There are times when working on energized equipment is warranted or justified. I would say energized work (hot work) is less likely to occur today if you know how to accurately apply the standards and requirements of the latest edition of NFPA 70E and OSHA, CFR 1910.333(a)(1).
In section 110.4 of the 2021 edition of 70E, you can find the requirements of when energized work within the restricted approach boundary of electrical equipment is allowed. First, when the work is infeasible to work on if deenergized, which would include testing and troubleshooting, or on systems operating at less than 50 volts. Secondly, if the work can be proven that additional risks and hazards will be introduced while the equipment is disconnected. Some examples would include shutting off the fan motor to a special hazardous environment, which could result in the death of people within this area. Even this task is a far stretch and with proper planning hot work could be avoided. Hopefully you understand the intent. Even work within the critical branch of a health care facility or hospital could be scheduled as a planned outage. Either way, the second scenario would require an Energized Electrical Work Permit (EEWP). OSHA does not consider the loss of revenue as justification for energized work even with the permit.
My view on the EEWP is not a permit or green flag for energized work, but rather an important document that when filled out properly will cause the workers and all the other stakeholders to ask if the work must be done energized and if it can be completed reasonably safe. Usually, they can find a way to work on the equipment in an electrically safe working condition. (See 120.5)
This would be considered deenergized and safe once all seven and possibly eight steps are completed.
Some of the elements of the document should include the following:
- Description of the circuit and equipment and location.
2. Description of the work to be performed.
3. Justification of why the power cannot be shut down.
4. Description of the safe work practices deployed.
5. Results of a shock risk assessment. (130.4(A)
- Limit approach boundary
- Restricted approach boundary
- PPE required.
6. Results of the arc flash risk assessment (130.5)
- Incident energy and working distance or arc flash PPE Category
- PPE and other protective equipment required.
- Arc flash boundary
7. Means to keep unqualified persons out of the work area.
8. Evidence of completion of a job briefing, including any specific hazards of this task.
9. Energized work approval from all stakeholders. SIGNATURES!
Once a person is required to sign off on the task then minds are changed so the work can be planned while in an electrically safe working condition. Explain to everyone that they could have a planned outage or an unplanned outage. They can either plan on an outage with the known timeframe and costs before the work. Or you can expect an unplanned outage with an indefinite time frame and countless unknown costs. Ask yourself if the equipment is can even be replaced after the event. If the equipment is obsolete then the costs and duration of the outage increases. This information should also be included in the EEWP to accurately communicate the extent of the damage if the work causes an arc flash event.
I have been saying this new mantra, “if the plumbers must turn of their systems, why don’t we?” What is the worse outcome if the occupancy is flooded with water? Contrast that to our electrical systems.
Hopefully energized work will be the last resort with you and your firm, and you request that all the boxes to be checked off before the work can be performed. You must also sign off on the fact that the work can be safely. If not, don’t sign off. Stand down. Your friends and family will thank you.
After everything is considered, I am sure we can find a way to work safer and plan to put the system in an electrically safe working condition (ESWP). In my experience training Arc Flash and NFPA 70E classes, I can see the younger generation becoming more acceptable to these standards than the older generation.
When troubleshooting and testing, the energized work permit (EEWP) is not required. However, the proper PPE is required while doing this task. Verify the testing and troubleshooting measurements, establish an electrically safe working condition then remove the PPE required for the incident energy at that part of the system. You may still have the job site or company specific PPE, like hard hats, safety glasses and gloves, steel toe boots and so forth.
If you or your company is seeking compliance and have questions with the requirements of OSHA, NFPA 70E, reach out to safety professionals for more information on classes, customized training or guidance in implementing an electrical safety policy from certified professionals for you and your employees. Doing so not only protects your employees, but also protects you from being up creek without a permit.