National Fire Protection Association. 1 Batterymarch Park, Quincy, MA Phone: Fax:

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1 National Fire Protection Association 1 Batterymarch Park, Quincy, MA Phone: Fax: M E M O R A N D U M TO: FROM: NFPA Technical Committee on XXXX Kimberly Shea DATE: September 9, 2013 SUBJECT: NFPA 70E SD TC Ballot Circulation (A2014) The September 6, 2013 date for receipt of the NFPA 70E First Draft ballot has passed. The preliminary First Draft ballot results are shown on the attached report. 25 Members Eligible to Vote 0 Ballots Not Returned In accordance with the NFPA Regulations Governing the Development of NFPA Standards, attached are reasons for negative votes for review so you may change your ballot if you wish. Abstentions and affirmative comments are also included. Ballots received from alternate members are not included unless the ballot from the principal member was not received. If you wish to change your vote, the change must be received at NFPA on or Monday, September 16, Members who have not returned a ballot may do so now. Such changes should be submitted through the NFPA Vote.net Ballot Site. The return of ballots is required by the Regulations Governing the Development of NFPA Standards.

2 NFPA 70E Second Draft Ballot (A14) Preliminary Results September 9, 2013 SR 16, Global Comment, See SR 16 SR 30, Global Comment, See SR 30 Affirmative 21 Affirmative with Comment 2 Palmer L. Hickman This revision will now clearly require the use of voltage rated gloves for systems rated at 208 and 240 volts. However, this revision may cause confusion for the user of 70E. The consequence could be less use of shock protection as the determination of the need to use gloves had been in the HRC table until now. Bobby J. Gray Staff should editorially add the word "nominal" after "120V" in new note d. This would not change intent or implementation but would prevent questions as to whether flucuations in voltage should be considered. There is no technical justification for this change. The vast majority of panels contain multiple voltages. In the range related to this change, normally there is up to 240 or 277 volts. There is no difference in the level of protection needed from a shock prospective between 150 and 277 volts. Both are in the same box. Requiring a 3 distance for 208 to 277 volts adds nothing to the level of safety for the individual, does not add clarity and is overly restrictive. The existing language is clear and represents real world installations. This change should not be made, the existing language should remain.

3 SR 44, Global Comment, See SR 44 Affirmative 20 Negative 4 Palmer L. Hickman We do not believe that the Technical Committee has received additional technical substantiation since the First Revision stage to warrant returning the threshold for dc shock protection to 100 volts. Vincent J. Saporita Based upon the OSHA cited instances, a dc shock hazard can still exist between V. Further study is warranted before accepting this change. This puts 70E in direct conflict with OSHA 1910 Subpart S. OSHA requirements are regulatory requirements and must be revised before a national consensus document can refute or change these requirements. This is a legal issue. This change sets people and companies up for willfull violations of the OSHA requirements Marcia L. Eblen Changing the lower limit of the DC table from 50V to 100V is in contradiction with Federal OSHA requirements. 70E should not encourage workers to disobey federal law. In addition, OSHA has provided specific USA incident data that shows fatalities from DC exposures between 50V and 100V. y changing the tables, inconsistencies now exist with section (D) describing when the restricted approach boundary requirements are invoked. However, I continue to be concerned about the action the 70E Committee took on actions related to the threshold requiring protection from energized DC circuit parts. At the meeting, the Committee voted to raise the threshold to 100 volts from 50 volts adopted at the last meeting. There is clear evidence before the Committee that voltages higher than 50 volts but lower than 100 volts can be, and have been, fatal. Papers submitted by those supporting the rise in the threshold indicate that there have been at least seven fatalities in China from contact with circuit parts energized at less than 100 volts DC. It was argued that the conditions typically involved working in very hot and confined locations and that those fatalities were in a country likely without confined space standards. I don t consider those arguments particularly persuasive. In the first place, the workers died of electric shock, not heat stress or other confined space hazards. I am aware of no evidence that heat stress exacerbates the effects of electric shock. While it is that perspiration can lower contact resistance, that is of wet conditions in general, and it has the same effect on AC electric shock events. It is one of the major reasons why the AC threshold is 50 volts. In the second place, China is not a third world country. China has adopted safety and health laws and has a professional occupational safety association. In addition, as I mentioned in an earlier , there have been at least three fatalities in the US involving DC circuits of less than 100 volts: These incidents, as well as the Chinese incidents, show that voltages over 50 volts DC are hazardous. Finally, setting the DC voltage threshold higher than 50 volts conflicts with the NEC and OSHA standards, which require guarding of exposed live parts operating at more than 50 volts DC. It s hard to understand why NFPA 70E would permit contact with 50 volt DC circuit parts that the installation codes require to be guarded. Clearly, if it is unsafe to install DC equipment with exposed live parts operating at more than 50 volts, it must also be unsafe to touch those parts during maintenance and repair. (Installation requirements will continue to prohibit contact during operation.) I believe that, given the accident history, it is unrealistic to believe that OSHA or the NEC will raise the existing 50 volt DC threshold.

4 SR 63, Global Comment, See SR 63 SR 1, Definition (100): Balaclava (Sock Hood)., See SR 1 Affirmative 21 Affirmative with Comment 1 Lee R. Hale The changed definition is now in alignment with the testing of an Arc Rated face shield and protects the back of the head as intended. Palmer L. Hickman The 2012 edition requires the nose to be covered. The committee has not been presented with evidence that workers should not be required to wear a balaclava that covers the nose area. Abstain 2 Drake A. Drobnick The current definition of Balaclava unconditionally excludes the nose from being covered directly by arc rated material. In some situations this guidance may not be prudent leading to burns to unprotected skin.

5 SR 2, Definition (100): Energized Electrical Work Permit., See SR 2 Affirmative 22 Negative 2 Bobby J. Gray I disagree with removal of the definition. The TC provided a negative statement to a proposal to the 2004 edition that the EEWP could be a procedure or other document that reflected the key elements of the permit. This is good information and should be placed into the defintion to help users understand the purpose of the permit. If we remove the defintion, there may be reluctance for the public to submit changes to fix the defintion as was pointed out in the commttee statement. This definition is still needed. The concept of permitting electrical work where electrical hazards are present has not yet been fully adopted by the general industry and is especially not generally understood by the construction industry. The reason the definition does not contain the criteria and expectations is that definitions cannot contain requirements. SR 68, Definition: Accessible, Readily (Readily Accessible)., See SR 68 Affirmative with Comment 1 I agree with the concept but the sentence needs to be re worded for it to make sense.

6 SR 3, Definition: Luminaire., See SR 3 SR 69, Definition: Premises Wiring (System)., See SR 69 SR 71, Definition: Switchboard., See SR 71

7 SR 72, Definition: Voltage, Nominal., See SR 72 SR 4, New Section after 110.1(A), See SR 4 Affirmative 22 Affirmative with Comment 1 Bobby J. Gray I applaud the TC for recognizing the need to formalize a requirement for an employer to have a documented maintenance program. But, I am disappointed the TC failed to see the value in a similar requirement for installation of electrical equipment and systems. I review many documented programs each year and invariably observe that these programs have no mention of an installation element, but instead focus on work practices only. Meanwhile cursory inspections indicate that electrical system modifications are being done by unqualified persons. The employees installing or modifying are not the qualified people that so many of you train. These are not the people that many of you represent as qualified workers or contractors. These are people the employer has assigned because he or she is not forced to put in writing how they will ensure their electrical equipment and systems are properly installed. As stated in 110.2(A), we rely on safe installations to protect the general worker from exposure to electrical hazards. Since more unqualified workers than qualified workers are electrocuted each year (NIOSH), perhaps we should re evaluate the priority we place on protecting those workers as well as the qualified workers. Louis A. Barrios While I agree that maintenance is an important element for the safe operation of electrical equipment, the proposed text is vague and uninforceable. Also the concept of maintenance and installation is already covered in the modifications to Informational Note 1 in SR 5 and as shown below, "Informational Note No. 1: Safety related work practices such as verification of proper maintenance and installation, alerting techniques, auditing requirements, and training requirements provided in this standard are administrative controls and part of an overall electrical safety program." Therefore the new subsectin "B" is redundant and unnecessary.

8 SR 5, Section No (A), See SR 5 It is the hazard that hurts people. The risk allows it to. The electrical safety program needs to address the hazards and elimination of the hazard first then a risk assessment needs to be performed for whatever hazard is left. If the focus is on the risk then people will not pay attention to elimination of the hazards SR 6, Section No (E), See SR 6 SR 7, Section No (G), See SR 7

9 SR 8, Section No (H)(1), See SR 8 SR 9, Section No (H)(2), See SR 9 SR 10, Section No (A), See SR 10 It is the hazard that hurts people. The risk allows it to. The electrical safety program needs to address the hazards and elimination of the hazard first then a risk assessment needs to be performed for whatever hazard is left. If the focus is on the risk then people will not pay attention to elimination of the hazards SR 11, Section No (B), See SR 11 Affirmative 22 Affirmative with Comment 1

10 Lee R. Hale Daleep C. Mohla I still believe we have not addressed the issue of new technology being introduced effectively or BAD habits being continually passed from one worker to the next. This version is better but still needs improvement to address changes for worker safety. Type of training required by 70E should be classroom and on the job. Electrical systems are getting very complex with the rapid introduction of electronics in every piece of electrical equipment (D) (2) requires Retraining in safety related work practices and applicable changes in this standard shall be performed at intervals not to exceed three years. This clearly implies that employees have to be trained in 70E based training. This can only be accomplished in an instructor lead classroom type environment. It is infeasible to perform this type of training on the job. On the job training is normally done by peers (e.g. a senior electrician training other electricians while working with them) Part of the training is risk assessment and I seriously doubt this can be accomplished in other than an instructor lead training in a class room. SR 13, Section No (C), See SR 13 Affirmative 22 Affirmative with Comment 2 Rodney J. West We recognize that some major certifying bodies provide CPR certification training that is valid for more than one year. As explained during the committee meetings, this section is not intended to require annual certification training but rather to require annual refresher training. While the document does not specify or define what constitutes refresher training, the employer can determine the type and extent of annual refresher training that is necessary to meet this requirement. Louis A. Barrios While I support the committee's efforts to simplify and provide additional clarity in this section, 110.2(C)(2)(a) should be modified to make it clear that "emergency procedures" are appropriate for the hazard or expected injuries and not left open to interpretation to cover all emergency procedures.

11 SR 14, Section No (D)(1), See SR 14 It is the responsibility of the employer to set the acceptable level of risk an employee can work under and the employer must establish the methods of protecting the employees. It is not the responsibility of the employee as outlined in 110.2(D)(1)(b)(4). The the concepts of hazard identification and risk assessment are being muddied with the changes to 70E related to risk and hazards. This will confuse those who will try to implement the requirements of this standard. SR 15, Section No (C), See SR 15 Affirmative 20 Negative 4 Louis A. Barrios The sole criteria for determining whether or not a documented meeting shall be held between a host employer and a contracto employer should not be dependent only on the hosts employer's qualifications and knowledge of the hazards. The contract employer and his/her knowledge of the hazards should also be considered. In fact, it may be more important for a documented meeting to occur when the host employer is not familiar with the electrical hazards at their site. Daleep C. Mohla The proposed new wording Where the host employer has knowledge of hazards covered by this Standard that are related to the contract employer s work, there shall be a documented meeting between the host employer and the contract employer is very ambiguous and has no merit at all. This leaves a big loop hole for not having a meeting at all. Why would a host employer have a meeting to explain the electrical hazards if it is not required (A) (1) requires the host employer is required to inform the contract employer of known hazards related to the contractor s work (A) (C) documentation is the next logical step to ensure requirements of 110.3(A) (1) have been met. The wording in the first draft There shall be a documented meeting between the host employer and the contract employer is needed to have some kind of formal transfer of knowledge and documentation to assure this hazards covered in 110.3(A) (1) have been conveyed to the contract employer. In absence of a clear requirement for documentation there will be no method to determine if contract employer has been informed of known hazards. A meeting should always take place before work begins. If the host employer does not have knowledge of hazards, it is their responsibility to find someone who does. The hazards must be communicated in order to allow proper protective measures to be taken. This wording will allow many host employers to simply not have a meeting and not communicate any hazard information. This weakens the document. James G. Stallcup This is an ambiguous statement. The host employer should be required to have a meeting.

12 SR 16, Section No (A)(4), See SR 16 SR 18, Section No (B)(3), See SR 18 The wording related to the handling of portable electric equipment in highly conductive locations should be removed and the guidance from this document should be to not do those things. Including phrases such as inundated with water, where employees are likely to contact or be drenched with water with guidance on how to handle portable electric equipment is completely contrary to the basic premise of the document. The guidance we should be providing in these situations is to not handle this equipment in those environments. We used to have language related to live line work and we took that out, the same should apply here. This is something that may have been accepted but should not be any longer. SR 19, Section No (C)(3), See SR 19

13 SR 20, Section No , See SR 20 Before verification can be done, an electrically safe work condition must first be established. This section of the standard should focus on establishing the electrically safe work condition. However, it seems to me that the section covers achieving, as well as verifying, an electrically safe working condition. SR 21, Section No (B)(2), See SR 21 Affirmative with Comment 1 Drake A. Drobnick Two new line items need to be added to the next edition in section 120.2(B) (3), (c) when there is a change in job assignment, (d) when the employee shows lack of knowledge or skill. SR 22, Section No , See SR 22 Affirmative with Comment 1 Palmer L. Hickman We wonder if the final wording accurately reflects all of what what is covered by Article 130. It almost sounds like a scope statement where only what is included it the scope of the article can be covered in the article. We submit that this wording may be inaccurate, incomplete and not necessary. Perhaps restating or incorporating the title of Article 130, "Work Involving Electrical Hazards", would be have beenmore appropriate.

14 SR 24, Section No [Excluding any Sub Sections], See SR 24 Affirmative 21 Negative 3 Palmer L. Hickman A worker s presence within the arc flash boundary seems as predictive of the likelihood that an arc flash hazard will exist as a worker s presence within the limited approach boundary is predictive of the likelihood that a shock hazard will exist. Drake A. Drobnick The definition of Arc Flash Hazard states that exposed energized parts or employee interaction could create a hazard. The Standard requires in section that an Electrically Safe Work Condition be established whenever an employee works within an exposed shock hazard boundary or when the employee interacts with enclosed equipment. It totally ignores the exposed arc flash hazard condition it recognizes within the definition. PI 63 sought to remedy this inconsistency and was accepted by the committee and included in FR 72. The Committee reversed its decision and removed the language by accepting PC 115. In the Committee s statement for removing FR 72, they suggest that a worker s presence within the arc flash boundary is not predictive of the likelihood that an arc flash incident will occur. Conversely, by mandating de energizing whenever an employee is located within the exposed shock protection boundary appears to conclude that the employee will always receive a shock at this location without regard to predictive likelihood. Abstain 1 The condition described in (3) still requires an electrically safe work condition to be established. The arc flash boundary can exceed the limited approach boundary and create a hazardous situation. Excluding this sets up a condition that will lead to misunderstanding the arc flash hazard, and will cause injuries. If within the arc flash boundary, an individual would be exposed to the hazard. The hazard should be removed by establishing an electrically safe work condition. SR 25, Section No (B)(1), See SR 25 Affirmative 21 Affirmative with Comment 2 Palmer L. Hickman Why is the arc flash boundary not listed here in this section? Lee R. Hale With the revised text the EWP can now be used effectively as it was orginally intended. Drake A. Drobnick The Committee's departure from the 2012 language in section 130.2(B) (1) dilutes and limits the application of the Energized Electrical Work Permit. By the acceptance of FR 75 and PC 116 which deletes the arc flash boundary and reduces the shock boundary action trigger for < 600 volts to < 12" or

15 SR 26, Section No (B)(2), See SR 26 Affirmative with Comment 1 Lee R. Hale With the revised text the EWP can now be used effectively as it was orginally intended. SR 27, Section No (B)(3), See SR 27 Affirmative with Comment 1 Lee R. Hale With the revised text the EWP can now be used effectively as it was orginally intended. SR 28, Section No (A) [Excluding any Sub Sections], See SR 28 Identification of the hazards is done through a hazard analysis. This section discusses hazards, not risk.

16 SR 29, Section No (A), See SR 29 Hazard identification determines voltage. Then the level of risk can be determined. SR 31, Sections 130.4(C), 130.4(D), See SR 31 There is no technical justification for the change from 300 to 150 volts. The vast majority of panels contain multiple voltages. In the range related to this change, normally there is up to 240 or 277 volts. There is no difference in the level of protection needed from a shock prospective between 150 and 277 volts. Both are in the same box. Requiring a 3 distance for 208 to 277 volts adds nothing to the level of safety for the individual, does not add clarity and is overly restrictive. The existing language is clear and represents real world installations. This change should not be made, the existing language should remain. However, I continue to be concerned about the action the 70E Committee took on actions related to the threshold requiring protection from energized DC circuit parts. At the meeting, the Committee voted to raise the threshold to 100 volts from 50 volts adopted at the last meeting. There is clear evidence before the Committee that voltages higher than 50 volts but lower than 100 volts can be, and have been, fatal. Papers submitted by those supporting the rise in the threshold indicate that there have been at least seven fatalities in China from contact with circuit parts energized at less than 100 volts DC. It was argued that the conditions typically involved working in very hot and confined locations and that those fatalities were in a country likely without confined space standards. I don t consider those arguments particularly persuasive. In the first place, the workers died of electric shock, not heat stress or other confined space hazards. I am aware of no evidence that heat stress exacerbates the effects of electric shock. While it is that perspiration can lower contact resistance, that is of wet conditions in general, and it has the same effect on AC electric shock events. It is one of the major reasons why the AC threshold is 50 volts. In the second place, China is not a third world country. China has adopted safety and health laws and has a professional occupational safety association. In addition, as I mentioned in an earlier , there have been at least three fatalities in the US involving DC circuits of less than 100 volts: These incidents, as well as the Chinese incidents, show that voltages over 50 volts DC are hazardous. Finally, setting the DC voltage threshold higher than 50 volts conflicts with the NEC and OSHA standards, which require guarding of exposed live parts operating at more than 50 volts DC. It s hard to understand why NFPA 70E would permit contact with 50 volt DC circuit parts that the installation codes require to be guarded. Clearly, if it is unsafe to install DC equipment with exposed live parts operating at more than 50 volts, it must also be unsafe to touch those parts during maintenance and repair. (Installation requirements will continue to prohibit contact during operation.) I believe that, given the accident history, it is unrealistic to believe that OSHA or the NEC will raise the existing 50 volt DC threshold.

17 SR 32, Section No , See SR 32 SR 33, Section No (D), See SR 33 SR 34, Section No (H), See SR 34 SR 35, Section No (A), See SR 35

18 SR 36, Section No (C)(9), See SR 36 SR 37, Section No (C)(10), See SR 37 Affirmative 22 Negative 2 Palmer L. Hickman We disagree that "this change clarifies that a balaclava is only required to be worn when the exposure is greater than 4 cal/cm2." This is not a clarification. This creates an unsubstantiated change and a conflict within Article 130. Section 130.7(C)(6) requires all parts of the body to be be protected by arc rated FR. The entire head is part of the body. In addition, the substantiation for the the public comment, which is the basis for this second revision, incorrectly correlates HRC 1 with an incident energy calculation of 4 calories. Rodney J. West We believe the clarification may conflict with the requirements in Sections 130.7(C)(1) and 130.7(C)(6). SR 40, Section No (C)(11), See SR 40

19 SR 41, Section No (C)(13), See SR 41 The change removes any requirements associated with trim, names or logos that may be attached to arc flash PPE. An informational note does not mean that any one will follow the requirements of the referenced standard. This dilutes the effort of providing arc flash PPE that will protect a person.

20 SR 45, Section No (C)(15), See SR 45 Affirmative 15 Affirmative with Comment 3 Rodney J. West The new table format provides additional clarity and gives guidance to users of the document. While the lists of tasks that do not require arc flash PPE remained the same, the new format clarifies that arc flash PPE is required for those same tasks when electrical equipment is not properly installed or maintained, when equipment doors or covers are off or open, or when there is evidence of impending failure. Dennis K. Neitzel I agree with the overall revisions of Table 130.7(C)(15)(A)(a), however I do not agree with the following part of it: In the Table 130.7(C)(15)(A)(a) section that states Task Normal operation of a circuit breaker (CB), switch, contactor, or starter, and where it goes on to state that Equipment Condition All of the following: The equipment is properly installed The equipment is properly maintained All equipment doors are closed and secured All equipment covers are in place and secured There is no evidence of impending failure Where it then states: Arc Flash PPE Required No This is not ; there will never be a case when there is a 100% guarantee that an arc flash will not occur, that may even blow the equipment enclosure door open or the cover off. Granted the risk is very low but not zero as implied here. The substantiation does not provide proof that the risk is zero and that no arc flash PPE is required for this task. This comment also applies to FR 68. Lee R. Hale The tables have a much cleaner and simplified look. The Arc Flash PPE Required header coupled with the "properly installed and maintained.."" section could be interperated two ways. However (A) (4) passed through the FR stage without an attendent PC submitted so the tables do match to 130.2(A)(4). The metal clad switchgear section had it's upper Kv value reduced from 38Kv to 15Kv which is safer for the worker. On balance, simplier and cleaner, there may need to be some revisions in Only time will tell. Negative 6 Daleep C. Mohla Please see document separately submitted for negative statement on SR 45 James G. Stallcup It has been our experience that well maintained equipment can sometimes fail and create an electrical arc. This concept in Table 130.7(C)(15)(A)(a) should have been rejected at the First Daft meeting. The continued effort to water down the arc flash requirements contained in this document is evident by acceptance of this concept. Even listed equipment, installed per the NEC and properly maintained fails. Numerous cases can be provided to show evidence that, at a certain level of arc flash incident energy, the equipment will not contain an arcing fault unless it has been designed and tested to contain it. There is no one who can walk up to piece of electrical equipment and determine whether it is listed, installed correctly, or properly maintained. There are just too many factors to consider in addition to those listed here, age of the equipment for example. Unless the equipment is put into an electrically safe work condition, electrical hazards exist and protection from those hazards is required. While in some cases a site may establish a policy that does not require PPE under conditions of extremely low risk, they are doing that with full knowledge that the risk, or likelihood of an event occurring is not zero, it is never zero as long as the equipment is energized. The titles at the top of the table should not say arc flash PPE required, yes or no, it should say high or low risk and the site has to then decide if they are going to require PPE to be worn. We cannot provide guidance from this document that says definitively, in all cases, without exception, that an individual will be safe without PPE even if the equipment is energized. That is a hazard/risk/likelihood evaluation that must be made, which is also a requirement of this document. Improvements have been made in the table, clearly, but this is not one of them. I am opposed to saying no PPE is required if the equipment is energized and the hazards are present. The text should be returned to the 2012 edition of 70E.

21 James B. Hayes Marcia L. Eblen Drake A. Drobnick The old document was better, and the Term (properly installed equipment ) is nebulus, and we should not sub for PPE, and there are other parts that are made i think un clear I think we are going the wrong way with this SR. The changes to the table made in this revision indicate that NO arc flash PPE is required for some activities (specifically operating equipment that has been properly installed and maintained). While the arc flash risk is low in this condition, it is not zero or gone. This in combination with the elimination of HRC 0 (PPE 0), will likely result in people wearing any clothing they choose. While section 130.7(C)(12) prohibits melting fabrics, the new tables do not specifically state that this section applies in all situations, even when the table indicates NO arc flash PPE required. By re titling the Table column header to PPE Required Y/N (PC 146) the Committee has created language that can easily be misconsd. The column provides a list of tasks that the Committee believes could create an arc flash hazard. Tasks marked yes (Y) require employee interaction, meaning they could create an initiating event. The column should more appropriately be titled "Likelihood of an Arc Flash Hazard Occurring." Another concern is the elimination of HRC 0. Previously the standard provided guidance for PPE when task exposures were at less than 1.2 calories. The new Tables provide no such guidance. As an example according to the new Tables, the normal operation of a 480 volt safety switch within a 36 arc flash boundary does not require PPE and does not disallow the employee from wearing a polyester tank top and shorts while performing this operation.

22 70E 2015 SR 45 Negative Statement Daleep Mohla The second revision SR 45 has some serious defects. These defects are so fundamental that an application of the provisions is likely to expose users to a greater risk than before. The fundamental defects in the table are: Conditions described in table 130.7(C) (15) (a) under which no arc flash PPE is required.i.e equipment is properly installed and maintained etc. It is indefensible and incorrect to state that no arc flash PPE is required under described conditions if equipment is energized. This can only be true if the equipment has been tested to withstand arcing fault conditions. Equipment not tested as Arc Resistant equipment is only tested for bolted faults. Informational Note 3 in 70E-2012 describes why bolted faults and arcing fault are entirely two different phenomena. The occurrence of an arcing fault inside an enclosure produces a variety of physical phenomena very different from a bolted fault. For example, the arc energy resulting from an arc developed in the air will cause a sudden pressure increase and localized overheating. 70E is permitting operation of non-arc resistant equipment with no arc flash PPE. Utilizing these conditions is not limited to any parameters of available short circuit current and overcurrent device clearing time. Following this table, there is no requirement for Arc Flash PPE, indoor or outdoor non arc resistant equipment, when operating a circuit breaker, switch, contactor, or starter up to 38 kv and 63,000 Amperes short circuit under the described conditions. Do we really want to find out equipment was not properly installed or maintained after an arc flash incident? Conditions under which an arc flash hazard exists and to be mitigated by use of PPE in table 130.7(15) (b) i.e. if equipment is not properly installed or maintained etc. Table (15) ((b) can only be used if maximum short circuit current and fault clearing times are known. The term equipment includes Overcurrent devices. Overcurrent device clearing time is dependent on maintenance of the equipment. Improper or inadequate maintenance can result in increased in opening time of overcurrent protective device thus increasing the incident energy it is infeasible to determine fault clearing time if equipment has not been properly maintained rendering the use of table totally useless for conditions for the equipment that has not been properly maintained. PPE for equipment not properly maintained cannot be selected from this table. Deletion of PPE 0 ( previously HRC 0) PPE Category 0 (previously HRC 0) has been deleted for all activities. HRC 0 as a minimum was required for all activities in the table. Now statement No arc flash PPE required will encourage operation of equipment in any clothing even in clothing made of materials such as flammable synthetic materials instead of non-melting fabrics required by HRC 0. HRC 0 required as a minimum Eye protection (safety glasses or safety goggles,) hearing protection (ear canal inserts) and heavy duty leather gloves for hand protection. Safety goggles or glasses, hearing protection and heavy duty leather gloves specified in HRC 0 will no longer be worn when people see certain operations do not require arc flash PPE. Hand injuries are most common due to the close proximity to the task. Previously, this protection from arc flash was provided by Heavy duty leather gloves even for HRC 0 According to 70E-2012, (10)(d) (1) Informational Note Heavy duty leather gloves have been shown to the have ATPV values in excess of 10 cal/cm2 1 of 2

23 70E 2015 SR 45 Negative Statement Daleep Mohla These tables will reduce the maintenance of the equipment..the 70E now provides an option to mitigate arc flash hazard by using PPE in Table 130.7(15)(b) even if equipment has not been properly installed or maintained.this is wrong message to send that arc flash PPE is a substitute for proper maintenance. Proper maintenance of equipment is essential The table (15) (a) permits normal operation of a circuit breaker, switch, contactor, or a starter is permitted without arc flash PPE. From experience, we all know, that most arc flash incidents occur during interaction with the equipment i.e. opening or closing operation The equipment is properly installed: How can a worker determine this? Just because it has been in service for 20 years does not guarantee that it was installed properly The equipment is properly maintained: How can a worker know this? Even if records or labels indicate recommended maintenance was done, this does not assure it was done properly. Maintenance normally is done at a frequency of one to five years depending on the equipment. How do we assure that equipment condition has not deteriorated to an unsafe level since the last maintenance? All equipment doors are closed and secured: A worker may be able to assess this by visual inspection All equipment covers are in place and secured: A worker may be able to assess this by visual inspection There is no evidence of impending failure: How can a worker assess this without opening doors or covers? If we could assess likelihood of impending failure by external inspection, infrared inspection and other diagnostic testing would not be necessary. The criteria listed in SR 45 suggest that risk of injury is determined by the equipment condition. There are two major reasons for disagreement with this rationale One: The arc flash hazard should be established by whether or not there is energy inside the equipment. If there is zero electrical energy inside the equipment, then No PPE would be a correct statement, however if there is electrical energy inside the equipment, then the PPE requirement should be based on the incident energy analysis and an assessment of the capability of the specific equipment to prevent or limit a worker s exposure to that energy. Two: The criteria listed in SR 45 ignore the possibility of human error in the installation, inspection and maintenance of electrical installations. Down playing this highly likely possibility by using the terms proper installation and proper maintenance as the default condition for establishing the need for PPE is counter to sound safety management practices. There is also possibility of human error on the part of the worker performing the task at hand and potentially at risk for serious injury will the worker follow the plan?, is it possible the worker may deviate from the plan? Is it possible the worker may make an error in equipment identification and be working in the wrong place/ etc., etc. If there is energy inside the equipment, a proper risk assessment may show there is residual risk, even if proper installation, proper maintenance, and enclosure integrity are verified. In my opinion, it is incorrect and inappropriate, and in some circles could be considered professionally unethical, to state No PPE Required without performing a hazard and risk assessment for the specific task and conditions current at that time. 2 of 2

24 SR 66, Section No (C)(16), See SR 66 Affirmative 20 Affirmative with Comment 1 Lee R. Hale The deletion of PPE Category 0 is problematic. We've "lost" the 100% cotton and heavy duty leather gloves component of PPE 0 and those requirements. With the new tables concept I can't see how to put this back in 130.7(C)(16)without a conflict to the rest of the standard. This needs to be addressed as a PI for Negative 3 Daleep C. Mohla PPE Category 0 (previously HRC 0) has been deleted for all activities. HRC 0 as a minimum was required for all activities in the table. Now statement No arc flash PPE required will encourage operation of equipment in any clothing even in clothing made of materials such as flammable synthetic materials instead of non melting fabrics required by HRC 0. HRC 0 required as a minimum Eye protection (safety glasses or safety goggles,) hearing protection (ear canal inserts) and heavy duty leather gloves for hand protection. Safety goggles or glasses, hearing protection and heavy duty leather gloves specified in HRC 0 will no longer be worn when people see certain operations do not require arc flash PPE. Hand injuries are most common due to the close proximity to the task. Previously, this protection from arc flash was provided by Heavy duty leather gloves even for HRC 0 According to 70E 2012, (10)(d) (1) Informational Note Heavy duty leather gloves have been shown to the have ATPV values in excess of 10 cal/cm2 James G. Stallcup I believe a Hazard/Risk Category 0 should be retained to provide a minimum risk category because facilities have their electrical safety program based on minimum requirements. Marcia L. Eblen Eliminating a specific definition of minimum clothing requirements below PPE 1 (HRC 1), without specific reference to (C)(12) will likely result in workers wearing melting and prohibited fabrics. Additionally, with the removal of PPE 0, other PPE is also not specifically shown as required e.g. hard hat and safety glasses. SR 42, Section No , See SR 42

25 SR 43, Section No , See SR 43 SR 39, Section No , See SR 39 SR 64, Section No , See SR 64 SR 46, Section No , See SR 46

26 SR 48, Section No , See SR 48 Note that the SR does not appear to indicate any change to this section. SR 49, Section No (C)(1), See SR 49 Total Voted : 25 For two third majority election, the affirmative votes needed are 16 For Simple majority, the affirmative votes needed are 13 SR 50, Section No (A)(1), See SR 50 Total Voted : 25 For two third majority election, the affirmative votes needed are 16 For Simple majority, the affirmative votes needed are 13

27 SR 51, Section No (A)(4), See SR 51 Total Voted : 25 For two third majority election, the affirmative votes needed are 16 For Simple majority, the affirmative votes needed are 13 SR 52, Section No (A)(5), See SR 52 SR 53, Section No (B)(1), See SR 53 Affirmative 22 Affirmative with Comment 1 Drake A. Drobnick The use of chemical goggles under a face shield is required where splash hazards exist. Goggles are listed as primary eye protection. The use of the word AND (PC 167) is correct. Rodney J. West While we agree with most of the revisions that resulted from SR53, we do not believe that adequate substantiation was provided to change the protective equipment requirements from Goggles or face shield to Goggles and face shield.

28 SR 54, Section No (B), See SR 54 SR 55, Section No , See SR 55 SR 65, Annex A, See SR 65 Marcia L. Eblen ASTM standards revision information in Annex A is not consistent with information approved by the TC at the second draft meeting. ASTM standards list the revision information in the number of the document, not separately. For example, ASTM F a is the correct representation of this standard, not (R2010a) listed after the document title.

29 SR 57, Sections B, See SR 57 Marcia L. Eblen ASTM standards revision information in Annex B is not consistent with information approved by the TC at the second draft meeting. ASTM standards list the revision information in the number of the document, not separately. For example, ASTM F a is the correct representation of this standard, not (R2010a) listed after the document title. SR 58, Section No. C.1.2.2, See SR 58 SR 73, Section No. C.2.1.1, See SR 73

30 SR 59, Section No. D.5.3, See SR 59 SR 60, Section No. F.3.1.5, See SR 60 SR 67, Section No. H.2, See SR 67 Affirmative 22 Affirmative with Comment 1 Lee R. Hale The revised text is now in alignment with the other PPE sections and requirments within the document. See my explanation of negative vote on SR 45.

31 SR 61, Section No. H.3, See SR 61 Rodney J. West While we agree with many of the revisions that result from SR61, we are voting negative to correlate with our vote and ballot comment on SR37. SR 62, Section No. O.2.3, See SR 62