TECHNICAL COMMITTEE ON Electrical Safety in the Workplace ... · Hyatt Regency St. Louis at the Arch, St. Louis, MO August 13 – 17, 2018 ... Steven D. Corrado Voting Alternate UL

TECHNICAL COMMITTEE ON

Electrical Safety in the Workplace Agenda

First Draft Meeting for NFPA 70E

Hyatt Regency St. Louis at the Arch, St. Louis, MO

August 13 – 17, 2018

08-18-01 Call to Order & Welcome

08-18-02 Introduction of Committee Members (Attachment A)

08-18-03 Approval of Previous Meeting Minutes (Attachment B)

08-18-04 Chairs Remarks

08-18-05 Staff Presentation

08-18-06 Task Group Reports and Review of Public Comments (Attachment C)

08-18-07 Old Business

08-18-08 New Business

08-18-09 Schedule Next Meeting

08-18-10 Adjournment

Attachment A: Technical Committee Roster

Address List No PhoneElectrical Safety in the Workplace EEW-AAANational Electrical Code®

Christopher Coache07/23/2018

EEW-AAALouis A. BarriosChairShell Global Solutions3333 Highway 6 SouthHouston, TX 77082-3101American Petroleum Institute

U 1/18/2001EEW-AAA

William Bruce BowmanPrincipalFox Systems, Inc.PO Box 1777Calhoun, GA 30703-1777Independent Electrical Contractors, Inc.Alternate: Lawrence S. Ayer

IM 3/4/2009

EEW-AAASteven C. ChybowskiPrincipalRockwell Automation Inc.1201 South 2nd StreetMilwaukee, WI 53204

M 10/18/2011EEW-AAA

Daryld Ray CrowPrincipalDRC Consulting, Ltd.143 S. East Ridge DriveSt. George, UT 84790The Aluminum Association, Inc.Alternate: Karl M. Cunningham

M 10/1/1995

EEW-AAAMichael J. DouglasPrincipalGeneral Motors Company5415 Wyndam LaneBrighton, MI 48116-4734Alternate: William R. Harris

U 10/20/2010EEW-AAA

Drake A. DrobnickPrincipal1394 Middlewood DriveSaline, MI 48176Alternate: Charles R. Miller

SE 1/17/1997

EEW-AAAThomas B. DysonPrincipalAmeren Services1901 Chouteau AvenueSt. Louis, MO 63103-3003Edison Electric Institute

U 08/11/2014EEW-AAA

Marcia L. EblenPrincipal10113 Del Almendra DriveOakdale, CA 95361-2238ASTM InternationalAlternate: Samuel B. Stonerock

SE 3/2/2010

EEW-AAAErnest J. GalloPrincipalTelcordia Technologies (Ericsson)444 Hoes LanePiscataway, NJ 08854-4157Alliance for Telecommunications Industry SolutionsAlternate: James E. Brunssen

U 08/11/2014EEW-AAA

Bobby J. GrayPrincipalHoydar/Buck, Inc.PO Box 146Selah, WA 98942Alternate: Larry D. Perkins

E 4/5/2001

EEW-AAAJames B. HayesPrincipalFlorida Institute of Technology150 West University BoulevardMelbourne, FL 32901

U 3/2/2010EEW-AAA

Palmer L. HickmanPrincipalElectrical Training Alliance5001 Howerton Way, Suite NBowie, MD 20715-4459International Brotherhood of Electrical WorkersAlternate: James T. Dollard, Jr.

L 10/3/2002

1



EEW-AAAKevin J. LippertPrincipalEaton Corporation1000 Cherrington ParkwayMoon Township, PA 15108National Electrical Manufacturers AssociationAlternate: Gregory J. Steinman

M 8/5/2009EEW-AAA

Terrance L. McKinchPrincipalMortenson Construction3278 South Duffield RoadLennon, MI 48449-9407Alternate: Jeffrey Paul Conkwright

U 08/03/2016

EEW-AAAMark McNellisPrincipalSandia National LaboratoriesPO Box 5800, MS0984Albuquerque, NM 87185Alternate: Heath Garrison

U 7/28/2006EEW-AAA

Daleep C. MohlaPrincipalDCM Electrical Consulting Services, Inc.4702 Summer LakesMissouri City, TX 77459-3958Institute of Electrical & Electronics Engineers, Inc.Alternate: Paul Dobrowsky

SE 1/14/2005

EEW-AAAJames K. NiemiraPrincipalS&C Electric Company8940 Ewing AvenueEvanston, IL 60203-1907

M 12/8/2015EEW-AAA

David A. PacePrincipalOlin Corporation1638 Industrial RoadMcIntosh, AL 36553American Chemistry CouncilAlternate: Roy K. Sparks, III

U 7/22/1999

EEW-AAAJames G. StallcupPrincipalGrayboy, Inc.6800 Meadow CreekNorth Richland Hills, TX 76182Alternate: James W. Stallcup, Jr.

SE 1/1/1991EEW-AAA

Charlie R. Thurmond IIIPrincipalThyssenKrupp Elevator9280 Crestwyn Hills DriveMemphis, TN 38125National Elevator Industry Inc.Alternate: Don Afman

IM 10/29/2012

EEW-AAAJohn M. TobiasPrincipalUS Department of the ArmyCECOM, Attn: Amsel-SFS-I3200 Raritan AvenueAberdeen Proving Grounds, MD 21005

U 10/18/2011EEW-AAA

Rodney J. WestPrincipalSchneider Electric5735 College Corner RoadOxford, OH 45056-1070Alternate: Bill Alderton

M 7/29/2005

EEW-AAAJames R. WhitePrincipalShermco Industries, Inc.2425 East Pioneer DriveIrving, TX 75061InterNational Electrical Testing AssociationAlternate: Ron Widup

IM 1/16/2003EEW-AAA

Jason WolfPrincipalThe ESCO Group3450 3rd StreetMarion, IA 52302National Electrical Contractors AssociationAlternate: Wesley L. Wheeler

IM 12/06/2017

2



EEW-AAASteven D. CorradoVoting AlternateUL LLC12 Laboratory DrivePO Box 13995Research Triangle Park, NC 27709-3995

RT 3/2/2010EEW-AAA

Thomas D. NorwoodVoting AlternateAVO Training Institute4271 Bronze WayDallas, TX 75237-1019

SE 10/4/2001

EEW-AAADon AfmanAlternateKone Elevator Inc.One Kone CourtMoline, IL 61265-1374National Elevator Industry Inc.Principal: Charlie R. Thurmond III

IM 04/08/2015EEW-AAA

Bill AldertonAlternateSchneider Electric5735 College Corner RoadOxford, OH 45056Principal: Rodney J. West

M 10/28/2014

EEW-AAALawrence S. AyerAlternateBiz Com Electric, Inc.2867 Stanton AvenueCincinnati, OH 45206Independent Electrical Contractors, Inc.Principal: William Bruce Bowman

IM 7/14/2004EEW-AAA

James E. BrunssenAlternateTelcordia Technologies (Ericsson)11 Ashwood PlaceParsippany, NJ 07054-2213Alliance for Telecommunications Industry SolutionsPrincipal: Ernest J. Gallo

U 08/11/2014

EEW-AAAJeffrey Paul ConkwrightAlternateMortenson Energy Services700 Meadow Lane NorthMinneapolis, MN 55422Principal: Terrance L. McKinch

U 12/06/2017EEW-AAA

Karl M. CunninghamAlternateAlcoa, Corporation201 Isabella StreetPittsburgh, PA 15212The Aluminum Association, Inc.Principal: Daryld Ray Crow

M 04/11/2018

EEW-AAAPaul DobrowskyAlternateInnovative Technology Services5701 South Holley RoadHolley, NY 14470-9754Institute of Electrical & Electronics Engineers, Inc.Principal: Daleep C. Mohla

SE 10/18/2011EEW-AAA

James T. Dollard, Jr.AlternateIBEW Local Union 981701 Spring Garden StreetPhiladelphia, PA 19130International Brotherhood of Electrical WorkersPrincipal: Palmer L. Hickman

L 4/14/2005

EEW-AAAHeath GarrisonAlternateNational Renewable Energy Laboratory15013 Denver West ParkwayGolden, CO 80401Principal: Mark McNellis

U 3/7/2013EEW-AAA

Eric GlaudeAlternateChevron1400 Smith StreetHouston, TX 77002American Petroleum Institute

U 8/2/2010

3



EEW-AAAWilliam R. HarrisAlternateGeneral Motors Company30200 Mound Road, Building 1-11Warren, MI 48092-2025Principal: Michael J. Douglas

U 08/17/2015EEW-AAA

Charles R. MillerAlternateLighthouse Educational ServicesCharles R. Miller Electrical Education & Training523 Five Oaks BoulevardLebanon, TN 37087Principal: Drake A. Drobnick

SE 10/29/2012

EEW-AAALarry D. PerkinsAlternateUS Department of Energy104 Redbud DriveHarriman, TN 37748Principal: Bobby J. Gray

E 10/27/2009EEW-AAA

Roy K. Sparks, IIIAlternateEli Lilly and CompanyLilly Technology Center South1400 West Raymond StreetDrop Code 4005Indianapolis, IN 46221-2004American Chemistry CouncilPrincipal: David A. Pace

U 12/06/2017

EEW-AAAJames W. Stallcup, Jr.AlternateGrayboy, Inc.6800 Meadow CreekNorth Richland Hills, TX 76182Principal: James G. Stallcup

SE 1/1/1994EEW-AAA

Gregory J. SteinmanAlternateThomas & Betts Corporation8155 T&B BoulevardMemphis, TN 38125-8888National Electrical Manufacturers AssociationPrincipal: Kevin J. Lippert

M 08/03/2016

EEW-AAASamuel B. StonerockAlternateSouthern California Edison Company3 Innovation WayPomona, CA 91768-2560ASTM InternationalPrincipal: Marcia L. Eblen


Wesley L. WheelerAlternateNational Electrical Contractors Association3 Bethesda Metro Center, Suite 1100Bethesda, MD 20814-6302National Electrical Contractors AssociationPrincipal: Jason Wolf

IM 03/03/2014

EEW-AAARon WidupAlternateShermco Industries2425 East Pioneer DriveIrving, TX 75061InterNational Electrical Testing AssociationPrincipal: James R. White

IM 7/17/1998EEW-AAA

Mike DohertyNonvoting MemberBlue Arc Electrical Safety Technologies, Inc.823 Donegal AvenueOshawa, ON L1J 6K5 CanadaCanadian Standards AssociationAlternate: Carolyn Black

SE 04/04/2017

EEW-AAACarolyn BlackAlt. to Nonvoting MemberMount Vernon Mills347 Tuscany Estates Rise NWUnit 13Calgary, AB T3L 0C8 CanadaCanadian Standards AssociationPrincipal: Mike Doherty


David M. WallisMember EmeritusConsultant9728 Denrob CourtParkville, MD 21234-1861

SE 10/10/1998

4



EEW-AAAChristopher CoacheStaff LiaisonNational Fire Protection AssociationOne Batterymarch ParkQuincy, MA 02169-7471

3/13/2015

5

Attachment B: Previous Meeting Minutes

Chairman’s Report for the TC on Electrical Safety in the Workplace,

70E, Second Draft Meeting

Signature October 31, 2016

1) Date(s) and location of meeting: July 18 – 21, 2016, Salt Lake City, UT.

2) List names of guests in attendance: See attached Appendix A.

3) List names of guests addressing the Panel/TC, the subject of their address,

and the length of time they spoke:

Rachel Bugaris of Panduit speaking on behalf of her PC-147 (permanently

mounted testers), 5 minutes. Michael Johnston, Chair of the Correlating Committee,

speaking on behalf of PC-151 and requirements of the NEC Style Manual regarding

prohibition of mandatory references to other standards, 5 minutes.

4) Number of Public Comments acted upon: 173

5) Number of Second Revisions created: 70

6) List any Task Groups appointed to work subsequent to the Second Draft

Meeting, along with the names of members of the Task Group(s): none

7) List any request contained in a Responses or Statement that require NEC

Correlating Committee attention: none

8) List any Public Comments or Second Revisions, in your opinion that needs to

be referred to another TC for information or correlation: none

9) List any Public Comments or Second Revisions that should be referred to the

Toxicity Advisory Committee: none

10) List all Public Comments or Second Revisions related to combustibles in

plenums or other air handling spaces: none

11) Identify any issues that should be brought to the attention of the NFPA

Research Foundation for their input and assistance: none

12) List any general requests for information or assistance from the NEC

Correlating Committee: none

13) Provide any additional information that you feel would be helpful to the NEC

Correlating Committee, staff, or to the process in general: none

Appendix A

Attendance

David Dini, Chair Christopher Coache, NFPA Staff Liaison

Principal Members in Attendance

William Bowman, American Petroleum Institute

Steven Chybowski, Rockwell Automation Inc.

Michael Douglas, General Motors Company

Drake Drobnick

Thomas Dyson, Edison Electric Institute Marcia Eblen, ASTM International

Ernest Gallo, Alliance for Telecommunications Industry

Bobby Gray, Hoydar/Buck, Inc.

Lee Hale, The Aluminum Association, Inc. James Hayes, Florida Institute of Technology

Palmer Hickman, International Brotherhood of Electrical Workers

John Luke, National Electrical Contractors Association

Mark McNellis, Sandia National Laboratories

Daleep Mohla, Institute of Electrical and Electronics Engineers, Inc.

Dennis Neitzel, AVO Training Institute, Inc.

David Pace, American Chemistry Council

James Stallcup, Grayboy, Inc. Charlie Thurmond III, National Elevator Industry Inc.

John Tobias, US Department of the Army Rodney West, Schneider Electric

Ron Widup, International Electrical Testing Association

Voting Alternate Members in Attendance

Kevin Lippert, National Electrical Manufacturers Association

James Niemira, S&C Electric Company

Alternate Members in Attendance

Bill Alderton, Schneider Electric Lawrence Ayer, Independent Electrical Contractors, Inc.

Steven Corrado, UL LLC Daryld Crow, The Aluminum Association

Paul Dobrowsky, Institute of Electrical and Electronics Engineers, Inc.

James Dollard, International Brotherhood of Electrical Workers

Heath Garrison, National Renewable Energy Laboratory

Eric Glaude, American Petroleum Institute

William Harris, General Motors Company Charles Miller, Lighthouse Educational Services

Thomas Norwood, AVO Training Institute Samuel Stonerock, ASTM International

Wesley Wheeler, National Electrical Contractors Association

Guests in Attendance

Daniel Roberts, Canadian Standards Association

Gregory Steinman, Thomas & Betts, ABB

Bill Burke, NFPA El-Sherif Nehad

Mark Hilbert, MRH Inspections and Training

Tim Rohrer, Exiscan

Al Havens, e-Hazard Management, LLC Denise Statham, Bulwark Protective Apparel

John Moody, Westexby Millitan Rachel Bugaris, Panduit Corp.

Michael Johnston, NECA Gil Moniz, NFPA

Attachment C: Public Comment Report

Public Input No. 125-NFPA 70E-2018 [ Global Input ]

Consider the following changes to the shock hazard boundary titles:

(1) "Limited Approach Boundary" to "Limited Shock Boundary"(2) "Restricted Approach Boundary" to "Restricted Shock Boundary"

Statement of Problem and Substantiation for Public Input

In my personal experience as a safety professional, I've found that field workers often confuse hazard boundaries because of ambiguity in the boundary title names. I've proposed the change because there is no value to the word "approach" in the current boundary title definitions, whereas there is a great deal of value in stating the hazard being controlled within the boundary title itself. Additionally, the change is consistent with "Arc Flash Boundary," which is unambiguous as to what hazard is being controlled.

Submitter Information Verification

Submitter Full Name: Phillip ClarkOrganization: National Renewable Energy LaboratoryStreet Address:City:State:Zip:Submittal Date: Fri Jun 08 15:48:48 EDT 2018Committee:

National Fire Protection Association Report https://submittals.nfpa.org/TerraViewWeb/ContentFetcher?commentPar...

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Proposal: All “Risk Assessment” references and requirements should be removed entirely fromNFPA7OE.

Substantiation:1) Risk assessment does not comport with the requirements of the “Style Manual”. 3.2.1 UnenforceableTerms. The NEC and NFPA 70E shall not contain references or requirements that are unenforceable. Bydefinition risk assessment is purely qualitative and subjective requiring “estimates”. Estimates as inestimates of likelihoods are NOT quantifiable. There is no way anyone attempting to apply theserequirements of NFPA 70E could possibly know what any AHJ would estimate at any point in time since therisk assessment estimates required by NFPA 70E are as myriad as the number of possible AHJ’s makingsuch estimates. Furthermore the Style Manual requirements in 1.3 require that standard requirements(NFPA 70E) be “suitable for adoption as a regulatory document”. If the U.S. Department of LaborOccupational Safety and Health Administration (OSHA) ever attempted to promulgate a regulatoryrequirement 33 based on such subjective criteria as “risk assessment” as defined in the document (NFPA70E), OSHA would immediately be sued upon announcement of such a subjective rule in the FederalRegister and the courts would incontrovertibly declare such a vague and subjective requirementunenforceable. There is plenty of existing case law on this.2) This requirement lacks supporting scientific documentation. The Technical Committee on FireDepartment Apparatus had required that “tires shall be replaced at least every seven (7) years or morefrequently in NFPA 1911 Standard for the Inspection, Maintenance, Testing, and Retirement of In-ServiceEmergency Vehicles. NFPA commissioned a study and the report issued from the study established that‘this requirement lacked supporting scientific documentation”. The requirement was immediately(announced in a TIA-Tentative Interim Amendment) removed from the standard. When “RiskAssessment” was incorporated into NFPA 70E from the source document (ANSI Z1O) it hadalready been established and stated in the source document (ANSI Z1O) that there was “noscientific basis behind determining the relationships between hazard, exposure and risk”,therefore it should immediately be removed from the 70E standard.3) Risk assessment requirement lacks supporting scientific documentation supporting its validity. Thesource/base standards from which “Risk Assessment” was originally obtained have their basis ininternational (ISO) “environmental” standards as well as ISO social responsibility standards.“Environmental” standards have nothing to do with occupational safety and health and electrical safetystandards.4) The definition of the occupational safety and health professional (as defined in the U.S. Department ofLabor Occupational Outlook Manual) is to “analyze work environments and work procedures to preventdisease or injury to workers”, not to asses in order to reduce probabilities, such as making estimates toreduce the severity of an injury including frequencies of exposures, etc.. Actuaries (as defined in the U.S.Department of Labor Occupational Outlook Manual) “assess the risk that an event will occur and they helpbusinesses and clients develop policies that minimize the cost of that risk”. Gambling with monetary costsare far different than gambling with human lives. Risk assessment for the protection of people is antitheticalto occupational safety and health in the U.S. and are antithetical to OSHA regulatory requirements.5) This requirement lacks supporting scientific documentation supporting its validity. The fundamentalapproach of risk assessment is antithetical to occupational safety and health and our entire societal moralcompass in the U.S. The “risk assessment” approach to injury or illness to humans has no place in healthand safety based standards. The base/source of risk assessment from ISO risk assessment model with theassociated definitions and guides defines the acceptable levels of risk (aka tolerable risk from ISO/IECGuide 51) as being predicated on “current values of society”. “Values” have nothing to do with the physicsinvolved in electrical safety.


Increased worker protection.



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Submitter Full Name: J BOrganization: State of NV ConsultationStreet Address:City:State:Zip:Submittal Date: Fri Jun 15 16:13:06 EDT 2018Committee:


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Proposal: Remove “Conformity Assessment” from 130.7(C)(14) and all related references.

Substantiation:1) Conformity Assessment does not comport with the requirements of the “Style Manual”. StyleManual 4.2 References to Other Standards. References to other standards shall not be inmandatory Code text. References to product standards shall be in an informative annex.References to other Standards shall be in the Informational Notes. ‘Conformity Assessment” isanother standard! Just because the codification number of “Conformity Assessment” was omittedit still remains another standard. No different than stating the “National Electrical Code” or “NEC”absent the inclusion of the codification number NFPA7O.2) “Conformity Assessment” lacks supporting scientific documentation supporting its validity. Theentire “Conformity Assessment” standard is entirely predicated on ISO standards. Specifically ISO9001 Quality Management Systems, ISO 17011 Conformity Assessments General Requirementsfor Accreditation Bodies, ISO 17021 Conformity Assessments for Bodies providing Audits andCertification, ISO 17025 General Requirements for Competency of Testing Labs, and ISO 170065conformity Assessment Requirements for Certifying products and Service. The high capital costsof abandoning the current U.S. standards and accreditation systems which are already in place inlieu of considerably more expensive and time consuming audits and certification protocolsassociated with ISO certification and ISO related certification organizations would severelyhandicap U.S. companies in both domestic as well as global markets if not completely drivecompanies out of business. This substantiation based on fiscal considerations has already beenaccepted by NFPA as a valid basis for removal of standard requirements (see Fire ProtectionResearch Foundation report: “Automotive Fire Apparatus Tire Replacement” Author: SreenivasanRanganathan and Minchao Yin, Fire Protection Research Foundation Date of issue: March 2015),“Due to high capital costs, the decision for replacing fire apparatus tires should be based on anobjective decision making process. The required replacement of tires after seven (7) years isplacing an undue financial burden on departments and agencies trying to comply with the 1911requirements.” The requirement was removed from the standard.3) This requirement lacks supporting scientific documentation that conformity assessment insuresthe safety and integrity of PPE and further does not comport with the requirements of the “StyleManual” to insure standard requirements are suitable for regulatory adoption. Conformityassessment doesn’t comport with existing OSHA regulatory requirements for PPE. The entireAmerican Society of Testing and Materials (ASTM) body of electrical protective equipment safetystandards that were developed in the U.S. and in place for decades were removed frommandatory text and replaced with standards not based in science. Unlike the body of ASTMstandards which are safety testing protocols (such as ASTM 1506) the current standards haveabsolutely no safety testing protocols whatsoever. They are entirely procedural, addressingdocumentation and certification procedures. NFPA 70E just replaced all of the ASTM safetytesting protocols administrative certification requirements with no science based testing to backthem up. The U.S. have been writing electrical standards since 1881 with the first NationalElectrical Code published in 1897. We don’t need to abandon that pedigree for the adoption ofpernicious requirements with no fact based, scientifically repeatable safety assurances.


Improved worker safety.


Submitter Full Name: J B


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Organization: State of NV ConsultationStreet Address:City:State:Zip:Submittal Date: Fri Jun 15 17:33:15 EDT 2018Committee:


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Replace all references to "1.2 cal/cm2" and/or "1.2 cal/cm (5 J/cm2)" to "0 cal/cm2" and/or "0cal/cm2 (0 J/cm2)", and remove any associated references to second degree burns, curable burns,non-curable burns, Stoll Cuve, etc.


When early pioneers of arc flash hazards research conducted their work and provided the first methods of determining what the arc flash hazards were, and how to provide protection, this effort targeted the areas of worst concern and greatest exposure first. The main focus was to prevent non-curable burn injuries, primarily with 600 volt and below equipment, the area where it was believed most of the injuries were occurring. This was done with the expectation that as others continued this effort, the methods of predicting the hazard and for protection would improve, which they have significantly, and that the areas targeted would be driven lower and lower till it reached zero..

As written, the 70E standard accepts the fact that people my be burned, but that the burns should be curable, with no long term, permanent affects. This was acceptable when we were trying to target the worst areas first for much more severe injuries and deaths, but we are at a point where the research is targeting less and less severe injuries as time goes on, a good thing. We do not need to publish a standard that says it's OK to burn someone, just don't burn them too bad. The standard and all of the associated codes and standards have matured to the point the lower limit should be zero cal/cm2. The guidance should not tolerate any injury potential, no matter how minor.

Several cycles ago, the guidance in the standard related to live line, bare hand work was removed because the committee felt the standard should not be giving guidance on live line work, it should be eliminating it and replacing it with guidance that results in improved employee safety, in sharp contrast to the attitude toward this work when the words were first included in the text. Very similar to many things that were considered acceptable years ago, and are not today. Also, the text related to the Prohibited Approach Boundary, which was associated with the live line work issue, was later also removed from the standard.

The committee needs to take the next step in the evolution of the standard and drive this to zero.


Submitter Full Name: David PaceOrganization: Olin CorporationAffiliation: SelfStreet Address:City:State:Zip:Submittal Date: Tue Jun 19 11:01:37 EDT 2018Committee:


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Proposal: All “Risk Assessment” references and requirements should be removed entirely fromNFPA 70E.Substantiation: Risk assessment does not comport with the requirements of the “Style Manual”.3.2.1 Unenforceable Terms. The NEC and NFPA 70E shall not contain references or requirementsthat are unenforceable.By definition risk assessment is purely qualitative and subjective requiring “estimates”. Estimatesas in estimates of likelihoods are NOT quantifiable. There is no way anyone attempting to applythese requirements of NFPA 70E could possibly know what any AHJ would estimate at any point intime since the risk assessment estimates required by NFPA 70E are as myriad as the number ofpossible AHJ’s making such estimates.Furthermore the Style Manual requirements in 1.3 require that standard requirements (NFPA 70E) be“suitable for adoption as a regulatory document”. If the U.S. Department of Labor OccupationalSafety and Health Administration (OSHA) ever attempted to promulgate a regulatory requirement.based on such subjective criteria as “risk assessment” as defined in the document (NFPA 70E),OSHA would immediately be sued upon announcement of such a subjective rule in the FederalRegister and the courts would incontrovertibly declare such a vague and subjective requirementunenforceable. There is plenty of existing case law on this.Proposal: Remove “Conformity Assessment” from 130.7(C)(14) and all related references.Substantiation: Conformity Assessment does not comport with the requirements of the “StyleManual”.Style Manual 4.2 References to Other Standards. References to other standards shall not be inmandatory Code text. References to product standards shall be in an informative annex. Referencesto other Standards shall be in the Informational Notes.“Conformity Assessment” is another standard! Just because the codification number of“Conformity Assessment” was omitted it still remains another standard. No different than statingthe “National Electrical Code” or “NEC” absent the inclusion of the codification number NFPA70.


Substantiation: Risk assessment does not comport with the requirements of the “Style Manual”. 3.2.1 Unenforceable Terms. The NEC and NFPA 70E shall not contain references or requirements that are unenforceable.By definition risk assessment is purely qualitative and subjective requiring “estimates”. Estimates as in estimates of likelihoods are NOT quantifiable. There is no way anyone attempting to apply these requirements of NFPA 70E could possibly know what any AHJ would estimate at any point in time since the risk assessment estimates required by NFPA 70E are as myriad as the number of possible AHJ’s making such estimates.Furthermore the Style Manual requirements in 1.3 require that standard requirements (NFPA 70E) be “suitable for adoption as a regulatory document”. If the U.S. Department of Labor Occupational Safety and Health Administration (OSHA) ever attempted to promulgate a regulatory requirement based on such subjective criteria as “risk assessment” as defined in the document (NFPA 70E), OSHA would immediately be sued upon announcement of such a subjective rule in the Federal Register and the courts would incontrovertibly declare such a vague and subjective requirement unenforceable. There is plenty of existing case law on this.

Substantiation: Conformity Assessment does not comport with the requirements of the “Style Manual”.Style Manual 4.2 References to Other Standards. References to other standards shall not be in mandatory Code text. References to product standards shall be in an informative annex. References to other Standards shall be in the Informational Notes. “Conformity Assessment” is another standard! Just because the codification number of “Conformity Assessment” was omitted it still remains another standard. No different than stating the “National Electrical Code” or “NEC” absent the inclusion of the codification number NFPA70


Submitter Full Name: John Grzywacz


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Organization: John "Grizzy" Grzywacz Inc.Street Address:City:State:Zip:Submittal Date: Sun Jun 24 19:32:46 EDT 2018Committee:


8 of 885 6/28/2018, 1:37 PM


All “Risk Assessment” references and requirements should be removed entirely from NFPA 70E.


Substantiation: This requirement lacks supporting scientific documentation. The Technical Committee on Fire Department Apparatus had required that “tires shall be replaced at least every seven (7) years or more frequently in NFPA 1911 Standard for the Inspection, Maintenance, Testing, and Retirement of In-Service Emergency Vehicles. NFPA commissioned a study and the report issued from the study established that “this requirement lacked supporting scientific documentation”. The requirement was immediately (announced in a TIA-Tentative Interim Amendment) removed from the standard. When “Risk Assessment” was incorporated into NFPA 70E from the source document (ANSI Z10) it had already been established and stated in the source document (ANSI Z10) that there was “no scientific basis behind determining the relationships between hazard, exposure and risk”, therefore it should immediately be removed from the 70E standard.


Submitter Full Name: John GrzywaczOrganization: John Grizzy Grzywacz Inc.Street Address:City:State:Zip:Submittal Date: Tue Jun 26 17:05:20 EDT 2018Committee:


9 of 885 6/28/2018, 1:37 PM


Remove “Conformity Assessment” from 130.7(C)(14) and all related references.


“Conformity Assessment” lacks supporting scientific documentation supporting its validity. The entire “Conformity Assessment” standard is entirely predicated on ISO standards (foreign standards). Specifically ISO 9001 Quality Management Systems, ISO 17011 Conformity Assessments General Requirements for Accreditation Bodies, ISO 17021 Conformity Assessments for Bodies providing Audits and Certification, ISO 17025 General Requirements for Competency of Testing Labs, and ISO 170065 Conformity Assessment Requirements for Certifying products and Service.The high capital costs of abandoning the current U.S. standards and accreditation systems which are already in place in lieu of considerably more expensive and time consuming audits and certification protocols associated with ISO certification and ISO related certification organizations would severely handicap U.S. companies in both domestic as well as global markets if not completely drive companies out of business. This substantiation based on fiscal considerations has already been accepted by NFPA as a valid basis for removal of standard requirements (see Fire Protection Research Foundation report: "Automotive Fire Apparatus Tire Replacement" Author: Sreenivasan Ranganathan and Minchao Yin, Fire Protection Research Foundation Date of issue: March 2015), “Due to high capital costs, the decision for replacing fire apparatus tires should be based on an objective decision making process. The required replacement of tires after seven (7) years is placing an undue financial burden on departments and agencies trying to comply with the 1911 requirements.” The requirement was removed from the standard.




10 of 885 6/28/2018, 1:37 PM


All “Risk Assessment” references and requirements should be removed entirely from NFPA 70E.


Risk assessment does not comport with the requirements of the “Style Manual”. 3.2.1 Unenforceable Terms. The NEC and NFPA 70E shall not contain references or requirements that are unenforceable. By definition risk assessment is purely qualitative and subjective requiring “estimates”. Estimates as in estimates of likelihoods are NOT quantifiable. There is no way anyone attempting to apply these requirements of NFPA 70E could possibly know what any AHJ would estimate at any point in time since the risk assessment estimates required by NFPA 70E are as myriad as the number of possible AHJ’s making such estimates.Furthermore the Style Manual requirements in 1.3 require that standard requirements (NFPA 70E) be “suitable for adoption as a regulatory document”. If the U.S. Department of Labor Occupational Safety and Health Administration (OSHA) ever attempted to promulgate a regulatory requirement based on such subjective criteria as “risk assessment” as defined in the document (NFPA 70E), OSHA would immediately be sued upon announcement of such a subjective rule in the Federal Register and the courts would incontrovertibly declare such a vague and subjective requirement unenforceable. There is plenty of existing case law on this.




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Remove “Conformity Assessment” from 130.7(C)(14) and all related references.


Conformity Assessment does not comport with the requirements of the “Style Manual”. Style Manual 4.2 References to Other Standards. References to other standards shall not be in mandatory Code text. References to product standards shall be in an informative annex. References to other Standards shall be in the Informational Notes.“Conformity Assessment” is another standard! Just because the codification number of “Conformity Assessment” was omitted it still remains another standard. No different than stating the “National Electrical Code” or “NEC” absent the inclusion of the codification number NFPA70.




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Public Input No. 373-NFPA 70E-2018 [ Section No. 90.1 ]

90.1 Purpose.The purpose of this standard is to provide for practical electrical safety as well as a practical safe workingarea for employees relative to the hazards arising from the use of electricity.


The purpose of this Standard should be to provide for practical electrical safety as well as a practical safe work area. This is in line with NFPA 70E being more prescriptive based and less performance based.


Submitter Full Name: Michael FontaineOrganization: National Electrical Safety Group, Inc.Street Address:City:State:Zip:Submittal Date: Wed Jun 27 16:30:57 EDT 2018Committee:


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Public Input No. 12-NFPA 70E-2018 [ New Section after 90.2(A) ]

TITLE OF NEW CONTENT: Communications utitlies need to be added to article 90.2(A) Coveredsimilar to those conditions that apply to electric utilities

A new section needs to be added to Article 90 as 90.2(A)(3) which covers office buildings, warehouses,garages, machine shops, recreational buildings, etc. of those owned or leased by communications utilitycompanies. Electricians and technicians working on electrical equipment within these areas are subject to the exactsame electrical hazards as those of electric utility companies working on the same equipment. Therefore,telecommunications utilities should not be exempt from their responsibilities to keep their employees safeunder the provisions of NFPA 70E.Consider the following verbiage for 90.2(A)(3)“Installa ons used by telecommunica ons u lity, such as office buildings, warehouses, garages, machine shops,recrea onal buildings, public access facili es, retail stores, call centers, and similar structures that are not an integralpart of a telecommunica ons u lity for the purposes of providing telecommunica ons services, such as CentralOffices, telecommunica ons field installa ons and other equipment used for signal or communica on services.”


A new section needs to be added to Article 90 as 90.2(A)(3) which covers office buildings, warehouses, garages, machine shops, recreational buildings, etc. of those owned or leased by communications utility companies. Because electricians and technicians working on electrical equipment within these areas are subject to the exact same electrical hazards as those of electric utility companies working on the same equipment. Therefore, telecommunications utilities should not be exempt from their responsibilities to keep their employees safe under the provisions of NFPA 70E.


Submitter Full Name: George ColeOrganization: APS/Palo Verde Nuclear Generating StationStreet Address:City:State:Zip:Submittal Date: Sat Jan 27 08:53:19 EST 2018Committee:


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Public Input No. 184-NFPA 70E-2018 [ Section No. 90.2(A) ]

(A) Covered.This standard addresses electrical safety-related work practices, safety-related maintenance requirements,and other administrative controls for employee workplaces that are necessary for the practical safeguardingof employees relative to the hazards associated with electrical energy during activities such as theinstallation, removal, inspection, operation, maintenance, and demolition of electric conductors, electricequipment, signaling and communications conductors and equipment, and raceways. This standard alsoincludes safe work practices for employees performing other work activities that can expose them toelectrical hazards as well as safe work practices for the following:

(1) Installation 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 controlcenter

Informational Note: This standard addresses safety of workers whose job responsibilities involveinteraction with energized electrical equipment and systems with potential exposure to electricalhazards. Concepts in this standard are often adapted to other workers whose exposure to electricalhazards is unintentional or not recognized as part of their job responsibilities. The highest risk forinjury from electrical hazards for other workers involve unintentional contact with overhead powerlines and electric shock from machines, tools, and appliances.

(3) Protection of untrained individuals who accidentally enter the workspace with electrical hazards


Many electrical workspaces are not effectively enclosed to protect the general public against inadvertent exposure to electrical hazards. This proposal will clarify that the general public is protected by the provisions of this standard as well as electricians.


Submitter Full Name: Michael AnthonyOrganization: Standards MichiganAffiliation: Standards Michigan Group, LLC | wwww.standardsmichigan.comStreet Address:City:State:Zip:Submittal Date: Tue Jun 19 08:27:12 EDT 2018Committee:


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(1) Installation of conductors and equipment that connect to the supply of electricityInstallations used by the electric utility,

(2) Electric utility as follows:

(3) Installations such as office buildings, warehouses, garages, machine shops, and recreationalbuildings

that are not an integral part of a generating plant, substation, or control center

(4)

(1)

(2) Structure-enclosed conductors such as switchgear, motor control centers, and transformers

Informational Note No. 1 : This standard addresses safety of workers whose job responsibilitiesinvolve interaction with energized electrical equipment and systems with potential exposure toelectrical hazards. Concepts in this standard are often adapted to other workers whose exposure toelectrical hazards is unintentional or not recognized as part of their job responsibilities. The highestrisk for injury from electrical hazards for other workers involve unintentional contact with overheadpower lines and electric shock from machines, tools, and appliances.

Informational Note No. 2: Electrical safety-related work practices for utility open-air electricalhazards such as transmission and distribution are covered by the National Electrical Safety Code(NESC) and 29 CFR 1910.269.


29 CFR 1910.269 and the NESC do not provide adequate electrical-safety work practices for all of the electrical hazards encountered in power generation facilities and substations. The practices in these standards are written with open-air single phase arcs in mind where distance is designed in for the worker's safety. When these same practices are adapted for use in front of the extremely high energy switchgear and breaker cubicles of power generation or substations, the workers are left underprepared for the risks of the task. These are the same hazards, if not greater, as those in other industrial applications and the work practices and thresholds outlined in this document should apply for those utility applications as well. We've already seen many utilities begin to use NFPA 70E as the best practice for safety practices, especially in the nuclear industry, which shows that this is a logical progression for the scope of these practices. Severe electrical injuries have occurred in the generation industry already that could have been prevented entirely if the concepts of NFPA 70E had been applied.

Related Public Inputs for This Document

Related Input RelationshipPublic Input No. 28-NFPA 70E-2018 [Section No. 90.2(B)]


Submitter Full Name: Andrew OlsenOrganization: Electrain LLC


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Street Address:City:State:Zip:Submittal Date: Mon Jan 29 17:22:29 EST 2018Committee:


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(3) Construction service provided by a public utility that is not intended as the permanent service Informational Note: See ANSI/IEEE C2 National Electrical Safety Code


The training of utility and building premise electricians are often different, though many electricians are trained for safety at both building premise wiring and utility wiring. Construction areas are a special hazard and best practice identified in the NESC would contribute to the goals of this document.


Submitter Full Name: Michael AnthonyOrganization: Standards MichiganAffiliation: Standards Michigan Group, LLC | www.standardsmichigan.comStreet Address:City:State:Zip:Submittal Date: Wed Jun 27 16:31:22 EDT 2018Committee:


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(3) This standard applies to the general public who may be accidentally exposed to electrical hazards thatare considered an electrical workspace.


There are many installations, particularly exterior installations normally regarded as electrical workspace/working clearance, where live equipment is exposed to the public. This document should make clear that the general public is as optimally protected as electricians.




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Public Input No. 379-NFPA 70E-2018 [ New Section after 90.2(B) ]

TITLE OF NEW CONTENT(C) The safety provisions of ANSI/IEEE C2 National Electrical Safety Code shall apply to installations thatare supplied power by the serving utility.


This should close a gap in coverage.




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Public Input No. 28-NFPA 70E-2018 [ Section No. 90.2(B) ]

(B) Not Covered.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, orautomotive vehicles other than mobile homes and recreational vehicles

(2) Installations of railways for generation, transformation, transmission, or distribution of power usedexclusively for operation of rolling stock or installations used exclusively for signaling andcommunications purposes

(3) Installations of communications equipment under the exclusive control of communications utilitieslocated outdoors or in building spaces used exclusively for such installations

(4) Installations under the exclusive control of an electric utility where such , other than structure-enclosed conductors such as switchgear, motor control centers, and transformers, where suchinstallations:

(5) Consist of service drops or service laterals, and associated metering, or

(6) Are located in legally established easements or rights-of-way designated by or recognized bypublic service commissions, utility commissions, or other regulatory agencies having jurisdictionfor such installations, or

(7) 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, or

(8) Are located by other written agreements either designated by or recognized by public servicecommissions, utility commissions, or other regulatory agencies having jurisdiction for suchinstallations. These written agreements shall be limited to installations for the purpose ofcommunications, metering, generation, control, transformation, transmission, or distribution ofelectric 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 Interior Bureau of Indian Affairs, military bases, lands controlled by portauthorities and state agencies and departments, and lands owned by railroads.


29 CFR 1910.269 and the NESC do not provide adequate electrical-safety work practices for all of the electrical hazards encountered in power generation facilities and substations. The practices in these standards are written with open-air single phase arcs in mind where distance is designed in for the worker's safety. When these same practices are adapted for use in front of the extremely high energy switchgear and breaker cubicles of power generation or substations, the workers are left underprepared for the risks of the task. These are the same hazards, if not greater, as those in other industrial applications and the work practices and thresholds outlined in this document should apply for those utility applications as well. We've already seen many utilities begin to use NFPA 70E as the best practice for safety practices, especially in the nuclear industry, which shows that this is a logical progression for the scope of these practices. Severe electrical injuries have occurred in the generation industry already that could have been prevented entirely if the concepts of NFPA 70E had been applied.

Related Public Inputs for This Document

Related Input RelationshipPublic Input No. 27-NFPA 70E-2018 [Section No. 90.2(A)] Adding the same scope to NFPA 70E


Submitter Full Name: Andrew OlsenOrganization: Electrain LLCStreet Address:


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City:State:Zip:Submittal Date: Mon Jan 29 17:53:41 EST 2018Committee:


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Public Input No. 118-NFPA 70E-2018 [ Article 100 ]

Article 100 DefinitionsScope. This article contains only those definitions essential to the proper application of this standard. It isnot intended to include commonly defined general terms or commonly defined technical terms from relatedcodes and standards. In general, only those terms that are used in two or more articles are defined inArticle 100. Other definitions are included in the article in which they are used but may be referenced inArticle 100. The definitions in this article shall apply wherever the terms are used throughout this standard.

Accessible (as applied to equipment).Admitting close approach; not guarded by locked doors, elevation, or other effective means. [70:100]Accessible (as applied to wiring methods).Capable of being removed or exposed without damaging the building structure or finish or not permanentlyclosed in by the structure or finish of the building. [70:100]Accessible, Readily (Readily Accessible).Capable of being reached quickly for operation, renewal, or inspections without requiring those to whomready access is requisite to take actions such as to use tools (other than keys), to climb over or under, toremove obstacles, or to resort to portable ladders, and so forth. [70:100]

Informational Note: Use of keys is a common practice under controlled or supervised conditions anda common alternative to the ready access requirements under such supervised conditions asprovided in NFPA 70, National Electrical Code.

Approved.Acceptable to the authority having jurisdiction.

Arc Flash Hazard.A source of possible injury or damage to health associated with the release of energy caused by an electricarc.

Informational Note No. 1: The likelihood of occurrence of an arc flash incident increases whenenergized electrical conductors or circuit parts are exposed or when they are within equipment in aguarded or enclosed condition, provided a person is interacting with the equipment in such a mannerthat could cause an electric arc. An arc flash incident is not likely to occur under normal operatingconditions when enclosed energized equipment has been properly installed and maintained.

Informational Note No. 2: See Table 130.5(C) for examples of tasks that increase the likelihood of anarc flash incident occurring.

Arc Flash Suit.A complete arc-rated clothing and equipment system that covers the entire body, except for the hands andfeet.

Informational Note: An arc flash suit may include pants or overalls, a jacket or a coverall, and abeekeeper-type hood fitted with a face shield.


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Arc Rating.The value attributed to materials that describes their performance to exposure to an electrical arcdischarge. The arc rating is expressed in cal/cm2 and is derived from the determined value of the arcthermal performance value (ATPV) or energy of breakopen threshold (EBT) (should a material systemexhibit a breakopen response below the ATPV value). Arc rating is reported as either ATPV or EBT,whichever is the lower value.

Informational Note No. 1: Arc-rated clothing or equipment indicates that it has been tested forexposure to an electric arc. Flame resistant clothing without an arc rating has not been tested forexposure to an electric arc. All arc-rated clothing is also flame-resistant.

Informational Note No. 2: Breakopen is a material response evidenced by the formation of one ormore holes in the innermost layer of arc-rated material that would allow flame to pass through thematerial.

Informational Note No. 3: ATPV is defined in ASTM F1959/F1959M, Standard Test Method forDetermining the Arc Rating of Materials for Clothing, as the incident energy (cal/cm2) on a materialor a multilayer system of materials that results in a 50 percent probability that sufficient heat transferthrough the tested specimen is predicted to cause the onset of a second degree skin burn injurybased on the Stoll curve.

Informational Note No. 4: EBT is defined in ASTM F1959/F1959M, Standard Test Method forDetermining the Arc Rating of Materials for Clothing, as the incident energy (cal/cm2) on a materialor a material system that results in a 50 percent probability of breakopen. Breakopen is defined as ahole with an area of 1.6 cm2 (0.5 in2) or an opening of 2.5 cm (1.0 in.) in any dimension.

Attachment Plug (Plug Cap) (Plug).A device that, by insertion in a receptacle, establishes a connection between the conductors of the attachedflexible cord and the conductors connected permanently to the receptacle. [70:100]Authority Having Jurisdiction (AHJ).An organization, office, or individual responsible for enforcing the requirements of a code or standard, or forapproving equipment, materials, an installation, or a procedure.

Informational Note: The phrase “authority having jurisdiction,” or its acronym AHJ, is used in NFPAdocuments in a broad manner, since jurisdictions and approval agencies vary, as do theirresponsibilities. Where public safety is primary, the authority having jurisdiction may be a federal,state, local, or other regional department or individual such as a fire chief; fire marshal; chief of a fireprevention bureau, labor department, or health department; building official; electrical inspector; orothers having statutory authority. For insurance purposes, an insurance inspection department,rating bureau, or other insurance company representative may be the authority having jurisdiction. Inmany circumstances, the property owner or his or her designated agent assumes the role of theauthority having jurisdiction; at government installations, the commanding officer or departmentalofficial may be the authority having jurisdiction.

Automatic.Performing a function without the necessity of human intervention.

Balaclava (Sock Hood).An arc-rated hood that protects the neck and head except for the facial area of the eyes and nose.

Barricade.A physical obstruction such as tapes, cones, or A-frame-type wood or metal structures intended to providea warning and to limit access.

Barrier.A physical obstruction that is intended to prevent contact with equipment or energized electrical conductorsand circuit parts or to prevent unauthorized access to a work area.

Bonded (Bonding).Connected to establish electrical continuity and conductivity. [70:100]Bonding Conductor or Jumper.A reliable conductor to ensure the required electrical conductivity between metal parts required to beelectrically connected. [70:100]


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Boundary, Arc Flash.When an arc flash hazard exists, an approach limit from an arc source at which incident energy equals 1.2cal/cm2 (5 J/cm2).

Informational Note: According to the Stoll skin burn injury model, the onset of a second degree burnon unprotected skin is likely to occur at an exposure of 1.2 cal/cm2 (5 J/cm2) for one second.

Boundary, Limited Approach.An approach limit at a distance from an exposed energized electrical conductor or circuit part within which ashock hazard exists.

Boundary, Restricted Approach.An approach limit at a distance from an exposed energized electrical conductor or circuit part within whichthere is an increased likelihood of electric shock, due to electrical arc-over combined with inadvertentmovement.

Branch Circuit.The circuit conductors between the final overcurrent device protecting the circuit and the outlet(s). [70:100]Building.A structure that stands alone or that is cut off from adjoining structures by fire walls with all openings thereinprotected by approved fire doors. [70:100]Cabinet.An enclosure that is designed for either surface mounting or flush mounting and is provided with a frame,mat, or trim in which a swinging door or doors are or can be hung. [70:100]Circuit Breaker.A device designed to open and close a circuit by nonautomatic means and to open the circuit automaticallyon a predetermined overcurrent without damage to itself when properly applied within its rating. [70:100]

Informational Note: The automatic opening means can be integral, direct acting with the circuitbreaker, or remote from the circuit breaker.

Conductive.Suitable for carrying electric current.

Conductor, Bare.A conductor having no covering or electrical insulation whatsoever. [70:100]Conductor, Covered.A conductor encased within material of composition or thickness that is not recognized by this Code aselectrical insulation. [70:100]Conductor, Insulated.A conductor encased within material of composition and thickness that is recognized by this Code aselectrical insulation. [70:100]Controller.A device or group of devices that serves to govern, in some predetermined manner, the electric powerdelivered to the apparatus to which it is connected. [70:100]Current-Limiting Overcurrent Protective Device.A device that, when interrupting currents in its current-limiting range, reduces the current flowing in thefaulted circuit to a magnitude substantially less than that obtainable in the same circuit if the device werereplaced with a solid conductor having comparable impedance.

Cutout.An assembly of a fuse support with either a fuseholder, fuse carrier, or disconnecting blade. The fuseholderor fuse carrier may include a conducting element (fuse link), or may act as the disconnecting blade by theinclusion of a nonfusible member.

De-energized.Free from any electrical connection to a source of potential difference and from electrical charge; not havinga potential different from that of the earth.


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Device.A unit of an electrical system, other than a conductor, that carries or controls electric energy as its principalfunction. [70:100]Disconnecting Means.A device, or group of devices, or other means by which the conductors of a circuit can be disconnectedfrom their source of supply. [70:100]Disconnecting (or Isolating) Switch (Disconnector, Isolator).A mechanical switching device used for isolating a circuit or equipment from a source of power.

Dwelling Unit.A single unit providing complete and independent living facilities for one or more persons, includingpermanent provisions for living, sleeping, cooking, and sanitation. [70:100]Electrical Hazard.A dangerous condition such that contact or equipment failure can result in electric shock, arc flash burn,thermal burn, or arc blast injury.

Informational Note: Class 2 power supplies, listed low voltage lighting systems, and similar sourcesare examples of circuits or systems that are not considered an electrical hazard.

Electrical Safety.Identifying hazards associated with the use of electrical energy and taking precautions to reduce the riskassociated with those hazards.

Electrical Safety Program.A documented system consisting of electrical safety principles, policies, procedures, and processes thatdirects activities appropriate for the risk associated with electrical hazards.

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 verify the absence of voltage, and, ifnecessary, temporarily grounded for personnel protection.

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

Enclosure.The case or housing of apparatus — or the fence or walls surrounding an installation to prevent personnelfrom unintentionally contacting energized electrical conductors or circuit parts or to protect the equipmentfrom physical damage.

Energized.Electrically connected to, or is, a source of voltage. [70:100]Equipment.A general term, including fittings, devices, appliances, luminaires, apparatus, machinery, and the like, usedas a part of, or in connection with, an electrical installation. [70:100]Exposed (as applied to energized electrical conductors or circuit parts).Capable of being inadvertently touched or approached nearer than a safe distance by a person. It is appliedto electrical conductors or circuit parts that are not suitably guarded, isolated, or insulated.

Exposed (as applied to wiring methods).On or attached to the surface or behind panels designed to allow access. [70:100]Fault Current.The amount of current delivered at a point on the system during a short-circuit condition.


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Fault Current, Available.The largest amount of current capable of being delivered at a point on the system during a short-circuitcondition.

Informational Note No. 1: A short circuit can occur during abnormal conditions such as a faultbetween circuit conductors or a ground fault. See Figure 100.0.

Figure 100.0 Available Fault Current.

Informational Note No. 2: If the dc supply is a battery system, the term available fault current refersto the prospective short-circuit current.

Fitting.An accessory such as a locknut, bushing, or other part of a wiring system that is intended primarily toperform a mechanical rather than an electrical function. [70:100]Fuse.An overcurrent protective device with a circuit-opening fusible part that is heated and severed by thepassage of overcurrent through it.

Informational Note: A fuse comprises all the parts that form a unit capable of performing theprescribed functions. It may or may not be the complete device necessary to connect it into anelectrical circuit.

Ground.The earth. [70:100]Ground Fault.An unintentional, electrically conducting connection between an ungrounded conductor of an electricalcircuit and the normally non–current-carrying conductors, metallic enclosures, metallic raceways, metallicequipment, or earth.

Grounded (Grounding).Connected (connecting) to ground or to a conductive body that extends the ground connection. [70:100]Grounded, Solidly.Connected to ground without inserting any resistor or impedance device. [70:100]Grounded Conductor.A system or circuit conductor that is intentionally grounded. [70:100]Ground-Fault Circuit Interrupter (GFCI).A device intended for the protection of personnel that functions to de-energize a circuit or portion thereofwithin an established period of time when a current to ground exceeds the values established for a Class Adevice. [70:100]

Informational Note: Class A ground-fault circuit interrupters trip when the current to ground is 6 mAor higher and do not trip when the current to ground is less than 4 mA. For further information, seeANSI/UL 943, Standard for Ground-Fault Circuit Interrupters.


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Grounding Conductor, Equipment (EGC).The conductive path(s) that provides a ground-fault current path and connects normally non–current-carrying metal parts of equipment together and to the system grounded conductor or to the groundingelectrode conductor, or both. [70:100]

Informational Note No. 1: It is recognized that the equipment grounding conductor also performsbonding.

Informational Note No. 2: See 250.118 of NFPA 70, National Electrical Code, for a list of acceptableequipment grounding conductors.

Grounding Electrode.A conducting object through which a direct connection to earth is established. [70:100]Grounding Electrode Conductor.A conductor used to connect the system grounded conductor or the equipment to a grounding electrode orto a point on the grounding electrode system. [70:100]Guarded.Covered, shielded, fenced, enclosed, or otherwise protected by means of suitable covers, casings, barriers,rails, screens, mats, or platforms to remove the likelihood of approach or contact by persons or objects to apoint of danger. [70:100]Hazard.A source of possible injury or damage to health.

Hazardous.Involving exposure to at least one hazard.

Incident Energy.The amount of thermal energy impressed on a surface, a certain distance from the source, generatedduring an electrical arc event. Incident energy is typically expressed in calories per square centimeter(cal/cm2).

Incident Energy Analysis.A component of an arc flash risk assessment used to predict the incident energy of an arc flash for aspecified set of conditions.

Insulated.Separated from other conducting surfaces by a dielectric (including air space) offering a high resistance tothe passage of current.

Informational Note: When an object is said to be insulated, it is understood to be insulated for theconditions to which it is normally subject. Otherwise, it is, within the purpose of these rules,uninsulated.

Interrupter Switch.A switch capable of making, carrying, and interrupting specified currents.

Interrupting Rating.The highest current at rated voltage that a device is identified to interrupt under standard test conditions.[70:100]

Informational Note: Equipment intended to interrupt current at other than fault levels may have itsinterrupting rating implied in other ratings, such as horsepower or locked rotor current.

Isolated (as applied to location).Not readily accessible to persons unless special means for access are used. [70:100]Labeled.Equipment or materials to which has been attached a label, symbol, or other identifying mark of anorganization that is acceptable to the authority having jurisdiction and concerned with product evaluation,that maintains periodic inspection of production of labeled equipment or materials, and by whose labelingthe manufacturer indicates compliance with appropriate standards or performance in a specified manner.


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Listed.Equipment, materials, or services included in a list published by an organization that is acceptable to theauthority having jurisdiction and concerned with evaluation of products or services, that maintains periodicinspection of production of listed equipment or materials or periodic evaluation of services, and whoselisting states that either the equipment, material, or service meets appropriate designated standards or hasbeen tested and found suitable for a specified purpose.

Informational Note: The means for identifying listed equipment may vary for each organizationconcerned with product evaluation; some organizations do not recognize equipment as listed unlessit is also labeled. The authority having jurisdiction should utilize the system employed by the listingorganization to identify a listed product.

Luminaire.A complete lighting unit consisting of a light source, such as a lamp or lamps, together with the partsdesigned to position the light source and connect it to the power supply. It may also include parts to protectthe light source or the ballast or to distribute the light. A lampholder itself is not a luminaire. [70:100]Maintenance, Condition of.The state of the electrical equipment considering the manufacturers’ instructions, manufacturers’recommendations, and applicable industry codes, standards, and recommended practices.

Motor Control Center.An assembly of one or more enclosed sections having a common power bus and principally containingmotor control units. [70:100]Outlet.A point on the wiring system at which current is taken to supply utilization equipment. [70:100]Overcurrent.Any current in excess of the rated current of equipment or the ampacity of a conductor. It may result fromoverload, short circuit, or ground fault. [70:100]

Informational Note: A current in excess of rating may be accommodated by certain equipment andconductors for a given set of conditions. Therefore, the rules for overcurrent protection are specificfor particular situations.

Overload.Operation of equipment in excess of normal, full-load rating, or of a conductor in excess of rated ampacitythat, when it persists for a sufficient length of time, would cause damage or dangerous overheating. A fault,such as a short circuit or ground fault, is not an overload. [70:100]Panelboard.A single panel or group of panel units designed for assembly in the form of a single panel, including busesand automatic overcurrent devices, and equipped with or without switches for the control of light, heat, orpower circuits; designed to be placed in a cabinet or cutout box placed in or against a wall, partition, orother support; and accessible only from the front. [70:100]Permanently Mounted Test Devices: Permanently installed devices that facilitate absence of voltagetesting from the outside of an electrical enclosure. These devices require; a certified installation byqualified persons at the point of work, must be adequately rated for the electrical system, and listed andlabeled for purpose of voltage measurement testing.

Premises Wiring (System).Interior and exterior wiring, including power, lighting, control, and signal circuit wiring together with all theirassociated hardware, fittings, and wiring devices, both permanently and temporarily installed. This includes:(a) wiring from the service point or power source to the outlets; or (b) wiring from and including the powersource to the outlets where there is no service point.

Such wiring does not include wiring internal to appliances, luminaires, motors, controllers, motor controlcenters, and similar equipment. [70:100]

Informational Note: Power sources include, but are not limited to, interconnected or stand-alonebatteries, solar photovoltaic systems, other distributed generation systems, or generators.

Qualified Person.One who has demonstrated skills and knowledge related to the construction and operation of electricalequipment and installations and has received safety training to identify the hazards and reduce theassociated risk.


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Raceway.An enclosed channel of metal or nonmetallic materials designed expressly for holding wires, cables, orbusbars, with additional functions as permitted in this standard. [70:100]Receptacle.A receptacle is a contact device installed at the outlet for the connection of an attachment plug. A singlereceptacle is a single contact device with no other contact device on the same yoke. A multiple receptacleis two or more contact devices on the same yoke. [70:100]Risk.A combination of the likelihood of occurrence of injury or damage to health and the severity of injury ordamage to health that results from a hazard.

Risk Assessment.An overall process that identifies hazards, estimates the likelihood of occurrence of injury or damage tohealth, estimates the potential severity of injury or damage to health, and determines if protective measuresare required.

Informational Note: As used in this standard, arc flash risk assessment and shock risk assessmentare types of risk assessments.

Service Drop.The overhead conductors between the utility electric supply system and the service point. [70:100]Service Lateral.The underground conductors between the utility electric supply system and the service point. [70:100]Service Point.The point of connection between the facilities of the serving utility and the premises wiring. [70:100]

Informational Note 1: The service point can be described as the point of demarcation between wherethe serving utility ends and the premises wiring begins. The serving utility generally specifies thelocation of the service point based on the conditions of service.

Shock Hazard.A source of possible injury or damage to health associated with current through the body caused by contactor approach to energized electrical conductors or circuit parts.

Informational Note: Injury and damage to health resulting from shock is dependent on the magnitudeof the electrical current, the power source frequency (e.g., 60 Hz, 50 Hz, dc), and the path and timeduration of current through the body. The physiological reaction ranges from perception, muscularcontractions, inability to let go, ventricular fibrillation, tissue burns, and death.

Short-Circuit Current Rating.The prospective symmetrical fault current at a nominal voltage to which an apparatus or system is able tobe connected without sustaining damage exceeding defined acceptance criteria. [70:100]Single-Line Diagram.A diagram that shows, by means of single lines and graphic symbols, the course of an electric circuit orsystem of circuits and the component devices or parts used in the circuit or system.

Special Permission.The written consent of the authority having jurisdiction. [70:100]Step Potential.A ground potential gradient difference that can cause current flow from foot to foot through the body.

Structure.That which is built or constructed. [70:100]Switch, Isolating.A switch intended for isolating an electric circuit from the source of power. It has no interrupting rating, andit is intended to be operated only after the circuit has been opened by some other means. [70:100]


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Switchboard.A large single panel, frame, or assembly of panels on which are mounted on the face, back, or both,switches, overcurrent and other protective devices, buses, and usually instruments. These assemblies aregenerally accessible from the rear as well as from the front and are not intended to be installed in cabinets.[70:100]Switchgear, Arc-Resistant.Equipment designed to withstand the effects of an internal arcing fault and that directs the internallyreleased energy away from the employee.

Switchgear, Metal-Clad.A switchgear assembly completely enclosed on all sides and top with sheet metal, having drawoutswitching and interrupting devices, and all live parts enclosed within grounded metal compartments.

Switchgear, Metal-Enclosed.A switchgear assembly completely enclosed on all sides and top with sheet metal (except for ventilatingopenings and inspection windows), containing primary power circuit switching, interrupting devices, or both,with buses and connections. This assembly may include control and auxiliary devices. Access to the interiorof the enclosure is provided by doors, removable covers, or both. Metal-enclosed switchgear is available innon-arc-resistant or arc-resistant constructions.

Switching Device.A device designed to close, open, or both, one or more electric circuits.

Touch Potential.A ground potential gradient difference that can cause current flow from hand to hand, hand to foot, oranother path, other than foot to foot, through the body.

Ungrounded.Not connected to ground or to a conductive body that extends the ground connection. [70:100]Unqualified Person.A person who is not a qualified person.

Utilization Equipment.Equipment that utilizes electric energy for electronic, electromechanical, chemical, heating, lighting, orsimilar purposes. [70:100]

Validated Installation. A documented installation procedure to insure that permanently mounted testdevices are installed and validated by qualified electrical workers as per the manufacturer’s instructions atthe correct point of work.

Voltage (of a Circuit).The greatest root-mean-square (rms) (effective) difference of potential between any two conductors of thecircuit concerned. [70:100]

Informational Note: Some systems, such as three-phase 4-wire, single-phase 3-wire, and 3-wiredirect-current, may have various circuits of various voltages.

Voltage, Nominal.A nominal value assigned to a circuit or system for the purpose of conveniently designating its voltage class(e.g., 120/240 volts, 480Y/277 volts, 600 volts). [70:100]

Informational Note 1: The actual voltage at which a circuit operates can vary from the nominal withina range that permits satisfactory operation of equipment.

Informational Note 2: See ANSI C84.1, Electric Power Systems and Equipment — Voltage Ratings(60 Hz).

Working Distance.The distance between a person’s face and chest area and a prospective arc source.

Informational Note: Incident energy increases as the distance from the arc source decreases. See130.5(C)(1) for further information.


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Working On (energized electrical conductors or circuit parts).Intentionally coming in contact with energized electrical conductors or circuit parts with the hands, feet, orother body parts, with tools, probes, or with test equipment, regardless of the personal protective equipment(PPE) a person is wearing. There are two categories of “working on”: Diagnostic (testing) is taking readingsor measurements of electrical equipment with approved test equipment that does not require making anyphysical change to the equipment; repair is any physical alteration of electrical equipment (such as makingor tightening connections, removing or replacing components, etc.).


Rationale for the additional definition—“Certified Installation” and “Permanently Mounted Test Devices”

Permanently mounted voltage test devices can only reduce the risk of creating an electrically safe work condition if correctly installed onto the right voltage source. The current exception language of 120.5(N) only requires these devices be installed “in accordance with the manufacturer’s instructions” and “at the point of work”. This language n

TECHNICAL COMMITTEE ON Electrical Safety in the Workplace ... · Hyatt Regency St. Louis at the Arch, St. Louis, MO August 13 – 17, 2018 ... Steven D. Corrado Voting Alternate UL

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