Energized Electrical Work Permit - Industrial Facility

The 2009 70E Standard states that if any work is done within the Limited Approach Boundary that an Energized Electrical Work Permit (EEWP) is required. The impression I get is that the EEWP is supposed to be a rare tool that is used.

At 120vac the LAB is 3 ft 6 in. According to this definition, when I open a Distributed Control cabinet or a PLC cabinet that uses 120 vac control voltage I can not even add an input or output circuit (such as a limit switch input or solenoid valve output) without shutting down the control system. Or I can not add conduit to the control cabinet with power on.

Based on this I would need to fill out an EEWP many times a week.

Is anybody else confronted with this issue? If so, how are you handling this?

The NFPA 70E Handbook gives this example in response to the requirements of where electrical safe working permit is required (130.1(B)(1)):

"Permits that cover routine work tasks to be performed by trained and qualified employees can be written to cover a long period of time." Multiple times a week seems to meet the definition of routine.

Their example is for replacing fuses done by a trained and qualified person. Adding conduit and wire to an energized panel may be pushing it though. That's something your local policy could decide?

What about using a hazard evaluation form something like in the Appendix F on NFPA 70E?
Maybe you can de-rate the hazard by applying certain methods of mitigation or work methods?

Eewp

I've gotten hung up on 130.1(B)(1) Where Required.

I initally thought the permit was for things that did not qualify as justification for energized work (greater hazard, infeasiblity, or <50V). However it actually says "when working on energized electrical conductors or circuit parts that are not placed in an electrically safe work condition (i.e. for the reasons of increased or additional hazard or infeasibility per 130.1) work to be performed shall be considered energized electrical work and shall be performed by written permit only."

In the handbook notes I read that infeasible is defined as impossible not simply inconvenient.

The task I am thinking of is installing and removing bus switches. It is possible to shutdown the entire bus (and half the plant) to install one but...
This is a task performed only by licensed electricians and they are dressed in the proper arc flash PPE while doing it. Any thoughts?

Also, I am looking for names of other companies who are fully NFPA-70E compliant (arc flash, gloves for shock protection and EEWP). The complaint we are getting is "nobody else is doing this, why must we".

infeasible does not mean impossible, it relates to such things as life safety systems, ie, shutting off power to the hospital floor to pop in a QO breaker in a 208 panel, or if the shutdown would increase the danger overall, ie, killing power to the reactor just after adding the catalyst, or, shutting down a large portion of an entire site, ie, a continuous process plant.

If you are talking about adding and removing bus duct switch drops, then I would say that is no different than adding or removing MCC buckets and can be done live. If you are tlaking about literally changing bus conductors in switchgear, or bolting on a whole mcc section to an existing line up - then shut it down.

To me "infeasable" means a jury of my peers would agree with me that working live was the safest option for the workker and the general public.

I can say that most if not all General Cable www.generalcable.comowned companies have or are in the process of NFPA 70E compliance. My facility started developing our program 6 years ago. We have the largest plant in the organization with >3000 buses and 11 switchgear stations. We modeled the utilities sub-station to the equipment level. It has taken some time to complete. But we have one of the most detailed programs then most would ever consider.

I have heard that Harley Davison plants have a good program with detailed modeling also.

Our 2000-4000A busway system along with almost everyone’s has a high IE. We created a policy that 480 fused busway bus plugs <200 can be installed and removed by qualified workers based on a limited time routine (standing) EWP. The thinking is that >200A sandwich busway bus plugs are heaver, harder to align properly along with some other factors that increase the chance of an accident. We shutdown that busway in the event >200A bus plugs are installed.

The process for this limited time routine (standing) EWP task is as follows:
1. Qualified worker trained in bus plug removals and installs all sizes.
2. Qualified worker demonstrates proficiency installing a <200A bus plug in a non-energized busway for training and observing.
3. A training document detailing the work and hazards is completed and signed by the workers and management.
3. Qualified worker will also sign a EWP designed for a limited time (1 year). The worker agrees a hazard exist but by using safe work practices, hazard mitigation techniques and PPE the worker agrees he/she can do the work safely.
4. The worker can op out if he/she at anytime feels uncomfortable with the safety of the task and can stop work at their discretion.

This type of hot work is policy or company dependent some my op for total power down while others may accept the above method of EWP. In my opinion, you can do one or the other. Many companies I see do not have the worker qualified for this task while others do. Your right, By all means you would not want just anyone doing this task that is not familiar, knowledgeable of the hazards, and aware of PPE.

My old job was getting large industrial companies 70E compliant. Started doing it in 2001. At this point, any large industrial plant that is not is way behind the curve. I don't really want to throw my entire client list on a forum but I promise everyone knows these 100+ companies I have worked with over the years. It has been pretty regional, some "pockets" of the US are just catching up but I would say we passed the "50% of large industrial plants are compliant" a year or two ago.

Where does it say this?

Where in 70E does it say this? "The 2009 70E Standard states that if any work is done within the Limited Approach Boundary that an Energized Electrical Work Permit (EEWP) is required."

I believe psThomas is talking about working on a live part greater >50v. Since psThomas mentions the limited approach boundary one is led to believe a task is under way or about to occur with work on a control circuit of 120v.

psThomas could be looking also at this: "Exemptions to Work Permit. Work performed within the Limited Approach Boundary of energized electrical
conductors or circuit parts by qualified persons ----------If the purpose
of crossing the Limited Approach Boundary is only for visual inspection and the Restricted Approach Boundary will not be crossed, then an energized electrical work permit shall not be required." Quoted from NFPA 70E-Edition 2009

According to NFPA 70E 110.8 "(2) Energized Electrical Work Permit. When working on energized electrical conductors or circuit parts that are not placed in an electrically safe work condition (i.e., for the reasons of increased or additional hazards or infeasibility per 130.1), work to be performed shall be considered energized electrical work and shall be performed by written permit only." Quoted from NFPA 70E Edition 2009.

As discussed there are many ways in dealing with this issue. One must remember 120v is a shock hazard only. Noted from the NFPA 70E Handbook, 2009 Edition is the creation of the (reptitive work job breifing). Those that work around 120v circuits routinely can use the routine job breifing. As

the use of the routine work permit to be NFPA 70E compliant. Also IMO, would include proper training in hazard avoidance, safe work practices and PPE selections as a signed training document. The documented training should be done at a minimum yearly.

psThomas, I remember thinking the same thing, about how confusing all this is. And how much hassle arc flash issues are going to be. It all starts to come clear with time that it not as difficult as it first appears. Be careful and ask questions because it is easy to stress yourself a lot. But in actuality the solutions are not that difficult to live with. I know because I have a boss that stress's me.

In the handbook it states that routine work by qualified persons may be performed with a standing long term permit (ie 3 months) providing it is limited to trained personnel. The 'ie' means 'for example' so most of the industry using the standing permit concept has interpretted 'ie' to be 12 months, as we do annual training. Since the requirement is to conform to 'industry practice' and NFPA70E is only a guide in lieu of a defacto standard - industry has adopted 12 months for the standing work permit duration.

Eewp

Thanks for all the input; I really appreciate it.