对于防火规范来说，比如以火灾自动报警为例，更像是我国的防火规范是规定做不做得问题，是shall得问题，而火灾自动报警规范规定怎么做得问题，是how 得问题。OSHA是政府组织，发布条例regulation。NFPA是非政府组织，可以发布standard，可以被政府认定为code。还有个概念要区分一下：law,泛指法律,法条等。regulation 法条,法规,一般指某一法律的规定，code,法典,具有规范体系的法律法规的汇总,如criminal code,刑法典
provision,一般规定条文,可以是双方订立的合同的约定条款,也可以是法律条款.等级较regulation 来说稍弱.
The Occupational Safety and Health Administration (OSHA) (/ˈoʊʃə/) is an agency of the United States Department of Labor. Congress established the agency under the Occupational Safety and Health Act (OSH Act), which President Richard M. Nixon signed into law on December 29, 1970. OSHA's mission is to "assure safe and healthy working conditions for working men and women by setting and enforcing standards and by providing training, outreach, education and assistance".[2] The agency is also charged with enforcing a variety of whistleblower statutes and regulations. OSHA is currently headed by Acting Assistant Secretary of Labor Loren Sweatt. OSHA's workplace safety inspections have been shown to reduce injury rates and injury costs without adverse effects to employment, sales, credit ratings, or firm survival.
The National Fire Protection Association (NFPA) is a nonprofit organization devoted to eliminating death, injury, property and economic loss due to fire, electrical and related hazards. The Occupational Safety and Health Administration (OSHA) and the NFPA have written many standards and regulations that build on one another. In the case of NFPA 70E: Standard for Electrical Safety in the Workplace, the OSHA regulations and NFPA standards work so well together it’s been said that OSHA provides the “shall” while NFPA provides the “how.”
OSHA bases its electrical safety standards (found in 29 Code of Federal Regulations (CFR) Part 1910 Subpart S and 29 CFR Part 1926 Subpart K) on the comprehensive information found in NFPA 70E. 29 CFR 1910.333(a) states that employers must employ safety-related work practices to prevent electrical shock or other injuries resulting from either direct or indirect electrical contact. NFPA 70E is the tool employers use to meet this OSHA requirement. For example, OSHA mandates that all services to electrical equipment be done in a de-energized state. “Working live” can only be done under special circumstances. NFPA 70E defines those special circumstances and sets rigid electrical safety limits on voltage exposures, work zone boundary requirements and necessary personal protective equipment (PPE). (See NFPA 70E-2018 Article 130 and OSHA subpart S part 1910.333(a)(1) for complete details.).
It is important to note that NFPA 70E is a voluntary national consensus safety standard published by NFPA primarily to assist OSHA in preparing its electrical safety standards. Federal OSHA has not incorporated NFPA 70E into the Code of Federal Regulations.
History of NFPA 70E
The first edition of NFPA 70E was published in 1979 and contained installation safety requirements borrowed from the National Electric Code. In 1981 safety-related work practice requirements were added. In 1995 “limits of approach” and “arc flash” concepts were introduced. Throughout the 1990’s and 2000’s the emphasis was on arc flash PPE requirements. Up to and including the 2012 editions, requirements to have an electrical safety program and policy were buried in the standard. Beginning with the 2015 edition, the focus began to shift from PPE requirements to the employer’s duty to create a comprehensive electrical safety program and integrating it into their occupational health and safety management system (OHSMS). Risk management terminology was defined and all requirements in the standard were harmonized with risk management principles. The hierarchy of risk control methods was introduced in an explanatory/informational note.
NFPA 70E-2018
The 2018 edition continues to focus on risk assessment and introduces human factors, such as human error, as part of the assessment. Emphasis is now placed on the hierarchy of risk controls methods (which has moved from an informational note into mandatory text, Article 110(H)(1)&(3)):
- Elimination
- Substitution
- Engineering controls
- Awareness(Training)
- Administrative controls
- PPE
Most notable changes to the 2018 edition include:
- Article 105.4 now explicitly states “Hazard elimination shall be the first priority in the implementation of safety-related work practices.”
- Article 120 - Establishing an Electrically Safe Work Condition, has been reorganized to provide a more logical sequence. A seven-step process for establishing and verifying an electrically safe work condition has been added as Article 120.5.
- Article 130 – Work Involving Electrical Hazards, has also been revised and reorganized:
- 130.4(A) and 130.5(A) now requires that risk assessments for shock and arc flash be performed. They must identify the hazard, estimate the likelihood of occurrence of injury or damage to health and the potential severity of injury or damage to health; and determine if additional protective measures are required, including the use of PPE.
- The previous arc flash hazard identification table has been modified and renumbered as Table 130.5(C). It can be used to determine the likelihood that an arc flash could occur.
- A new Table (130.5(G)) has been added and it identifies the arc-rated clothing and other PPE requirements that are to be used with the incident energy analysis method for selecting arc flash PPE.
- A new labeling exception (130.5(H) Exception 1) allows labels applied prior to the effective date of this edition to be used if they complied with the requirements for equipment labeling in the standard in effect at the time the labels were applied.
- Tables and text that specified PPE standards have been moved to informational tables or notes. Employers still are required to verify that appropriate PPE is given to employees and 130.7(C)(14)(b) was added to provide guidance on conformity assessments.
- Article 320 introduces voltage thresholds of 50Vac and 100Vdc for batteries and battery rooms. Article 330 was extensively revised to address safety-related maintenance issues associated with lasers. Article 350 introduces an Electrical Safety Authority as a possible authority having jurisdiction over laboratories.
Need for NFPA 70E
Article 110 of NFPA 70E identifies the general requirements for electrical safety-related work practices. One major requirement is performing a risk assessment before any work is started. The risk assessment must address employee exposure to electrical hazards and identify the process to be used by the employee to identify hazards, assess risks and implement risk control according to the hierarchy of risk control methods. The procedure must address the potential for human error and its negative consequences on people, processes, the work environment and equipment.
Article 120 requires employers to establish, document, and implement a lockout/tagout program and specify lockout/tagout procedures to safeguard workers from exposure to electrical hazards.
Article 130 of the standard specifically addresses work involving electrical hazards and covers:
- 130.1(1): any work condition that requires an electrically safe work condition; and
- 130.1(2): any work involving safety-related work practices, assessments, precautions, and procedures when an electrically safe work condition cannot be established
To quantify the risk present in the covered work NFPA 70E-2018 identifies two assessments that must be done for each affected electrical equipment piece:
- Shock Risk Assessment – 130.4(A)1-3
- Arc Flash Risk Assessment – 130.5(A) 1-3
These assessments must identify the hazards, estimate the likelihood of the occurrence and potential severity of injury or damage to health and determine if additional protective measures are required, including the use of personal protective equipment (PPE).
Article 130.7 addresses requirements for personal and other protective equipment of employees exposed to electrical shock and arc flash hazards when the risk associated with these hazards is not adequately reduced by the first five hierarchy of risk control methods: (1) elimination, (2) substitution, (3) engineering controls, (4) awareness, or (5) administrative controls.
The previous arc flash hazard identification for AC/DC current system, Table 130.7(C)(15)(A)(a) of the 2015 edition was modified to provide a more detailed estimate of the likelihood of occurrence of an arc flash incident. It is now coded as 130.5(C). If likelihood does exist (designated as a yes response in the table) appropriate arc flash PPE must be determined by one of two methods:
- Incident energy analysis method – Annex D and 130.5(G) or
- Arc flash PPE category method – 130.7(C)(15)(a) or (b)*
One or the other method must be used, but not both on the same piece of electrical equipment.
*Fault clearing times (cycle fault) of overcurrent protective devices must be known to use this method. If not known an incident energy analysis must be completed.
Incident Energy Analysis Method
Annex D provides guidance on completing an incident energy analysis to calculate the incident energy and flash boundary. Once the calculations are completed Table 130.5(G) can be referenced to select appropriate arc-rated clothing and other PPE. It should be noted table 130.5(G) only references two PPE energy levels and corresponding PPE:
- Incident energy exposure equal to 1.2 cal/cm2 up to 12 cal/cm2
- Arc-rated clothing with an arc rating equal to or greater than the estimated incident energya
- Long sleeve shirt and pants or coverall or arc flash suit (SR)
- Arc-rated face shield and arc-rated balaclava or arc flash suit hood (SR)b
- Arc-rated outerwear (e.g., jacket, parka, rainwear, hard hat liner) (AN)
- Heavy-duty leather gloves, arc-rated gloves, or rubber insulating gloves with leather protectors (SR)c
- Hard hat
- Safety glasses or safety goggles (SR)
- Hearing protection
- Leather footwear
- Incident energy exposures greater than 12 cal/cm2
- Arc-rated clothing with an arc rating equal to or greater than the estimated incident energya
- Long sleeve shirt and pants or coverall or arc flash suit (SR)
- Arc flash suit hood
- Arc-rated outerwear (e.g., jacket, parka, rainwear, hard hat liner) (AN)
- Heavy-duty leather gloves, arc-rated gloves, or rubber insulating gloves with leather protectors (SR)c
- Hard hat
- Safety glasses or safety goggles (SR)
- Hearing protection
- Leather footwear
SR: Selection of one group is required.
AN: As needed.
aArc ratings can be for a single layer, such as an arc-rated shirt and pants or a coverall, or for a flash suit or a multi-layer system if tested as a combination consisting of an arc-rated shirt and pants, coverall, and arc flash suit.
bFace shields with a wrap-around guarding to protect the face, chin, forehead, ears, and neck area are required by 130.7(C)(10)(c). Where the back of the head is inside the arc flash boundary, a balaclava or an arc flash hood shall be required for full head and neck protection.
cRubber insulating gloves with leather protectors provide arc flash protection in addition to shock protection. Higher class rubber insulating gloves with leather protectors, due to their increased material thickness, provide increased arc flash protection.
Arc Flash PPE Category Method
The PPE category method first references Table 130.7(C)(15)(a) for AC current applications or 130.7(C)(15)(b) for DC current applications to determine the arc flash PPE category and arc flash boundary based on the equipment being evaluated. The maximum available fault current, maximum fault-clearing time, and minimum working distances for each equipment type must be known and followed to use this Table. If any condition fall outsides the listed parameters or are unknown the incident energy analysis method must be used. Once the arc-flash category is determined, Table 130.7(C)(15)(c) is referenced to identify all PPE needed for each applicable arc-flash PPE category.
Personal Protective Equipment Table 130.7(C)(15)(c)
Arc-Flash PPE Category 1
Arc-Rated Clothing, Minimum Arc Rating of 4 cal/cm2 a
Arc-rated long-sleeve shirt and pants or arc-rated coverall
Arc-rated face shield or arc flash suit hood
Arc-rated jacket, parka, rainwear, or hard hat liner (AN)
Protective Equipment
Hard hat
Safety glasses or safety goggles (SR)
Hearing protection (ear canal inserts)c
Heavy-duty leather glovesd
Leather footwear (AN)
Arc-Flash PPE Category 2
Arc-Rated Clothing, Minimum Arc Rating of 8 cal/cm2 a
Arc-rated long-sleeve shirt and pants or arc-rated coverall
Arc-rated flash suit hood or arc-rated face shieldb and arc-rated balaclava
Arc-rated jacket, parka, rainwear, or hard hat liner (AN)
Protective Equipment
Hard hat
Safety glasses or safety goggles (SR)
Hearing protection (ear canal inserts)c
Heavy-duty leather glovesd
Leather footwear (AN)
Arc-Flash PPE Category 3
Arc-Rated Clothing Selected so that the System Arc Rating Meets the Required Minimum Arc Rating of 25 cal/cm2 a
Arc-rated long-sleeve shirt (AR)
Arc-rated pants (AR)
Arc-rated coverall (AR)
Arc-rated flash suit jacket (AR)
Arc-rated flash suit pants (AR)
Arc-rated flash suit hood
Arc-rated glovesd
Arc-rated jacket, parka, rainwear, or hard hat liner (AN)
Protective Equipment
Hard hat
Safety glasses or safety goggles (SR)
Hearing protection (ear canal inserts)c
Leather footwear
Arc-Flash PPE Category 4
Arc-Rated Clothing Selected so that the System Arc Rating Meets the Required Minimum Arc Rating of 40 cal/cm2 a
Arc-rated long-sleeve shirt (AR)
Arc-rated pants (AR)
Arc-rated coverall (AR)
Arc-rated flash suit jacket (AR)
Arc-rated flash suit pants (AR)
Arc-rated flash suit hood
Arc-rated glovesd
Arc-rated jacket, parka, rainwear, or hard hat liner (AN)
Protective Equipment
Hard hat
Safety glasses or safety goggles (SR)
Hearing protection (ear canal inserts)c
Leather footwear
AN = as needed (optional)
AR = as required
SR = selection required
aArc rating is defined in Article 100
bFace shields are to have wrap-around guarding to protect not only the face but also the forehead, ears, and neck, or, alternatively, an arc-rated arc flash suit hood is required to be worn.
cOther types of hearing protection are permitted to be used in lieu of or in addition to ear canal inserts provided they are worn under an arc-rated arc flash suit hood.
dIf rubber insulating gloves with leather protectors are used, additional leather or arc-rated gloves are not required. The combination of rubber insulating gloves with leather protectors satisfies the arc flash protection requirement.
Labeling Electrical Hazards
Article 130.5(H) states electrical equipment that is likely to require examination, adjustment, servicing, or maintenance while energized shall be marked with a label containing all the following information:*
- Nominal system voltage
- Arc flash boundary
- At least one of the following:
- Available incident energy and the corresponding working distance, or the arc flash PPE category in Table 130.7(C)(15)(a) or Table 130.7(C)(15)(b) for the equipment; but not both
- Minimum arc rating of clothing; or
- Site-specific level of PPE
*Exception 1: Unless changes in the electrical distribution system(s) render the label inaccurate, labels applied prior to the effective date of this edition of the standard shall be acceptable if they complied with the requirements for equipment labeling in that standard in effect at the time the labels were applied. *Exception 2: In supervised industrial installations where conditions of maintenance and engineering supervisions ensure that only qualified persons monitor and service the system, the information required in 130.5(H)(1)-(3) shall be permitted to be documented in a manner that is readily available to person likely to perform examination, servicing, maintenance, and operation of the equipment while energized.
It is important to note the information displayed on the label should only be present based on the method used to determine the arc-flash risk assessment. If the arc-flash PPE category method is used, only the PPE category should appear (1-4). If an incident energy analysis method is used the incident energy (cal/cm²) should appear. Must be one or the other displayed. See example below:
All calculations and data on the label must be documented to support the information on the label. The data shall be reviewed for accuracy at intervals not to exceed five years. The owner of the electrical equipment is responsible for the documentation, installation and maintenance of the labels.
Commonly Asked Questions
Q: What if my job task is not listed in table 130.7(C)(15)(a) and 130.7(C)(15)(b) of NFPA 70E-2018 electrical safety standard?
A: The incident energy must be calculated for the job task. Annex D of the NFPA 70E-2018 standard can be referenced, or an approved online arc calculator like the Duke Flux calculator can be used.
Q: Is compliance with NFPA 70E electrical safety standard mandatory?
A: No. NFPA 70E is a national consensus safety standard published by NFPA primarily to assist OSHA in preparing electrical safety standards. Federal OSHA has not incorporated it into the CFRs.
Q: Can I be cited for not complying with NFPA 70E?
A: Yes. The employer must assess the workplace for electrical hazards and the need for PPE under 29 CFR 1910.335(a)(1)(i). Details on how to comply with this standard are left up to the employer. The employer is expected to use the best means available to comply with this requirement, and that is done through consensus standards like NFPA 70E. Compliance with 70E will help ensure compliance with this OSHA requirement. In the event of an injury or death due to an electrical accident, if OSHA determines that compliance with 70E electrical safety standard would have prevented or lessened the injury, OSHA may cite the employer under the general duty clause. In a 2003 standards interpretation letter, OSHA stated 70E electrical safety standard can be used as evidence of whether the employer acted reasonably..
Sources
NFPA 70E-2018 Standard for Electrical Safety Requirements for Employee Workplaces, National Fire Protection Association, 1-617-770-3000.
ASTM F1506 Standard, ASTM International, 1-610-832-9585.
Occupational Safety and Health Administration (OSHA), www.osha.gov (29 CFR Part 1910 Subpart S and 29 CFR Part 1926 Subpart K).
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