Often the results of an arc flash study may recommend very heavy and restrictive PPE. This frequently leads to concerns about heat exhaustion, diminished ability to move, reduced senses, and others which many consider to also be a hazard.

Typically the recommendations for PPE focus on the arc flash hazard and ignore the possible hazards that the arc flash protection may introduce.

The National Electrical Safety Code (NESC) used by electric utility companies, has a very good and common sense exception to arc flash PPE requirements and addresses the hazards that PPE may present with the following language:

410(A)(3)(b) states:

[INDENT=1]Exception: If the clothing or clothing system required by this rule has the potential to create additional or greater hazards than the possible exposure to the heat energy of the electric arc, then clothing or a clothing system with an effective arc rating less than that required by this rule may be worn.[/INDENT]

Here is this week’s question:

Should NFPA 70E have an exception to use less PPE if the required PPE may cause a greater hazard?

• Yes
• No
• It Depends

This is great one for a lively debate!

Sorry about the choppiness of the question, I had to shorten it to fit the allotted characters.

NFPA 70E only dictates PPE requirements when you are using the 'task tables'.
When you perform calculations to determine the Arc Flash Incident Energy, it is up to your company to decide what PPE is needed for protection, per 130.5(B)(1), considering the risk of the event occurring.

For example: the PPE selection Table 130.7(C)(16) lists some specific PPE for HRC 2, and requires it have a minimum arc rating of 8 cal/cm². Many companies have reverse interpreted this to mean that any calculated location above 8cal/cm² must then use PPE from the HRC 3 or 4 portions of the table. However Annex H Table H.3b, uses the same (HRC 2) PPE selections, but allows it to go up to 12 cal/cm².

Who would determine whether the risk is greater or not?

My experience has been that this is addressed with a safety committee made up of representatives from the various departments, crews etc.

The exception is just that. An exception. Most of the time, they will attempt to wear appropriately rated PPE but there are some cases where it is not practical and they make exceptions.

Just curious whether anyone thought such an exception was a good/bad idea for NFPA 70E? I'm sure it would also open up the proverbial "can of worms"

It just really struck me as a convenient excuse not to wear the appropriate PPE, or for a company to try and justify not having the proper PPE yet requiring live work with workers in under-rated gear. - but perhaps that is just the pessimist in me.

I agree with you Larry. In the utility world, they have quite a few controls in place and use this exception only when necessary. The exception is in place with very good intentions when properly used. However in general industry, I could certainly see room for abuse.

I voted no because of the risk of abuse. We have moved, over the past 10 years, to a much safer environment for electrical workers and I would not trust a lot of the industrial world to use any excuse to go backwards safety wise

It's a no brainer. If your rules do not address the greater hazard first and foremost, they fail to qualify as safety rules. A pessimistic view should not be used as an excuse to expose workers to this greater hazard. And abuse by one company should not be used as an excuse to expose the workers of a non-abusing company to the greater risk. Don't forget, the question assumes there is a greater hazard present. Who decides and how it is decided is a difficult and related, but separate question that should have no affect on the answer to this one.

Most of those using 70E are also subject to the OSHA General Duty Clause as well, which I believe already obligates them to consider all hazards.

I was not suggesting workers be exposed to a greater hazard at all

I was saying that workers might be exposed to higher hazards if a company self-regulates the decision to what is considered to be a greater hazard with the proper PPE being used.

The only real reason that I have found that is reasonable on the NESC exception is doing "barehand" work. In this case the hazard "could" be greater than the 8 cal/cm2 stainless/aramid suit BUT the suit is the only real option for doing this work. To suit up for the hazard of being IN a 325KV arc is not reasonable in any suit. Wear the proper PPE for the work practice and assure that arc doesn't happen. Being IN a suit for the arc will not help when it is basically running through your body. Calling the NESC clause a "heat stress" clause as some have inferred when this was being discussed doesn't really get the point of the liability and hazard to the worker of trying to figure out what is the greatest hazard. That's my thoughts anyway.

"heat stress" clause? Interesting interpretation of the conversation. There is a lot more to it than heat stress although that is certainly one of the concerns. My personal experience is the 2 most common uses of the exception that I see from utilities are linemen not using face shields (very common and not a heat stress issue). The other is a heat stress issue and involves heavier PPE in the desert Southwest. Especially in the summer when the temperatures easily reach 115 to 118 degrees. we hit 119 once this year in the Phoenix area. Ask most utilities and it is a mix of both heat and non heat related issues.

This is a very good conversation. I wonder about 2 things:

• If this exception was available in NFPA 70E, how many companies would use it or would liability be an overriding issue for any consideration of using reduced PPE?
• How many companies (or individuals) would abuse it? I can see this potentially being a problem with some, but I would hope common sense and the urgency for worker safety would keep people from making bad decisions. Perhaps this would be similar to the judgement required about working electrically safe - is de-energizing infeasible or is it inconvenient. That line sometimes gets blurred too but most make the correct decision.

I'm not sure what the answer is or that anyone would really know the answer but I have heard similar stories about utilities reducing PPE in some instances as a practical matter. I have not heard of any significant injury as a result.

I had to vote "It depends" because on the surface it seems like a good idea but I'm not sure about the details or how it would ultimately be used.

There is no need for the exception. Draft 2015 70E requires either using tables or doing a RISK (not hazard) analysis. When doing a risk analysis is when greater hazard would be considered.

It sounds as if they are still providing an option to use the tables and ignore the possibly greater risks. Safety should not be optional.

The same questions/objections above would still apply.

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Great News! When I posted this question on Sunday, I was really uncertain how the responses would line up. The discussion has been great with many sides of the issue being discussed. As you stated, it sounds like this will be addressed although in a different form. - It will be interesting to see how it all unfolds in the industry. Thanks

It will be very interesting. I assume people initially will either not consider risk and keep things as they are - hazard only. I say this because of the liability climate. It will be interesting to see how the use of risk evolves of the next several years.

Wow. I never have seen anyone use the exception of "greater hazard" to get out of the face shield. Most just indicate that the standard didn't "require" faceshields. The exception didn't cover hard hats or faceshields. It is for clothing/apparel. The faceshield part should go back to OSHA. 1910.269 doesn't address faceshields but OSHA 1910.335 (a)(1)(v) has required them since 1991 for eye or face protection from arc flash. Seems strange but a utility might get away with no faceshields. Most of my clients are using them for meter pulling and LV switching.

Our people have never used face shields on overhead work. I think this is pretty common from what I have seen.

It is very common. I only know if one utility which wears them in the US. More are doing it in the EU than in the US.
I think the LV is the most dangerous for burns to the face. Arc energies on power lines tend to be fairly low due to traveling of the arc and quicker clearing times. In LV you get box effects, higher fault currents and longer clearing times so the arc events tend to be worse. I'd try out some of the new weight balancing shields. They might catch on with line workers.

It is quite common not to use face shields for overhead work. I have heard from several sources that the main reason is due to wind. There is a concern that wind could catch it (like a sail) and create a potential hazard. Just thought I would pass this along.