Best Practice 71

EFCOG Best Practice #71

(03/10/10)

Title: Adoption of NFPA 70E 2009 in place of NFPA 70E 2004

Facility: DOE Complex

Points of Contact: Michael D. Hicks, 208-526-3724, hicksmd@id.doe.gov

John P. Schaleger, 509 373-2202, John_P_Schaleger@rl.gov

Randy S. Spaniel, 509-373-1146, Randy_S_Spaniel@rl.gov

Brief Description of Best Practice: NFPA 70E^® – 2009 is recommended for approval across the DOE Complex as an upgrade to NFPA 70E^® – 2004 in 10 CFR 851 Worker Safety and Health Plans (WSHP).

Why the best practice was used: 10 CFR 851 lists safety and health consensus standards with which the contractor must comply when applicable to site hazards (851.23). Only the versions of consensus standards that were in effect on February 9, 2006 were promulgated pursuant to rulemaking therefore only those specifically cited versions are required by the Rule. Contractors may include successor versions of the consensus standards that provide equal or greater worker protection if included in their DOE-approved worker safety and health program.

What are the benefits of the best practice: The use of the 2009 edition of NFPA 70E^® is at least as protective as the 2004 edition, and even more protective in some areas, such that the new edition should be considered for DOE Complex wide acceptance. NFPA 70E^® – 2009 is recommended for approval across the DOE Complex as an upgrade to NFPA 70E^® – 2004.

What problems/issues were associated with the best practice:

Issue: ARTICLE 130 — WORK INVOLVING ELECTRICAL HAZARDS

130.1 Justification for Work. (B) Energized Electrical Work Permit. (1) Where Required.

The new revision does not specifically require an Energized Electrical Work Permit (EEWP) for working “near” energized electrical conductors or circuit parts only for working “on” energized electrical conductors or circuit parts. This change clarifies the intent that the permit is required for work actually performed on energized parts.

An EEWP is a formal process requiring senior level management and safety approval to conduct energized electrical work during conditions that “demonstrate that deenergizing introduces additional or increased hazards or is infeasible due to equipment design or operational limitations.”

Wording was modified from “(2004) If live parts are not placed in an electrically safe work condition, work to be performed shall be considered energized electrical work and shall be performed by written permit only.” to “(2009) When working on energized electrical conductors or circuit parts that are not placed in an electrically safe work condition, work to be performed shall be considered energized electrical work and shall be performed by written permit only.”

Review of this change to NFPA 70E by the 851 committee determined that this is a reduction of Worker Safety due to relaxing the conditions that require an EEWP from any time when a worker is within the Limited Approach Boundary working ON or NEAR exposed energized circuits and components, to only being required when working ON energized circuits and components.

The application of this change as written would reduce a requirement to prepare and approve an EEWP for work on a 240 Volt system from 3.5 feet, to “Avoid Contact,” and for work on a 480 Volt system from 3.5 feet, to “1 inch.”

851 review committee’s recommendation related to this section is to maintain the scope of EEWP requirements currently in place, and document this modification within the facility’s Worker Safety and Health Program (WSHP), and/or Electrical Safety Standard.

Issue: ARTICLE 320 — SAFETY REQUIREMENTS RELATED TO BATTERIES AND BATTERY ROOMS

320.7 Protection. (E) Section Isolating Equipment.

The new revision increases the threshold for isolation device requirements to 250VDC from 120VDC. Since 250VDC is considered the acceptance working level threshold and is consistent with the NEC Article 480.7.

NFPA 70E-2009 has modified the section isolating equipment requirements “(2004) Where the battery section exceeds 120 volts, the installation shall include an isolating switch, plugs, or links, as required, to isolated sections of the battery, or part of the battery for maintenance.” 70E-2009 raised this requirement to 250 Volts. The 851 committee has determined that although consistent with NFPA 70 requirements, this is a reduction in Worker Safety due to doubling the hazardous potential voltage in each battery section provided.

The 851 committee’s recommendation related to this section is to maintain the requirement of 120 Volts vice 250 Volts, and document this modification within the WSHP, and/or Electrical Safety Standard.

These issues should be clarified in the 10 CFR 851 WSHP when adopting NFPA 70E 2009.

How the success of the Best Practice was measured: A detailed gap analysis of NFPA 70E versions 2009 and 2004 was performed and the link to the document is provided below.

Gap analysis of NFPA 70E versions 2009 and 2004