was increased by one number for tasks that involve an arc flash hazard within an

enclosure, i.e. HRC1 tasks (clothing with an Arc Rating of 4 required) were to be increased to HRC2 which wouldrequire an arc rating of 8, HRC2 tasks were to be increased to HRC3 (clothing arc rating increased from 8 to 25), HRC3tasks were to be increased to HRC4 (clothing arc rating increased from 25 to 40), HRC4 were to be increased to

221Printed on 1/19/2011




Category

Rubber Insulating

Gloves

Insulated and





-- -- --


0 N N




1 Y Y



1 N N


0 N N


1 Y Y




-- -- --


1 N N




2* Y Y


2* Y Y




-- -- --


1 N N





Category

Rubber Insulating

Gloves

Insulated and




2* Y Y


0 Y Y


2* Y Y



2* Y Y






4 N N


1 N N




-- -- --


2 N N





2* Y Y


0 Y Y


2* Y Y




4 N N


2 N N

Other 600 V Class (277 V through 600 V, nominal) Equipment Parameters:

Maximum of 65 kA short circuit current available; Maximum of 0.03 sec (2 cycle) fault clearing time; Minimum 18 in. working distance (except as

-- -- --



Category

Rubber Insulating

Gloves

Insulated and


indicated) Potential Incident Energy using above parameters: 7.1 calories/ cm2 Potential Arc Flash Boundary using above parameters: 53 inches



2* N N


1 N N


2* Y Y













3 N N





4 Y Y


0 Y Y


3 Y Y




4 N N


3 N N


0 N N





Category

Rubber Insulating

Gloves

Insulated and




3 N N





4 Y Y


2 Y Y


4 Y Y




4 N N


3 N N









2 Y Y



0 N N






0 N N


Work on exposed energized electrical conductors and circuit parts, including 4 Y Y



Category

Rubber Insulating

Gloves

Insulated and


voltage testing


4 N N


3 N N
















(f) For equipment protected by upstream current limiting fuses with arcing fault current in their current limiting range (1⁄2 cycle fault clearing time or less), the hazard/risk category required may be reduced by one number. Specific Notes (as referenced in the table): 1. Maximum of 25 kA short circuit current available; maximum of 0.03 sec (2 cycle) fault clearing time. 2. Maximum of 65 kA short circuit current available; maximum of 0.03 sec (2 cycle) fault clearing time. 3. Maximum of 42 kA short circuit current available; maximum of 0.33 sec (20 cycle) fault clearing time. 4. Maximum of 35 kA short circuit current available; maximum of up to 0.5 sec (30 cycle) fault clearing time.

Report on Comments – June 2011 NFPA 70EHRC4+1 since there is not and HRC5 level. The IEEE paper that was supplied with Proposal 70E-322 indicated that anarc flash in an enclosure with an incident energy of approximately 40 cal required clothing with an arc rating of 65 to100.(3) The need for clothing with an increased arc rating applies to all tasks listed in Table 130.7(C)(9) in which the arc

flash is an enclosure.Since the arc-in-a-box task addressed in Annex D.5.2 would involve tasks listed in Table 130.7(C)(9) the need for

protective clothing with an increased arc rating can logically be extended to the non-mandatory information in Annex D.The proposed changes to the Tables and to Annex D have been modified versus the original Proposal (70E-322) in thatthe changes proposed in this comment are more specifically focused on the tasks which involve an arc flash hazardinside an equipment enclosure.The Committee Statement, “The substantiation does not support the comprehensive changes to HRC categories for alllevels of equipment recommended by the submitter” for Proposal 70E-322. An IEEE paper by Neal and Lang wassubmitted as substantiation for the significant decrease in the arc rating of clothing in arc exposures which involve anequipment enclosure. An additional IEEE paper and a PowerPoint presentation has been provided with this commentto increase the substantiation for the proposed changes. The IEEE paper by Lang, Jones and Neal provides anapproach to PPE selection for a large workplace taking into account the reduction in the arc rating of clothing in arc flashexposures which involve an equipment enclosure. The PowerPoint presentation by Eblen and Short adds furthersubstantiation as to the reduction in the “effective” arc rating of clothing in arc flash exposures which involve anequipment enclosure.Note: Supporting material is available for review at NFPA Headquarters.

Until the research is complete, the field studies & substantiation does not support the changesto HRC categories for all levels of equipment recommended by the submitter.



222Printed on 1/19/2011


_______________________________________________________________________________________________Dale Edwin Scherry, Scherry Engineering and Consulting, Inc.

70E-343Although it was recommended to specifically change the wording of the notes, the committee

seemed to view the recommendations as a calculation procedure rather than to use the calculations as a means tosupport the recommendations. Therefore, it is now suggested that Note 4 be applied to 600V Class Motor ControlCenters and to Other 600VClass (277V through 600V, nominal) Equipment as well as 600V Class Switchgear. Also,add Switchboards to listing for MCC’s. In addition, References to Notes 2 and 3 should be eliminated.

****Insert Table 130.7(9) Log #167 Here****

Note 2 of the table limits the fault clearing time of the short circuit to 2 cycles. This 2 cycle requirementis presented for many types of equipment including: A) Most of the table for MCC’s; and B) Other 600V Class (277Vthrough 600V) Equipment. There are several tasks involving locations within the equipment, except after the feederprotective device, which would be protected by the upstream device. The upstream device must be set above 2-cyclesclearing time for this upstream protective device to allow for any level of appropriate coordination with subsequentfeeders, otherwise both the feeder and main would trip. If the various types of equipment would exist in a distributionsystem, as they do in some systems, there would be a considerable lack of coordination across the distribution systemand therefore the 2 cycle limitation is not practical. It is believed that Note 4 which applies to 600V Class Switchgear isthe only note that permits a more practical approach to providing both coordination and protection from an arc flashhazard and thus should be applied to all 600V equipment.Note: Supporting material is available for review at NFPA headquarters.

The committee reaffirms rejection of Proposal 70E-343. The recommendation does not providesufficient technical substantiation. The table method is intended for use where an incident energy analysis has not beenperformed. See the committee action on Comment 70E-334.



223Printed on 1/19/2011


Table 130.7(C)(9) continued Tasks Performed on Energized Equipment Hazard/Risk

Category Rubber

Insulating Gloves

Insulated and Insulated Hand

Tools CB or fused switch operation with covers off 1 Y N


2* Y Y

Work on energized electrical conductors and circuit parts of utilization equipment fed directly by a branch circuit of the

panelboard or switchboard

2* Y Y

600 V Class Motor Control Centers (MCCs) — Note 2 4 (except as indicated)


1 2 N N

CB or fused switch or starter operation with enclosure doors closed

0 N N

Reading a panel meter while operating a meter switch 0 N N CB or fused switch or starter operation with enclosure doors

open 1 2 N N


2* 3 Y Y


0 Y Y


2* Y Y

Insertion or removal of individual starter “buckets” from MCC — Note 3

4 Y N

Application of safety grounds, after voltage test 2* Y N Removal of bolted covers (to expose bare, energized electrical

conductors and circuit parts) — Note 3 4 N N

Opening hinged covers (to expose bare, energized electrical conductors and circuit parts) — Note 3

1 2 N N

Work on energized electrical conductors and circuit parts of utilization equipment fed directly by a branch circuit of the

motor control center

2* Y Y

600 V Class Switchgear (with power circuit breakers or fused switches) — Note 4


2 N N

CB or fused switch operation with enclosure doors closed 0 N N Reading a panel meter while operating a meter switch 0 N N

CB or fused switch operation with enclosure doors open 1 2 N N Work on energized electrical conductors and circuit parts,

including voltage testing 2* 3 Y Y


0 Y Y


2* 3 Y Y


4 N N

Application of safety grounds, after voltage test 2* Y N Removal of bolted covers (to expose bare, energized electrical

conductors and circuit parts) 4 N N


2 N N


Other 600 V Class (277 V through 600 V, nominal) Equipment — Note 2 (except as indicated)

Lighting or small power transformers (600 V, maximum) Removal of bolted covers (to expose bare, energized

electrical conductors and circuit parts) 2* 4 N N


1 N N


2* 3 Y Y

Application of safety grounds, after voltage test 2* Y N Revenue meters (kW-hour, at primary voltage and current)


Cable trough or tray cover removal or installation 1 2 N N Miscellaneous equipment cover removal or installation 1 N N


1 2 Y Y

Application of safety grounds, after voltage test 2* Y N Insertion or removal of plug-in devices into or from busways 2* 4 Y N

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


3 N N

Contactor operation with enclosure doors closed 0 N N Reading a panel meter while operating a meter switch 0 N N

Contactor operation with enclosure doors open 2* N N Work on energized electrical conductors and circuit parts,

including voltage testing 4 Y Y


0 Y Y


3 Y Y


4 N N

Application of safety grounds, after voltage test 3 Y N




Modify the table included in ROP draft as per table below with markings

****Insert Table Here****

Table 130.7(C)(9) in 70E-2009 is issued in the ROP draft as Table 130.8 (C)(15)(1). Since the tableincorporates changes proposed in more than one proposal, the table in the ROP draft has been used as a base.

Work performed within Arc Flash Boundary cannot have a HRC 0 as indicated in the table.Arc flash boundary is based on available short circuit current and protective device opening time and cannot be

reduced with doors closed or covers installed except for tested and listed arc resistant equipment.HRC cannot be reduced for activities performed with doors closed except for arc resistant equipment.HRC for work being performed at 120 V cannot have fewer hazards unless we change the available fault and clearing

time. Working on control circuit of energized equipment increases the potential of an arc fault because a person isinteracting with equipment in very close proximity.Arc resistant switchgear has a minimum arc flash boundary of 12 inches and any work performed within that distance

requires a minimum HRC 1 PPE.Grounding and tested device in arc resistant construction equipment can only be utilized as Grounding device with

door closed.I have discussed this with a leading manufacturer of arc resistant switchgear and recommendation is a minimum 4

cal/cm2 PPE, face protection, hearing protection and leather protectors

See the committee action and statement on Comment 70E-313. Additionally, see thecommittee action and statement on Comment 70E-340.


HICKMAN, P.: The action taken on this comment conflicts with the existing requirements of 130.7(C)(1) and (5) as wellwith the action taken on Proposal 70E-186. Also see our explanation of negative on comment 70-339.


224Printed on 1/19/2011


Table 130.8(C)(15)(1) Hazard/Risk Category Classifications and Use of Rubber Insulating Gloves and Insulated and Insulating Hand Tools Tasks Performed on Energized Equipment

Hazard/Risk Category

Rubber Insulating

Gloves

Insulated & Insulating

Hand Tools

Maximum Available Short Circuit

Current & Clearing Time

Arc Flash Boundary (inches)

Panelboards or Other Equipment Rated 240 V and Below


0 1 N N

25kA @ 0.03 sec (2 cycles)

20

Circuit breaker (CB) or fused switch operation with covers on

0 1 N N

25kA @ 0.03 sec (2 cycles)

0 20

CB or fused switch operation with covers off

0 1 N N 25kA @ 0.03 sec (2 cycles)

20


1 Y Y 25kA @ 0.03 sec (2 cycles)

20

Remove/install CBs or fused switches


20

Removal of bolted covers (to expose bare, energized electrical conductors and circuit parts

1 N N 25kA @ 0.03 sec (2 cycles)

20

Opening hinged covers (to expose bare, energized electrical conductors and circuit parts

0 1 N N 25kA @ 0.03 sec (2 cycles)

20



20

Panelboards, Switchboards, and Other Equipment Rated > 240V and up to 600



20

Circuit breaker (CB) or fused switch operation with covers on

0 1 N N 25kA @ 0.03 sec (2 cycles)

0 30

CB or fused switch operation with covers off

1 Y N 25kA @ 0.03 sec (2 cycles)

30



30

Remove/install CBs or fused switches


30



30



0 1 N N 25kA @ 0.03 sec (2 cycles)

30



30

600 V Class Motor Control Centers (MCCs)



55

CB or fused switch or starter operation with enclosure doors closed

0 2 N N 65kA @ 0.03 sec (2 cycles)

0 55

Reading a panel meter while operating a meter switch

0 1 N N 65kA @ 0.03 sec (2 cycles)

0 55

CB or fused switch or starter operation with enclosure doors open

0 2 N N 65kA @ 0.03 sec (2 cycles)

55



55


0 2 Y Y 65kA @ 0.03 sec (2 cycles)

15 55

Work on control circuits with energized electrical conductors and circuit parts> 120 V, exposed


20 55

Insertion or removal of individual starter “buckets” from MCC

4 Y N 42kA @ 0.33 sec (20 cycles)

165

Application of temporary protective grounding equipment, after voltage test


55


4 N N 42kA @ 0.33 sec (20 cycles)

165


1 4 N N 42kA @ 0.33 sec (20 cycles)

165

Work on energized electrical conductors and circuit parts of utilization equipment fed directly by a branch circuit of the motor control center

2 4 Y Y 65kA @ 0.03 sec (2 cycles)

55

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


2 4 N N 35kA @ 0.5 sec (30 cycles)

235

CB or fused switch operation with enclosure doors closed

0 4 N N 35kA @ 0.5 sec (30 cycles)

0 235


0 1 N N 35kA @ 0.5 sec (30 cycles)

0

CB or fused switch operation with enclosure doors open

1 4 N N 35kA @ 0.5 sec (30 cycles)

235


2 4 Y Y 35kA @ 0.5 sec (30 cycles)

235



0 4 Y Y 35kA @ 0.5 sec (30 cycles)

235


2 4 Y Y 35kA @ 0.5 sec (30 cycles)

235



235

**Text/page missing from Original submission***


0 4 Y Y 35kA @ 0.5 sec (30 cycles)

420



420


4 N Y 35kA @ 0.5 sec (30 cycles)

420



420



420



420


0 1 N N 35kA @ 0.5 sec (30 cycles)

0 12

Metal Clad Switchgear, 1 kV through 38 kV



420

CB operation with enclosure doors closed 2 4 N N 35kA @ 0.5 sec (30 cycles)

420


0 1 N N 35kA @ 0.5 sec (30 cycles)

420

CB operation with enclosure doors open 4 N N 35kA @ 0.5 sec (30 cycles)

420



420



15



20 420




420



420



420


3 4 N N 35kA @ 0.5 sec (30 cycles)

420

Opening voltage transformer or control power transformer compartments


420

Arc-Resistant Switchgear Type 1 or 2 (for clearing times of �0.5 sec with a perspective fault current not to exceed the arc-resistant rating of the equipment)

CB operation with enclosure door closed 0 1 N N 35kA @ 0.5 sec (30 cycles)

0 12

Insertion or removal (racking) of CBs from cubicles, doors closed

0 1 N N 35kA @ 0.5 sec (30 cycles)

0 12

Insertion or removal of CBs from cubicles with door open


420



15

Insertion or removal (racking) of ground and test device with door closed (For Grounding Only)

0 1 N N 35kA @ 0.5 sec (30 cycles)

420 12

Insertion or removal (racking) of voltage transformers on or off the bus door closed

0 1 N N 35kA @ 0.5 sec (30 cycles)

420 12

Other Equipment 1 kV through 38 kV Metal-enclosed interrupter switchgear, fused or unfused Switch operation of arc-resistant-type construction, tested in accordance with IEEE C37.20.7, doors closed only

0 1 N N 35kA @ 0.5 sec (30 cycles)

0 12

Switch operation, doors closed 2 4 N N 35kA @ 0.5 sec (30 cycles)

420



420



420


3 4 N N 35kA @ 0.5 sec (30 cycles)

420

Outdoor disconnect switch operation (hookstick operated)


420


Outdoor disconnect switch operation (gang-operated, from grade)


420

Insulated cable examination, in manhole or other confined space


420

Insulated cable examination, in open area 2 Y N 35kA @ 0.5 sec (30 cycles)

420

Notes: (1) Rubber insulating gloves are gloves rated for the maximum line-to-line voltage upon which work will be done. (2) Insulated and insulating hand tools are tools rated and tested for the maximum line-to-line voltage upon which work will be done, and are manufactured and tested in accordance with ASTM F 1505, Standard Specification for Insulated and Insulating Hand Tools. (3) Y = yes (required), N = no (not required). (4) The use of “N” does not indicate that rubber insulating gloves, insulated and insulating hand tools are not required in all cases. Rubber insulating gloves, insulated and insulating hand tools may be required by 130.4, 130.8 (C) (7), and 130.8(D). (5) For systems rated less than 1000 volts, the fault currents and upstream protective device clearing times are based on an 18 in. working distance. (6) For systems rated 1 kV and greater, the Hazard/Risk Categories are based on a 36 in. working distance. (7) For equipment protected by upstream current limiting fuses with arcing fault current to their current limiting range (1/2 cycle fault clearing time or less), the hazard/risk category required may be reduced by one number. (8) For power systems up to 600V, the Arc Flash Boundary was determined by using the following information: When 0.03 second trip time was used, that indicated MCC or panelboard equipment protected by a molded-case circuit breaker. Working distance used is (445 mm)18” arc gap used is 32 mm for switchgear and 25 mm for MCC protective device type 0 for all. When 0.33 or 0.5 second trip time was used, that indicated a LVPCB (drawout circuit breaker) in switchgear. Working distance is (610 mm) 24”, arc gap used is 32 mm, protective device type 0 for all. All numbers were rounded up or down depending on closest multiple of “5”. (9) For power systems from 1 kV to 38 kV, the Arc Flash Boundary was determined by using the following information: No maximum values were given in the 2009 edition of the NFPA 70E for short circuit current or operating time. Two sets of equations were performed [35 kA AIC and 0.2 second operating time] and [26 kA AIC and 0.2 second operating time]. 0.2 seconds was used by adding the typical maximum total clearing time of the circuit breaker to an estimated value for relay operation. This coincides with the IEEE 1584 values of 0.18 second operating time and 0.08 tripping time rounded off. A short-circuit current of 35 kA was used a maximum (HRC-4@ ~ 40cal/cm2) and 26 kA was used to compare the effects of lowering the short circuit current (HRC -4 @ ~30 cal/cm2). Working distance used was (909 mm) 36”, arc gap was (455 mm) 6”, protective device type 0 for all.



70E-347aWith the acceptance of this proposal, the title to Table 130.8(C)(15)(1) should also have been

revised. It should now read as follows:

The title of this table needs to reflect that it is for ac equipment only.



_______________________________________________________________________________________________70E-347a Log #CC1 EEW-AAA


70E-347aRevise committee action on Proposal 70E-347a as follows:

****Insert 70E_LCC1_Tbl130.7(C)(9)(2) Here****

The revisions to actions taken on Proposal 70E-347a correct transposition errors by removing notesaddressing the ac shock protection table, correct a calculation error, and provide additional information to harmonizewith actions taken on the ac shock protection table.

The revisions to actions taken on Proposal 70E-314a will correct transpose errors byremoving notes addressing the ac shock protection table, correct a calculation error, and provides additional informationto harmonize with actions taken on the ac shock protection table.



225Printed on 1/19/2011

70E_LCC1_Tbl 130.7(C)(9)(2)_Rec A2011 ROC 1

Revise Table 130.8(C)(15)(2) as follows:

Table 130.8(C)(15)(2) Hazard/Risk Category Classifications and Use of Rubber Insulating Gloves and Insulated and Insulating Hand Tools—dc Equipment

Tasks Performed on Energized Equipment Hazard/Risk Category

Rubber Insulating Gloves(bh)

Insulated and Insulating Hand Tools

Storage Batteries, Direct-Current Switchboards and other DC supply sources >100V <250V Notes 5,6 Parameters: Voltage: 250 V Maximum Arc Duration and Working Distance: 2 sec @ 18 inches

Work on energized electrical conductors and circuit parts, including voltage testing where arcing current is >1 kA and <4 kA Potential Arc Flash Boundary using above parameters at 4 kA: 36 inches

1a Y Y


2a Y Y


3a Y Y

Storage Batteries, Direct-Current Switchboards and other DC supply sources >250V <600V Notes 5,6 Parameters: Voltage: 600V Maximum Arc Duration and Working Distance: 2 sec @ 18 inches

Work on energized electrical conductors and circuit parts, including voltage testing where arcing current is >1 kA and <1.5 kA

1a Y Y

70E_LCC1_Tbl 130.7(C)(9)(2)_Rec A2011 ROC 2

Potential Arc Flash Boundary using above parameters at 1.5 kA: 36 inches Work on energized electrical conductors and circuit parts, including voltage testing where arcing current is >1.5 kA and <3 kA Potential Arc Flash Boundary using above parameters at 3 kA: 48 inches

2a Y Y


3a Y Y


4a Y Y

General Notes (applicable to the entire table): (a) If acid exposure is possible, the clothing shall be protective from acid and arc rated to the hazard according to ASTM F1891 or equivalent and evaluated by ASTM F1296 for acid protection. (b) In clean rooms or other electrical installations, which cannot allow leather protectors for arc flash exposure, ASTM F496 shall be followed for using rubber insulating gloves without leather protectors and the rubber gloves chosen shall be arc rated to the potential exposure level of the HRC category.



70E-347aRevise the 130.8(C)(7)(a) informational note as follows:

Informational Note: Table 130.8(C)(15)(1) and Table 130.8(C)(15)(2) provides further information on tasks where rubberinsulating gloves are required.

The informational note regarding the use of rubber insulating gloves needs a reference to the new DCHazard/Risk Category table to correlate with the action taken on Proposal 70E-347a.



_______________________________________________________________________________________________70E-349 Log #355 EEW-AAA


70E-347aThe objective of this comment is to request the technical committee to clarify if the reference to

notes 5 and 6 in Column 1 of the new Table 130.8(C)(15)(2) is meant to be to General Notes (a) and (b), or to someother notes that were not included in the proposal.

The committee action on Proposal 70E-347a created a new Table 130.8(C)(15)(2) Hazard/RiskCategory Classifications and Use of Rubber Insulating Gloves and Insulated and Insulating Hand Tools — dcEquipment. Column 1 of the new table refers twice to “Notes 5, 6” however the new table does not contain either a note5 or a note 6.The reference must be corrected for clarity in use of the document.

The committee action on Committee Comment 70E-247a (Log #CC1). meet the intent of therecommendation.



226Printed on 1/19/2011



70E-347aReject Proposal 70E-347a.

While the industry needs a table such as this and it has been good to see this proposed table publishedin the ROP for public review, inadequate technical substation has been provided to add this new table.

Proposal 70E-347a incorporates the most conservative of three methods, some based onempirical data, used in industry currently to estimate arc flash exposure from DC sources.


HICKMAN, P.: We reiterate our concerns that adequate technical substantiation has not been provided. Thecommittee statement indicating that “…the most conservative of three methods, some based on empirical data…” as abasis for the protection did not address our concerns.


_______________________________________________________________________________________________70E-351 Log #65 EEW-AAA



The action will require use of balaclava for Hazard Risk Category 2 work. Use of hard hat and faceshield along will not be allowed. Hard hat and face shield have been know to provide adequate protection alone.Requiring the use of a balaclava under the hard hat for this work is unnecessary. HRC 2* should be retained soemployees can continue to wear hard hat and face shields alone for HRC 2 and hard hat/face shield/balaclava for higherrisk HRC 2* work.

The committee reaffirms the acceptance of Proposal 70E-355. The requirement for a balaclavain HRC 2 is necessary for complete protection of the head.


BARRIOS, L.: The only substantiation provided for mandating the use of a balaclava sock hood is that injury "may"occur to the back of the head when wearing a face shield alone. No technical substantiation has been providedindicating injuries are likely to occur when wearing a properly rated and fitted face shield for incident energies below 12cal/cm2. This requirement is overly restrictive for lower energy exposures. Interesting enough, the committee took adifferent action on Comment 70E-355, where the committee indicates that the substantiation did not support requiringbalaclava sock hoods for HRC 1 tasks. The committee correctly based its decision on the lack of substantiation. Thecommittee should reverse it's action on this comment, because there is also lack of substantiation.WILMER, K.: Comment should have been accepted. The standard should not require the use of balaclava for

Hazard Risk category 2 work. Use of hard hat and face shield alone should be allowed as they have been known toprovide adequate protection. Requiring the use of a balaclava under the hard hat for this work is unnecessary. Otheractions will allow only balaclavas that cover the nose "tactical balaclavas" which will make the wearing of balaclavasunder hard hats for all HRC 2 work more uncomfortable. HRC 2* should be retained to allow employees to continue towear hard hat and face shields alone for HRC 2 and hard hat/ face shield/balaclava for higher risk HRC 2* work.


227Printed on 1/19/2011



70E-355Committee action should be reject.




BARRIOS, L.: The only substantiation provided for mandating the use of a balaclava sock hood is that injury "may"occur to the back of the head when wearing a face shield alone. No technical substantiation has been providedindicating injuries are likely to occur when wearing a properly rated and fitted face shield for incident energies below 12cal/cm2. This requirement is overly restrictive for lower energy exposures. Interesting enough, the committee took adifferent action on Comment 70E-355, where the committee indicates that the substantiation did not support requiringbalaclava sock hoods for HRC 1 tasks. The committee correctly based its decision on the lack of substantiation. Thecommittee should reverse it's action on this comment, because there is also lack of substantiation.WILMER, K.: See my Explanation of Negative on Comment 70E-351 (Log #65).


_______________________________________________________________________________________________70E-353 Log #30 EEW-AAA





The committee accepts the direction from the Technical Correlating Committee to correlate theaction on this proposal with the action taken on Proposal 70E-358. See the committee action taken on Comments70E-359 and 70E-360.



228Printed on 1/19/2011






The committee accepts the direction from the Technical Correlating Committee to correlate theaction on this proposal with the action taken on Proposal 70E-350. See the committee action taken on Comments70E-359 and 70E-360.



_______________________________________________________________________________________________70E-355 Log #90 EEW-AAA


70E-348Add "arc-rated balaclava" under the arc-rated clothing heading for Hazard/Risk Category 1.

All parts of the body are required to be protected by FR when inside the AFPB per 130.7(C)(1) and130.7(C)(5). Also, see Comment on Affirmative for Proposal 70E-348 in the ROP.

The substantiation does not support the expansion to use balaclavas for HRC 1 tasks. TheTables are based on hazard/risk and the committee concludes that the risk of injury to the back of the head in an HRC 1task is very low and a balaclava is not required.


HICKMAN, P.: The action taken on this comment appears to conflict with the existing requirements of 130.7(C)(1) and(5).


BARRIOS, L.: In its committee statement for Comment 70E-355, the committee correctly concludes that substantiationdoes not support the expansion to use balaclavas for HRC 1 tasks. The committee must use the same logic it used tocome to this conclusion and reconsider its actions on Comments 70E-351 and 70E-352, where the same degree ofsubstantiation was used.

229Printed on 1/19/2011



70E-363Delete the joules per square centimeter values in this Table.

By definition in Article 100, arc rating is expressed in calories per square centimeter. In addition,Section 3.2.7.3.3, Industry Practice, of the NEC Style Manual indicates that where industry practice is to express units ininch-pound units, the inclusion of SI units shall not be required.



HICKMAN, P.: We support the decision to delete the reference to joules per square centimeter and to list calories persquare centimeter only as provided for in 3.2.7.3.3 (Industry Practice) of the NEC Style Manual. Calories per squarecentimeter is industry practice.

_______________________________________________________________________________________________70E-357 Log #131 EEW-AAA


70E-357The committee action on 70E-357 should have been Accept. The “AN” for gloves in Hazard/Risk

Category 0 should be deleted so that workers are required to wear gloves for tasks listed as Hazard/Risk Category 0.This comment is submitted by the full CSA Z462 Workplace Electrical Safety Technical Committee.

The “AN” (as needed) does not provide the worker with usable guidance as to the circumstances when gloves would beneeded.According to 130.7(C)(9) FPN No. 1 paragraph 2, Hazard/Risk Category 0 does not mean that the "risk" or likelihood of

an arc flash event is impossible; it means the likelihood is "extremely low." As such, there is still the possibility of an arcflash event.Should an arc flash event occur it is important to recognize that the employee’s hands will be closer to the source of

the arc flash energy.Based on the parameters of Table 130.7(C)(9) users of the Hazard/Risk Category method may potentially be exposed

to incident energy as high as 40 calories/cm2. In such a scenario the employee’s hands would potentially be exposed toincident energy significantly higher than 40 calories/cm2. Even in instances where incident energy may be relatively lowat the typical working distance of 18 inches, it will still be significantly higher at the employee’s hands.Section 130.3 (B) (1) recognizes the need for additional PPE for parts of the body that are closer to the arc flash

hazard than the working distance.

The submitter has not substantiated the need for leather gloves for all HRC 0 tasks. There arecertain HRC 0 tasks in Table 130.7(C)(9) such as reading a panel meter while operating a meter switch, where leathergloves are not deemed necessary.



230Printed on 1/19/2011


_______________________________________________________________________________________________Roger F. Parry, The DuPont Company, Inc.

70E-362Adopt the concept of multilayer systems with for meeting the requirements

of HRC 2 as noted in the original ROP comment. This includes the following changes that were identified in Proposal70E-362 (Log #478):Revise all occurrences of “...FR Protective Clothing System...”Revise Note 1: “See Table 130.7(C)(11) for typical clothing characteristics and 130.7(C)(12)(a) for layering information.

Arc rating for a garment or system of garments is expressed in cal/cm2.”Revise Note 5: “A multilayer protective clothing system based on FR shirt and FR pants over flammable underlayers

used for Hazard/Risk Category 2 is allowed and shall have a minimum arc rating of 8. Flammable underlayers that arenot part of a multilayer protective clothing system shall be completely covered by a suitably rated protective clothingsystem.”Revise Note 6: “An alternate is to use FR coveralls (minimum arc rating of 8) instead of FR shirt and FR pants. The

resulting system shall have a minimum arc rating of 8.”A significant technical basis was presented in the original proposal to justify the reinstatement of the

use of arc rated multilayer systems using flammable underlayers for PPE for HRC 2 (part of proposal not dealing withremoval of “risk”). These systems were documented to clearly meet and exceed the requirements of Table 130.7(C)(10)(with the addition of lightweight flammable underlayer components obtaining an arc rating on the FR component basedon the Breakopen Threshold Energy value [EBT]). No technical basis was supplied by the 70E technical committee toreject this proposal and information presented.These systems (flammable underlayers in arc rated multilayer systems) demonstrate that significant added arc thermal

energy protection is afforded ((in the form of alternate solutions to HRC 2 protection requirements) with underlayerignition values in excess of ~2-3X the arc rating.A further benefit to the inclusion of these combinations is enhanced usability by providing potential ergonomic and heat

stress related improvement opportunities. As noted, these systems are viable PPE solutions recognized and arcrateable by the required (ASTM F 1959) testing standard, the basis for wearing apparel PPE arc ratings in NFPA 70E. Inaddition, utility is demonstrated as multilayer systems containing flammable underlayers are currently and preferablyused commercially by users who perform an arc hazard calculation and follow the guidance identified in 130.4(B)(1) and130.7(C)(12). These users are looking for cost, ergonomic, and heat stress solutions.Note that the arc rating, using ASTM F 9159, of a multilayer system that incorporates flammable layers is based on the

performance of the FR layers - essentially identifying when breakopen (Breakopen Threshold Energy value [EBT]) of theFR layer occurs and a flammable underlayer is exposed.

The HRC method provides a means for PPE selection. The submitter's recommendation toadd non-melting flammable under layers to the method creates unnecessary complexity.



231Printed on 1/19/2011



70E-350This proposal should have been accepted in principle (APR)

The requirement for an FR hard hat liner should be relocated (as suggested) from the “protective equipment” list to the“protective clothing” list as follows:Arc-rated jacket, parka, rainwear, or hard hat liner (AN)

This comment is submitted in an effort to address the note from the TCC directing the committee tocorrelate the action on this proposal with the action taken on proposal 70E-358.The TCC requested this correlation due to the fact that an action to accept (as taken on this proposal) infers that all of

the submitters’ suggestions were accepted as submitted. However, the 70E technical committee modified thesubmitters’ suggestion for usability and correlation with other actions including the action o proposal 70E-358. Therecommendation in this comment is exactly the same as the text in the 70E draft prepared by NFPA staff.



_______________________________________________________________________________________________70E-360 Log #165 EEW-AAA


70E-358Continue to accept in principle (APR)

The suggested revision should be incorporated into the “protective clothing” list in HRC’s 1 and 2 as follows:Arc-rated jacket, parka, rainwear, or hard hat liner (AN)

This comment is submitted in an effort to address the note from the TCC directing the committee tocorrelate the action on this proposal with the action taken on proposal 70E-350.The TCC requested this correlation due to the fact that there were differences in the actions taken on these two

proposals. The committee intent is clear and is seen in the 70E draft prepared by NFPA staff. The suggestions made bythe submitters of proposals 70E-350 and 70E-358 are very similar and the action on both proposals should have been toaccept in principle. The intent of this comment is to provide clarification for the TCC and the public. Additionally, HRC 2*is deleted by other committee actions and the suggested revisions occur only in HRC 1 & 2. The recommendation in thiscomment is exactly the same as the text in the 70E draft prepared by NFPA staff.



232Printed on 1/19/2011



70E-355Committee action should be reject.




BARRIOS, L.: See my negative ballot comment on Comments 70E-351 and 70E-352.WILMER, K.: See my Explanation of Negative on Comment 70E-351 (Log #65).


_______________________________________________________________________________________________70E-362 Log #194 EEW-AAA




The comment is rejected based on Section 4.4.5 of the NFPA Regulations GoverningCommittee Projects covering the required content of public comments. Referring to comments on other proposals doesnot provide the committee with a direct recommendation and related substantiation.



233Printed on 1/19/2011



70E-347aWith the acceptance of this proposal, this article should also have been revised. It should now read

as follows:Once the Hazard/Risk Category has been identified

from Tables 130.8(C)(15)(1) or 130.8(C)(15)(2) (including associated notes) and the requirements of 130.8(C)(915) toTable 130.8(C)(16) shall be used to determine the required PPE for the task...

The addition of the dc table needs to be added to this article.Also corrected the change in section 130.8(C)(9) to 130.8(C)(15).



_______________________________________________________________________________________________70E-364 Log #285 EEW-AAA


70E-355Reject the proposal and restore the text to that existing in the 2009 Edition.

Substantiation for the change was not provided with the proposal. If the present tasks of Table130.7(C)(9)associated with “HRC 2” are examined, do these tasks realistically require a sock hood in addition to anarc-rated face shield? Adding this requirement may lead to blatant noncompliance with the standard due to the worker’sperception of excessive PPE for the task. Keep in mind the present FPN No. 1 of 130.7(A): “FPN No. 1: The PPErequirements of 130.7 are intended to protect a person from arc flash and shock hazards. While some situations couldresult in burns to the skin, even with the protection selected, burn injury should be reduced and survivable....”



BARRIOS, L.: See my negative ballot comments on Comments 70E-351 and 70E-352. Also as indicated by thesubmitter, the Standard begins to lose credibility when requirements are introduced that are not technicallysubstantiated and where the worker's perception of the PPE requirements are blatantly excessive.WILMER, K.: See my Explanation of Negative on Comment 70E-351 (Log #65).


234Printed on 1/19/2011



70E-355Reject the proposal and restore the text to that existing in the 2009 edition.

Adequate substantiation for the change was not provided with the proposal. If the present tasks ofTable 130.7(C)(9) associated with "HRC 2" are examined, do these tasks realistically require a sock hood in addition toan arc-rated face shield? Adding this requirement may lead to blatant noncompliance with the standard due to theworker's perception of excessive PPE for the task. Keep in mind the present FPN No. 1 of 130.7(A) which states: "ThePPE requirements of 130.7 are intended to protect a person from arc flash and shock hazards. While some situationscould result in burns to the skin, even with the protection selected, burn injury should be reduced and survivable..."



BARRIOS, L.: See my negative ballot comments on Comments 70E-351 and 70E-352. Also as indicated by thesubmitter, the Standard begins to lose credibility when requirements are introduced that are not technicallysubstantiated and where the worker's perception of the PPE requirements are blatantly excessive.WILMER, K.: See my Explanation of Negative on Comment 70E-351 (Log #65).


_______________________________________________________________________________________________70E-366 Log #320 EEW-AAA


70E-357This proposal should have been Accepted.

The hands will be exposed to more energy than the body in the event an arc flash occurs. Leathergloves are shown in the Table as "AN". "As Needed" has not been defined other than the remark at the end of the tableAN = As needed (optional). This means leather gloves are not required at any time for any task that is HRC 0. If theseTables will continue to be used then they should err on the side of caution.

The submitter has not substantiated the need for leather gloves for all HRC 0 tasks. There arecertain HRC 0 tasks in Table 130.7(C)(9) such as reading a panel meter while operating a meter switch, where leathergloves are not deemed necessary.



235Printed on 1/19/2011



70E-356The Committee should have accepted the deletion of the word “Protective”.

In NFPA Glossary of Terms there is a definition for “protective clothing” an important part of thatdefinition are the words “clothing designed to provide minimum protection”. The listed in the Table related to HRC 0 arenot designed to provide protection nor have they been given a rating by anybody. To call these items “protectiveclothing” is misleading the public into thinking they are “rated”. Unless someone can provide a “rating” for this clothing itshould not be called “protective clothing”. It is clothing that may or may not provide any protection.

The committee considers all clothing requirements in 130.7(C)(10) to be protective.


PACE, D.: This comment should have been accepted. The word "protective" should be deleted as proposed. Thecommittee statement saying "the committee considers all clothing in 130.7(C)(10) to be protective" is well and good butthe fact remains that the existing wording is a source of confusion that needs to be removed. If clothing listed isprotective, then there has to be guidance on what protection it provides and that does not exist. Listing the articles asrequired clothing is correct, calling them protective is not. They have no rating. If the committee intends them to beused up to a certain exposure level, say 1.2 cal/cm2 then it should say that.


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HRC 1Leather work shoes (AN) 11HRC 2Leather work shoes11HRC 3Leather work shoes11HRC 4Leather work shoes11*EH (Electrical Hazard) shoes meeting ASTM F2413 provide extra protection since they have insulated soles but they

may not be used for primary protection. DI (Dielectric Shoes)shoes meeting ASTM F1117 shall be used when the worklocation or task may introduce step potential hazards. EH leather shoes may be worn under DI overshoes.

This wording clarifies the mention of both the EH F2413 shoes AND the DI F2413 shoes. DI shoes arementioned in F2413 as shoes which meet ASTM F1117. EH shoes meet the sole test in F2413. In 130.7(C) (7) thestandard points out that Insulated soles may not be used for primary protection but doesn’t clarify that the standard isspeaking of DI shoes vs. EH shoes. Using the standard terms, EH and DI and citing the proper ASTM Standards F2413for EH and F1117 for DI shoes will make things clearer.

The suggested note does not provide clarity or usability. Table 130.7(C)(9) does not addressEH or DI footwear.The table does not mention EH or DI at this point but it should. There is no huge cost in EH shoes and they have been

shown to save lives but the standard confuses these shoes with dielectric shoes in all except one statement. Thestatement note above will clarify what the committee means. If you cannot agree to make this a requirement, pleaseconsider making it an explanatory note. OSHA clearly defines EH and DI shoes as does ASTM F2413 but neither givesguidance on when to use them. NFPA 70E only mentions that EH shoes may not be used for step potential but doesn’tcite clearly that DI shoes are to be used for step potential. You call them di electric overshoes which is ONLY one typeof di-electric shoe. I would suggest mentioning footwear meeting the proper standard rather than a vague term.We talk about shoes and overshoes but never define what we mean. Either they are EH or DI or neither but make the

requirement clear. Just saying shoes then listing ASTM F2413 which contains all shoes is unclear and opens companiesup to liability and interpretation.When we mean DI say so. When we mean EH, say so. If we don’t mean either, say so.Citing D2413 can mean ED shoes which should only be used when they are required to prevent a greater hazard like

explosions or in chip factories in which they prevent ruining production runs. Listing ASTM F2413 is not enough.

The committee accepts in principle the inclusion of information on the benefits of using EHshoes. The committee has accepted a new informational note to 130.7(C)(7). The informational note in 130.7(C)(7) hasbroader application and is not limited to the tables. The committee rejects the inclusion of the note in Table130.7(C)(10). Table 130.7(C)(10) does not address shock protection. See the action and statement on Comment70E-303



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The requirement to add balaclava (sock hoods) to Table 130.7(C)(10) for HRC 2 is not technicallysubstantiated. No reports have been brought to the NFPA 70E committee showing individuals have been injured whilewearing properly rated face shields “with wrap-around guarding to protect not only the face, but also the forehead, ears,and neck”.



BARRIOS, L.: See my negative ballot comments on Comments 70E-351, 70E-352, 70E-364 and 70E-365. There hasbeen no technical substantiation presented to mandate the use of balaclava sock hoods for incident energy exposuresless than 12 cal/cm2. The committee should use the same logic it used to correctly reach the conclusion that abalaclava sock hood is not required for HRC 1 and make the same decision for HRC2. The same level of justificationwas used in both cases.WILMER, K.: See my Explanation of Negative on Comment 70E-351 (Log #65).


_______________________________________________________________________________________________70E-370 Log #1 EEW-AAA



Garments that are not arc-rated shall not be permitted to be used to increase the arc rating of a garment or of aclothing system.

The recommended text revising the committee action on Proposal 70E-372 is intended to furtherclarify that garments that are not arc-rated cannot increase the arc rating of either a garment or a clothing system. Therecommended text incorporates the text recommended in the comment on affirmative on Proposal 70E-372.



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70E-372The Committee Action on Proposal 70E-372 should have been Reject:

The committee should not have accepted adding a new sentence to the end of the second paragraph of Section130.7(C)(12): “Garments that are not arc-rated shall not be permitted to be used to increase the arc rating of a clothingsystem.”Also, the committee should not delete the two sentences in Section 130.7(C)(12) as follows: “All personal protective

equipment shall be maintained in a sanitary and functionally effective condition. Personal protective equipment items willnormally be used in conjunction with one another as a system to provide the appropriate level of protection.”

1. The proposal to disallow the use of non-arc-rated garment to increase the arc rating of a clothingsystem:a) Is in conflict with ASTM F 1959 Standard Test Method for Determining the Arc Rating of Materials for ClothingSection 3.1.11.1, which permits multiple-layer arc rated specimens to contain ignitable underlayers.b) Lacks technical substantiation.The submitter’s substantiation regarding HRC1 to 4 clothing is not germane to the issue of how a system arc-rating isobtained. ASTM F 1959 specifies how the arc-rating is to be obtained, and as noted, permits the use of ignitableunderlayers to achieve a system arc-rating.The Arc Rating of a multilayer system is typically higher and therefore offers substantially more thermal protectionagainst a predicted second-degree skin burn injury – see ASTM Research Report No. FR18-1001 / ASTMF18-1036-CPMS for an example of protection offered by FR/non-FR layered systems. (We should attach this report ifwe reference it)Layered arc-rated clothing systems incorporating either non-ignitable or ignitable underlayers are used as daily-wear arcflash protection to mitigate ergonomic and heat stress related issues.2. The first sentence proposed for deletion by the submitter requires PPE to be maintained in a sanitary and

functionally effective state. In community garment situations, this is an important maintenance selection criteria andshould be reinforced by leaving the existing text within this section.3. The second sentence proposed for deletion by the submitter is a statement of fact and needs to be retained. It

reinforces that the concept of – e.g., multi-layered systems (e.g., FR over FR, FR over non-FR clothing, etc.),multi-component systems (e.g., switching jacket combos, beekeeper hoods with integrated headwear, etc.), and otheritems in addition to clothing (e.g., foot protection, insulated gloves & leather protectors, eye wear, hearing protection,etc.) - make up the arc personal protective equipment ensemble.

The committee continues to support the action taken on Proposal 70E-372 as modified bycomment 70E-370. The committee continues to prohibit flammable underlayers from counting towards the arc-ratingbecause there is no assurance that there will be consistency on the part of the user in selecting the tested underlayer.The committee continues to delete and relocate the text in this section for clarity. See Section 130.7(C)(16).


HITTEL, M.: The appropriate action is accept. The actions taken are in conflict with ASTM F1959.


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70E-373The Committee Action on Proposal 70E-373 should have been Reject:

The committee should not have accepted adding a new sentence to the end of the second paragraph of Section130.7(C)(12): “Garments that are not arc-rated shall not be permitted to be used to increase the arc rating of a clothingsystem.”Also, the committee should not delete the two sentences in Section 130.7(C)(12) as follows: “All personal protective

equipment shall be maintained in a sanitary and functionally effective condition. Personal protective equipment items willnormally be used in conjunction with one another as a system to provide the appropriate level of protection.”

1. The proposal to disallow the use of non-arc-rated garment to increase the arc rating of a clothingsystem:a) Is in conflict with ASTM F 1959 Standard Test Method for Determining the Arc Rating of Materials for Clothing

Section 3.1.11.1, which permits multiple-layer arc rated specimens to contain ignitable underlayers.b) Lacks technical substantiation.

The submitter’s substantiation regarding HRC1 to 4 clothing is not germane to the issue of how a system arc-rating isobtained. ASTM F 1959 specifies how the arc-rating is to be obtained, and as noted, permits the use of ignitableunderlayers to achieve a system arc-rating.The Arc Rating of a multilayer system is typically higher and therefore offers substantially more thermal protectionagainst a predicted second-degree skin burn injury – see ASTM Research Report No. FR18-1001 / ASTMF18-1036-CPMS for an example of protection offered by FR/non-FR layered systems.Layered arc-rated clothing systems incorporating either non-ignitable or ignitable underlayers are used as daily-wear arcflash protection to mitigate ergonomic and heat stress related issues.2. The first sentence proposed for deletion by the submitter requires PPE to be maintained in a sanitary and

functionally effective state. In community garment situations, this is an important maintenance selection criteria andshould be reinforced by leaving the existing text within this section.3. The second sentence proposed for deletion by the submitter is a statement of fact and needs to be retained. It

reinforces that the concept of – e.g., multi-layered systems (e.g., FR over FR, FR over non-FR clothing, etc.),multi-component systems (e.g., switching jacket combos, beekeeper hoods with integrated headwear, etc.), and otheritems in addition to clothing (e.g., foot protection, insulated gloves & leather protectors, eye wear, hearing protection,etc.) - make up the arc personal protective equipment ensemble.

The committee continues to support the action taken on Proposal 70E-373 as modified bycomment 70E-370. The committee continues to prohibit flammable underlayers from counting towards the arc-ratingbecause there is no assurance that there will be consistency on the part of the user in selecting the tested underlayer.The committee continues to delete and relocate the text in this section for clarity. See Section 130.7(C)(16).




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70E-372Reject this proposal and eliminate the committee revision “Garments that are not arc-rated shall not

be permitted to be used to increase the arc rating of a clothing system.”The new sentence proposed for inclusion by both the submitter and committee action is unjustified and

is in conflict with the ASTM standard test method, ASTM F 1959 (the standard responsible for determining the ArcRating value). A fabric can either have an Arc Rating based on its Arc Thermal Performance Value [ATPV] or itsBreakopen Threshold Energy value [EBT] (see section 3.1.11.1 and 4.3.1 of ASTM F1959 for details). For example, asingle layer FR fabric will, in most cases, have an Arc Rating based on ATPV. However, by adding a flammableunderlayer (such as cotton or other non-melting material which is allowed by the F1959 standard), additional thermalinsulation is provided by the flammable layer such that when the composite is exposed to an arc,breakopen of the FR layer occurs before a burn injury is predicted. In this case, the Arc Rating of theis the Breakopen Threshold Energy value [EBT] (in multiple layer specimens, if some of the layers are ignitable,breakopen occurs when these layers are exposed). The Arc Rating is typically higher in this configuration (and offersother benefits such as providing substantially more thermal protection against a predicted second-degree skin burninjury – see ASTM Research Report No. FR18-1001 / ASTM F18-1036-CPMS for an example of protection offered byFR/non-FR layered systems).In addition, many companies currently employ an effective layering program with FR and flammable underlayers

that meets the arc hazard protection requirements to mitigate ergonomic and heat stress related issues.And opposed to the submitter’s assertion, there’s been no technical basis supplied to support restricting users (andeliminating current commercial hybrid layering marketplace solutions that perform against the ASTM F1959 standard)from selecting whatever arc protective they wish to employ when adopting 130.7(C)(12) that protects against thearc hazard and at the same time addresses their other requirements.Also note that the current text in 130.7(C)(12)(a) reiterates the system arc rating breakopen requirements for these

types of layered systems.

The committee continues to support the action taken on proposal 70E-372 as modified bycomment 70E-370.




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70E-373Reject Proposal 70E-373 (Log #64).

This language is a restatement of language in Proposal 70E-372. Proposal 70E-372 places thelanguage into the correct location. Document clarity.

The committee concludes that the language is necessary in both areas as one deals withfactors in selection of protective clothing the other area deals with layering.



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70E-373Reject this proposal and eliminate the committee revision “Garments that are not arc-rated shall not

be permitted to be used to increase the arc rating of a clothing system.”The new sentence proposed for inclusion by both the submitter and committee action is unjustified and

is in conflict with the ASTM standard test method, ASTM F 1959 (the standard responsible for determining the ArcRating value). A fabric system can either have an Arc Rating based on its Arc Thermal Performance Value [ATPV] or itsBreakopen Threshold Energy value [EBT] (see section 3.1.11.1 and 4.3.1 of ASTM F1959 for details). For example, asingle layer FR fabric will, in most cases, have an Arc Rating based on ATPV. However, by adding a flammableunderlayer (such as cotton or other non-melting material which is allowed by the F1959 standard), additional thermalinsulation is provided by the flammable layer such that when the composite multi-layer system is exposed to an arc,breakopen of the FR layer occurs before a burn injury is predicted. In this case, the Arc Rating of the multi-layer systemis the Breakopen Threshold Energy value [EBT] (in multiple layer specimens, if some of the layers are ignitable,breakopen occurs when these layers are exposed). The Arc Rating is typically higher in this configuration (and offersother benefits such as providing substantially more thermal protection against a predicted second-degree skin burninjury – see ASTM Research Report No. FR18-1001 / ASTM F18-1036-CPMS for an example of protection offered byFR/non-FR layered systems).In addition, many companies currently employ an effective layering program with FR and flammable underlayers for

everyday use that meets the arc hazard protection requirements to mitigate ergonomic and heat stress related issues.And opposed to the submitter’s assertion, there’s been no technical basis supplied to support restricting users (andeliminating current commercial hybrid layering marketplace solutions that perform against the ASTM F1959 standard)from selecting whatever arc protective system they wish to employ when adopting 130.7(C)(12) that protects against thearc hazard and at the same time addresses their other requirements.Also note that the current text in 130.7(C)(12)(a) reiterates the system arc rating breakopen requirements for these

types of layered systems.

The committee continues to support the action taken on Proposal 70E-373 as modified bycomment 70E-370. The committee continues to prohibit flammable underlayers from counting towards the arc-ratingbecause there is no assurance that there will be consistency on the part of the user in selecting the tested underlayer.




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Garments that are not arc-rated shall not be permitted to be used to increase the arc rating of a garment or of aclothing system.

The recommended text revising the committee action on Proposal 70E-373 is intended to furtherclarify that garments that are not arc-rated cannot increase the arc rating of either a garment or a clothing system. Therecommended text incorporates the text recommended in the comment on affirmative on Proposal 70E-373.




_______________________________________________________________________________________________70E-377 Log #193 EEW-AAA




The comment is rejected based on Section 4.4.5 of the NFPA Regulations GoverningCommittee Projects covering the required content of public comments. Referring to comments on other proposals doesnot provide the committee with a direct recommendation and related substantiation.



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70E-378The action on the proposal should have been to “Accept in Part,” as described in Mr. Hamer’s

Explanation of Negative. Revised the wording as follows: “Leather protectors or Arc-Rated gloves shall be worn whererequired for arc flash protection.”

“Leather protectors” are meant to be used in conjunction with insulating rubber gloves, and notseparately. There is no reason that regular leather gloves cannot be used for arc flash protection. The acceptability ofleather gloves has been demonstrated by experience.

Revise Section 130.7(C)(13)(c) as modified by Proposals 70E-378 and 70E-375 as follows:(c) Hand Protection.(1) Heavy-duty leather gloves protectors or arc-rated gloves shall be worn where required for arc flash protection.Informational Note: Heavy-duty leather gloves are made entirely of leather with minimum thickness of 0.03" (0.7mm),are unlined or lined with non-flammable, non-melting fabrics. Heavy-duty leather gloves meeting this requirement havebeen shown to have ATPV values in excess of 10 cal/cm2.(2) Where insulating rubber gloves are used for shock protection, leather protectors shall be worn over the rubber

gloves.Informational Note: Rubber insulating gloves, arc rated gloves, or leather protectors provide hand protection against

arc flash hazard. Leather protectors for rubber insulating gloves provide protection suitable up to 8 cal/cm2. During higharc flash exposures leather can shrink and cause a decrease in protection. The leather protectors worn over rubberinsulating gloves provide additional arc flash protection for the hands for arc flash protection exposure. over 8 cal/cm2.2. Change leather gloves to “Heavy duty leather gloves “ in Table 130.7( C)(10)

The differences between use of leather gloves and heavy duty leather gloves have beenreconciled. The description of acceptable heavy duty leather gloves have been revised from weight ( 12 oz/yd2) tothickness of leather based on information on the current manufacturing control methods.



HICKMAN, P.: We suggest that the metric dimension should appear first without parenthesis and the “0.03” dimensionshould follow in parenthesis.

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70E-378The action on the proposal should have been to "Accept in Part" as described in Mr. Hamer's

explanation of Negative.Revise the wording as follows: "Leather protectors or Arc-Rated gloves shall be worn where required for arch flash

protection.""Leather protectors" are meant to be used in conjunction with insulating rubber gloves, and not

separately. There is no reason that regular leather gloves cannot be used for arc flash protection. The acceptability ofleather gloves has been demonstrated by experience.




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70E-380Committee action should Reject.

The action will mean that employers who do calculations must require flash hoods for exposures over12 cal/cm2. But employers who use Tables C9 and C10 will be able to use balaclava under a hard hat for HRC 2exposures. Table C10 indicates that HRC 2 protective equipment must have minimum arc rating of 8 cal/cm2 and HRC3 must have minimum arc rating of 25 cal/cm2. So, for the same task, a table user will be allowed to wear a hard hatand balaclava while someone who does calculations will be required to wear a flash hood. The committee should clarifyif this is the intent.

The committee reaffirms acceptance Proposal 70E-380. It is necessary to require an arc ratedbalaclava in addition to an arc rated face shield when the back of the head is within the arc flash protection boundary.Additionally, an arc rated hood must be used when the anticipated incident energy exposure exceeds 12 calories percentimeter squared.


BARRIOS, L.: See my negative ballot comments on Comments 70E-351, 70E-352, 70E-364, 70E-365 and 70E-369.HITTEL, M.: The appropriate action is accept. The committee statement is based on original substantiation that does

not justify this change. Part 1 of the original proposal expands requirement for "when the back of the head is within thearc flash boundary" but the substantiation clearly contemplates exposures greater than 12 cal and the convective effectsinvolved. Part 2 of the proposal is substantiated in the original proposal, but Part 1 does not necessarily follow from it(i.e. it is possible for the head to be within the arc flash boundary, but the exposure is less than 12 cal).WILMER, K.: Comment should have been accepted. The proposal as accepted will require employers who do

calculations to require flash hoods for exposures over 12 cal/cm2. But employers who use tables C9 and C10 will beable to use balaclava under a hard hat for HRC 2 exposures. Table C10 indicates that HRC 2 protective equipmentmust have minimum arc rating of 8 cal/cm2 and HRC 3 must have minimum arc rating of 25 cal/cm2. So, for the sametask, a table user will be allowed to wear a hard hat and balaclava while someone who does calculations will be requiredto wear a flash hood.


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The action will mean that employers who do calculations must require flash hoods for exposures over12 cal/cm2. But employers who use tables C9 and C10 will be able to use balaclava under a hard hat for HRC 2exposures. Table C10 indicates that HRC 2 protective equipment must have minimum arc rating of 8 cal/cm2 and HRC3 must have minimum arc rating of 25 cal/cm2. So, for the same task, a table user will be allowed to wear a hard hat andbalaclava while someone who does calculations will be required to wear a flash hood. The committee should clarify ifthis is the intent.



BARRIOS, L.: See my negative ballot comments on Comments 70E-351, 70E-352, 70E-364, 70E-365 and 70E-369.HITTEL, M.: See my Explanation of Negative on Comment 70E-380 (Log #182).WILMER, K.: See my Explanation of Negative on Comment 70E-380 (Log #182).


_______________________________________________________________________________________________70E-382 Log #102 EEW-AAA


70E-380Delete second sentence in 1: "Arc rated balaclauas..."

This sentence is a secondary definition which conflicts with the Article 100 Balaclaua definition.Document clarity.



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70E-380The committee action should be Reject.

Support Mr. Hamer's comment in the Explanation of Negative.





_______________________________________________________________________________________________70E-384 Log #402 EEW-AAA


70E-380Reject the first part of this proposal.

1. An arc rated balaclava shall be used with an arc rated faceshield when the back of the head is within the Arc FlashProtection Boundary. Arc rated balaclavas shall cover the neck and head other than the eyes, nose and mouth area. Anarc rated hood shall be permitted to be used instead of an arc rated faceshield and balaclava.

As the accepted text now reads balaclava is required whenever the back of the head is within the AFboundary. There should be some research into prior injuries that could have been prevented before making thisrequirement. The 70E TC should evaluate the normal practice of facing the hazard so that the back of the head wouldnot be exposed even though it is in the AF boundary. How many injuries would have been prevented by this proposedchange? The industry is depending upon the 70E TC for real safety answers, not just a straight line extension of OSHA.

The committee accepts the recommendation to delete the second sentence but rejects thre remainder of therecommendation.

The committee action on Comment 70E-382 deletes the second sentence. The committeereaffirms acceptance of Proposal 70E-380 as modified by Comment 70E-382. It is necessary to require an arc ratedbalaclava in addition to an arc rated face shield when the back of the head is within the arc flash protection boundary.




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70E-380Remove the words "nose and mouth area" from the accepted language.

There is no reason to allow a balaclavas to have unprotected holes. Eye openings allow primaryprotection such as safety glasses or goggles to be accommodated.


BARRIOS, L.: No technical substantiation was provided to require covering of the nose and mouth area with thebalaclava sock hood.


HICKMAN, P.: While we do not necessarily disagree with the action, we note that we do not believe that the NFPA70E Technical Committee was provided with definitive information on what part of the face is permitted to remainuncovered by an arc rated balaclava.

_______________________________________________________________________________________________70E-386 Log #340 EEW-AAA


70E-380Revise the accepted text to read as follows for clarity.

Head Protection1. An arc flash hood rated for the anticipated incident energy exposure shall be used.2. An arc rated balaclava with an arc rated face shield shall be permitted for incident energy level exposure of 12

cal/cm2 and below, when the back of the head is within the arc flash boundary . The balaclava shall cover the neck andhead other than the eyes, nose and mouth area.

The accepted text has been rewritten for clarity. This also clarifies that a balaclava is permitted as analternate where arc flash exposure is 12 cal/cm2 or less and is not necessarily the preferred choice with arc flash hoodas an alternate.

The recommended revision does not provide additional clarity.



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70E-376, 70E-377Remove the following newly accepted words: "When the incident energy exposure is greater than

12 cal/cm2 a suitably rated arc flash suit hood shall be used." This language is duplicated in Proposal 70E-380 (Log#244) Subsection 2 where it is appropriately placed.

Document clarity.



_______________________________________________________________________________________________70E-388 Log #238 EEW-AAA


70E-376The committee action should have been to Accept in Part and that part was the changes to part (c).

The information being added to (a) is not required since it is redundant with the section it is added to.We are now requiring a "suitably rated arc flash suit hood" when wearing a "suitably rated arc flash suit" which,according to the previous sentence in the paragraph, includes the hood. Also, the addition to (a) is a duplication of130.8(C)(10)(b)(2) which was added by proposal70E-380 and there is no need to have the requirement listed twice.

The recommendation is unclear. The recommendation does not provide specific text. Thecomment does not comply with Section 4.4.5 of the NFPA Regulations Governing Committee Projects.



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The action will mean that employers who do calculations must require flash hoods for exposures over12 cal/cm2. But employers who use tables C9 and C10 will be able to use balaclava under a hard hat for HRC 2exposures. Table C10 indicates that HRC 2 protective equipment must have minimum arc rating of 8 cal/cm2 and HRC3 must have minimum arc rating of 25 cal/cm2. So, for the same task, a table user will be allowed to wear a hard hat andbalaclava while someone who does calculations will be required to wear a flash hood. The committee should clarify ifthis is the intent.

See committee action and statement on Comment 70E-380.


BARRIOS, L.: See negative ballot comment on Comment 70E-380.WILMER, K.: See my Explanation of Negative on Comment 70E-380 (Log #182).


_______________________________________________________________________________________________70E-390 Log #92 EEW-AAA


70E-375Accept Proposal 70E-375 in principle by replacing "leather protectors" with "heavy duty leather

gloves" in the committee action.See explanation of negative in ROP ballot on Proposal 70E-305. Leather protectors are not intended

to be used as work gloves and have not been evaluated for use without leather protectors and are not intended to beused as arc flash protection in accordance with the scope of ASTM F696, Standard Specification for Leather Protectorsfor Rubber Insulating Gloves and Mittens.




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70E-375Remove all references to 8 cal/cm2 in the Informational Note.

Currently neither leather protectors or insulated gloves are rated for arc protection. Additionally, noASTM test method exists to qualify such rating.




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70E-381Continue to accept proposal 70E-381 as modified below. Note that 130.7(C)(14) from the 2009

edition of NFPA 70E has been editorially relocated in the proposal stage to 130.8(C)(11).Modify the first paragraph as follows:

FR Arc rated clothing shall be listed and shall meet the requirementsdescribed in 130.7(C)(14) and 130.7(C)(15).

The action taken by the committee in the proposal stage to further clarify the information in the existingFine Print/Informational Notes is prudent.The acronym FR is deleted because the definition of Flame Resistant (FR) was deleted in the proposal stage.The submitter of this proposal has pointed out that there are significant issues that are worthy of additional

consideration with the manufacturing of protective clothing. The action of the NFPA 70E Technical Committee to acceptproposal 70E-381 clearly illustrates that the committee recognizes that serious issues exist in the manufacturing of arcrated clothing.The requirement for materials to meet an ASTM standard is prudent. However, the applicable ASTM standard

addresses the material only. There is presently no mechanism in place to ensure that each piece of arc rated clothingmanufactured/assembled will perform as anticipated. The only assurance we have today is that that the fabricperformance has been evaluated. It is imperative to mandate that garments used as personal protective equipment (arcrated clothing) be manufactured in accordance with a standard that is in essence a manufacturing quality assuranceplan.Requiring that clothing designed to protect persons from thermal energy be listed is not new in the family of NFPA

codes and standards. In fact, the present edition (2007) of NFPA 2112requires that garments be listed and labeled. The requirement

exists in Chapter 4 as follows:4.1.3 All flame-resistant garments shall be labeled and listed.Mandating that all arc rated garments be listed, is the only practical method to ensure that the PPE required to protect

persons from arc flash hazards will function as designed in an arc flash incident.Note that the modifications suggested in this proposal are not new material and this concept has had public review in

the ROP as required by the NFPA consensus process. The comment on affirmative made by Mr. Hickman includes thesuggested modifications.

The committee accepts the recommendation to change "FR" to "arc-rated". The committee does not accept theaddition of "shall be listed and".

The substantiation does not support that products currently available in the market, that aredocumented as meeting protective clothing standards, are creating wide-spread safety problems. In accordance with thecurrent ASTM F1506, all arc-rated garments are required to be labeled to indicate the garment has been manufacturedin accordance with that performance specification.



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_______________________________________________________________________________________________T. J. Woods, Wyoming Electrical JATC

70E-199Add new text as follows:

Barricades shall be used in conjunction with safety signs where it is necessary to prevent or limit employee access towork areas containing energized conductors or circuit parts. Conductive barricades shall not be used where it mightcause an electrical hazard. Barricades shall be placed no closer than the Limited Approach Boundary given in Table130.2(C). , or the Arc Flash Protection Boundary as determined by 130.3(A), whichever is greater.

There is no language in the standard currently that prevents unprotected workers from entering the ArcFlash Protection Boundary if it exceeds the Limited Approach Boundary (LAB). In many situations the Arc FlashProtection Boundary can be as much as 10 feet, but the Limited Approach Boundary may only be 3 feet 6 inches,leaving workers not wearing appropriate FR clothing in extreme hazard. I referenced Proposal 70E-199 (Log #49)because of comments from Bobby Gray referencing the same problem.

The recommendation is not consistent with the content of Proposal 70E-199. Therecommendation related to barricades and the subject of Proposal 70E-199 is the electrical work permit.


GRAY, B.: The submitter is recommending the action taken on Proposal 70E-199, which requires an EEWP beforeworking within the arc flash boundary, should have extended to requiring the establishment of a warning barrier for otherworkers at that distance if it is greater than the LAB. This is not new information since it was introduced in an affirmativevote to Proposal 70E-199. The recommendation is valid and should be accepted.


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70E-389The committee action on this proposal should have been accept in principle. The text should be

revised to read as follows.A single line diagram, where provided for the electrical system, shall be maintained and may be used to show a workingdistance and the calculated incident energy values and indicate the date the arc flash hazard analysis was performed asan option to placing this information on the equipment label. If this option is used, the location of this data on the singleline diagram shall correspond to the location of the required equipment field labels.

Showing the information listed in proposal 70E-260, as recommended by the committee, on a singleline diagram should be an acceptable alternative to posting detailed information on the equipment label. The daterequirement would be satisfied by the drawing revision block which is dated and describes the revision. If the updatedstudy indicates no changes to the data on the drawing, the revision could be noted as “Verified arc flash hazard analysisresults” and the date. The other items listed in proposal 70E-260 could easily be added and maintained on the singleline diagrams. Just because this data is not typically found on a single line diagram is not justification for rejecting thisproposal. Maintaining the proposed data on a single line diagram will not be as difficult as posting it on the equipmentlabels and then changing all of the labels in 5 years just to change the date of the study. Allowing the detailedinformation to be indicated on the drawing would mean the label information could be kept as brief as possible and stillgive the electrician the hazard information they need to work safely.

The committee reaffirms that the proposed text is too restrictive and reflects a requirement forequipment label data that is not typically found on single-line diagrams. Labeling information is specified by thecommittee action on Committee Comment 70E-248a (Log #CC7).



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The committee statement, "The authority having jurisdiction is typically not in a position to makeperformance-based decisions on a manufacturer’s product. Allowing an AHJ to override manufacturer's guidance andindustry consensus standards may put maintenance personnel at risk." fails to acknowledge the fact that the proposalrefers to a "proven" maintenance program. We at the Savannah River Site have had a very rigorous circuit breakertesting program where the circuit breakers are removed from service, tested at the shop against the manufacturer'srequirements and coordination curves and returned to service. The track record of these circuit breakers was so goodthat several years ago the time interval between tests was extended to five years with no degradation in performance ordeviation from the manufacturer's curves. This is a "proven" program that is effective and should be allowed to remain ineffect, rather than just arbitrarily changed.I restate my position from the proposal substantiation."The establishment of the new 205.3 requirement without regard to existing programs becomes an unnecessary

expense with no appreciable increase in safety for those facilities. Allowing the AHJ to make the specific case calls willnot create an unsafe condition, but allow the facilities to continue to exercise their good engineering practices to assureproper operation of overcurrent devices."

The facility owner, facility manager, or the employer is responsible for equipment maintenanceand employee safety. The requirement to comply with industry consensus standards does not prevent the maintenanceprogram to be modified based on the experience of the facility owner or facility manager. For example, NFPA 70B-2010and ANSI/NETA MTS-2007 addresses application of maintenance and reliability experience in establishing an electricalequipment maintenance program.



_______________________________________________________________________________________________70E-396 Log #93 EEW-AAA


70E-409Delete the Informational Note that appears after 300.3.

This recommendation is intended to be editorial. It appears that this text was inadvertently left in thedocument. Regardless, it should be removed. This same text that is recommended for deletion in this comment wasproposed to be added in Proposal 70E-409. Accordingly, a recommendation to delete the Informational Note (formerly aFPN) to 300.3 was included in a comment on Affirmative in the ROP balloting.



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70E-408Delete the Informational Note that appears after 300.3.

This recommendation is intended to be editorial. It appears that this text was inadvertently left in thedocument. Regardless, it should be removed. This same text that is recommended for deletion in this comment wasproposed to be added in Proposal 70E-409. The recommendation to delete the Informational Note was included in acomment on Affirmative in the ROP balloting.



_______________________________________________________________________________________________70E-398 Log #130 EEW-AAA


70E-416The committee action on 70E-416 should have been Accept in Principle with the following

modification to the proposed new text:

The electrical components and accessory equipment of electrolytic cells covered by Section 310 shall be kept insafe and proper working condition.

A ground fault shall be investigated and removed without delay a plan for its removal be implemented.This comment is submitted by the full CSA Z462 Workplace Electrical Safety Technical Committee.

The CSA Z462 technical committee acknowledges the NFPA 70E technical committee statement that proposal 70E-416has merit. However, the CSA Z462 technical committee would like the NFPA 70E technical committee to reconsidertheir statement that the proposal is better suited as a general requirement in Chapter 1.Although employees working on or around electrolytic cells have training regarding the hazards associated with suchwork, in many instances they are do not have an electrical trade background. The CSA Z462 technical committeebelieves that this unique situation warrants the addition of a requirement specific to this section to ensure that electricalcomponents and accessory equipment of electrolytic cells covered by Section 310 is kept in safe and proper workingcondition for the safety of these employees.The CSA technical committee believes that changing “removed without delay” to “a plan for its removal be implemented”1. Addresses the NFPA 70E technical committee concern that the proposal introduces a vague term (“without delay”)2. Meets the intent of the submitter3. Does not create new material

The requirements in the recommendation are covered by the general requirements in newSection 205.3 resulting from the committee action on Comment 70E-293.



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70E-417Committee action should Accept in Part.

Committee action should indicate that 325.4.(E) Handling Hazards is not accepted. Requiringemployers to comply with NIOSH lifting index is not appropriate. Ergonomic lifting hazards is outside the scope of NFPA70E.

The committee concurs that it was the intent of the committee action on Proposal 70E-417 todelete Section 325.4(E) shown in the recommendation for Proposal 70E-417. The committee concurs with thesubstantiation.



_______________________________________________________________________________________________70E-400 Log #192 EEW-AAA


70E-417Committee action should Accept in Part.

Committee action should indicate that 325.4(E) Handling Hazards is not accepted. Requiringemployers to comply with NIOSH lifting index is not appropriate. Ergonomic lifting hazards is outside the scope of NFPA70E.




_______________________________________________________________________________________________70E-400a Log #CC8 EEW-AAA


70E-417Revise Section 320.1 FPN to read:

(5) IEEE 1106, IEEE Recommended Practice for Installation, Maintenance, Testing, and Replacement of VentedNickel-Cadmium Batteries for Stationary Applications, 2002 2005.

The referenced standard, IEEE 1106, now has a publication date of 2005.



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70E-453The Technical Correlating Committee directs that the committee clarify the committee action taken

on this proposal.The Technical Correlating Committee understands that the committee action on this proposal accepts the

recommended text in (B) and also modifies the Fine Print Note.This is a direction from the Technical Correlating Committee on National Electrical Code® in


The committee action on Comment 70E-403 addresses the concern expressed in the TechnicalCorrelating Committee comment.



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_______________________________________________________________________________________________Keith W. Schuh, Fermilab

70E-453As requested by the TCC, the following is a clarification of the committee’s action. The new section

320.3 (B) should read as follows.320.3(B) Ground-fault detection shall be based on the type of dc grounding systems

utilized.A dc grounding system can be one of four types:

An ungrounded dc system, in which neither pole of the battery is connected to ground. Work on such asystem is normally carried out with the battery isolated from the battery charger. If an intentional ground is placed at oneend of the battery, an increased shock hazard would exist between the opposite end of the battery and ground. Also, ifanother ground develops within the system (e.g., dirt and acid touching the battery rack), it creates a short circuit thatcould cause a fire. An ungrounded dc system is typically equipped with an alarm to indicate the presence of a groundfault.

A solidly grounded dc system, in which either the positive or negative pole of the battery is connected directlyto ground. No ground detection circuitry is required on this type of grounded system. Ground fault detection on thistype of grounded system serves no purpose and is typically not provided.

A resistance grounded dc system is a variation of a Type 1 system in which the midpoint of the battery isconnected to ground through a resistance. The resistance is typically used to enable operation of ground fault alarmsystem.

A tapped solid ground, either at the center point or at another point to suit the load system. No grounddetection circuitry is required on this type of grounded system. Ground fault detection on this type of grounded systemserves no purpose and is typically not provided.

Ground-fault detection shall be based on the type of dc grounding systems utilized.

A resistance grounded dc system is a variation of a Type 1 system in which the midpoint of the battery isconnected to ground through a resistance. The resistance is typically used to enable operation of a ground fault alarmsystem.

Ground fault detection on this type of grounded system serves no purpose and is typically not provided.




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_______________________________________________________________________________________________The Technical Correlating Committee directs that the action on this comment be reported as Accept in

Principle in Part. The committee did not accept the relocation of the Fine Print Note to the Annex as requested.

Stephen McCluer, APC by Schneider Electric / Rep. IEEE Stationary Battery Committee70E-453

Ground-fault detection shall be based on Personnel shall determine the typeof dc grounding systems utilized prior to testing for ground faults.

A dc grounding system can be one of four types:An ungrounded dc system, in which neither pole of the battery is connected to ground.

Work on such a system is normally carried out with the battery isolated from the battery charger. If an intentional groundis placed at one end of the battery, an increased shock hazard would exist between the opposite end of the battery andground. Also, if another ground develops within the system (e.g., dirt and acid touching the battery rack), it creates ashort circuit that could cause a fire. An ungrounded dc system is typically equipped with an alarm to indicate thepresence of a ground fault.

A solidly grounded dc system, in which either the positive or negative pole of the battery is connected directlyto ground

A resistance grounded dc system is a variation of a Type 1 system where in which the midpoint of the batteryis connected to ground through a resistance. The resistance is typically used to enable operation of analarm ground fault alarm system

A tapped solid ground, either at the center point or at another point to suit the load system

Not all battery systems have dc ground fault detection systems. For personnel safety reasons, it is important tounderstand the grounding methodology being used and to determine the appropriate manner of detecting ground faults.If an unintended ground develops within the system (e.g., dirt and acid touching the battery rack), it can create a shortcircuit that could cause a fireCommonly used dc grounding systems include, but may not be limited to:

An ungrounded dc system, in which neither pole of the battery is connected to ground. If an unintentionalground occurs at any place in the battery, an increased potential would exist, allowing fault current to flow between theopposite end of the battery and the ground. An ungrounded dc system is typically equipped with an alarm to indicate thepresence of a ground fault.

A solidly grounded dc system, in which either the most positive or most negative pole of the battery isconnected directly to ground. If an unintentional ground occurs, it introduces a path through which fault current can flow.A ground detection system is not typically used on this type of grounded system.

A resistance grounded dc system is a variation of a Type 1 system in which the battery is connected to groundthrough a resistance. Detection of a change in the resistance typically enables activation of a ground fault alarm.Introducing an unintentional ground at one point of the battery could be detected and alarmed. A second unintentionalground at a different point in the battery would create a path for short circuit current to flow.

A solidly grounded dc system, either at the center point or at another point to suit the load system. If anunintentional ground occurs on either polarity, it introduces a path through which short circuit current can flow A grounddetection system is not typically used on this type of grounded system.

1. The committee action seems to be an installation requirement: “Ground-fault detection shall bebased the type of dc grounding systems utilized.” This comment amends the text to make it a safety requirement todetermine the type of grounding system being utilized prior to using ground detection test equipment. Because therecan be many different types of grounding systems, misapplication could result in shock or arc flash.2. This comment asks to move the information from an FPN (Informational Note) to an Informational Annex. The

IEEE stationary battery committee has revised the text to clarify the differences between the various grounding typesand has added text to clarify the hazards that can be encountered on each type of grounding system. This annexincludes no mandatory language for style manual compliance.

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The committee accepts the recommendation to revise the text of 320.3(C)(2). The committeeaccepts in principle the informational text and locates it as an informational note to Section 320.3(C)(2). The titleproposed for the new annex is not included as part of the informational note.



_______________________________________________________________________________________________70E-404 Log #242 EEW-AAA


70E-472Revise to as follows:

Work on battery systems shall only be performed when lighting is sufficient for the technician to readnecessary documents and to safely perform the work.Employees shall not enter spaces, containing batteries unless illumination is provided that enables the employees to

perform the work safely.Informational Note: Battery terminals are normally exposed and pose possible shock hazard: Batteries are also

installed in steps or tiers that may cause obstructions.The wording accepted at the ROP meeting has been modified to remove the ambiguous term

“sufficient.” An informational note has been added to clarify the rationale for including this requirement in Article 320.Considering batteries have exposed terminals and can be installed in steps or tiers, it is important that illumination bementioned in Article 320 to highlight a possible concern.



_______________________________________________________________________________________________70E-405 Log #33 EEW-AAA


70E-472The Technical Correlating Committee directs that further consideration be given to the comments

expressed in the voting.This is a direction from the Technical Correlating Committee on National Electrical Code® in


The committee action on Comment 70E-404 addresses the concern expressed in the TechnicalCorrelating Committee comment.



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action taken on Proposal 70E-485. This proposal contains a general statement for hazard warning with (A) struckthrough; however, Proposal 70E-485 established a (B).


The committee actions on Comments 70E-407 and 70E-409 address the concerns expressedin the Technical Correlating Committee comment.



_______________________________________________________________________________________________70E-407 Log #46 EEW-AAA


70E-479The committee action should have been to reject Proposal 70E-479 (Log #342).

The battery task group agrees with the TCC and believes that this proposal is redundant with proposal70E-485 Log #348. The task group recommends that proposal 70E-479 Log #342 should have been rejected. Thisaction would remove the redundancy and the need for correlation; and still meet the intent of the task group.



_______________________________________________________________________________________________70E-408 Log #35 EEW-AAA





The committee actions on Comments 70E-407 and 70E-409 address the concerns expressedin the Technical Correlating Committee comment.



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_______________________________________________________________________________________________The Technical Correlating Committee directs that the accepted text be revised for clarity as follows:

The following warning signs or labels shall be posted in appropriate locations:(1) Electrical hazard warnings indicating the shock hazard due to the battery voltage and the arc hazard due to the

prospective short-circuit current.(2) Chemical hazard warnings, applicable to the worst case when multiple battery types are installed in the same

space, indicating:(a) indicating the potential presence of explosive gas (when applicable to the

battery type);(b) the prohibiting prohibition of open flame and smoking; and(c) the warning of the danger of chemical burns from the electrolyte (when applicable to the battery type; and(d)applicable to the worst case when multiple battery types are installed in the same space(3) Notice for personnel to use and wear protective equipment and apparel appropriate to the hazard the approach

boundary for the battery.(4) Notice prohibiting access to unauthorized personnel

Keith W. Schuh, Fermilab70E-485

Revise text as follows:The following signs warnings shall be posted in appropriate locations:

(1) Electrical hazard warning signs indicating the shock hazard due to the battery voltage and the arc hazard due to theprospective short-circuit current.(2) Chemical hazard warning signs:(a) indicating the potential presence of explosive gas (when applicable to the battery type);(b) danger of hydrogen explosion from prohibiting open flame and smoking; and(c) warning of the danger of chemical burns from the electrolyte (when applicable to the battery type); and(d) applicable to the worst case when multiple battery types are installed in the same space

(3) Notice for personnel to use and wear protective equipment and apparel appropriate to the approach boundary forthe battery.(4) Notice prohibiting access to unauthorized personnel

This action will address the concern of the TCC for correlation with 70E-485 Log #348 and 70E-479Log #342.The battery task group recommends that the word sign be removed from the text. The task group accepts the use of a

label for the means of warning.

Revise the recommendation as follows:1. Revise the first sentence to read:

The following warnings signs or labels shall be posted in appropriate locations.2. Change "warning" to "warnings" in (1) & (2)

The revisions are made to provide additional clarity and for correct grammer.



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_______________________________________________________________________________________________Mindy Wang, Ampco Safety Tools

70E-487Proposal 70E-487 Log# 350 should not be accepted; current provision should be kept.

Proposal 70E-487 Log#350 should not be accepted due to the following:

· The substantiation for Proposal 70E-487 Log#350 states that “The amount of hydrogen in code-compliant batteryinstallations is well below the LFL and LEL; therefore, sparking caused by insulated tools cannot ignite hydrogen.Non-sparking tools are not necessary and should not be mandated...” We agree that there is likely no ignition hazard ifthe hydrogen in battery rooms is not within the flammability limits. However, we believe that guidance is prudent in theevent that a flammable environment develops as could be expected with ventilation or equipment malfunction. In“Guidelines for Fire Corps Standard Operating Procedures in the Event of Hydrogen Releases”, N. Grasso and theothers stated that “Hydrogen is colorless, odorless, tasteless and therefore not detectable by the human senses”Although the ventilation requirement in article 320 prevents liberated hydrogen gas from exceeding 1% concentration,hydrogen can exceed 1% concentration in an enclosed battery room due to ventilation or equipment failure. Forexample, based on the assumptions and examples given by GB Industrial Battery on their website athttp://giantbatteryco.com/GLOSSARY/Calculate.Industrial.Battery.Hydrogen.Gas.Emission.html , a typical lead acidmotive power battery develops approximately 0.01474 cubic feet of hydrogen per cell at standard temperature andpressure, 20% of overcharge during a recharge, 6-hour rated capacity of battery in ampere hours, gas released duringthe last 4 hours of an 8-hour charge, 24 cells per battery, 450 ampere size battery, hydrogen concentration can becalculated (24x0.2x0.01474x450)/4=7.9596 cubic feet per battery per hour. Assume 75 batteries stored,7.9596x75=596.97 cubic feet of hydrogen released per hour. For a room with a flat roof, 80 feet long, 60 feet wide, 30feet tall, room size is 80x60x30=144,000 cubic feet, it will only take 9.6 hours for hydrogen to reach its LEL of 4%concentration. In a smaller room such as 40’ x 40’ X 10’ = 16,000 cubic feet, it will only take 65 minutes for hydrogen toreach its LEL of 4% concentration. The point is that in the event of ventilation or equipment failure, batteries can quicklycreate a flammable environment that is not detectable by the human senses.· Non-sparking hand tools are used to guard against mechanical sparks such as impact and friction sparks, which are

both a potential ignition source in flammable environments. Hand tools used on batteries such as pliers, screwdriverswrenches, and sockets are used in a torque application, i.e. tools will make contact in a rubbing action. Friction sparksare generated from rubbing or surface contact between steel and other materials. While insulated steel tools protectagainst electrical shock, they can still generate friction sparks and therefore create an ignition hazard in a flammableenvironment. This occurs when the exposed metal parts of the insulated steel tool rub against another hard surfacesuch as steel nuts and bolts used on the terminal clamps. Impact sparks, however, are created by a steel object beingstruck or dropped on another hard surface. Since striking tools are not likely to be used in battery rooms and the steelexposed working surface of an insulated tool are minimal and not likely to hit the ground if a tool is dropped; it is notlikely that an impact spark would be an ignition hazard in battery rooms.

· In a document entitled, Frictional Sparking, Martin Sheldon stated that “It is well known that the sharpening of steeltools on a grindstone is accompanied by showers of sparks.” Sheldon went on to say “frictional heating and sparkoccurs when two solid bodies come into contact with each other, because of microscopic surface irregularities, they donot touch over the whole of their surfaces but only at a relative few spots. At the actual contact spots adhesion occursbetween the two bodies and if they are moved relative to each other the work necessary to overcome this adhesion isconverted into heat, raising the temperature of the bodies…..As the contact spots are forced apart fragments of thematerials may be broken off and projected into the surroundings…These small particles of material have arisen from theareas where work was expended. If these particles are heated sufficiently the glowing particles will appear as frictionalsparks.”· In a test study conducted by W. Bartknecht, Ignition Capability of Hot Surfaces and Mechanically Generated Sparks in

Flammable Gas and Dust/Air Mixtures, showed that if steel is rubbed against steel for a longer duration, (0.5-2.0seconds), as could be expected in hand tool use, then friction sparks are generated. It goes on to conclude that Steelfriction sparks are more ignition-effective then steel grinding sparks.· Another test by R.E. Bruderer, Ignition Properties of Mechanically Sparks and Hot Surfaces in Dust/Air Mixtures,

reported that “systematic tests with steel friction sparks resulted in the ignition of the easily ignitable flammable gases(hydrogen) and combustible dusts.”

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Report on Comments – June 2011 NFPA 70E· M.J. Burgess and R.V. Wheeler also reported immediate ignitions of hydrogen-air obtained by rubbing mild steel on

mild steel at 2 meter per second in Safety Mines Research Bd. Paper 46, H.M.S.O.· NFPA 30, Flammable and Combustible Liquids, Chapter 6, section 6.5.1 lists frictional heat or sparks as sources of

ignition of flammable vapors and precaution shall be taken to control ignition sources.· OSHA Flammable and Combustible Liquids regulation, 29 CFR Parts 1910.106(b)(6) states that precaution shall be

taken to eliminate or control sources of ignitions including frictional heat and mechanical sparks to prevent the ignition offlammable vapors.· In Frictional Sparking, Martin Sheldon reported steel friction sparks are incandescent particles at temperatures around

1500°C/2732°F· NFPA 921, Guide for Fire and Explosion Investigations 2008 Edition, Chapter 5 Basic Fire Science Table 5.76.1.1

Reported Burning and Sparking Temperature of Selected Ignition Sources under Mechanical Sparks lists a Steel toolspark temperature at 2550°F.· NFPA Handbook 20th edition, Section 9, Chapter 17 Oxygen-Enriched Atmospheres, Table 9.17.3 Ignition and

Flammability Properties of Combustible Liquids and Gases in Air and Oxygen at Atmospheric Pressure, Hydrogen-airmixtures have a minimum ignition temperature of 520°C/968°F. Therefore the temperature of a steel spark far exceedsthe minimum ignition temperature of hydrogen which means that when the atmosphere is flammable, a steel tool sparkis capable of igniting hydrogen.· Recognizing the potential for steel tools to be an ignition source in flammable environments, the Occupational Safety

& Health Administration (OSHA) provides guidance in booklet 3080 Hand and Power Tools, 2002 revised, “iron andsteel hand tools may produce sparks that can be an ignition source around flammable substances. Where this hazardexists, spark-resistant tools should be used.”· Therefore, friction from continuous or intermittent contact between steel and other materials giving a rubbing action

can produce sparks that are capable of igniting hydrogen.

· Submitter is aware that there has been discussion on availability issue, for example, one document on EFCOG siteindicated availability of these tools is a concern (document is attached for reference). Recently, however, themarketplace has recognized the need for these tools and availability is much improved. Currently, there are multiplemanufacturers that make these tools and major industrial equipment distributors who are and/or will be distributing thesetools. Internet search engines such as Bing, Yahoo & Google have made it easier to find these products. Similarly,Industrial Business to Business Search Engines, such as ThomasNet, that connect industrial buyers and suppliersprovide sources for finding these products. Today insulated non-sparking tools are broadly available.

This sample of OSHA documented accidents illustrates that accidents do happen when proper safety measures arenot taken to guard against friction sparks from steel tools.· Listed as accident#82 on dust incident data compiled by the Chemical Safety Board(CSB), an explosion resulted as a

spark created by a worker with an Allen wrench who was turning a screw to adjust a machine. The spark ignited somepropellant dust and a vacuum system carried the fire another room where a barrel of dust exploded.· OSHA inspection# 124728437, employee #1 and a coworker, both maintenance mechanics, were working in a 30 in.

by 36 in. manhole at a Space Age Fuel gas station in Gresham, OR. Employee #1 was trying to change a fuel pump,while the coworker watched from outside the manhole. Employee #1 was using an Allen wrench to loosen the bolts onthe fuel pump lead when he apparently created a spark that ignited the gas fumes in the manhole, causing an explosion.Employee #1 suffered burns to his face, hands, arms, and legs. He was transported to hospital for treatment.· OSHA inspection# 126764497, employee #1 was performing maintenance work on equipment used to make ignition

caps for automotive air bags. He ran into some problems and called maintenance, but instead of waiting for them toarrive, he dismantled and attempted to reassemble the parts. In the process, he put in a part upside down. The part hadfour screws, and while two of them were still able to be installed, the other two no longer matched with their holes.Unaware that the part was upside down, Employee #1 tried to force one of the screws in at an angle. The frictionresulting from this effort ignited the cap's residual explosive material. Flames flashed up the sleeve of Employee #1'ssmock and he sustained third-degree burns to his arm.· OSHA inspection# 309946457, employee #1 was working in the hydrogenation area when he removed the lid from

Converter Number 1 and placed it on the ground next to the approximately 25-in.-diameter opening to the converter.Employee #1 then removed the gasket from around the lid and used a wire-brush grinder to remove the silicone that hadsealed the gasket to the lid. Converter Number 1 contained a mixture of vegetable oil and hydrogen. While Employee #1was grinding the lid, sparks mixed with the hydrogen and exploded. Employee #1 was thrown approximately 7 ft into theair and onto some overhead pipes. Employee #1's right arm was severed and he was killed.NFPA 70E is a safe work practice standard including protective equipment and tools. As such, when considering

battery rooms that can reasonably be expected to become flammable environments, friction sparks from insulated steel

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Report on Comments – June 2011 NFPA 70Etools should not be overlooked as an ignition source. Unless it can easily be determined that the hydrogenconcentrations in a battery room are not within the flammability limits, it is a safer work practice to require the use ofinsulated non-sparking tools in these environments. We respectfully request the Committee to reconsider and implementa safer practice to keep the current provision of 320.9. Without this provision, insulated steel tools are likely to be usedwhich in flammable environments expose employees to an explosion and fire hazard.

Revise the text in Section 320.3(C)(3) (this section number is based on the ROP draft) to read:320.3 (C)(3) Tools and Equipment.(a) Tools and equipment for work on batteries shall be equipped with handles listed as insulated for the maximum

working voltage(b) Battery terminals and all electrical conductors shall be kept clear of unintended contact with tools, test equipment,

liquid containers and other foreign objects(c) Non-sparking tools shall be required when the hazard identification and risk assessment required by 110.7 (F)

justify their use.The revisions meet the intent of the recommendation and point out that non-sparking tools are

only necessary when it has been determined through the hazard identification and risk assessment required by110.7(F).



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_______________________________________________________________________________________________Stephen McCluer, APC by Schneider Electric / Rep. IEEE Stationary Battery Committee

70E-417

****Insert Include 70E_L115_R.doc****

****Insert Include 70E_L115_S.doc Here****

The submitter has presented a very involved comment that is attempting to create a new articlefor safety requirements related to batteries and battery rooms from the existing requirements in Article 320 of the 2009edition of NFPA 70E, changes that were accepted from Proposals 70E-418 through 70E-487, concepts from thesubmitter's Proposal 70E- 417, and some proposed revisions and additions to address the committee statement toProposal 70E-417. The committee notes that many of the recommendations made by this submitter are included incommittee comment on Proposal 70E-417.The substantiation for this comment is embedded in 37 different notes, some of which are confusing to the committee.

For example, in Note 1, the submitter notes that the scope is revised per committee action on Proposal 70E-418,however, the submitter has inserted the word “work” into the first sentence without substantiation.The committee reaffirms its actions on Proposals 70E-418 through 70E-487 which revised Article 320 to remove

installation requirements and improve the readability of the article. The committee commends the submitter for hisefforts in attempting to further improve the article, but rejects the submitters recommendation for a new Article 325 forthe reasons stated above. The committee suggests in the future that individual proposals be made for each section withclear substantiation for each individual change.



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1 NFPA 70E L115 Rec A2011 ROC

Article 325 Safety Requirements Related to Batteries and Battery Rooms 325.1 Scope The requirements of this article cover the This article covers electrical work safety requirements necessary for the practical safeguarding of employees while working with exposed stationary storage batteries where the nominal voltage exceeds that exceed 50 volts nominal. [See Note 1]

Informational note For additional information on safety best practices while working on stationary batteries, see the following documents

(1) NFPA 1, Fire Code, 2009, Chapter 52, Stationary Storage Battery Systems (2) NFPA 70, National Electrical Code, 2011, Article 480, Storage Batteries, (3) IEEE Std. 450 , IEEE Recommended Practice for Maintenance, Testing and Replacement of Vented Lead-Acid Batteries for Stationary Applications, 2002 (4) IEEE Std. 937, Recommended Practice for Installation and Maintenance of Vented Lead-Acid Batteries for Photovoltaic Systems, 2007 (5) IEEE 1106 , IEEE Recommended Practice for Installation, Maintenance, Testing and Replacement of Vented Nickel-Cadmium Batteries for Stationary Applications, 2002 (6) IEEE 1184, IEEE Guide for Batteries for Uninterruptible Power Supply Systems, 2006 (7) IEEE 1188, IEEE Recommended Practice for Maintenance, Testing and Replacement of Valve-Regulated Lead-Acid (VRLA) Batteries for Stationary Applications, 2005 (8) IEEE Standard 1657, Recommended Practice for Personnel Qualifications for Installation and Maintenance of Stationary Batteries, 2009.

[See Notes 2 & 15] (9) OSHA 29 CFR 1926.441, “Batteries and battery charging,” (10) OSHA 29 CFR 1910.305(j)(7), “Storage batteries” (11) DHHS (NIOSH) Publication No. 94-110, Applications Manual for the Revised NIOSH Lifting Equation, 1994

[See Note 2] 325.2 Definitions. For the purpose of this chapter, the following definitions shall apply [See Note 3] Authorized personnel. The person in charge of the premises, or other persons appointed or selected by the person in charge of the premises, to perform certain duties associated with stationary storage batteries. [See Note 4] Battery. A system consisting of two or more electrochemical cells connected in series or parallel and capable of storing the electrical energy received and which can give it back by reconversion. [See Note 5] Battery room. A room specifically intended for the installation of batteries that have no other protective enclosure. [See Note 6] Cell. The basic electrochemical unit, characterized by an anode and a cathode used to receive, store, and deliver electrical energy


[See Notes 7 & 8] Electrolyte A solid, liquid, or immobilized liquid medium that provides the ion transport mechanism between the positive and negative electrodes of a cell. [See Note 9] Nominal voltage. The value assigned to a cell or battery of a given voltage class for the purpose of convenient designation; the operating voltage of the cell or system may vary above or below this value [See Note 10] Pilot cell. One or more cells chosen to represent the operating parameters of the entire battery (sometimes called “temperature reference cell). [See Note 11] Prospective Fault Short Circuit Current. The highest level of fault current that can occur at a point on a circuit. This is the fault current that can flow in the event of a zero impedance short-circuit and if no protection devices operate. [See Note 12] Valve-regulated lead-acid (VRLA) cell - A lead-acid cell that is sealed with the exception of a valve that opens to the atmosphere when the internal pressure in the cell exceeds atmospheric pressure by a pre-selected amount, and which provides a means for recombination of internally generated oxygen and the suppression of hydrogen gas evolution to limit water consumption. [See Note 13] Vented cell - A type of cell in which the products of electrolysis and evaporation are allowed to escape freely into the atmosphere as they are generated (also called a “flooded cell”) [See Note 14] 325.3 Qualified personnel

Informative Note: For descriptions of the training recommended for various levels of battery technician certification, see IEEE Standard 1657, Recommended Practice for Personnel Qualifications for Installation and Maintenance of Stationary Batteries

[See Notes 2 & 15] (A) Qualification Only qualified personnel shall work on battery systems. (B) Documentation In addition to the requirements of 110.6(D), personnel shall be trained, and records shall be maintained documenting such qualification, for service on the specific battery technology being serviced.

Informative Note: For descriptions of the training recommended for various levels of battery technician certification, see IEEE Standard 1657, Recommended Practice for Personnel Qualifications for Installation and Maintenance of Stationary Batteries

[See Note 15] (C) Education Training shall include demonstrated knowledge and skill levels on:

(1) proper work environment (2) personal protective equipment (PPE) (3) electrical shock hazards (4) insulation (5) lockout/tagout procedures (6) electrostatic discharge (ESD) precautions (7) ventilation precautions (8) working clearances, egress paths, and task lighting (9) battery lifting and handling considerations (10) battery fire hazards and response (11) First aid

[See Note 16] [See Note 17]


325.4 Safety procedures [See Note 18] (A) General safety hazards

(1) Battery Room or Enclosure Requirements (a) Personnel access to energized batteries Each battery room or battery enclosure shall be

accessible only to authorized personnel [See Note 22] [See Note 23] (b) Illumination. Work on battery systems shall only be performed when if lighting is sufficient for the

technician employee to read necessary documents and to safely perform the work. [See Note 24] [See Note 25]

(2) Apparel Personnel shall not wear electrically conductive objects such as jewelry while working on a battery system.

[See Note 26] [See Note 27]

(3) Alarms Where installed, alarms for early warning of abnormal conditions of battery operation shall

be tested a minimum of once yearly. The alarm system shall be tested for an audible alarm and visual indication at the battery location, and where applicable, at a remote manned control point.

[See Note 19]

Informational Note: Battery Conditions monitored for early warning typically include:

(a) For vented cells (i) Overvoltage (ii) Undervoltage (iii) Overcurrent (iv) Ground fault (v) Ventilation/exhaust system failure

[See Note 20] (b) For VRLA cells (i) Overvoltage (ii) Undervoltage (iii) Overcurrent (iv) Ground fault (v) Over-temperature, as measured at the pilot cell (vi) Ventilation/exhaust system failure

[See Note 20] (4) Hazard Warnings The following warnings shall be posted at the entrance to the battery room or

enclosure: [See Note 21] [See Note 28]

(a) Electrical hazard warning signs indicating the shock hazard due to the battery voltage and the arc hazard due to the prospective short-circuit current

[See Note 12] Informational Note: Because internal resistance and/or prospective short circuit are not always provided on battery container labels or data sheets, and because many variables can be introduced into a battery layout, the battery manufacturer should be consulted for accurate data. Variables can include, but are not limited to;

- series connections - parallel connections


- charging methodology - temperature - charge status - dc distribution cable size and length

(b) Chemical hazard warning signs: (i) indicating the potential presence of explosive gas (when applicable to the battery type); (ii) prohibiting open flame and smoking; (iii) warning of the danger of chemical burns from the electrolyte (when applicable to the battery

type); and (iv) applicable to the worst case when multiple battery types are installed in the same space

(c) Notice requiring personnel to use and wear protective equipment and apparel appropriate to the approach boundary for the battery. (d) Notice prohibiting access to unauthorized personnel

[Note 29 ] [Note 30 ] (B) Electrolyte hazards

(1) Batteries with liquid electrolyte. The following protective equipment shall be available to employees performing any type of service on a battery with liquid electrolyte:

(a) Goggles or face shield appropriate for the electrical hazard and the chemical hazard (b) Gloves appropriate for the chemical and electrical hazards (c) Protective aprons appropriate for the chemical hazard and electrical hazards (d) Portable or stationary water facilities for rinsing eyes and skin in case of contact with electrolyte (e) Sufficient neutralizing agent to neutralize a spill from the largest battery container to:

(i) a Ph between 7.0 and 9.0 for lead-acid batteries; or (ii) a Ph between 5.0 and 7.0 for alkaline batteries

(6 f) Electrolyte spill clean-up and disposal tools [See Note 31]

(2) Batteries with solid or immobilized electrolyte. The following protective equipment shall be available to employees performing any type of service on a battery with solid or immobilized electrolyte: (a) Goggles or face shield appropriate for the electrical hazard (b) Gloves appropriate for the chemical and electrical hazards (c) Protective clothing appropriate for electrical hazard (d) Lifting devices of adequate capacity for units greater than 45 lbs (21.5 kg)

[See Note 32] (C) Electrical hazards


(1) Arc Flash. When performing maintenance on or within reach of batteries, the minimum personnel protective equipment shall be in accordance with the recommendations of Table 325-1. 130.7(C)(9)(2).

[See Note 33]

(2) Battery Short-Circuit Current. The battery manufacturer shall be consulted regarding the sizing of the battery short-circuit protection and for battery short circuit current values.

(3) DC Ground-Fault Detection. Ground-fault detection shall be based on the type of dc grounding

systems utilized. [See Note 34]

Informational Note A dc grounding system can be one of four types:

Type 1 – ungrounded. An ungrounded dc system is one in which neither pole of the battery is connected to ground. Work on such a system is normally 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 exist between the opposite end of the battery and ground. Also, if another ground develops within the system (e.g., dirt and acid touching the battery rack), it can create a short circuit that could cause a fire. An ungrounded dc system is typically equipped with an alarm to indicate the presence of a ground fault.

Type 2 – solid ground. A solidly grounded dc system is one in which either the positive or negative pole of the battery is connected directly to ground. No ground detection circuitry is required on this type of grounded system. This type of grounded system typically does not use ground detection circuitry.

Type 3 – resistance ground. A resistance grounded dc system is a variation of a Type 1 system in which the midpoint of the battery is connected to ground through a resistance. The resistance is typically used to enable operation of a ground fault alarm system.

Type 4 – tapped ground. A tapped solid ground is one in which ground is connected either at the center point or at another point to suit the load system. No ground detection circuitry is required on this type of grounded system. This type of grounded system typically does not use ground detection circuitry.

[See Note34] [See Note 35]

(4) Tools and Equipment.

(a) Tools and equipment for work on batteries shall be equipped with handles listed as insulated for the maximum working voltage

[See Note36] (b) Battery terminals and all electrical conductors shall be kept clear of unintended contact with tools, test equipment, liquid containers, and other foreign objects.

(D) Fire hazards Battery cell flame arresters shall be inspected for proper installation and unobstructed ventilation

(a) Portable or fixed Class C fire extinguisher shall be in battery rooms where suitable for the battery technology

Informational note: (CO2 extinguishers are not recommended for most battery types because they have the potential to cause thermal shock to batteries, thereby increasing the possibility of damage).


(b) Battery cell flame arresters shall be inspected for proper installation and unobstructed ventilation

[See Note37] (E) Handling hazards

(1) When handling battery containers, personnel shall not be exposed to a NIOSH lifting index greater than 3.0

(2) Lifting devices of adequate capacity shall be used for loads greater than 45 lbs (21.5kg) (3) Lifting harnesses or devices shall be used when designed by the battery manufacturer for specific

battery types.

1 NFPA 70E L115 Sub A2011 ROC

The Committee’s action was to “accept in principle in part” as modified by committee action on proposals 418 through 487. The following comments address all of those proposals as footnotes to the proposed text. This comment intends to show the Article as it would appear after the committee action on all 70 of the proposals. Changes to the original text of Proposal 70E-471 are highlighted in legislative text. [Note 1] SCOPE is revised per Committee Action of Proposal #70E-418 [Note 2] Two referenced documents that were included in the original proposal and do not appear in

existing NFPA 70E-2009 should remain. #8 is a standard that helps define a qualified person specifically for batteries #11 is a standard on heaving lifting – a normal activity in battery service.

An argument can be made that these two standards are outside the scope of “electrical” safety, but neither one should be excluded from the tasks that an employee will perform as part of the electrical work. If not referenced here, where else can anybody go to find out what qualifies a person to work on batteries? This comment adds a cross reference on training to Article 110.6(D) in paragraph 325.3. Proposal # 70E-417 Committee statement 4.(c) states that lifting and rigging requirements are outside the scope of this document. Battery electrical work will automatically include activities such as moving, installing, or removing battery units. To ignore such activities (because they might be addressed somewhere else, but we won’t tell you where) does a disservice to the user and maybe even to NFPA. These documents are included in an informational note so compliance is not mandatory. The purpose is to say, “While you’re at it, you will also need to understand and comply with these other standards that are a particular concern for battery systems.”

[Note 3] The introductory sentence is deleted from Definitions per Committee Action on Proposal # 70E-

417 and 70E-427 [Note 4] Definition of Accessories is deleted per Committee Action on Proposals # 70E-417 and 70E-

426 Definition of Authorized Personnel is revised per Committee Action on Proposals # 70E-417

and 70E-427 [Note 5] Definition of Battery is revised per Committee Action on Proposals # 70E-417 and #70E-428 [Note 6] Definition of Battery Room is revised per Committee Action on Proposals # 70E-417 and #70E-

429 [Note 7] Definition of Cell is revised per Committee Action on Proposals # 70E-417 and #70E-430 [Note 8] Definitions of Charging, Constant Current Charge, Constant Voltage Charge, Container, and

Discharging) are deleted per Committee Action on Proposals # 70E-417 and #70E-431 [Note 9] Definition of Electrolyte is revised per Committee Action on Proposals # 70E-417 and #70E-

433 Definition of Electrolyte Density is deleted per Committee Action on Proposals # 70E-417 and

#70E-434 Definition of Flame Arrestor Vent Plug is deleted per Committee Action on Proposals # 70E-

417 and l #70E-435 Definition of Gassing is deleted per Committee Action on Proposals # 70E-417 and #70E-436 Definition of Intercell and Interrow Connection is deleted per Committee Action on Proposals #

70E-417 and #70E-437


Definition of Intercell Connector Safety Cover is deleted per Committee Action on Proposals # 70E-417 and #70E-438

[Note 10] Definition of Nominal Voltage is revised per Committee Action on Proposals # 70E-417 and

#70E-439

[Note 11] Definition of Pilot Cell is revised per Committee Action on Proposals # 70E-417 and #70E-440 Definitions of Secondary Battery, Secondary Cell, Stepped Stand, Terminal Post, and Tiered

Stand, are deleted per Committee Action on Proposals # 70E-417 and #70E-441 [Note 12] Definition of Prospective Fault Current was not addressed by the Committee in the ROP. This

definition should be revised from “fault current” to “short circuit current” because that is the way the term is used in 325.4(A)(4)(a) and associated FPN in the text of Proposal #70E-417 and in this comment

[Note 13] Definition of Valve-Regulated Lead-Acid (VRLA) Battery is revised per Committee Action on

Proposals # 70E-417 and #70E-442 Definition of Vent Plug is revised per Committee Action on Proposals # 70E-417 and #70E-443 [Note 14] Definition of Vented Battery is revised per Committee Action on Proposals # 70E-417 and

#70E-444 Definition of VRLA is deleted per Committee Action on Proposals # 70E-417 and #70E-445 [Note 15] New 325.3, Qualified Personnel, including sub-paragraphs (A) and (B), are retained from the

original proposal. The informative note is moved to below 325.3(B). 325.3(A) restates the requirement that only qualified personnel should work on battery

systems. 325.3(B) builds on that statement by referring the reader to the training requirements of 110.6(D), and it requires that personnel shall be trained on the specific type of battery. This is important because there are many types of batteries; the correct procedure on one can be dangerous on another. This device-specific requirement does not appear elsewhere in NFPA 70E and should remain in the battery section.

325.3(C) and associated subparagraphs are deleted. This action should satisfy the intent of Committee statement 4(a) on Proposal #70E-417. [Note 16 ] The following paragraphs have been deleted from the NFPA 70E-2009 version per the

committee actions in the ROP. Deleted all of 320.3(A), including FPNs, per Committee action on Proposals #70E-417 and

70E-448 Deleted all of 320.3(C), including FPNs, per Committee action on Proposals #70E-417 and

70E-450 Deleted all of 320.3(D), per Committee action on Proposals #70E-417 and 70E-451 Deleted all of 320.3(E), including FPNs, per Committee action on Proposals #70E-417 and

#70E-452 Deleted all of 320.3(G), per Committee action on Proposals #70E-417 and 70E-454 [Note 17 ] Renumbered 320.3(B) to 325.3(A) and revised title per Committee action on Proposals

#70E-417 and 70E-449 Moved contents to 325.4(C)(2) and 325.4(C)(3) Moved itemized texts to FPNs, per Committee action on Proposals #70E-417 and 70E-453 [Note 18] Proposal 70E-417, which the committee approved in principle, created a new section 325.4,

Safety Procedures, and relocated several paragraphs from the existing 70E Standard under


this section. It grouped activities into five categories of activities: (A) General safety hazards; (B) Electrolyte hazards; (C) Electrical hazards; (D) Fire hazards; and (E) Handling hazards.

[Note 19] Contents of former 320.3(H) Alarms were relocated under 325.4(A)(3) in proposal #70E-417.

The text shown is per Committee action on Proposal # 70E-455. Proposal #417 editorially revised the text to clarify that, when they have been installed, the

alarm systems (not the alarm conditions) shall be tested (text is same as previously accepted). Proposal 417 added text to clarify that the alarm systems shall be tested to demonstrate that

they work at all locations where they are monitored, both local and remote (text is same as previously accepted).

[Note 20] The Committees action on 70E-455 was to delete testing of ventilation system failure alarms.

This comment recommends to keep the text as originally proposed. Ventilation/exhaust system alarms should be tested, even though these are mechanical in nature, because inspection for hazardous gas prior to entering a battery room should be a routine step in any battery electrical maintenance procedure. A ventilation failure alarm would alert the employee to a potentially dangerous environment. Reliability of the system should the responsibility of those who use it.

[ Note 21] Proposal #70E-459 revised text to include the words “or enclosure.” This text originally

appeared under 320.5 and is now consolidated under a new section 325.4(A)(4) for safety procedures > alarms. (Text is same as previously accepted).

[Note 22] This text was approved in Proposal #70E-460. It originally appeared in 320.5 and 320.5(A)(1). Note 23] Installation requirements were DELETED from the original NFPA 70E-2009 text per committee

actions on Proposal #70E-417 and the following proposals: 320.5.(A)(1)(a) per Proposal #70E-461 320.5(A)(1)(b) per Proposal #70E-462 320.5(A)(1)(c)&(d) per Proposal #70E-463 320.5(A)(1)(e) & FPN per Proposal #70E-464 320.5(A)(2) per Proposal #70E-465 320.5(A)(3) per Proposal #70E-466 320.5(A)(4) & FPN per Proposal #70E-467 320.5(B) (ALL) per Proposal #70E-468 320.5(C) (ALL) per Proposal #70E-469 320.5(D), (D)(1), & (D)(2) per Proposal #70E-470 320.5(E), (E)(1), & (E)(2) per Proposal #70E-471

[Note 24] Former 320.5(F), Illumination, was relocated in Proposal 70E-417 to new 325.4(A)(1)(6). The revised text is per Committee action on Proposal 70E-472. COMMENT: Two negative comments challenged whether the language is too vague to be enforceable and suggested that the text should reference a level per IESNA Lighting Handbook. The latter would make this an installation requirement and therefore beyond the scope of this Standard. The intent of this paragraph is to defer to the judgment of a qualified person to determine the sufficiency of lighting to safely perform the work, and to empower an employee to refuse to do electrical work on batteries if – in his judgment - lighting conditions are unsafe.

[Note 25] Deleted former 320.5(G), Location of Luminaires, per Committee action on Proposal # 70E-473

(Text is same as previously accepted on Proposal # 70E-417). [Note 26] 325.4(A)(2), Apparel, revised per Committee action (2) on Proposal # 70E-417


[Note 27] Deleted former 320.6, Enclosure requirements, per Committee action on Proposals # 70E-417, 70E-476 and 70E-477

[Note 28] Text of 325.4(A)(4), Hazard Warnings, revised per Committee action on Proposals #70E-479

and 70E-485 [formerly paragraphs 320.7 and 320.7(A)(1) ]. (Text is the same as previously accepted on Proposal # 70E-417).

COMMENT ON TCC ACTION in the ROP: It appears that TCC may have misread the

proposal. Proposal #70E-479 shows paragraph underlined, not strikethrough (as stated by the TCC comment), indicating it was meant to be included (not deleted). 70E-485 changes the numbering of paragraph (F) to (B), which is fully consistent with the numbering system because the existing (B) through (G) were deleted in other proposals

[Note 29] Deleted all of former 320.4, Installation of batteries, per Committee action on Proposals #70E-

417, 70E-456 & 457 [Note 30] Deleted former 320.7(B), Switching & Control Equipment, per Committee action on Proposals

#70E-417 and 70E-481 Deleted former 320.7(C), Ground Fault Protection, per Committee action on Proposals #70E-

417and 70E-482 (See also Committee action on proposal #70E-453) Deleted former 320.7(D), Main Isolating Switch, per Committee action on Proposals #70E-

417and 70E-483 Deleted former 320.7(E), Section Isolating Equipment, per Committee action on Proposals

#70E-417 and 70E-484 [Note 31] 325.4(B)(1)(6) paragraph numbering has been corrected per Committee statement 4(b) on

Proposal 70E-417. Text of 325.4(B) is per Committee action on Proposal # 70E-486. (Text is identical to Proposal 70E-417)

It is noted that Proposal #70E-486 would have changed the following paragraphs. It is not clear if it was the committee’s intent to accept the text of Proposal # 70E-417 or # 70E-486 (both were accepted in principle).

320.8(A) [ which is now 325.4(B)(1) ] Batteries with solid or immobilized Electrolyte. The following protective equipment

shall be made available to and used by employees performing any type of service on a battery with solid or immobilized electrolyte:

The intent of the above text is to ensure that the employee actually uses the PPE that is

made available by the employer. The below text of Proposal #70E-486 did not use the same parallel language in what is now 325.4(B)(2)

320.8(A)(3) [ which is now 325.4(B)(1)(d) ] Portable or stationary water facilities for rinsing quick drenching or flushing of the eyes

and skin body in case of contact with electrolyte [Note 32] Deleted text of 325.4(B)(2)(d), lifting devices, per Committee action 4(c) on Proposal# 70E-

471 [Note 33] Committee action 4(d) on Proposal #417 was to delete paragraph 325.4(C)(1), which says

that the NFPA 70E tables should be used to determine appropriate PPE for DC systems when working on or within reach of batteries. The Committee’s comment was


“The concept of keeping clear of unintended contact is vague. Measures can be implemented to protect against unintended contact. Equipment that is accessible for testing presents the risk of unintended contact.”

The comment suggests the need for PPE, but it seems to have little to do with actually selecting the appropriate PPE. It seems to advocate measures to prevent accidental contact, which sound like installation requirements, and would therefore be outside the scope of this Standard.

This comment modifies the text to refer to an approved new table 130.7(C)(9)(2), per Committee action on Proposal #70E-347a.

[Note 34] Text of 325.4(C)(3) and FPN’s revised per Committee action on Proposals #70E-417and

#70E-453. This comment adds the name of each type of grounded system for greater clarity. The committee’s action on Type 2 and Type 4 was to delete the statement that ground fault

detection is not necessary for these types of grounded systems. This comment retains the statement, but rewords it in non-mandatory language.

Note 35] Proposal #70E-417 deleted former 320.5(H), outlet locations. This is consistent with

Committee action of Proposals #70E-474 and 70E-475 (no change from Proposal #70E-417). [Note 36] Text of 325.4(C)(4), Tools & equipment, per Committee action on Proposal # 70E-487 (no

change from Proposal #70E-417). . [Note 37] Text of 325.4(D)(a) requires employees to have portable fire extinguishers on hand when the

building is not equipped with Class C (stored electrical energy) fire suppression. A FPN explains the hazard of using CO2 extinguishers on batteries. Both statements are deleted per Committee action 4(e) on Proposal #70E-417.

Portable fire extinguishers cannot be considered “tools.” Requirements for, or Information about portable fire extinguishers appropriate for battery work should not be considered workplace electrical safety and is therefore outside the scope of NFPA 70E.



70E-491This should be an “Accept in Principle.” Reword for clarity:

(2) The use, and where appropriate maintenance, of the personal protective equipment needed and tools required toperform the work safely.The sentence would read: (2) The use and appropriate maintenance of the personal protective equipment and toolsrequired to perform the work safely.”

The accepted text is awkward. The proposed revision is form the Comment on Affirmative by Mr.Hamer from the ROP.



_______________________________________________________________________________________________70E-413 Log #116 EEW-AAA

_______________________________________________________________________________________________John F. Bender, Underwriters Laboratories Inc.

70E-495Revise text as follows:

B.1.6 UL Publications. Underwriters Laboratories Inc., 333 Pfingsten Road, Northbrook, IL 60062-2096ANSI/UL 943, Standard for Ground-Fault Interrupters, 2006, Revised 2008 2010.ANSI/UL 1203, Explosion-Proof and Dust-Ignition-Proof Electrical Equipment for Use in Hazardous (Classified)

Locations, 2006, Revised 2009.Update referenced standards to most recent revisions.



270Printed on 1/19/2011



70E-497The committee is urged to reconsider this issue, as not prohibiting arc flash calculations on

overdutied equipment can place workers in greater danger, one with covers removed.Presently arc flash hazard studies are being performed where results are calculated for ALL system

locations, regardless of whether or not the equipment is rated to handle the system’s available fault duty. Thecalculated arc flash results (used on labels and work permits) may not have a very high incident energy, so the resultswould not show the extremely dangerous condition that actually exists. Why would anyone knowingly want to removecovers and work on overdutied equipment placing themselves in extreme danger? And yet, because 70E has nocaution/disclaimer regarding supplying arc flash hazard results for such equipment, that is exactly what is happening.A second caution/guideline needs to be made for the outright incorrect practice of using protective device opening timesin arc flash hazard equations that are above the interrupting rating of the device. Manufacturers only providetime-current curves up to the device’s interrupting rating. Does the person performing the calculation know more thanthe manufacturer about the device’s opening time under high fault conditions? Where are these times used in arc flashequations coming from? The opening time is not provided, so the incident energy simply cannot be calculated.Overdutied breaker contacts can weld and overdutied fuses may not clear, so that the arc flash hazard continues

uninterrupted, never opening the circuit. This topic needs to be addressed in this edition of 70E, as studies are beingperformed that place arc flash hazard labels on equipment that should not be there, making them appear the same asother properly rated equipment. This dangerous practice must end.

The committee reaffirms that engineering judgment is an important part of performing anincident energy analysis. It is not the intent of the committee to address work practices associated with installations thatdo not comply with NEC requirements. Applying an overcurrent protective device outside of its listing is contrary to110.3(B) and 110.9 of the NEC. See the committee statement on Comment 70E-276.



HICKMAN, P.: We do not necessarily agree with the committee statement.

271Printed on 1/19/2011


_______________________________________________________________________________________________Craig M. Wellman, CMW Consulting

70E-505Accept this proposal with modification: Delete all equations and tables in Annex D from D2 through

to D9 and delete references to papers in D1.Deleting the IEEE 1584 equations, which are now widely used, while retaining historic methods would

lead people in the wrong direction: it would encourage use of obsolete methods. NFPA 70E should be pointing peopletoward the latest methods published in standards. This area of technology used to be so new that only published paperspresented methods of addressing the issue, but now both IEEE 1584 and the NESC address it with solutions agreedupon through standards processes.Deleting all equations and tables in Annex D, from D2 through D9 and pointing people just toward the standards in D1

would a real step forward. It would avoid the problem of 70E presenting outdated methods when IEEE 1584 or theNESC are updated.

The committee reaffirms that Annex D provides the user with some knowledge of variouscalculation methods and provides guidance on where each method may be found in its entirety. Deleting onecalculation method without removing all others may imply that the committee favors one method over another and that isnot accurate.




_______________________________________________________________________________________________70E-416 Log #377 EEW-AAA


70E-507Accept this proposal with modification: Delete all equations and tables in Annex D from D2 through

to D9 and delete references to papers in D1.Deleting the IEEE 1584 equations, which are now widely used, while retaining historic methods would

lead people in the wrong direction: it would encourage use of obsolete methods. NFPA 70E should be pointing peopletoward the latest methods published in standards. This area of technology used to be so new that only published paperspresented methods of addressing the issue, but now both IEEE 1584 and the NESC address it with solutions agreedupon through standards processes.Deleting all equations and tables in Annex D, from D2 through D9 and pointing people just toward the standards in D1

would a real step forward. It would avoid the problem of 70E presenting outdated methods when IEEE 1584 or theNESC are updated.





272Printed on 1/19/2011



70E-500Accept this proposal but with modifications to the proposed text in D1:

1. Delete all references to the papers by Ralph Lee, Dick Doughty and Tom Neal in the existing table D.1 . The tablewill then read as follows:

***Insert Table D.1 Calculation methods and Limitations here*

2. Add the following text after Table 1:The process of performing an arc-flash hazard calculation study may be summarized as follows:Collect the power system configuration and installation data such as single-line diagrams, equipment nameplate data

and cable lengths, types and ratings. Get from the serving utility the maximum available fault current it could supply andthe minimum it could supply – the maximum and minimum bolted fault currents at the service point(s).Determine the system modes of operation or switching scenarios such as maximum utility available fault current with

all large motors running, minimum utility available fault current with no large motors running, and standby generator onlyrunning.Calculate the available bolted fault current at each bus (the equipment where an employee might perform work while

the system is energized and the protective device that would interrupt the fault for the modes of operation. Themaximum incident energy may be possible when the available fault current is less than the maximum fault current. Afault in a switchboard might be interrupted by an upstream utility fuse.Document the classes of equipment, voltages and grounding method at each bus.Calculate the arc-fault current at each bus and protective device for the modes of operation.Find the protective device characteristics and determine the interrupting time or current limiting action for each

protective device for an arc-fault at each bus for each mode of operation.Calculate the incident energy for each bus based on the arc-fault current, the protective device interrupting time or

current limiting action, the class of equipment, the voltage class and grounding method for each switching scenario.Determine the maximum probable incident energy calculated for each bus.

Annex D contains equations for a collection of methods without clear recommendations to guide a useron which to apply and without an easy to follow explanation of the standard process that should be followed to performan arc-flash hazard calculations study.In the past including all of these equations was a good way to give people tools to address the new problem of the arc

flash hazard as the tools were being developed. Now the Ralph Lee paper and the Doughty/Neal paper are of historicinterest only and should not be offered as tools for use. They have been superseded by IEEE 1584, a standard, basedon testing, which applied the methods pioneered by Dick Doughty, Tom Neal, and Lanny Floyd.Today IEEE 1584 is in wide use by thousands of qualified people and ANSI/IEEE C2 has been updated with new

Section 410 tables, a valuable addition to that standard. Users should be directed to those standards because theycontain the current recommended methods.IEEE 1584 explains the process of performing arc-flash hazard calculations in detail as well as providing equations.

Providing equations without explaining how to apply them can result in incorrect applications and errors.Simply referring people to the standards instead of providing their equations avoids the problem of 70E containing

outdated equations or tables when the referenced standards are revised.The Committee stated in its rejection of this proposal that, “The various incident energy and arc flash boundary

calculation methods presented in Annex D provide guidance for the user of the document to understand the basicconcepts.” In answer, the proposed summary of the process of performing an arc-flash hazard calculations study will beof far greater help to those interested in understanding the concepts than the present text and elimination of the manydifferent methods will simplify the selection of methods.

See the committee action and statement on Comment 70E-415. In addition, the committeedoes not accept the recommended text detailing how an arc flash study is to be performed. Annex D pertains tocalculation methods and it is not accurate to summarize the process of an arc-flash study in this section of the Annex.


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1 70E_L378_Tbl D.1_A2011ROC_R

Table D.1 Calculation methods and Limitations

Document Source Limitations/Parameters

D.2, D.3, D.4

Ralph Lee paper Calculates Arc Flash Protection Boundary for arc in open air; conservative over 600 V and becomes more conservative as voltage increases

D.5 Doughty/Neal paper Calculates incident energy for 3-phase arc on systems rated 600 V and below; applies to short-circuit currents between 16 kA and 50 kA

D.6 Ralph Lee paper Calculates incident energy for 3-phase arc in open air on systems rated above 600 V; becomes more conservative as voltage increases

1 IEEE Std. 1584 Calculates incident energy and Arc Flash Protection Boundary for: 208 V to 15 kV; 3-phase; 50 Hz to 60 Hz; 700 A to 106,000 A short-circuit current; and 13 mm to 152 mm conductor gaps

2 ANSI/IEEE C2 NESC-Section 410 Tables 410-1 and Table 410-2

Calculates incident energy for open air phase-to-ground arcs 1 kV to 500 kV for live-line work



_______________________________________________________________________________________________70E-418 Log #95 EEW-AAA


70E-505Accept Proposal 70E-505.

See substantiation and explanation of negative vote for Proposal 70E-505.





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70E-5071. Add a new sentence at the beginning of Annex D7 as follows:

The information contained in this Annex has been extracted from IEEE Standard 1584-2002 “Guide for performing ArcFlash Hazard Calculations” and may not reflect all the necessary information for performing such calculations. User isencouraged to consult the IEEE 1584 latest version to understand the basis, limitation, rationale and other pertinentinformation for proper application and for the current contents of the latest version of the IEEE standard.2.Delete the FPN in Annex D7 because the same wording exists in 130.7 FPN No. 2 and this applies to all cases and

not just Annex D7.IEEE 1584- 2002 is being revised and updated to reflect current technology and methods. User of this

information should be made aware that the information contained in NFPA 70E is based on what may or may not be thelatest version of IEEE standard 1584. In that case user should consult the latest version to avoid conflicts with theextracted material in NFPA 70E and contents of IEEE 1584.

Revise Annex D, Section D.7 as follows:This section detailsprovides excerpts

from IEEE 1584information available for estimating incident energy and Flash Protection Boundaries based on statisticalanalysis and curve fitting of available test data. An IEEE working group produced the data from tests it performed toproduce models of incident energy. Based on the selection of standard personal protective equipment (PPE) levels (1.2,8, 25, and 40 cal/cm2), it is estimated that the PPE arc rating will be equal to or greater than actual measured testvalues of incident energy in 95% of the cases.Informational Note: When incident energy exceeds 40 cal/cm2 at the working distance, greater emphasis than normalshould be placed on de-energizing before working on or near the exposed electrical conductors or circuit parts.The complete data, including a spreadsheet calculator to solve the equations, can be found in the IEEE 1584,

. Users are encouraged to consult the latest version of the completedocument to understand the basis, limitation, rationale, and other pertinent information for proper application of thestandard. It can be ordered from the Institute of Electrical and Electronics Engineers, Inc., 445 Hoes Lane, P.O. Box1331, Piscataway, NJ 08855-1331.

The committee accepts the revisions in principle but revises and relocates the recommendedtext to various parts of the first two paragraphs of D.7 for better clarity. Selection of PPE is properly determined basedon the proper use of NFPA 70E and the Stoll curves.



HICKMAN, P.: The parallel text located as 130.7(A) informational note No. 2 should be deleted in conjunction with thiscommittee action that deletes the informational note in D.7. The informational note in D.7 was the basis for the inclusionof 130.7(A) informational note No. 2.

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The proposal and associated paper is submitted by highly respected individuals that are involved inarc flash hazard analysis. The technique proposed was presented as a tutorial at an IEEE industry conference. Thereare many existing facilities that still need an arc flash hazard analysis completed. Individuals need a simple method touse even when just examining the equipment to determine conductor sizes, lengths, overcurrent device ratings orsettings and other necessary date to perform a detailed arc flash analysis. Other methods are already included in AnnexD so adding this one will provide guidance to users.

The submitter has not been provided sufficient substantiation to place this calculation method inAnnex D. There are many published short-cut methods of estimating incident energy derived from the IEEE 1584equations. Each technique has limitations and should be researched in its entirety.



_______________________________________________________________________________________________70E-421 Log #362 EEW-AAA


70E-519The committee action on proposal 70E-519 should have directed the references in proposed Annex

F Figure F.1 be correlated with the correct Sections in the document.The proposed Annex F Figure F.1 contains references to multiple sections of the document. Some

committee actions on other proposals have resulted in changes in section numbers (such as the relocation of entiresections in Article 110).This correlation is necessary to avoid confusion for users of the document.

Figure 1 references are to be revised as followed:Under “Hazard Identification” change 110.7(F) to 110.3(F)Under “Initial estimated risk” change 110.3(B)(1) to 130.3(B)(1)Under “Protective device” change 130.7(D)(1) (a) (f) (h) (i) to 130.8(D)Under “Information for use” change 120.2(F)(1)(a) to 120.2(F)(1)Under “Systems that increase awareness change “130.7(E)(1) (2) (3) to 130.8(E)Under “Training/Procedures” change 110.6(A) (B) (C) (D) (E) to 110.2Under “Work organization and instruction” change 130.5(B) to 130.6(C) and 130.6(A) to 130.7(A)Under “Personal protective equipment” change 130.3(B) to 130.5(B) and 130.7 to 130.8.

The committee updates the references in Figure F.1 and simplifies the references wherenecessary.



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70E-519The committee action on proposal 70E-519 should have been to Accept in Part. The part that

should have been accepted includes everything up to Section F.5 and Figure F.4. Figure F.5 should not have beenaccepted.

The proposed Annex material is complete without Figure F.5.Figure F.5 serves no useful purpose:• There isn’t any reference in the proposed Annex material to Figure F.5.• The information in Figure F.5 does not correlate to any of the information found in Annex F.• On its own, Figure F.5 contains very little useful information, rather it refers to another document identified as “the

detailed report” that is not included in the submission.



_______________________________________________________________________________________________70E-423 Log #368 EEW-AAA

_______________________________________________________________________________________________Jerry E. Rivera, National Electrical Contractors Association

70E-522aDelete text as follows:

Less than or equal to 1.2 cal/cm2

Face shield for projectile protection (AN)It is not anticipated to have substantial amount of energy released for the use of a face shielf much

less under anything less than 1.2 cal/cm2.

Face shields cannot be deleted since they may be required for incident energy exposures lessthan 1.2 cal/cm2 where there is a possibility of projectiles. The comment also does not provide technical substantiationto delete the text “less than”.


CARPENTER, T.: The committee action should have been to accept. The Committee Statement used for the RejectAction is correct when it says that the "comment also does not provide technical justification to delete the text "lessthan"." However, there should not have to be any justification to not require PPE when the the energies are less than1.2 cals/cm2. We don't require any AR PPE while standing just outside of the arc flash boundary (e.g. in an area withincident energy up to 1.1999 cals/cm2) so why do we recommend here that it is needed down to 0.0 cals/cm2. Also, theCommittee Statement as says that, "Face shields cannot be deleted since they may be required for incident energyexposures less than 1.2 cal/cm2, where there is a possibility of projectiles." However, the last sentence of FPN No. 1under 130.7(A) states, "The PPE requirements of 130.7 do not address protection against physical trauma other thanexposure to the thermal effects of an arc flash." As such, the Committee Statement is saying that we are recommendingsomething in an annex that is not covered by the requirements in the standard.


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70E-522aCommittee action should be Accept in Part.

(1) Table H.2 indicates that PPE is required for tasks “Less than or equal to 1.2 cal/cm2.” That meansthat PPE is required for tasks where the exposure has been calculated to be 0 cal/cm2. There should be a lower levelwhere no PPE is required. Employers should not be required to wear PPE for tasks with 0 cal/cm2. The table should bechanged to indicate that all PPE listed in the “Less than or Equal to 1.2 cal/cm2” is “AN” or “As needed".(2) Table H.2, note 3 implies that cotton clothes can be worn under arc rated clothes. It also says that the innermost

layer of non-FR clothing can be included in the multi layer system arc rating if the complete system including theinnermost layer is arc rated. This is in conflict with the action on 70E-352 which added this statement: “Garments thatare not arc-rated shall not be permitted to be used to increase the arc rating of a clothing system. “ Note 3 should bedeleted.(3) Table H.2 indicates that “arc-rated face shield and arc-rated balaclava or arc flash suit hood” are required for

exposures calculated at greater than 1.2 to 12 cal/cm2. The action on 70E-348 requires balaclava at HRC 2. The panelstatement on that proposal indicated clearly that it was not the intent of the committee to require balaclava at HRC1. ButTable H.2 indicates that it is required at exposures down to 1.2 cal/cm2, which conflicts with 70E-348. Table H.2 shouldbe revised to indicate that balaclava at greater than 1.2 to 12 cal/cm2 is AN or “As Needed.”

The committee accepts in principle the revision to Note 3 of Table H.2 and should read as follows:(3) Arc ratings can be for a single layer such as a arc-rated shirt and pants or a coverall, or for an arc flash suit or for a

multi layer system consisting of a combination of arc-rated shirt and pants, coverall and arc flash suit. The innermostlayer of clothing can be, nonmelting (according to ASTM F1506-08) or non-arc-rated natural fiber. Inclusion of theinnermost layer of nonmelting or non-arc-rated clothing as part of the multi layer system arc rating requires that thecomplete system including the innermost layer be arc tested to determine the system arc rating.

The remainder of the recommendation is rejected since the requested changes conflict with thePPE requirements in Section 130.7.


CARPENTER, T.: The committee should have accepted substantiation (1) also as it would have cleared up the issuewith the present guidance in Annex H to have AR clothing in areas with arc flash hazards less than 1.2 cals/cm2. As itreads now, we are recommending AR clothing at all times, even while laying on your couch at home.


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_______________________________________________________________________________________________The Technical Correlating Committee directs that the final action be reported as “Accept in Principle” as a

result of the Technical Committee’s action and statement.Thomas E. Neal, Neal Associates Ltd. and Oberon Company

70E-289, 70E-290The technical committee actions for Proposals 70E-289 and 70E-290 should have been Accept in

Principle in Part with the following action:The committee accepts in principle the proposal to add the new PPE Table but with the table added in Annex H as

Table H.5 rather than in Section 130.7(A), and also the committee accepts in principle the new text in Annex Hreferencing the new table as follows:

A summary of the specific sections within 130.7(C) which describe the personal protective equipment required bythis standard for electrical hazards is provided in Table H.5.

*** Insert Table 70E_L113_Rec Here****

The committee correlates the action on this proposal with actions taken on 70E-294 and 70E-377.The committee accepts the part of the proposed new PPE table referenced as “Option 3” in the proposal.

The submitter agrees with the following part of the Committee Statement: “The recommendation maybe better suited as reference material in an Annex.” The submitter agrees with the substantiation for adding thisinformation summary provided in Proposals 70E-289 and 70E-290.

Section H.2 has been revised to read:H.2 Arc-Rated Clothing and Other Personal Protective Equipment (PPE) for Use with a Hazard Analysis. Table H.2provides a summary of specific sections within the 70E standard describing personal protective equipment for electricalhazards. Guidance on the selection of arc rated clothing and other personal protective equipment for users whoconduct a hazard analysis to determine the incident energy exposure (in calories/cm2) to the work.

The committee prefers including this Table as H.3.2. Renumber existing Table H.3 as H.3.1.The committee also notes that the first sentence of H.3 and the informational note to 130.5(B)(1) (section numbersbased on ROP draft) will have to reflect the inclusion of this new table.

****Insert 70E_L113_Tb H.5_CA Here****



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70E_L113_Rec_ROC A2011

[Attachment for New PPE Table for Comment on Proposals 70E-289 and 70E-290, all new text]

Table H.5 Summary of Specific Sections Describing Personal Protective Equipment for Electrical Hazards

Shock Hazard Personal Protective Equipment Applicable Section(s)


130.7(C)6(a)

Rubber insulating sleeves (as needed) 130.7(C)6(a)

Class G or E hard hat (as needed) 130.7(C)3

Safety glasses or goggles (as needed) 130.7(C)4

Dielectric overshoes (as needed) 130.7(C)7

Arc Flash Hazard Personal Protective Equipment Applicable Section(s)

Incident Energy Exposures up to and including 1.2 calories/cm2

Clothing: non-melting or untreated natural fiber long sleeve shirt and long pants or coverall

130.7(C)1; 130.7(C)12(d)

Gloves: leather 130.7(C)6(b); 130.7(C)13(c)

Hard hat: class G or E 130.7(C)3

Faceshield: covers the face, neck and chin 130.7(C)3



Shoes or boots: heavy duty leather (as needed) 130.7(C)13(d)

Incident Energy Exposures > 1.2 calories/cm2

Clothing: arc-rated clothing system with an arc rating appropriate to the anticipated incident energy exposure

130.7(C)1; 130.7(C)2; 130.7(C)5; 130.7(C)12(d)

Clothing underlayers (when used): Arc-rated or non-melting untreated natural fiber

130.7(C)(12)(c); 130.7(C)14; 130.7(C)(15)

Gloves:

Exposures > 1.2 calories/cm and 8 calories/cm2: Heavy duty leather gloves (e.g. > 12 oz/yd2)

Exposures > 8 calories/cm2: Rubber insulating gloves with their leather protectors; or

Arc-rated gloves

130.7(C)6(b); 130.7(C)13(c)

Hard hat: class G or E 130.7(C)1; 130.7(C)3

Face shield:

Exposures > 1.2 calories/cm and 12 calories/cm2: Arc-rated faceshield that covers the face, neck and chin and an arc-rated

balaclava or an arc-rated arc flash suit hood

Exposures > 12 calories/cm2: Arc-rated arc flash suit hood

130.7(C)1; 130.7(C)3; 130.7(C)13(a); 130.7(C)13(b)

[See TC action on 70E-377]



Shoes or boots:



130.7(C)13(d)

70E_L113_Tb H.5_CA_ A2011

Table H.5 Summary of Specific Sections Describing Personal Protective Equipment for Electrical Hazards Shock Hazard Personal Protective Equipment Applicable Section(s)


130.8(C)7(a)

Rubber insulating sleeves (as needed) 130.8(C)7(a) Class G or E hard hat (as needed) 130.8(C)3 Safety glasses or goggles (as needed) 130.8(C)4 Dielectric overshoes (as needed) 130.8(C)8 Arc Flash Hazard Personal Protective Equipment Applicable Section(s) Incident Energy Exposures up to and including 1.2 calories/cm2 Clothing: non-melting or untreated natural fiber long sleeve shirt and

long pants or coverall 130.8(C)1; 130.8(C)9(d)

Gloves: Heavy-duty leather 130.8(C)7(b); 130.8(C)10(d) Hard hat: class G or E 130.8(C)3 Faceshield: covers the face, neck and chin (as needed) 130.8(C)3 Safety glasses or goggles 130.8(C)4; 130.8(C)10(c) Hearing protection 130.8(C)5 Shoes or boots: heavy duty leather (as needed) 130.8(C)10(e) Incident Energy Exposures > 1.2 calories/cm2 Clothing: arc-rated clothing system with an arc rating appropriate to the

anticipated incident energy exposure 130.8(C)1; 130.8(C)2; 130.8(C)6;

130.8(C)9(d) Clothing underlayers (when used): Arc-rated or non-melting untreated

natural fiber 130.8(C)9(c); 130.8(C)11; 130.8(C)12

Gloves: Exposures > 1.2 calories/cm and 8 calories/cm2:

Heavy duty leather gloves (e.g. > 12 oz/yd2) Exposures > 8 calories/cm2:

Rubber insulating gloves with their leather protectors; or Arc-rated gloves

130.8(C)7(b); 130.8(C)10(d)

Hard hat: class G or E 130.8(C)1; 130.8(C)3 Face shield:

Exposures > 1.2 calories/cm and 12 calories/cm2: Arc-rated faceshield that covers the face, neck and chin and an arc-

rated balaclava or an arc-rated arc flash suit hood Exposures > 12 calories/cm2:

Arc-rated arc flash suit hood

130.8(C)1; 130.8(C)3; 130.8(C)10(a); 130.8(C)10(b); 130.8(C)10(c)

Safety glasses or goggles 130.8(C)4; 130.8(C)10(c) Hearing protection 130.8(C)5 Shoes or boots Footwear:



130.8(C)10(e)



70E-522aCommittee action should beAccept in Part.

(1) Table H.2 indicates that PPE is required for tasks "Less than or equal to 1.2 cal/cm2. That meansthat PPE is required for tasks where the exposure has been calculated to be 0 cal/cm2. There should be a lower levelwhere no PPE is required. Employers should not be required to wear PPE for tasks with 0 cal/cm2. The table should bechanged to indicate that all PPE listed in the "Less than or Equal to 1.2 cal/cm2" is "AN" or "AS needed".(2) Table H.2, Note 3 implies that cotton clothes can be worn under arc rated clothes. It also says that the innermost

layer of non-FR clothing can be included in the multi-layer system arc rating if the complete system, including theinnermost layer is arc rated. This is in conflict with the action on 70E-372 which added this statement: "Garments thatare not arc-rated shall not be permitted to be used to increase the arc rating of a clothing system." Note 3 should bedeleted.(3) Table H.2 indicates that "arc-rated face shield and arc-rated balaclava or arc flash suit hood" are required for

exposures calculated at greater than 1.2 to 12 cal/cm2. The action on 70E-348 requires balaclava at HRC-2. The panelstatement on that proposal indicated clearly that it was not the intent of the committee to require balaclava at HRC1.But Table H.2 indicates that it is required at exposures down to 1.2 cal/cm2, which conflicts with 70E-348. Table H.2should be revised to indicate that balaclava at greater than 1.2 to 12 cal/cm2 is "AN" or "As Needed."



CARPENTER, T.: See substantiation for negative vote on Comment 70E-424.


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70E-300Accept Proposal 70E-300 in Principle in Part.

Add a new second sentence to M.1.1 to read as follows:Garments that are not arc-rated shall not be permitted to be used to increase the arc rating of a garment or of a

clothing system.The Technical Correlating Committee directed that the committee action on Proposal 70E-300 be

correlated with the action taken on Proposal 70E-372 and 70E-373. Doing so would meet the intent of the submitter inhis recommendation to have language added to M.1.1 to clarify that the arc rating of a garment and/or clothing systemcannot be increased by a layer(s) of non-arc rated garments.The recommended text in this comment provides the TCC desired correlation between Proposal 70E-300 and

Proposals 70E-372 and 70E-373 using the text provided in the affirmative ballot comment on Proposals 70E-372 and70E-373. This recommended text would be consistent with the 70E Technical Committee action taken on Proposals70E-372 and 70E-373, add that clarity into M.1.1 sought by the submitter of proposal 70E-300, and provided thecorrelation between Proposal 70E-300 and Proposal 70E-372 and 70E-373 sought by the TCC.

Revise the recommendation to read:Garments that are not arc-rated shall should not be permitted used to increase the arc rating of a garment or of a

clothing system.The committee action revises the text to non-mandatory language.


HITTEL, M.: The appropriate action is reject. The actions taken are in conflict with ASTM F1959.


_______________________________________________________________________________________________70E-428 Log #9 EEW-AAA


70E-300Accept Proposal 70E-300 in Part.

Add a new sentence to M.1.1 as recommended in Proposal 70E-300.It does not appear that the committee statement on proposal 70E-300 addressed the part of Proposal

70E-300 which sought to add a sentence to M.1.1 in Annex M where the submitter sought to clarify that the arc rating ofa garment and/or clothing system cannot be increased by a layer(s) of non-arc rated garments. Adding this text in M.1.1will add the necessary correlation and clarity between M.1.1 and 130.7(C)(12) and 130.7(C)(12)(a).

The intent of the recommendation is met by the committee action on Comment 70E-427.




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70E-531The Technical Correlating Committee requests that the committee action be reconsidered and



The committee accepts the comment from the Technical Correlating Committee and affirmsthat the last sentence of the proposed annex referencing the table is to be deleted to correlate with the action take onProposal 70E-538.



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70E-537It was the action of the Technical Correlating Committee that further consideration be given to the

proposal to eliminate the use of mandatory language in the proposed Annex.Also, further consideration should be given to revise Figures X.2 and X.3 to remove the phrase “shock hazard” to

correlate with the National Electrical Code.In addition, further consideration should be given to incorporating the label changes in X.3 from Proposal 70E-260.


Reject Proposal 70E-537.The committee accepts the direction of the Technical Correlating Committee (TCC) to further

consider the concerns expressed in its comment and has decided to reject its original action on Proposal 70E-537(Proposed Annex Q). The committee rejected Proposal 70E-537 because there are multiple options of conveying theinformation required by 130.3(C) as modified by Committee Comment 70E-248a (Log #CC7). Additionally the annexprovided information on NEC compliance that is outside the scope of NFPA 70E. The committee directs staff to deleteall references that were created to point to this proposed new annex.


DROBNICK, D.: I agree with the Committee’s action to accept the direction of the TCC and update Annex Q per theirspecific instructions. I disagree with the Committee’s rejection of Proposal 70E-537 which was accepted at the ROP.The NEC 110.16 directs the reader to 70E for labeling information. The rejected Annex provided examples much likethose found in the Canadian companion document CSA Z-462 showing label format and content. Without suchguidance inconsistent labeling schemes provided currently within software packages or created by end users will beperpetuated.GRAY, B.: The TCC recommended that the Annex be reworded but the committee removed the Annex instead of

rewording it. This Annex has a lot of good information dealing with labeling and ANSI Z535 that will help the workers inthe field understand the potential hazards in a uniform method. Since this is not addressed in the document with thelevel of information it should not have been removed. This annex would provide workers important informationregardless of who they work for in industry.


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70E-538The committee action to "Accept in Part" Proposal 70E-538 should be modified.

The part accepted should include the proposed text and the first, second and ninth (last) columns of the proposedtable.The part not accepted are columns three through eight that cross reference other standards.

****Insert Include 70E_L133_R.doc Here*****

This comment is submitted by the full CSA Z462 Workplace Electrical Safety Technical Committee.The CSA Z462 technical committee acknowledges the NFPA 70E technical committee statement that the referencedstandards in the recommended table will be constantly updated and the information in the table will be out of date atvarious times in each edition cycle of NFPA 70E.However, the CSA Z462 technical committee is of the opinion that the table adds significant value to the propose annexmaterial because it demonstrates how the requirements of NFPA 70E correspond with key elements of recognizedoccupational health and safety management systems.The CSA Z462 technical committee is of the opinion that the recommended revision to the proposal:1. Addresses the concern of the NFPA 70E technical committee that the referenced standards in the recommended

table will be constantly updated and the information in the table will be out of date at various times in each edition cycleof NFPA 70E.2. Meets the intent of the submitter (the CSA Z462 technical committee).3. Is not new material

The committee rejects the addition of the table with the limited columns. The addition of thecolumns does not increase the usability or clarity of the standard.



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Annex X Aligning Implementation of this Standard with Occupational Health and Safety Management Standards

Aligning implementation of this Standard with occupational health and safety management Standards

This Annex is not a part of the requirements of this NFPA document but is included for informational purposes only..

X.1 General

Injuries from electrical energy are a significant cause of occupational fatalities in the workplace in the United States. This Standard specifies requirements unique to the hazards of electrical energy. By itself, however, this Standard does not constitute a comprehensive and effective electrical safety program. The most effective application of the requirements of this Standard can be achieved within the framework of a recognized health and safety management system standard.

ANSI/AIHA Z10 provides comprehensive guidance on the elements of an effective health and safety management system, and is one recognized Standard. ANSI/AIHA Z10 is harmonized with other internationally recognized Standards, including CAN/CSA Z1000, ISO 14001, and OSHAS 18001. Some companies and other organizations have proprietary health and safety management systems that are aligned with the key elements of ANSI/AIHA Z10.

The most effective design and implementation of an electrical safety program can be achieved through a joint effort involving electrical subject matter experts and safety professionals knowledgeable about safety management systems. This collaboration can help ensure that proven safety management principles and practices applicable to any hazard in the workplace are appropriately incorporated into the electrical safety program.

This Annex provides guidance on implementing this Standard within the framework of ANSI/AIHA Z10 and other recognized or proprietary comprehensive occupational health and safety management system Standards. Table X.1 summarizes the harmonization of the key elements of recognized occupational health and safety management systems and the corresponding requirements of this Standard.

Table X.1

Correspondence between this Standard and key elements of recognized Occupational Health and Safety Management System (OHSMS) Standards

Key Elements of OHSMS NFPA 70E Article or Section Intent and objective of OHSMS*

Scope 90

Reference publications Annex A

Definitions 100

OHSMS

General Who is responsible to establish, maintain and review the electrical safety program?

How are affected workers involved in development and implementation?

Responsibility, accountability, and authority

110.7

Management representatives Worker participation OHS policy 110

Planning

General This is not about task planning, but about planning the overall electrical safety program.

What are the relevant codes and standards?

What resources are needed to assure sustainability?

Review Legal and other requirements 130.2; Annexes C and K

Hazard and risk identification and assessment

110.7(F); 110.8(B)(1); 130.2(B); 130.3; Annex F

OHS objectives and targets

Implementation

General 110.7 What systems, infrastructure, and resources are needed to meet the program objectives?

Preventive and protective measures

Emergency prevention, preparedness, and response

110.7


Competence and training 110.7

Communication and awareness 110.7(G); Annex I

Procurement Contracting Management of change

Documentation

General 110.7 What documents and document control systems are needed to implement and effective program and to monitor compliance with objectives?

Control of documents Control of records 110.8(B)(2); 130.1(B)

Evaluation and corrective action

General How will program performance be monitored, measured and analyzed to enable ongoing improvement?

Monitoring and measurement 110.7(D)

Incident investigation and analysis Internal audits 110.7(H); 120.2(C)(3)

Preventive and corrective action

Management review

General How will senior management stay informed of progress toward, and needs to achieve program objectives?

Continual improvement

Review input

Review output

*This column provides examples of questions that can be asked while implementing a comprehensive and effective electrical safety program. It is not an exhaustive list.



70E-539The committee action on 70E-539 should have been Accept for the addition of a new annex on

safety-related electrical maintenance.

****Insert Include 70E_L134_R.doc Here****

This comment is submitted by the full CSA Z462 Workplace Electrical Safety Technical Committee.The CSA Z462 technical committee respectfully acknowledges the NFPA 70E technical committee statement that

NFPA 70B and NETA standards address how to perform safety-related electrical maintenance. However, the intent ofthe proposed annex is to demonstrate the need to perform safety-related electrical maintenance, as well as provide theuser of the document useful and relevant information to assist in the application of the 70E in the workplace.Much of the information found in the various 70E Annexes can be found in source document[s], but that does not

negate the need for the inclusion of that material in 70E.The proposed Annex provides the user with guidance on the importance and relevance of safety-related electrical

maintenance, a topic so important to 70E that there is an entire Chapter dedicated to it. The safety of workers can begreatly impacted when equipment does not operate as required due to a lack of maintenance.

The committee reaffirms that the material is covered by references to NFPA 70B and NETAstandards in the 70E standard.



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70E_L134_Figure X.1_ROC_A2011

Figure X.1 Typical Power System Time‐Current‐Curve



70E-533The committee action on this proposal should have been to accept in principle. The diagram

indicates two tie breakers but the text appears to be written for one tie breaker. The main and tie circuit breakers in thediagram should be numbered and referred to in the text by the appropriate number for clarity. This could apply to theVTs and buses as well. No revisions are proposed for paragraph XX.1 The proposed revisions to paragraph XX.2 are asfollows.

Following is an outline that could be adapted as a procedure on a double-ended substation (see Figure XX.2) or otherarrangement depending on the specifics of the installation:

***Insert Figure XX.2 here***

· The use of the secondary, low voltage, side of the voltage transformers (VTs) depends on the specification and supplyinstallation of VTs on both the “line side” and “bus side” of the circuit breakers to be phased.· Initially, open all circuit breakers. Insert only the circuit breakers necessary to perform the operation in each stepdescribed below. All other circuit breakers not involved in that step should be withdrawn from their cubicles to the “testposition” where the primary voltage stabs are not engaged. For the configuration shown with two tie breakers, only oneof the tie breakers needs to be opened and withdrawn. In this example, tie breaker 52-3 remains closed. One source VTwill be used as the reference VT for each measurement. In this example, the left-side source 1 VT-L1 is used as thereference.· First, insert and close the left-side source 1 circuit breaker 52-1 onto the left-side bus 1 and measure that properline-to-line voltages are present. Then measure the voltages between the respective A, B, and C phase secondaryterminals (A to A, B to B, and C to C) of the left-side source side VT-L1 and the left-side bus VT-B1. All voltages shouldbe zero.· Insert and close the tie circuit breaker 52-4 on the “dead” right-side bus and assure that proper line-to-line voltages arepresent. Measure the voltages between the respective A, B, and C phase secondary terminals of the left-side sourceside VT-L1 and the right-side bus VT-B2. All voltages should be zero.· Open the tie and left-side source circuit breakers 52-1 and 52-4 and withdraw the circuit breakers to the test positions.· Measure the voltages between the respective A, B, and C phase secondary terminals of the left-side source sideVT-L1 and the right-side source VT-L2. All voltages should be zero or near zero. Since this step is measuring thedifferences in voltage between source 1 and source 2, it is possible that the readings will be slightly above zero if theline-to-line voltages of each source are not exactly the same.· Insert and close the right-side source circuit breaker 52-2 onto the right-side bus 2 and measure that proper line-to-linevoltages are present. Then measure the voltages between the respective A, B, and C phase secondary terminals of theright-side source side VT-L2 and the right-side bus VT-B2. All voltages should be zero.· Insert and close the tie circuit breaker 52-4 on the “dead” right-side bus and assure that proper line-to-line voltages arepresent. Measure the voltages between the respective A, B, and C phase secondary terminals of the left-side sourceside VT-L2 and the left-side bus VT-B1. All voltages should be zero.· The phase relationships of all the VTs have been proven if the above steps have been followed.· Open the tie circuit breaker 52-4 and withdraw it, then insert and close the left-side circuit breaker 52-1.· As a final verification step, measure that proper line-to-line voltages are present on the bus VTs on both sides of theopen tie circuit breaker. Then measure the voltages between the respective A, B, and C phase of the left-side busVT-B1 and the right-side bus VT-B2. All voltages should be zero or near zero.If the voltages measured in the above step are zero or near zero, the phasing is correct and the tie circuit breaker can

be inserted and safely closed, as during a closed-transition bus transfer or for a normally-closed tie configuration.For metal-clad and metal-enclosed circuit breaker switchgear, the phasing tests with hot sticks can

expose the workers to very high incident energy levels (transformer secondaries) and a higher than normal risk becausethe equipment has to be energized and the safety shutters have to be lifted in order to access the bus stabs. In addition,they have to work within the confines of the breaker cubicles which places them very close to the arc should a faultoccur. The confined working space also increases the chances of an arc or fault being intitiated. The phasing meter andhot sticks may require two workers, exposing both of them to the hazards. Measuring voltages on the secondary of a VT

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Report on Comments – June 2011 NFPA 70Ecan be done by one person. Incident energies can’t be calculated for a generic system but the line side main breakerlevels could exceed 40 cal/cm2 and the use of VTs as proposed could lower the workers exposure to less than 4 cal/cm2.These values are based on ranges calculated for the distribution system in one of our plants. This proposal is anexcellent example of how equipment design and procedures can be adapted to reduce the hazards to which the workersare exposed and should be included in the standard.

There are numerous electrical procedures and methods that could be place in the NFPA 70Estandard. The proposed annex does not warrant being included in the NFPA 70E standard.



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M E M O R A N D U M - NFPA · A.3.1 ANSI Publications ANSI A14.3, Safety Requirements for Fixed...

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