Updates to the 2024 edition of NFPA 70E®

By Derek Vigstol, Contributor

Every three years the electrical industry and those in the work force that keep the lights on and the motors spinning find out how NFPA 70E®: Standard for Electrical Safety in the Workplace® has been revised. Several questions arise when a new version is released. The main question being asked is how will this affect the day-to-day work that we do? Will there be new processes or procedures we need in our ESP? Will long-standing procedures need to change for compliance to revisions?

The 2024 edition of NFPA 70E received no challenges at the NFPA Technical Meeting in June of 2023, and the document became effective in May of 2023. Many of have thumbed through a copy by now or scrolled through NFPA’s online tool NFPA LiNK® looking for any of the highlighted text indicating that a change has taken place. However, even if we have found the changes, it is still a good exercise to go through what the revisions mean to us.

This revision cycle focused on adding clarity and making the document easier to find the information. Many changes have no real impact on how we stay safe from electricity, they are just in a new location. Our focus will be on revisions that move the needle. Good news, there weren’t very many. Let’s dive in and examine how the 2024 edition of NFPA 70E was revised to make the workplace even safer from electrical hazards.

The first major revision in NFPA 70E that we will examine took place in section 120.6, formerly 120.5 but it moved due to the addition of a scope statement in accordance with the NEC Style Manual. The revision is to the language in how we verify an electrically safe work condition(ESWC). Language has been added to clarify that the test we make for the absence of voltage to prove de-energization must happen at each point of work. This might not seem like a huge shift, especially if this is how your ESP already spelled this out but for many this creates an interesting new process.

The idea to require the absence of voltage test at each point of work stems from a public input that aimed to align NFPA 70E better with the requirements found in OSHA 1910 Subpart S that states the circuit elements to be worked on need to be verified as being de-energized. This was strengthened by several instances where workers have either de-energized the incorrect circuit or began working on the wrong equipment. In an ideal world, equipment labeling, and one-line drawings would always be accurate and workers would always be on top of their game, but we live in the real world where mistakes are made, and labels aren’t always accurate. Testing what we are about to touch at the point we are about to contact them helps minimize the mistakes. Even if we operate the wrong switch or equipment is mislabeled, putting our probes on the parts doesn’t lie if we follow the live-dead-live process.

The next revision under the microscope involves job safety planning. This section has moved from section 110.5(I) to section 110.3(I). New for 2024 is the requirement that the job safety plan must include an emergency response plan. In addition to the usual scope of work, risk assessment results, and risk mitigation measures, we are now required to write down a plan for what to do when the unthinkable occurs.

This new requirement benefits safety in two ways. First, it forces the workers to figure out important items for responding in an emergency, such as AED location and emergency contacts. This cuts down on the time responding to a worker being shocked or in an arc flash. Recovering from these events depends on how quickly help can be given to those who need it.

The other way this improves safety in the workplace is when energized work is performed due to de-energization posing an additional hazard or increased risk. The reality of this kind of energized work is that it also increases the chance of accidental de-energization. Energized work can easily cause a fault that can trip the upstream overcurrent protective device. When this happens, the additional hazard or increased risk that was trying to be avoided by working energized is now a reality. Take life-support equipment in a hospital, for example. If the equipment is de-energized, those in need will be adversely affected. However, if a fault occurs causing an unplanned shutdown for an unknown duration, will the people who need the life-support equipment be saved? The time to figure that out is before the arc flash has occurred, not after. Then once you have a plan to deal with the fall out of accidental de-energization, you might be able to implement the back-up plan first and prevent energized work in the first place.

Another revision in NFPA 70E worth talking about is how the requirements surrounding the electrically safe work condition have evolved. For as long as I can remember there has been a section in NFPA 70E that required an ESWC if work posed a shock or an arc flash hazard. There was also a section that stated energized work was permitted if the work created additional hazards/increased risk or was infeasible when de-energized. This energized work section also granted permission to perform energized normal operation of equipment provided certain conditions were met. However, there was nothing saying that it was one or the other. There was no statement in the ESWC rule that said to create an ESWC unless an energized work justification existed. So, the committee decided that it would be best to turn the justifications for energized work into exceptions to the general rule that an ESWC be created.

Although it is just a seemingly small shift, it has already had great success in clarifying that energized work is the exception to the general rule of creating an ESWC. It also helps curb the practice of searching for a way to fit into the “energized work” section of NFPA 70E. It is much more accurate to say that NFPA 70E requires an ESWC if shock and arc flash hazards are present unless one of the exceptions is met. Additionally, the committee also added a new exception to the list. This exception allows a disconnect or isolating element to be operated for the purpose of creating an ESWC or to return equipment to service after an ESWC, provided the risk assessment doesn’t result in an unacceptable risk involved in the operation. This is like normal operation but allows equipment such as a disconnect switch to be operated while the line side is still energized if some of the items in a normal operating condition are not verified, such as properly maintained or being rated for the available fault current. However, if there is evidence of impending failure identified, that would constitute a level of unacceptable risk.

There are also a few honorable mentions that are worth noting. New for 2024 and beyond, all definitions will be in Article 100 with article specific definitions being indicated by the specific article in parenthesis. There is also a new annex to aid in assessing the condition of maintenance as proper maintenance becomes a larger part of the safety conversation. Another honorable mention is some revisions to Table 130.4(E)(a) to better align with OSHA approach boundary tables. The last honorable mention is that certain energy thresholds were clarified in Chapter 3 articles to indicate when Chapter 3 articles apply and modify Chapter 1 general requirements. One such change is in Article 320 for batteries and battery rooms. The scope statement in this article now states that it applies to battery systems with voltages over 100 volts or short circuit power over 1000 watts. However, be careful here not to slip into thinking that NFPA 70E doesn’t apply to battery systems under 100 volts. The general rules in Chapter 1 of NFPA 70E still apply to battery systems with a voltage under 100 volts. Also, remember that Article 320 modifies Chapter 1 and therefore, unless there is a specific rule stated in Article 320 that modifies what Chapter 1 requires, the general rules in Chapter 1 apply to battery systems above 100 volts as well.

While this is just a taste of some of the more important revisions for the 2024 edition of NFPA 70E, it is a good start in digging into the direction the committee is taking when it comes to keeping workers safe from electrical hazards. I encourage everyone who uses NFPA 70E to spend some time going over the revisions and what they mean to your electrical safety program. Many of the latest revisions likely will have little to no impact on our day-to-day but this is always a needed exercise to ensure our programs are compliant with industry consensus standards. Until next time, stay safe out there and remember to always test before you touch.

Derek Vigstol is an electrical safety and maintenance consultant for e-Hazard Management, LLC. He is also the co-host of e-Hazard’s electrical safety and maintenance focused podcast, Plugged into Safety, which can be found wherever you enjoy your podcast listening. He can be reached at derek.vigstol@e-hazard.com.