A Better Understanding of NFPA 70E: Equipment Labeling is Not the Same as Performing a Risk Assessment

I receive many questions from companies in the process of implementing an electrical safety work program. Can their own employees conduct risk assessments? Who should they hire? How do they know if an organization is qualified to do the work? While I am unable to answer those questions, my recent blog about knowing what is involved with risk assessments can help provide some guidance. Equipment is required to be labeled with the highest voltage and incident energy or PPE category. This worst-case condition can be used for 100 percent of tasks associated with the equipment. However, another of my Electrical Safety Month blogs discusses how a risk assessment could address tasks performed within that equipment. There is a difference between providing a label to attach to equipment and performing a risk assessment. Which was the contractor hired to perform?

Since most contract organizations use the more detailed incident energy analysis method rather than the PPE category method, there are two quick checks you can use to determine which one the contractor delivered. One check comes from 130.5(B). If equipment condition and maintenance is not questioned, the contractor is simply providing a label. Be aware that information on that label might create an unsafe condition for the employee. Another quick check is in 130.5(G). If the contractor did not address tasks conducted closer than the typical working distance, they are likely only providing a label. If they ask about the tasks to be performed on the specific equipment then provide the incident energy at the hand position, for example, they might be providing more than a label. Neither of these checks verify that a proper risk assessment has been performed but you are being provided with additional information necessary to conduct an assessment and develop safe work practices.

These quick checks may help determine if the contractor performed the work that they were hired to perform. Determining the maximum voltage or incident energy is identification of electrical hazards. Risk assessments are much more involved and assessments for specific tasks are typically not conducted by a contract company. Providing labels or calculating incident energy at the hand position is not a confirmation that a contractor is qualified, or that a proper assessment was performed. There are many other things you must verify when hiring a contractor to conduct such work. Make sure that you do your homework before hiring someone to be responsible for your employee's safety.

Next time: The 2021 edition of NFPA 70E, Standard for Electrical Safety in the Workplace.

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Christopher Coache
Senior Electrical Engineer

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