Public Comment No. 151-NFPA 70E-2016 [ Global Input ]

Transcription

1 of 403 9/2/2016 9:49 AM Public Comment No. 151-NFPA 70E-2016 [ Global Input ] Action Number (8)(c) (c) Equipment Approval. Temporary protective grounding equipment shall be approved. shall meet the requirements of ASTM F855, Standard Specification for Temporary Protective Grounds to be Used on De-energized Electric Power Lines and Equipment. Informational Note: ASTM F855, Standard Specification for Temporary Protective Grounds to be Used on De-energized Electric Power Lines and Equipment, containing information on temporary protective grounding equipment, is an example of a standard that is often used in the approval process. Action Number (C)(7)(a) Exception Exception: Where it is necessary to use rubber Rubber insulating gloves without leather protectors shall be approved, and may only be used under limited circumstances when there is no risk of damaging the rubber glove. When used in this manner, gloves must be de-rated by half or de-rated to the next lower category. When used without leather protectors, they shall not be reused with leather protectors until they pass a visual and electrical retest. the requirements of ASTM F496, Standard Specification for In-Service Care of Insulating Gloves and Sleeves, shall be met. Informational Note: ASTM F496, Standard Specification for In-Service Care of Insulating Gloves and Sleeves, containing additional information for the use of rubber insulating gloves without leather protectors is an example of a standard that is often used in the approval process. Action Number (C)(7)(c) (Modify the first sentence and delete last sentence and add the following text:) (c) Maintenance and Use. (Add new last sentence) The maximum intervals between tests shall be approved. (Retain existing Informational Note) Table 130.7(C)(7)(c) (Delete column three, Governing Standard for Test Voltage) Delete the first mandatory note blow the Table Relocate the second mandatory note directly below the table. Add the following new Informational Note: Informational Note: ASTM F478, Standard Specification for In-Service Care of Insulating Line Hose and Covers; ASTM F479, Standard Specification for In-Service Care of Insulating Blankets; ASTM F496, Standard Specification for In-Service Care of Insulating Gloves and Sleeves containing information related to in-service and testing requirements for rubber insulating equipment are examples of standards that are often used in the approval process. Action Number (C)(11) Exception Exception: Fiber blends that contain materials that melt, such as acetate, acrylic, nylon, polyester, polyethylene, polypropylene, and spandex, shall be permitted if such blends in fabrics are approved and if such blends in fabrics meet the requirements of ASTM F1506, Standard Performance Specification for Flame Resistant and Arc Rated Textile Materials for Wearing Apparel for Use by Electrical Workers Exposed to Momentary Electric Arc and Related Thermal Hazards and do not exhibit evidence of a melting and sticking hazard during arc testing. according to ASTM F1959/F1959M, Standard Test Method for Determining the Arc Rating of Materials for Clothing

2 of 403 9/2/2016 9:49 AM Informational Note No. 1: ASTM F1959/F1959M, Standard Test Method for Determining the Arc Rating of Materials for Clothing, containing information on test methods used to determine the arc rating of fabrics is an example of a standard that is often used in the approval process. Informational Note No. 2: ASTM F1506, Standard Performance Specification for Flame Resistant and Arc Rated Textile Materials for Wearing Apparel for Use by Electrical Workers Exposed to Momentary Electric Arc and Related Thermal Hazards, containing information on how to determine which fabrics do not exhibit evidence of melting and dripping is an example of a standard that is often used in the approval process. Action Number (C)(14) (C)(14) (14) Standards for Personal Protective Equipment (PPE). PPE shall be approved conform to the standards listed in Table 130.7(C)(14). Informational Note No. 1: Non-arc-rated or flammable fabrics are not covered by any of the standards in Informational Note Table 130.7(C)(14). See 130.7(C)(11) and 130.7(C)(12). Informational Note No. 2: The standards for Personal Protective Equipment (PPE) are contained in Informational Note Table 130.7(C)(14). Change the title of existing Table 130.7(C)(14) as seen below: Informational Note Table 130.7(C)(14) Standards For Personal Protective Equipment (PPE) Action Number 6 Table 130.7(C)(15)(a) Note 2(f). ( Informational Note to Note 2: See IEEE Table 1 for further information regarding notes b through d.) Action Number 7 Table 130.7(C)(15)(b) Note 1 Note 1: Apparel that can be expected to be exposed to electrolyte must be approved and meet both of the following conditions: (1) Be evaluated for electrolyte protection in accordance with ASTM F1296, Standard Guide for Evaluating Chemical Protective Clothing Informational Note: ASTM F1296, Standard Guide for Evaluating Chemical Protective Clothing, containing information on evaluating apparel for electrolyte protection is an example of a standard that is often used in the approval process. (2) Be arc-rated in accordance with ASTM F1891, Standard Specification for Arc Rated and Flame Resistant Rainwear Informational Note: ASTM F1891, Standard Specification for Arc Rated and Flame Resistant Rainwear, containing information on evaluating arc-rated apparel is an example of a standard that is often used in the approval process. Action Number (D)(1)(g) and (h) (g) Rubber Insulating Equipment. Rubber insulating equipment used for protection from unintentiontal contact with energized conductors or circuit parts shall be approved meet the requirements of the ASTM standards listed in Table 130.7(G). Informational Note: Informational Note Table 130.7(G) provides examples of standards that are often used in the approval process. (h) Voltage-Rated Plastic Guard Equipment. Plastic guard equipment for protection of employees from unintentional contact with energized conductors or circuit parts, or for protection of employees or energized equipment or material from contact with ground, shall be approved meet the requirements of the ASTM standards listed in Table 130.7(G)..

3 of 403 9/2/2016 9:49 AM Informational Note: Informational Note Table 130.7(G) provides examples of standards that are often used in the approval process. Action Number (E)(1) (1) Safety Signs and Tags. Safety signs, safety symbols, or tags shall be used where necessary to warn employees about electrical hazards that might endanger them. Such signs and tags shall be approved meet the requirements ANSI Z535, Series of Standards for Safety Signs and Tags, given in Table 130.7(G). Informational Note No. 1: Safety signs, tags, and barricades used to identify energized look-alike equipment can be employed as an additional preventive measure. Informational Note No. 2: Informational Note Table 130.7(F) provides examples of standards that are often used in the approval process. Action Number (G) and Table 130.7(G), old 130.7(F) (revised in FR) (G) Standards for Other Protective Equipment. Other protective equipment required in 130.7(D) shall be approved conform to the standards given in Table 130.7(G). Informational Note: Informational Note Table 130.7(G) provides examples of standards that are often used in the approval process. Revise title of Table 130.7(G) as follows: Informational Note Table 130.7(G) Standards on Other Protective Equipment Action Number 11 New Table and Table 130.7(C)(15)(a) Revise the following category: Arc-resistant switchgear Type 1 or 2 [for clearing times of < 0.5 sec (30 cycles) with a perspective fault current not to exceed the arc-resistant rating of the equipment], and metal-enclosed interrupter switchgear, fused or unfused of arc-resistant-type construction, tested in accordance with IEEE C , 1 kv through 15 kv Add the following informational note after the table: Informational Note: IEEE C , Guide for Testing Metal-Enclosed Switchgear Rated Up to 38 kv for Internal Arcing Faults is an example of a standard that is often used in the approval process. Action Number (A) Inspection and Testing of Protective Equipment and Protective Tools. (A) Visual. Safety and protective equipment and protective tools shall be visually inspected for damage and defects before initial use and at intervals thereafter, as service conditions require, but in no case shall the interval exceed 1 year, unless approved specified otherwise by the respective ASTM standards. Action Number (C)(16) Personal Protective Equipment Conformity Assessment. (a) All personal protective equipment referenced in Table 130.7(C)(14) shall be approved comply with the associated referenced standard. (b) Effective January 1, 2018, all personal protective equipment shall be approved. comply with ANSI/ISEA 125, American National Standard for Conformity Assessment of Safety and Personal Protective Equipment, conformity assessment The marking of personal protective equipment shall be approved. The conformity assessment shall be in accordance with one of the following: Level 1, 2, or 3 in its entirety, and shall be marked in accordance with Section 9 of ANSI/ISEA 125. (1) Level 1 Conformity Assessment. Personal protective equipment shall be self-certified and marked accordingly. (2) Level 2 Conformity Assessment. Personal protective equipment shall be certified by an accredited testing laboratory and marked accordingly.

4 of 403 9/2/2016 9:49 AM (3) Level 3 Conformity Assessment. Personal protective equipment shall be certified by an accredited third party and marked accordingly. Informational Note: ANSI/ISEA 125, American National Standard for Conformity Assessment of Safety and Personal Protective Equipment, is an example of a standard that is often used in the approval process. Type your content here... Additional Proposed Changes File Name Description Approved 70E-mand-ref-tg-final.docx Final work of the task group Statement of Problem and Substantiation for Public Comment This comment submitted on behalf of a task group chartered to develop and submit comments to meet the direction of the NEC Correlating Committee to comply with the NEC Style Manual prohibition of mandatory references to other standards. The decision to reconsider is left to the full 70E committee. This task group simply developed comments for the full committee to consider. The task group consisted of Larry Ayer, Wes Wheeler, Paul Dobrowsky, Vince Saporita, Rod West and Jim Dollard. Where a mandatory reference was made in the 70E Standard, the TG developed proposed revisions to bring the requirements in line with the NEC Style Manual. The mandatory references are removed and where appropriate an Informational Note is added to inform the standard user of the applicable nationally recognized standard to apply. Related Item Correlating Committee Note No. 16-NFPA 70E-2016 [Global Input] Public Input No. 332-NFPA 70E-2015 [Global Input] Submitter Information Verification Submitter Full Name: James Dollard Organization: IBEW Local Union 98 Street Address: City: State: Zip: Submittal Date: Mon May 09 06:36:02 EDT 2016 Committee Statement Committee Action: Resolution: Statement: Rejected but see related SR SR-39-NFPA 70E-2016 Additional response to PC-34 and PC-151: Mandatory references has been removed and relocated into informational notes, informational tables and positive text in conformance with the NEC Style Manual. Also see SR-25, 36, 35, 40, 42, 43, 44, 45, 62, 63, 65, 66, 67 and 68. The table note on test intervals is modified for clarity. The mandatory reference in Table 130.7(C) (7)(c) and the first note to the table are removed and relocated to an informational note. Positive text was inserted and the exception deleted in 130.7(C)(7)(a) to insert requirements previously addressed with a mandatory reference.

5 70E Mandatory References Task Group Global Public Comment Substantiation This comment submitted on behalf of a task group chartered to develop and submit comments to meet the direction of the NEC Correlating Committee to comply with the NEC Style Manual prohibition of mandatory references to other standards. The decision to reconsider is left to the full 70E committee. This task group simply developed comments for the full committee to consider. The task group consisted of Larry Ayer, Wes Wheeler, Paul Dobrowsky, Vince Saporita, Rod West and Jim Dollard. Where a mandatory reference was made in the 70E Standard, the TG developed proposed revisions to bring the requirements in line with the NEC Style Manual. The mandatory references are removed and where appropriate an Informational Note is added to inform the standard user of the applicable nationally recognized standard to apply. 1

6 Action Number (8)(c) (c) Equipment Approval. Temporary protective grounding equipment shall be approved. shall meet the requirements of ASTM F855, Standard Specification for Temporary Protective Grounds to be Used on De-energized Electric Power Lines and Equipment. Informational Note: ASTM F855, Standard Specification for Temporary Protective Grounds to be Used on De-energized Electric Power Lines and Equipment, containing information on temporary protective grounding equipment, is an example of a standard that is often used in the approval process. Action Number (C)(7)(a) Exception Exception: Where it is necessary to use rubber Rubber insulating gloves without leather protectors shall be approved, and may only be used under limited circumstances when there is no risk of damaging the rubber glove. When used in this manner, gloves must be derated by half or de-rated to the next lower category. When used without leather protectors, they shall not be reused with leather protectors until they pass a visual and electrical retest. the requirements of ASTM F496, Standard Specification for In-Service Care of Insulating Gloves and Sleeves, shall be met. Informational Note: ASTM F496, Standard Specification for In- Service Care of Insulating Gloves and Sleeves, containing additional information for the use of rubber insulating gloves without leather protectors is an example of a standard that is often used in the approval process. 2

7 Action Number (C)(7)(c) (Modify the first sentence and delete last sentence and add the following text:) (c) Maintenance and Use. (Add new last sentence) The maximum intervals between tests shall be approved. (Retain existing Informational Note) Table 130.7(C)(7)(c) (Delete column three, Governing Standard for Test Voltage) Delete the first mandatory note blow the Table Relocate the second mandatory note directly below the table. Add the following new Informational Note: Informational Note: ASTM F478, Standard Specification for In- Service Care of Insulating Line Hose and Covers; ASTM F479, Standard Specification for In-Service Care of Insulating Blankets; ASTM F496, Standard Specification for In-Service Care of Insulating Gloves and Sleeves containing information related to in-service and testing requirements for rubber insulating equipment are examples of standards that are often used in the approval process. 3

8 Action Number (C)(11) Exception Exception: Fiber blends that contain materials that melt, such as acetate, acrylic, nylon, polyester, polyethylene, polypropylene, and spandex, shall be permitted if such blends in fabrics are approved and if such blends in fabrics meet the requirements of ASTM F1506, Standard Performance Specification for Flame Resistant and Arc Rated Textile Materials for Wearing Apparel for Use by Electrical Workers Exposed to Momentary Electric Arc and Related Thermal Hazards and do not exhibit evidence of a melting and sticking hazard during arc testing. according to ASTM F1959/F1959M, Standard Test Method for Determining the Arc Rating of Materials for Clothing Informational Note No. 1: ASTM F1959/F1959M, Standard Test Method for Determining the Arc Rating of Materials for Clothing, containing information on test methods used to determine the arc rating of fabrics is an example of a standard that is often used in the approval process. Informational Note No. 2: ASTM F1506, Standard Performance Specification for Flame Resistant and Arc Rated Textile Materials for Wearing Apparel for Use by Electrical Workers Exposed to Momentary Electric Arc and Related Thermal Hazards, containing information on how to determine which fabrics do not exhibit evidence of melting and dripping is an example of a standard that is often used in the approval process. 4

9 Action Number (C)(14) (C)(14) (14) Standards for Personal Protective Equipment (PPE). PPE shall be approved conform to the standards listed in Table 130.7(C)(14). Informational Note No. 1: Non-arc-rated or flammable fabrics are not covered by any of the standards in Informational Note Table 130.7(C)(14). See 130.7(C)(11) and 130.7(C)(12). Informational Note No. 2: The standards for Personal Protective Equipment (PPE) are contained in Informational Note Table 130.7(C)(14). Change the title of existing Table 130.7(C)(14) as seen below: Informational Note Table 130.7(C)(14) Standards For Personal Protective Equipment (PPE) Action Number 6 Table 130.7(C)(15)(a) Note 2(f). (Informational Note to Note 2: See IEEE Table 1 for further information regarding notes b through d.) 5

10 Action Number 7 Table 130.7(C)(15)(b) Note 1 Note 1: Apparel that can be expected to be exposed to electrolyte must be approved and meet both of the following conditions: (1) Be evaluated for electrolyte protection in accordance with ASTM F1296, Standard Guide for Evaluating Chemical Protective Clothing Informational Note: ASTM F1296, Standard Guide for Evaluating Chemical Protective Clothing, containing information on evaluating apparel for electrolyte protection is an example of a standard that is often used in the approval process. (2) Be arc-rated in accordance with ASTM F1891, Standard Specification for Arc Rated and Flame Resistant Rainwear Informational Note: ASTM F1891, Standard Specification for Arc Rated and Flame Resistant Rainwear, containing information on evaluating arc-rated apparel is an example of a standard that is often used in the approval process. Action Number (D)(1)(g) and (h) (g) Rubber Insulating Equipment. Rubber insulating equipment used for protection from unintentiontal contact with energized conductors or circuit parts shall be approved meet the requirements of the ASTM standards listed in Table 130.7(G). Informational Note: Informational Note Table 130.7(G) provides examples of standards that are often used in the approval process. 6

11 (h) Voltage-Rated Plastic Guard Equipment. Plastic guard equipment for protection of employees from unintentional contact with energized conductors or circuit parts, or for protection of employees or energized equipment or material from contact with ground, shall be approved meet the requirements of the ASTM standards listed in Table 130.7(G).. Informational Note: Informational Note Table 130.7(G) provides examples of standards that are often used in the approval process. Action Number (E)(1) (1) Safety Signs and Tags. Safety signs, safety symbols, or tags shall be used where necessary to warn employees about electrical hazards that might endanger them. Such signs and tags shall be approved meet the requirements ANSI Z535, Series of Standards for Safety Signs and Tags, given in Table 130.7(G). Informational Note No. 1: Safety signs, tags, and barricades used to identify energized look-alike equipment can be employed as an additional preventive measure. Informational Note No. 2: Informational Note Table 130.7(F) provides examples of standards that are often used in the approval process. Action Number (G) and Table 130.7(G), old 130.7(F) (revised in FR) (G) Standards for Other Protective Equipment. Other protective equipment required in 130.7(D) shall be approved conform to the standards given in Table 130.7(G). Informational Note: Informational Note Table 130.7(G) provides examples of standards that are often used in the approval process. 7

12 Revise title of Table 130.7(G) as follows: Informational Note Table 130.7(G) Standards on Other Protective Equipment Action Number 11 New Table and Table 130.7(C)(15)(a) Revise the following category: Arc-resistant switchgear Type 1 or 2 [for clearing times of < 0.5 sec (30 cycles) with a perspective fault current not to exceed the arcresistant rating of the equipment], and metal-enclosed interrupter switchgear, fused or unfused of arc-resistant-type construction, tested in accordance with IEEE C , 1 kv through 15 kv Add the following informational note after the table: Informational Note: IEEE C , Guide for Testing Metal-Enclosed Switchgear Rated Up to 38 kv for Internal Arcing Faults is an example of a standard that is often used in the approval process. Action Number (A) Inspection and Testing of Protective Equipment and Protective Tools. (A) Visual. Safety and protective equipment and protective tools shall be visually inspected for damage and defects before initial use and at intervals thereafter, as service conditions require, but in no case shall 8

13 the interval exceed 1 year, unless approved specified otherwise by the respective ASTM standards. Action Number (C)(16) Personal Protective Equipment Conformity Assessment. (a) All personal protective equipment referenced in Table 130.7(C)(14) shall be approved comply with the associated referenced standard. (b) Effective January 1, 2018, all personal protective equipment shall be approved. comply with ANSI/ISEA 125, American National Standard for Conformity Assessment of Safety and Personal Protective Equipment, conformity assessment The marking of personal protective equipment shall be approved. The conformity assessment shall be in accordance with one of the following: Level 1, 2, or 3 in its entirety, and shall be marked in accordance with Section 9 of ANSI/ISEA 125. (1) Level 1 Conformity Assessment. Personal protective equipment shall be self-certified and marked accordingly. (2) Level 2 Conformity Assessment. Personal protective equipment shall be certified by an accredited testing laboratory and marked accordingly. (3) Level 3 Conformity Assessment. Personal protective equipment shall be certified by an accredited third party and marked accordingly. Informational Note: ANSI/ISEA 125, American National Standard for Conformity Assessment of Safety and Personal Protective Equipment, is an example of a standard that is often used in the approval process. 9

14 of 403 9/2/2016 9:49 AM Public Comment No. 203-NFPA 70E-2016 [ Global Input ] Mandatory references to ASTM and other referenced safety related standards should not be removed. In particular requirements for electrical protective equipment and tools must maintain their current referenced standards. To do otherwise would expose workers to electrical hazards and would reduce the protection currently provided by NFPA70E. Manufacturing, test specifications and in-service care of PPE and tools and equipment for electrical protection is critical to their purpose in performing as primary protection for workers againts the hazards of electricity. Statement of Problem and Substantiation for Public Comment NFPA 70E will only continue to provide adequate protection for workers if the referenced ASTM and other Naitonal Consensus standards are maintained. Related Item Public Input No. 203-NFPA 70E-2015 [New Section after 350.5] Submitter Information Verification Submitter Full Name: Joshua Chard Organization: Altec Inc Affilliation: ASTM F18 Street Address: City: State: Zip: Submittal Date: Mon May 16 15:08:46 EDT 2016 Committee Statement Committee Action: Resolution: Rejected All mandatory references to specific standards have been relocated to informational notes or revised to comply with the NEC Style Manual. Where applicable requirements were added to address previous mandatory references in the standard.

15 of 403 9/2/2016 9:49 AM Public Comment No. 210-NFPA 70E-2016 [ Global Input ] Type your content here.. Replace term "Arc Flash" with term "Electric Arc". Statement of Problem and Substantiation for Public Comment Arc flash is a nick name or street name of the phenomena known as Electric Arc. The term arc flash is representing only one property of the electric arc, which is not the major hazard. The major hazard of the electric arc is its thermal effect on the worker and PPE that he is wearing. And a very large part of the standard is actually addressing thermal effects not just a flash. Related Item First Revision No. 20-NFPA 70E-2015 [New Definition after Definition: Luminaire.] Submitter Information Verification Submitter Full Name: Mikhail Golovkov Organization: Arcflashcrt Street Address: City: State: Zip: Submittal Date: Mon May 16 18:31:43 EDT 2016 Committee Statement Committee Action: Resolution: Rejected The term arc flash is a commonly used term in the electrical industry. Numerous books, courses, standards, and papers exist related to this phenomenon. Replacing the term arc flash with electric arc would not improve the clarity or usability of the standard. Using the term electric arc may introduce confusion because many electric arcs (welders, snap switches, etc.) would not be considered an arc flash event.

16 of 403 9/2/2016 9:49 AM Public Comment No. 34-NFPA 70E-2016 [ Global Input ] The Correlating Committee directs that Public Input 332 be reconsidered. Statement of Problem and Substantiation for Public Comment The Correlating Committee directs that Public Input 332 be reconsidered to bring 70E into compliance with the requirements in the 2015 NEC Style Manual. Related Item Public Input No. 332-NFPA 70E-2015 [Global Input] Submitter Information Verification Submitter Full Name: Cc On Nec-Aac Organization: NFPA Street Address: City: State: Zip: Submittal Date: Mon Mar 14 15:03:41 EDT 2016 Committee Statement Committee Action: Resolution: Statement: Rejected but see related SR SR-39-NFPA 70E-2016 Additional response to PC-34 and PC-151: Mandatory references has been removed and relocated into informational notes, informational tables and positive text in conformance with the NEC Style Manual. Also see SR-25, 36, 35, 40, 42, 43, 44, 45, 62, 63, 65, 66, 67 and 68. The table note on test intervals is modified for clarity. The mandatory reference in Table 130.7(C) (7)(c) and the first note to the table are removed and relocated to an informational note. Positive text was inserted and the exception deleted in 130.7(C)(7)(a) to insert requirements previously addressed with a mandatory reference.

17 of 403 9/2/2016 9:49 AM Public Comment No. 43-NFPA 70E-2016 [ Global Input ] The Correlating Committee directs that the Committee review Article 120 in its entirety for vague and unenforceable language (appropriate, they, consulted, etc.), subdivisions without titles and no parent text and Style Manual compliance. Statement of Problem and Substantiation for Public Comment Correlating Committee Directive. Related Item Correlating Committee Note No. 10-NFPA 70E-2016 [Article 120] Submitter Information Verification Submitter Full Name: CC on NEC-AAC Organization: NFPA Street Address: City: State: Zip: Submittal Date: Mon Mar 14 15:53:27 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-25-NFPA 70E-2016 Statement: Sections 120.3(E) and 120.3(F) are relocated to (E) and (F), respectively, because electrical circuit interlocks and control devices are more appropriately addressed in lockout/tagout principles. Sections 120.2(H)(1) and 120.2(H)(2) are relocated to 120.4(A)(4) and 120.4(A)(5), respectively, because the more descriptive requirements for simple and complex lockout/tagout are more appropriately addressed in lockout/tagout procedures. Established is removed from 120.2(G)(1) because it is unnecessary. Section 120.2(G)(3) is deleted because it is not related to the coordination of hazardous energy control procedures. The informational note in 120.2(A) is moved below the requirement. Section replaces Elements of to Process for in verifying because it is a more descriptive phrase for the procedure. List item 120.5(7) is revised to address any known voltage source to correlate with revisions in 110.4(E). A new exception was added to 120.5(7) recognizing that a permanently mounted test device that is listed and labeled can be used at the point where work is to be performed.

18 of 403 9/2/2016 9:49 AM The word policy was changed to procedure in 120.5(6) because it describes action to be taken. Section 120.5(8)(C) is revised to relocate the mandatory reference into an informational note in compliance with the NEC Style Manual.

19 0 of 403 9/2/2016 9:49 AM Public Comment No. 89-NFPA 70E-2016 [ Global Input ] Type your content here... I would like to submit again my proposal on Public input No 103-NFPA 70E-2015 {Section No 130.2)A)(4) be included in the Normal Operation section. Persons performing the normal operation of the electrical equipment shall be task specific trained to that equipment to understand the established procedures to control the energy for that specific device. This training shall include the risk hazard analysis and appropriate measures to protect against arc flash and shock hazards. The committee response was that the Standard already requires that all tasks be performed by qualified persons. This is true. So there should be no reason not to include it in the Normal Operation section. The problem is the Normal Operation section is being treated as a stand alone section. People are interpreting that to mean a person can walk up to a breaker with a calculated arc flash hazard greater than 1.2 cal/cm2 and operate the equipment without the proper PPE for that hazard because it meets the definition of "Normal Operation." This is going to get someone seriously hurt when the breaker fails while being operated in a normal operation function and it has an arc flash hazard greater than 1.2 cal/cm2.. People need to be trained to do the risk hazard analysis and wear the appropriate PPE for the arc flash hazards present for that particular device even though it is a normal operation. Please include my proposal in the final language for Normal Operation. Here is some additional information to consider why we need to include PPE when performing a Normal Operation. OSHA also requires that equipment be properly maintained and wear the approriate PPE for the hazard. We had an incident in our plant a few years ago in which a 4,160 volt starter was being placed in service. The equipment was brand new and was properly installed and commissioned by factory service technician. All of the proper proceedures per the manufacturer were followed. This was about a normal as you can get using the 70E definition. It was branfd new equipment so there were no maintenance issues. When the technician energized the system for the first time, he was wearing a full arc flash suit for the incident energy that had been calculated. It was a very good thing as the starter exploded when the breaker was energized. There was an internal defect causing a short between the B phase line and the C phase motor leads once the breaker was energized. This was not caught by the factiry service technician. Had this techician followed the Normal Operation procedure and not been wearing PPE, he would have ben severly burned. This language in the Normal Operation has to change to include PPE for the hazard before someone is seriously injured. Statement of Problem and Substantiation for Public Comment The problem that would be resolved is the misuse of the Normal Operation language as it is currently stated. It needs to be clarified that just because it is normal operation does not exclude a person from wearing the appropriate PPE required for the specific device being operated. That person must be properly trained to do the risk hazard analysis and wear the appropriate PPE for the hazard involved. I recognize that the standard already requires that a person be qualified to perform a task. I am just asking that this language be repeated in the normal operation section to prevent any further misuse of this section. Related Item Public Input No. 103-NFPA 70E-2015 [Section No (A)(4)] Submitter Information Verification Submitter Full Name: Joe Rachford

20 1 of 403 9/2/2016 9:49 AM Organization: Nucor Steel Gallatin Street Address: City: State: Zip: Submittal Date: Sat Apr 16 06:59:15 EDT 2016 Committee Statement Committee Action: Rejected Resolution: What the submitter is proposing is already covered by other sections of the standard.

21 2 of 403 9/2/2016 9:49 AM Public Comment No. 102-NFPA 70E-2016 [ Definition: Boundary, Arc Flash. ] Boundary, Arc Flash. When an arc flash hazard arcing fault exists, an approach limit from an the arc source at which incident energy equals 1.2 cal/cm 2 (5 J/cm 2 ). Informational Note: According to the Stoll skin burn injury model, the onset of a second degree burn on unprotected skin is likely to occur at an exposure of 1.2 cal/cm 2 (5 J/cm 2 ) for one second. Statement of Problem and Substantiation for Public Comment This Public Comment is submitted by Daniel Roberts in behalf of the Canadian Standards Association (CSA) Z462 Workplace Electrical Safety Technical Committee. The proposed revision correlates with Section 130.5(B) Arc flash boundary, which states: The arc flash boundary shall be the distance at which the incident energy equals 1.2 cal/cm2 (5 J/cm2). The proposed revision provides clarity by associating the boundary with an arcing fault rather than with the concept of a hazard existing. The statement when a hazard exists is not helpful. Whether or not a hazard exists can become a subjective interpretation and is open to debate. However, whether or not an arcing fault exists is not open to interpretation. It is, or is not. The proposed revision also correlates with the revision to Arc Flash Hazard definition IN No. 1. The phrase An arc flash hazard may exist when was revised to The likelihood of occurrence of an arc flash incident increases when. The purpose of this revision was to harmonize with the risk assessment principles found throughout the document. Rather than state that a hazard does or does not exist, it is more appropriate to refer to the likelihood of occurrence of an arc flash incident. The phrase likelihood of occurrence occurs 17 times in a similar context in the 2015 edition of the document. Related Item Public Input No. 320-NFPA 70E-2015 [Definition: Boundary, Arc Flash.] First Revision No. 9-NFPA 70E-2015 [Definition: Boundary, Arc Flash.] First Revision No. 4-NFPA 70E-2015 [Definition: Arc Flash Hazard.] Submitter Information Verification Submitter Full Name: Daniel Roberts Organization: Schneider Electric Affilliation: CSA Z462 Technical Committee Street Address: City: State: Zip: Submittal Date: Thu Apr 21 15:15:06 EDT 2016 Committee Statement Committee Action: Resolution: Rejected The committee continues to affirm the definition created in First Revision No. 9. The submitter has not provided additional substantiation to alter the text as originally proposed in Public Input 320 and again in Public Comment 102.

22 3 of 403 9/2/2016 9:49 AM Public Comment No. 91-NFPA 70E-2016 [ Definition: Accessible, Readily (Readily Accessible). ] Accessible, Readily (Readily Accessible). Capable of being reached quickly for operation, renewal, or inspections without requiring those to whom ready access is requisite to actions such as to use tools, to climb over or remove obstacles, or to resort to portable ladders, and so forth. [70:100] Statement of Problem and Substantiation for Public Comment Revise this definition to match the definition in the 2017 edition of the NEC. This will likely have to be done by a Committee Comment. Related Item Public Input No. 393-NFPA 70E-2015 [New Article after 100] Submitter Information Verification Submitter Full Name: Palmer Hickman Organization: Electrical Training Alliance Street Address: City: State: Zip: Submittal Date: Tue Apr 19 15:18:34 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-3-NFPA 70E-2016 Statement: This revision updates the definition of readily accessible to correlate with the definition that will appear in the upcoming 2017 edition of the National Electrical Code. Both the original and the newly updated definitions are extracted verbatim from the NEC. The informational note is revised to provide clarity.

23 4 of 403 9/2/2016 9:49 AM Public Comment No. 104-NFPA 70E-2016 [ Definition: Arc Flash Hazard. ] Arc Flash Hazard. A dangerous condition source of possible injury or damage to health associated with the possible release of energy caused by an electric arc. Informational Note No. 1: The likelihood of occurrence of an arc flash incident increases when energized electrical conductors or circuit parts are exposed or when they are within equipment in a guarded or enclosed condition, provided a person is interacting with the equipment in such a manner that could cause an electric arc. An arc flash incident is not likely to occur under normal operating conditionswhen enclosed energized equipment has been properly installed and maintained. Informational Note No. 2: See Table for examples oftasks that increase the likelihood of an arc flash incident occurring. Statement of Problem and Substantiation for Public Comment The proposed revision provides consistency within the document with the definition of hazard and with the revised definition of shock hazard. Shock Hazard. A source of possible injury or damage to health associated with current through the body caused by contact or approach to energized electrical conductors or circuit parts. Related Item First Revision No. 4-NFPA 70E-2015 [Definition: Arc Flash Hazard.] First Revision No. 78-NFPA 70E-2015 [Definition: Shock Hazard.] Submitter Information Verification Submitter Full Name: Daniel Roberts Organization: Schneider Electric Street Address: City: State: Zip: Submittal Date: Thu Apr 21 18:56:53 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-2-NFPA 70E-2016 Statement: The term dangerous condition is replaced with source of possible injury or damage to health to provide consistency with the definition of shock hazard. The word possible is removed from the definition as it was redundant.

24 5 of 403 9/2/2016 9:49 AM Public Comment No. 35-NFPA 70E-2016 [ Definition: Arc Flash Hazard. ] See Statement for CC note Arc Flash Hazard. A dangerous condition associated with the possible release of energy caused by an electric arc. Informational Note No. 1: The likelihood of occurrence of an arc flash incident increases when energized electrical conductors or circuit parts are exposed or when they are within equipment in a guarded or enclosed condition, provided a person is interacting with the equipment in such a manner that could cause an electric arc. An arc flash incident is not likely to occur under normal operating conditionswhen enclosed energized equipment has been properly installed and maintained. Informational Note No. 2: See Table for examples oftasks that increase the likelihood of an arc flash incident occurring. Statement of Problem and Substantiation for Public Comment The Correlating Committee directs that Informational Note 1 be reviewed to improve word clarity as suggested in the FD ballot comment(s). Related Item First Revision No. 4-NFPA 70E-2015 [Definition: Arc Flash Hazard.] Submitter Information Verification Submitter Full Name: Cc On Nec-Aac Organization: NFPA Street Address: City: State: Zip: Submittal Date: Mon Mar 14 15:05:15 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-2-NFPA 70E-2016 Statement: The term dangerous condition is replaced with source of possible injury or damage to health to provide consistency with the definition of shock hazard. The word possible is removed from the definition as it was redundant.

25 6 of 403 9/2/2016 9:49 AM Public Comment No. 94-NFPA 70E-2016 [ Definition: Arc Rating. ] Arc Rating (ATPV). The value attributed to materials that describes their performance to exposure to an electrical arc discharge. The arc rating is expressed in cal/cm 2 and is derived from the determined value of the arc thermal performance value (ATPV) or energy of breakopen threshold (E BT ) (should a material system exhibit a breakopen response below the ATPV value). Arc rating is reported as either ATPV or E BT, whichever is the lower value. Informational Note No. 1: Arc-rated clothing or equipment indicates that it has been tested for exposure to an electric arc. Flame resistant clothing without an arc rating has not been tested for exposure to an electric arc. All arc-rated clothing is also flame-resistant. Informational Note No. 2: Breakopen is a material response evidenced by the formation of one or more holes in the innermost layer of arc-rated material that would allow flame to pass through the material. Informational Note No. 3: ATPV is defined in ASTM F1959/F1959M, Standard Test Method for Determining the Arc Rating of Materials for Clothing, as the incident energy (cal/cm 2 ) on a material or a multilayer system of materials that results in a 50 percent probability that sufficient heat transfer through the tested specimen is predicted to cause the onset of a second degree skin burn injury based on the Stoll curve. Informational Note No. 4: E BT is defined in ASTM F1959/F1959M, Standard Test Method for Determining the Arc Rating of Materials for Clothing, as the incident energy (cal/cm 2 ) on a material or a material system that results in a 50 percent probability of breakopen. Breakopen is defined as a hole with an area of 1.6 cm 2 (0.5 in 2 ) or an opening of 2.5 cm (1.0 in.) in any dimension. Statement of Problem and Substantiation for Public Comment This comment is intended to be an editorial segregation of arc rating based on how an ATPV-based arc rating is to be recorded in accordance with 12.3 of ASTM F1959/F1959M-14. This comment adds (ATPV) to clarify that ATPV arc rating differs from an arc rating determined by breakopen threshold. This would be consistent with 12.3 of ASTM F1959/F1959M-14 to "Report the ATPV as the material specimens Arc Rating (ATPV)..." A companion comment will attempt to accomplish the same for arc rating determined by breakopen threshold as set forth in of ASTM F1959/F1959M-14. Related Item Public Input No. 330-NFPA 70E-2015 [Definition: Arc Rating.] Submitter Information Verification Submitter Full Name: Palmer Hickman Organization: Electrical Training Alliance Street Address: City: State: Zip: Submittal Date: Wed Apr 20 10:18:27 EDT 2016 Committee Statement Committee Action: Rejected

26 7 of 403 9/2/2016 9:49 AM Resolution: This present definition is accurate and provides a single location for users of the document to reference. While the definitions that appear in ASTM F1959 are accurate, introducing multiple defined terms in this standard may confuse users. The arc rating assigned to PPE is the lower of the Arc Thermal Performance Value (ATPV) or the Energy Breakopen Threshold (EBT). PPE is not marked with both values for arc rating. Garments that are marked with an Ebt rating do not have an ATPV rating. Due to the nature of the fabric, if a garment is Ebt rated, it breaks open before transmission of heat through the garment exceeds the Stoll curve. Garments that are marked with an ATPV rating have an Ebt value also, but this is usually a much higher number and is not required to be determined by ASTM F1959.

27 8 of 403 9/2/2016 9:49 AM Public Comment No. 95-NFPA 70E-2016 [ Definition: Arc Rating. ] Arc Rating (E BT ). The value attributed to materials that describes their performance to exposure to an electrical arc discharge. The arc rating is expressed in cal/cm 2 and is derived from the determined value of the arc thermal performance value (ATPV) or energy of breakopen threshold (EBT) (should a material system exhibit a breakopen response below the ATPV value). Arc rating is reported as either ATPV or E BT, whichever is the lower value. Informational Note No. 1: Arc-rated clothing or equipment indicates that it has been tested for exposure to an electric arc. Flame resistant clothing without an arc rating has not been tested for exposure to an electric arc. All arc-rated clothing is also flame-resistant. Informational Note No. 2: Breakopen is a material response evidenced by the formation of one or more holes in the innermost layer of arc-rated material that would allow flame to pass through the material. Informational Note No. 3: ATPV is defined in ASTM F1959/F1959M, Standard Test Method for Determining the Arc Rating of Materials for Clothing, as the incident energy (cal/cm 2 ) on a material or a multilayer system of materials that results in a 50 percent probability that sufficient heat transfer through the tested specimen is predicted to cause the onset of a second degree skin burn injury based on the Stoll curve. Revise this informational note to the current definition of breakopen in of ASTM F1959/F1959M -14 Informational Note No. 4: EBT is defined in ASTM F1959/F1959M, Standard Test Method for Determining the Arc Rating of Materials for Clothing, as the incident energy (cal/cm 2 ) on a material or a material system that results in a 50 percent probability of breakopen. Breakopen is defined as a hole with an area of 1.6 cm 2 (0.5 in 2 ) or an opening of 2.5 cm (1.0 in.) in any dimension. [revise this "definition" to the current ASTM F1959 standard]. Statement of Problem and Substantiation for Public Comment This comment is a companion to the comment creating a definition for arc rating determined by ATPV. There are important differences between the two methods of determining arc rating. A definition for both arc rating determined by ATPV and an arc rating determined from breakopen threshold is warranted to make this clear. Per of ASTM F1959/1959M, "... the EBT value shall be reported as the arc rating value of the tested system and noted in the test report as Arc Rating (EBT). In addition, it would appear that some of the information in the definition of arc rating and associated informational notes do not reflect what is in the most current edition of ASTM F1959/1959M (such as pointed out in the recommendations in this comment. Related Item Public Input No. 330-NFPA 70E-2015 [Definition: Arc Rating.] Submitter Information Verification Submitter Full Name: Palmer Hickman Organization: Electrical Training Alliance Street Address: City: State: Zip: Submittal Date: Wed Apr 20 10:24:49 EDT 2016 Committee Statement

28 9 of 403 9/2/2016 9:49 AM Committee Rejected Action: Resolution: This present definition is accurate and provides a single location for users of the document to reference. While the definitions that appear in ASTM F1959 are accurate, introducing multiple defined terms in this standard may confuse users. The arc rating assigned to PPE is the lower of the Arc Thermal Performance Value (ATPV) or the Energy Breakopen Threshold (EBT). PPE is not marked with both values for arc rating. Garments that are marked with an Ebt rating do not have an ATPV rating. Due to the nature of the fabric, if a garment is Ebt rated, it breaks open before transmission of heat through the garment exceeds the Stoll curve. Garments that are marked with an ATPV rating have an Ebt value also, but this is usually a much higher number and is not required to be determined by ASTM F1959.

29 0 of 403 9/2/2016 9:49 AM Public Comment No. 12-NFPA 70E-2016 [ Definition: Barrier. ] Barrier. A physical obstruction that is intended to prevent contact with equipment or energized electrical conductors and circuit parts or to prevent unauthorized access to a work area. Statement of Problem and Substantiation for Public Comment A Barrier must not be confused with a Barricade. A Barricade keeps unauthorized people out by limiting their access. A Barrier prevents inadvertent contact with exposed energized conductors or circuit parts falling under the purview of the Standard. The proposed change will eliminate people using these terms interchangeably. Barricade-> Unauthorized Access Prevention. Barrier -> Inadvertent Contact Prevention (of exposed energized conductors). Related Item First Revision No. 4-NFPA 70E-2015 [Definition: Arc Flash Hazard.] Submitter Information Verification Submitter Full Name: Steven Schuette Organization: Global Risk Consultants Street Address: City: State: Zip: Submittal Date: Thu Feb 25 13:12:28 EST 2016 Committee Statement Committee Action: Rejected Resolution: A barrier may be a fence (for example) used to prevent unauthorized access to a work area.

30 1 of 403 9/2/2016 9:49 AM Public Comment No. 103-NFPA 70E-2016 [ Definition: Boundary, Limited Approach. ] Boundary, Limited Approach. An approach limit at a distance from an exposed energized electrical conductor or circuit part within which a shock hazard exists. Statement of Problem and Substantiation for Public Comment This Public Comment is submitted by Daniel Roberts in behalf of the Canadian Standards Association (CSA) Z462 Workplace Electrical Safety Technical Committee. The brevity of the proposed revised definition provides clarity. The boundary exists when a conductor is: 1) energized; and 2) exposed. Adding a third qualifier within which a shock hazard exists is misleading. A shock hazard exists whenever a conductor is energized and capable of delivering sufficient current to harm a person, whether the conductor is exposed or not. The proposed revision is also consistent with the definition of Boundary, Restricted Approach, which does not contain the qualifier within which a shock hazard exists. This demonstrates that this phrase is unnecessary. Related Item Public Input No. 322-NFPA 70E-2015 [Definition: Boundary, Limited Approach.] First Revision No. 5-NFPA 70E-2015 [Definition: Boundary, Restricted Approach.] Submitter Information Verification Submitter Full Name: Daniel Roberts Organization: Schneider Electric Affilliation: CSA Z462 Technical Committee Street Address: City: State: Zip: Submittal Date: Thu Apr 21 18:12:26 EDT 2016 Committee Statement Committee Action: Resolution: Rejected The definition is clear and the proposed revision to the definition does not enhance usability or clarity for users of the standard.

31 2 of 403 9/2/2016 9:49 AM Public Comment No. 30-NFPA 70E-2016 [ Definition: Electrical Safety Program. ] Electrical Safety Program. A documented system consisting of electrical safety principles, policies, procedures, and processes that directs activities appropriate for the risk associated with electrical hazards. Statement of Problem and Substantiation for Public Comment Delete the definition of Electrical Safety Program that was created by the action of FR13 at the First Draft meeting of the 2018 edition of NFPA 70E. It is unnecessary, inaccurate and incomplete. Related Item First Revision No. 13-NFPA 70E-2015 [New Definition after Definition: Electrical Safety.] Submitter Information Verification Submitter Full Name: Palmer Hickman Organization: Electrical Training Alliance Street Address: City: State: Zip: Submittal Date: Mon Mar 07 14:34:18 EST 2016 Committee Statement Committee Action: Resolution: Rejected The phrase "electrical safety program" is used in NFPA 70E. Providing this definition is helpful to users. The submitter did not provide any suggested improvements.

32 3 of 403 9/2/2016 9:49 AM Public Comment No. 166-NFPA 70E-2016 [ Definition: Electrically Safe Work Condition. ] Electrically Safe Work Condition. A state in which an electrical conductor or circuit part has been disconnected from energized parts, locked/tagged in accordance with established standards, tested to ensure to verify the absence of voltage and, if necessary, grounded with temporary protective grounding equipment has been applied. Statement of Problem and Substantiation for Public Comment The word "ensure" is replaced with "verify". Testing verifies the absence of voltage, but does not necessarily "ensure" the absence of voltage. "Grounded" is added at the beginning of the last series in the clause for proper grammar. Related Item First Revision No. 11-NFPA 70E-2015 [Definition: Electrically Safe Work Condition.] Submitter Information Verification Submitter Full Name: Louis Barrios Organization: Shell Global Solutions Affilliation: American Petroleum Institute Street Address: City: State: Zip: Submittal Date: Fri May 13 08:16:19 EDT 2016 Committee Statement Committee Action: Rejected but see related SR Resolution: SR-4-NFPA 70E-2016 Statement: The revised definition enhances clarity for the users of the document.

33 4 of 403 9/2/2016 9:49 AM Public Comment No. 125-NFPA 70E-2016 [ Definition: Ground-Fault Circuit Interrupter, Special Purpo... ] Ground-Fault Circuit Interrupter, Special Purpose (SPGFCI). A device intended for the protection of personnel that functions to de-energize a circuit or portion thereof within an established period of time when a current to ground exceeds the values established for Class C, D, and E devices. Informational Note: Classes C, D, and E ground-fault circuit interrupters trip when the current to ground is 20 ma or higher and do not trip when the current to ground is less than 15 ma. For further information, see UL 943C, Outline of Investigation for Special Purpose Ground-Fault Circuit Interrupters. Additional Proposed Changes File Name Description Approved 70E_2018_Comment_to_FR_28_Delete_the_definition_of_SPGFCI.docx 70E SPGFCI Statement of Problem and Substantiation for Public Comment Delete the definition of SPGFCI As both Type A and Type C,D, and E are termed GFCI for personnel protection, users may not realize the difference in protection provided by Type A ( GFCI) and Type C,D, and E ( SPGFCI). Type C,D, and E have special installation instructions that may not be clear to users. For example the SPGFCI requires a laarger equipment grounding conductor to provide protection Recognizing the installation concerns NEC CMP-2 created 2017-NEC second revisions that deleted the references to the Special Purpose GFCI in Art Their reasons had to do with special installation requirements for these GFCIs (Class C, D and E) that may not be apparent to the installer or user. Type A provides both ventricular fibrillation and let go protection with no and special enhancements. Type C, D and E, may or may not provide let go protection Type C, can only to be used where voltage to ground is greater than 150 Voltsbut does not exceed 300 volts to ground and requires a low impedance equipment grounding conductor or double insulation. Class D can only be used with one or more conductors over 300 volts to ground, and with specially sized, reliable grounding, to provide a low impedance path so that the voltage across the body during a fault does not exceed 150 volts. Even though these stipulations and conditions are mentioned in UL 943C, but it may be readily accessible to every user. The following details should be added in 70E to advise users on key requirements and conditions of use of such devices. This covers ground-fault circuit-interrupters intended for use in one of the following applications: a) Where the voltage to ground is greater than 150 volts and equipment grounding or double insulation is required by the National Electrical Code, ANSI/NFPA 70 CLASS C GROUND-FAULT CIRCUIT-INTERRUPTER A groundfault circuit-interrupter that is intended to be used in circuits with no conductor over 300 V AC to ground where reliable equipment grounding or double insulation is provided. CLASS D GROUND-FAULT CIRCUIT-INTERRUPTER A ground-fault circuit-interrupter that is intended to be used in circuits with one or more conductors over 300 volts to ground, and with specially sized, reliable grounding, to provide a low impedance path so that the voltage across the body during a fault does not exceed 150 volts. 2 CLASS E GROUND-FAULT CIRCUIT-INTERRUPTER A ground-fault circuit-interrupter that is intended to be used in circuits with one or more conductors over 300 volts to ground but with conventional equipment grounding provided for the protected equipment in the system or double insulation. These ground-fault circuit-interrupters respond rapidly to open the circuit before the magnitude and duration of the current flowing through the person s body exceeds the limits for ventricular fibrillation. Informational Note:, 1. 1Classes C, D, and E ground-fault circuit interrupters trip when the current to ground is 20 ma or higher and do not trip when the leakage current to ground is less than 15 ma. For further information, see UL 943C, Outline of Investigation for Special Purpose Ground-Fault Circuit Interrupters 2. Class C devices provide ventricular fibrillation protection and may not provide let go protection 3. For Class D devices The grounding conductor may need to be

34 5 of 403 9/2/2016 9:49 AM a larger gauge than would normally be selected in order to provide protection to personnel in event of a ground-fault. Rationale: Using the same term as GFCI used for class A devices without an adequate explanation to users may result in incorrect application. The additional language proposed was extracted from UL 943C. Related Item First Revision No. 28-NFPA 70E-2015 [New Definition after Definition: Ground-Fault Circuit Inter...] Submitter Information Verification Submitter Full Name: Daleep Mohla Organization: DCM Electrical Consulting Serv Street Address: City: State: Zip: Submittal Date: Tue Apr 26 09:56:38 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-23-NFPA 70E-2016 Statement: The proposed definition is not necessary and is inappropriate as the term does not exist in the body of the standard.

35 Delete the definition of SPGFCI As both Type A and Type C,D, and E are termed GFCI for personnel protection, users may not realize the difference in protection provided by Type A ( GFCI) and Type C,D, and E ( SPGFCI). Type C,D, and E have special installation instructions that may not be clear to users. For example the SPGFCI requires a laarger equipment grounding conductor to provide protection Recognizing the installation concerns NEC CMP-2 created 2017-NEC second revisions that deleted the references to the Special Purpose GFCI in Art Their reasons had to do with special installation requirements for these GFCIs (Class C, D and E) that may not be apparent to the installer or user. Type A provides both ventricular fibrillation and let go protection with no and special enhancements. Type C, D and E, may or may not provide let go protection Type C, can only to be used where voltage to ground is greater than 150 Voltsbut does not exceed 300 volts to ground and requires a low impedance equipment grounding conductor or double insulation. Class D can only be used with one or more conductors over 300 volts to ground, and with specially sized, reliable grounding, to provide a low impedance path so that the voltage across the body during a fault does not exceed 150 volts. Even though these stipulations and conditions are mentioned in UL 943C, but it may be readily accessible to every user. The following details should be added in 70E to advise users on key requirements and conditions of use of such devices. This covers ground-fault circuit-interrupters intended for use in one of the following applications: a) Where the voltage to ground is greater than 150 volts and equipment grounding or double insulation is required by the National Electrical Code, ANSI/NFPA 70 CLASS C GROUND-FAULT CIRCUIT-INTERRUPTER A ground-fault circuit-interrupter that is intended to be used in circuits with no conductor over 300 V AC to ground where reliable equipment grounding or double insulation is provided. CLASS D GROUND-FAULT CIRCUIT-INTERRUPTER A ground-fault circuit-interrupter that is intended to be used in circuits with one or more conductors over 300 volts to ground, and with specially sized, reliable grounding, to provide a low impedance path so that the voltage across the body during a fault does not exceed 150 volts. 2 CLASS E GROUND-FAULT CIRCUIT-INTERRUPTER A ground-fault circuit-interrupter that is intended to be used in circuits with one or more conductors over 300 volts to ground but with conventional equipment grounding provided for the protected equipment in the system or double insulation. These ground-fault circuit-interrupters respond rapidly to open the circuit before the magnitude and duration of the current flowing through the person s body exceeds the limits for ventricular fibrillation. Informational Note:, 1. 1Classes C, D, and E ground-fault circuit interrupters trip when the current to ground is 20 ma or higher and do not trip when the leakage current to ground is less than 15 ma. For further information, see UL 943C, Outline of Investigation for Special Purpose Ground-Fault Circuit Interrupters 2. Class C devices provide ventricular fibrillation protection and may not provide let go protection 3. For Class D devices The grounding conductor may need to be a larger gauge than would normally be selected in order to provide protection to personnel in event of a ground-fault. Rationale: Using the same term as GFCI used for class A devices without an adequate explanation to users may result in incorrect application. The additional language proposed was extracted from UL 943C.

36 6 of 403 9/2/2016 9:49 AM Public Comment No. 164-NFPA 70E-2016 [ Definition: Ground-Fault Circuit Interrupter, Special Purpo... ] Ground-Fault Circuit Interrupter, Special Purpose (SPGFCI). A device intended for the protection of personnel that functions to de-energize a circuit or portion thereof within an established period of time when a current to ground exceeds the values established for Class C, D, and E devices. Informational Note: Classes C, D, and E ground-fault circuit interrupters trip when the current to ground is 20 ma or higher and do not trip when the current to ground is less than 15 ma. For further information, see UL 943C, Outline of Investigation for Special Purpose Ground-Fault Circuit Interrupters. Statement of Problem and Substantiation for Public Comment Note to committee - please coordinate the action taken on this with the action taken on Public Comments No 162 and 163. SPGFCI devices are listed to UL 943C - Outline of Investigation for Special Purpose Ground-Fault Circuit- Interrupters. According to UL 943C, in applications where the voltage to ground exceeds 150 volts but does not exceed 300 volts, a Class C SPGFCI is to be used. In applications where the voltage to ground exceeds 300 volts, a Class D SPGFCI may be used if an oversized equipment grounding conductor is installed. If an oversized equipment grounding conductor is not installed, a Class E SPGFCI is to be used. These requirements are not mentioned in the new exceptions, creating the possibility of these devices being misapplied. In order to avoid potential confusion with Class A GFCI protection, the committee should mention SPGFCI devices in Annex O instead of as an exception in If the committee relocates references to SPGFCI from to Annex O then the definition is no longer requrired as the term will not appear in the body of the standard. Related Item First Revision No. 23-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: Rodney West Organization: Schneider Electric USA Street Address: City: State: Zip: Submittal Date: Thu May 12 11:05:30 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-23-NFPA 70E-2016 Statement: The proposed definition is not necessary and is inappropriate as the term does not exist in the body of the standard.

37 7 of 403 9/2/2016 9:49 AM Public Comment No. 54-NFPA 70E-2016 [ Definition: Ground-Fault Circuit Interrupter, Special Purpo... ] Ground-Fault Circuit Interrupter, Special Purpose (SPGFCI). A device intended for the protection of personnel that functions to de-energize a circuit or portion thereof within an established period of time when a current to ground exceeds the values established for Class C, D, and E devices. Informational Note: Classes C, D, and E ground-fault circuit interrupters trip when the current to ground is 20 ma or higher and do not trip when the current to ground is less than 15 ma. For further information, see UL 943C, Outline of Investigation for Special Purpose Ground-Fault Circuit Interrupters. Statement of Problem and Substantiation for Public Comment The definition and all other text relating to SPGFCI devices should be deleted from the standard. Allowing ground fault protection for personnel through the use of two devices with very different levels of protection will not be understood or applied correctly by the majority of the readers of this document. The reader will be left with the question of whether or not the "unsafe" current level is 4 to 6 ma or 15 to 20 ma. If a Class A GFCI device is not available, protection should be provided using an assured equipment grounding conductor program as stated in the existing text. If added, the SPGFCI will cause confusion and will certainly create a potential unsafe condition. Related Item First Revision No. 28-NFPA 70E-2015 [New Definition after Definition: Ground-Fault Circuit Inter...] Submitter Information Verification Submitter Full Name: David Pace Organization: Olin Corporation Affilliation: Self Street Address: City: State: Zip: Submittal Date: Wed Mar 16 18:35:33 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-23-NFPA 70E-2016 Statement: The proposed definition is not necessary and is inappropriate as the term does not exist in the body of the standard.

38 8 of 403 9/2/2016 9:49 AM Public Comment No. 32-NFPA 70E-2016 [ Definition: Incident Energy. ] Incident Energy. The amount of thermal energy impressed on a surface, a certain distance from 18 inches from the source, generated during an electrical arc event. Incident energy is typically expressed in calories per square centimeter (cal/cm 2 ). Statement of Problem and Substantiation for Public Comment Arc flash calculation software typically defaults to an IEL of 18 inches based on the distance of the employee's face and chest area from the arc source. Defining incident energy at 18 inches will align NFPA 70E with the accepted 18 inch default of arc flash software and differentiate the IEL distance of 18 inches from greater exposure distances. Greater distances are addressed with a proposed new definition for Incident Energy Exposure as identified in Public comment 31. Related Public Comments for This Document Related Comment Relationship Public Comment No. 31-NFPA 70E-2016 Both definitions are interrelated and changing the incident [New Definition after Definition: Incident energy definition to 18 inches helps differentiate between Energy Analysis.] the two definitions. Public Comment No. 33-NFPA 70E-2016 [Section No (E)] Related Item Public Input No. 143-NFPA 70E-2015 [New Definition after Definition: Incident Energy Analysis.] Submitter Information Verification Submitter Full Name: Richard Waters Organization: Batelle Energy Alliance Street Address: City: State: Zip: Submittal Date: Mon Mar 14 13:09:05 EDT 2016 Committee Statement Committee Rejected Action: Resolution: The working distance is not always 18 inches. For example, the working distance may be 12 inches or 24 inches. See Informative Annex D.3.1 for some examples of typical working distances used for incident energy calculations.

39 9 of 403 9/2/2016 9:49 AM Public Comment No. 193-NFPA 70E-2016 [ Definition: Maintenance, Condition of. ] Maintenance, Condition of. The state of the electrical equipment s condition considering the manufacturer s recommendations instructions and applicable industry codes and standards. Statement of Problem and Substantiation for Public Comment Change the word "recommendations" to "instructions". The term "instructions" is more consistently used in NFPA 70E especially in Chapter 2. The word "instructions" is also used in NEC 110.3(B) as a requirement to be followed for listed equipment. Manufacturer's recommendations can be a suggestion that is not necessarily mandatory or would need to be considered in all applications. Related Item First Revision No. 20-NFPA 70E-2015 [New Definition after Definition: Luminaire.] Submitter Information Verification Submitter Full Name: Paul Dobrowsky Organization: Innovative Technology Services Street Address: City: State: Zip: Submittal Date: Mon May 16 09:18:41 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-5-NFPA 70E-2016 Statement: The revised definition clarifies consideration of multiple methods to maintain equipment and better aligns with the terminology used in Chapter 2 and other NFPA documents. The word condition is removed to avoid using a portion of the term being defined within the definition as directed in the National Electrical Code Style Manual Section

40 0 of 403 9/2/2016 9:49 AM Public Comment No. 36-NFPA 70E-2016 [ Definition: Maintenance, Condition of. ] See statement for CC Note Maintenance, Condition of. The state of the electrical equipment s condition considering the manufacturer s recommendations and applicable industry codes and standards. Statement of Problem and Substantiation for Public Comment The Correlating Committee directs the committee to review the proposed definition for grammar and clarity. Related Item First Revision No. 20-NFPA 70E-2015 [New Definition after Definition: Luminaire.] Submitter Information Verification Submitter Full Name: Cc On Nec-Aac Organization: NFPA Street Address: City: State: Zip: Submittal Date: Mon Mar 14 15:25:00 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-5-NFPA 70E-2016 Statement: The revised definition clarifies consideration of multiple methods to maintain equipment and better aligns with the terminology used in Chapter 2 and other NFPA documents. The word condition is removed to avoid using a portion of the term being defined within the definition as directed in the National Electrical Code Style Manual Section

41 1 of 403 9/2/2016 9:49 AM Public Comment No. 55-NFPA 70E-2016 [ Definition: Shock Hazard. ] Shock Hazard. A source of possible injury or damage to health associated with current through the body caused by contact or approach to energized electrical conductors or circuit parts. Informational Note: Injury and damage resulting from shock is a function dependent o the magnitude of the magnitude electrical current, the power source frequency, path, and time the current flows (i.e.60 Hz, 50 HZz DC), and the path and the time duration of current flow through the body. The physiological reaction ranges from perception, muscular contractions, inability to let go, ventricular fibrillation, tissue burns, and death. Statement of Problem and Substantiation for Public Comment The revisions provide clarity in that they provide a better understanding of the intent of the Committee. Simply using words such as magnitude and frequency alone will be misunderstood by those using the standard that do not have an electrical background or knowledge, such as Occupational Safety and Health professionals. Related Item First Revision No. 78-NFPA 70E-2015 [Definition: Shock Hazard.] Submitter Information Verification Submitter Full Name: David Pace Organization: Olin Corporation Affilliation: Self Street Address: City: State: Zip: Submittal Date: Wed Mar 16 18:51:25 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-6-NFPA 70E-2016 Statement: The revised informational note provides additional clarity and information to users of the document.

42 2 of 403 9/2/2016 9:49 AM Public Comment No. 37-NFPA 70E-2016 [ Definition: Working Distance. ] See Statement for CC Note Working Distance. The distance between an arc source and the face and chest area of a person. Statement of Problem and Substantiation for Public Comment The Correlating Committee directs that the definition of working distance be compared to the use of the term in 130.7(C)(15) and provide clarity. Related Item First Revision No. 15-NFPA 70E-2015 [New Definition after Definition: Voltage, Nominal.] Submitter Information Verification Submitter Full Name: Cc On Nec-Aac Organization: NFPA Street Address: City: State: Zip: Submittal Date: Mon Mar 14 15:33:45 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-7-NFPA 70E-2016 Statement: The definition has been revised and a new informational note has been added to provide clarity.

43 3 of 403 9/2/2016 9:49 AM Public Comment No. 31-NFPA 70E-2016 [ New Definition after Definition: Incident Energy Analysis. ] TITLE OF NEW CONTENT Incident Energy Exposure. The exposure in cal/cm 2 to an employee's face and chest area that was determined by an arc flash hazard analysis based on the employee's distance from a prospective arc source. Statement of Problem and Substantiation for Public Comment Defining Incident Energy Exposure will help to clarify the difference between incident energy (any surface) and incident energy exposure (employee) and the statement about incident energy exposure level in Article 130.5(C)(1) Related Public Comments for This Document Related Comment Public Comment No. 32-NFPA 70E-2016 [Definition: Incident Energy.] Public Comment No. 33-NFPA 70E-2016 [Section No (E)] Related Item Relationship Public Input No. 143-NFPA 70E-2015 [New Definition after Definition: Incident Energy Analysis.] Submitter Information Verification Submitter Full Name: Richard Waters Organization: Batelle Energy Alliance Street Address: City: State: Zip: Submittal Date: Mon Mar 14 12:08:42 EDT 2016 Committee Statement Committee Action: Rejected Resolution: Defining the term Incident Energy is sufficient. There is no need to define an additional term.

44 4 of 403 9/2/2016 9:49 AM Public Comment No. 127-NFPA 70E-2016 [ New Definition after Definition: Electrical Safety Program. ] TITLE OF NEW CONTENT Near miss Type your content here... Additional Proposed Changes File Name NFPA_70E_-2018_Public_Comment_Near_Miss_definition.docx Description Approved Statement of Problem and Substantiation for Public Comment Electrical safety program should include a requirement for investigation of every Near miss to minimize the possibility a serious accident or fatality. This term currently does not exist in 70E and is proposed to be added to 110.1( H). Addition of this new definition if the term is accepted for utilization in 110.1(H) will explain to user the intent of the term Related Item First Revision No. 26-NFPA 70E-2015 [New Section after 110.1(H)] Submitter Information Verification Submitter Full Name: Daleep Mohla Organization: DCM Electrical Consulting Serv Street Address: City: State: Zip: Submittal Date: Tue Apr 26 10:32:26 EDT 2016 Committee Statement Committee Action: Resolution: Rejected The text in 110.1(J) which requires investigation into electrical incidents does not need further clarification with a defined term.

45 Near miss: A narrowly avoided event or occurrence that could have caused an electrical injury or a fatality due to electric shock, arc flash, arc blast or thermal burns. Informational Note: A near miss is an unplanned event that did not result in injury or fatality but had the potential to do so. Only a fortunate break in the chain of events prevented an injury or fatality Rationale: These terms are currently not defined in 70E

46 5 of 403 9/2/2016 9:49 AM Safety. ] Public Comment No. 126-NFPA 70E-2016 [ New Definition after Definition: Electrical TITLE OF NEW CONTENT Type your content here... Electrical Incident : An event or occurence causing an injury or fatality to employees due to direct or indirect exposure to an electrical source Statement of Problem and Substantiation for Public Comment Add a new definition of Electrical Incident utilized in FR (H) uses a term Electrical incident but the term is not defined in the standard. Related Item First Revision No. 26-NFPA 70E-2015 [New Section after 110.1(H)] Submitter Information Verification Submitter Full Name: Daleep Mohla Organization: DCM Electrical Consulting Serv Street Address: City: State: Zip: Submittal Date: Tue Apr 26 10:22:25 EDT 2016 Committee Statement Committee Action: Resolution: Rejected The text in 110.1(J) which requires investigation into electrical incidents does not need further clarification with a defined term.

47 6 of 403 9/2/2016 9:49 AM Public Comment No. 23-NFPA 70E-2016 [ New Definition after Definition: Exposed (as applied to ene... ] TITLE OF NEW CONTENT Type your content here...new Definition: Potential Exposure Locations: Stating that exposure can be related to any live part located not just in switchboards and panelboards,but also at any enclosure,(such as JB's troughs, cans,light fixtures etc.) which under a live condition (energized state) could result in an individual contacting a exposed live conductor and possibly sustaning an Injury or worse. ( To many apprentice and electrician do not understand that a common splicing of a live conductor within any enclosure can result in live parts contacted improperly which can lead to injury or death). Additional Proposed Changes File Name Description Approved NFPA_comment.doc This definition will help both young and old understand that there is a risk of injury not only from large equipment but also from common everyday systems such as lights Junction boxes etc. Becoming hung up to a live circuit is not addressed enough and this is a large item for construction electricians to learn and accept. Statement of Problem and Substantiation for Public Comment Would help to better make our apprentice, Journeyman and others start to learn to be more aware of common every day items that can cause injury or death prior to it happening. This line added to the document would help to push companies into making sure no live situations are taken lightly. Related Item Public Input No. 23-NFPA 70E-2015 [Section No (D)(2)] Submitter Information Verification Submitter Full Name: BRIAN FERREIRA Organization: PROFESSIONAL ELECTRIC Affilliation: Safety Director Street Address: City: State: Zip: Submittal Date: Fri Feb 26 09:16:53 EST 2016 Committee Statement Committee Action: Resolution: Rejected The proposed definition is not necessary and is inappropriate as the term does not exist in the body of the standard.

48 Public Comment No. 1-NFPA 70E-2016 TITLE OF NEW CONTENT Type your content here...new Definition: Potential Exposure Locations: Stating that exposure can be related to any live part located not just in switchboards and panel boards, also at any enclosure,(such as JB's troughs, cans,light fixtures etc.) which under a live condition (energized state) could result in an individual contacting a exposed live conductor and possibly sustaining an Injury or worse. (Too many apprentice and electrician do not understand that a common splicing of a live conductor within any enclosure can result in live parts contacted improperly which can lead to injury or death). additional Proposed Changes File Name Description Approved TITLE_OF_NEW_CONTENT_Potential_Exposure.docx This definition will help both young and old understand that there is a risk of injury not only from large equipment but also from common everyday systems such as lights Junction boxes etc. Becoming hung up to a live circuit is not addresed enough and this is a large item for construction electricians to learn and accept. Statement of Problem and Substantiation for Public Comment Submitter Information Verification This PC has not been submitted yet Copyright Assignment I, BRIAN FERREIRA, hereby irrevocably grant and assign to the National Fire Protection Association (NFPA) all and full rights in copyright in this Public Comment (including both the Proposed Change and the Statement of Problem and Substantiation). I understand and intend that I acquire no rights, including rights as a joint author, in any publication of the NFPA in which this Public Comment in this or another similar or derivative form is used. I hereby warrant that I am the author of this Public Comment and that I have full power and authority to enter into this copyright assignment. By checking this box I affirm that I am BRIAN FERREIRA, and I agree to be legally bound by the above Copyright Assignment and the terms and conditions contained therein. I understand and intend that, by checking this box, I am creating an electronic signature that will, upon my submission of this form, have the same legal force and effect as a handwritten signature

49 7 of 403 9/2/2016 9:49 AM Public Comment No. 152-NFPA 70E-2016 [ New Definition after Definition: Exposed (as applied to wir... ] Fault Current. The amount of current delivered during a short circuit condition. Fault Current, Available. The largest amount of current capable of being delivered during a short-circuit condition. Informational Note: A short circuit can occur during abnormal conditions such as; a fault between circuit conductors or a ground fault. See Figure 100-AFC. Figure 100-AFC (See attached word document for Figure 100-AFC) Type your content here... TITLE OF NEW CONTENT Additional Proposed Changes File Name Description Approved ASSC-AFC-TG-Final.docx Final task group work Statement of Problem and Substantiation for Public Comment This comment is submitted on behalf of a task group appointed by the NEC Correlating Committee to review the use of the terms, fault current, available fault current, short circuit current and available short circuit current. This comment does not represent new material. Public inputs 87 and 471 seek clarity in the use of these terms. In order to achieve the necessary level of clarity, two basic definitions are submitted for consideration. The proposed definition of fault current is defined as, the amount of current delivered during a short circuit condition. This is definition simply illustrates that fault current is some type of a fault that leaves the circuit path to return to the source of supply. The proposed definition of available fault current simply illustrates that this value considers the largest amount of fault current. This defined term recognizes that as the supply source changes, the level of fault current available at a given point on a circuit will change. An informational note is provided after the defined term available fault current. The intent of this IN is to inform the user of the standard that a short circuit can occur during abnormal conditions such as; a fault between circuit conductors or a ground fault. The IN includes a figure to provide additional clarity. This figure includes pictorial information to show where the terms available fault current, interrupting rating, short circuit current rating and prospective short circuit will apply. The task group members included; Christine Porter, Vince Saporita, Rod West, Mark McNellis, Larry Ayer, Paul Dobrowsky, Alan Manche and Jim Dollard. Related Item Public Input No. 87-NFPA 70E-2015 [Global Input]

50 8 of 403 9/2/2016 9:49 AM Public Input No. 471-NFPA 70E-2015 [Global Input] Submitter Information Verification Submitter Full Name: James Dollard Organization: IBEW Local Union 98 Street Address: City: State: Zip: Submittal Date: Mon May 09 06:54:39 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-8-NFPA 70E-2016 Statement: This revision defines the terms fault current and available fault current which are used throughout the document. This improves usability of the document by creating definite, distinct, clear and concise definitions of widely used terms. The figure was added to assist in understanding these terms.

51 ASCC/AFC Task Group Public Comment Fault Current. The amount of current delivered during a short circuit condition. Fault Current, Available. The largest amount of current capable of being delivered during a short-circuit condition. Informational Note: A short circuit can occur during abnormal conditions such as; a fault between circuit conductors or a ground fault. See Figure 100-AFC. Figure 100-AFC This comment is submitted on behalf of a task group appointed by the NEC Correlating Committee to review the use of the terms, fault current, available fault current, short circuit current and available short circuit current. This comment does not represent new material. Public inputs 87 and 471 seek clarity in the use of these terms. In order to achieve the necessary level of clarity, two basic definitions are submitted for consideration. The proposed definition of fault current is defined as, the amount of current delivered during a short circuit condition. This is definition simply illustrates that fault current is some type of a fault that leaves the circuit path to return to the source of supply.

52 The proposed definition of available fault current simply illustrates that this value considers the largest amount of fault current. This defined term recognizes that as the supply source changes, the level of fault current available at a given point on a circuit will change. An informational note is provided after the defined term available fault current. The intent of this IN is to inform the user of the standard that a short circuit can occur during abnormal conditions such as; a fault between circuit conductors or a ground fault. The IN includes a figure to provide additional clarity. This figure includes pictorial information to show where the terms available fault current, interrupting rating, short circuit current rating and prospective short circuit will apply. The task group members included; Christine Porter, Vince Saporita, Rod West, Mark McNellis, Larry Ayer, Paul Dobrowsky, Alan Manche and Jim Dollard.

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54 0 of 403 9/2/2016 9:49 AM Public Comment No. 92-NFPA 70E-2016 [ Article 105 ] Article 105 Application of Safety-Related Work Practices and Procedures Scope. Chapter 1 covers electrical safety-related work practices and procedures for employees who are exposed to an electrical hazard in workplaces covered in the scope of this standard Purpose. These practices and procedures are intended to provide for employee safety relative to electrical hazards in the workplace. Informational Note: For general categories of electrical hazards, see Informative Annex K Responsibility. (A) Employer Responsibility. The employer shall have the following responsibilities: (1) Establish, implement, and document the safety-related work practices required and procedures required by this standard (2) Provide employees with training in the employer s safety-related work practices and procedures. (B) Employee Responsibility. The employee shall comply with the safety-related work practices and procedures provided by the employer Priority. Hazard elimination shall be the first priority in implementation of safety-related work practices. Informational Note: Elimination is the first risk control method listed in the hierarchy of risk control identified in 110.1(H) Organization. Chapter 1 of this standard is divided into five articles. Article 100 provides definitions for terms used in one or more of the chapters of this document. Article 105 provides for application of safety-related work practices. Article 110 provides general requirements for electrical safety-related work practices and procedures. Article 120 provides requirements for establishing an electrically safe work condition. Article 130 provides requirements for work involving electrical hazards. Statement of Problem and Substantiation for Public Comment "and procedures" was added in several (including the article title) locations to correlate with the use of the phrase in the article scope and purpose with its use throughout Article 105 for consistency. Related Item Public Input No. 354-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: Palmer Hickman Organization: Electrical Training Alliance Street Address: City: State:

55 1 of 403 9/2/2016 9:49 AM Zip: Submittal Date: Tue Apr 19 15:30:56 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-10-NFPA 70E-2016 Statement: Article 105 is revised to provide clarity and consistency with current wording found in Section Sections 105.3(A)(1) and were reviewed and revised for grammatical accuracy.

56 2 of 403 9/2/2016 9:49 AM Public Comment No. 170-NFPA 70E-2016 [ Section No ] Priority. Hazard elimination shall be the first priority in the implementation of safety-related work practices. Informational Note: Elimination is the first risk control method listed in the hierarchy of risk control identified in 110.1(H). Statement of Problem and Substantiation for Public Comment Added "the" before "implementation" to improve grammar. Related Item First Revision No. 17-NFPA 70E-2015 [New Section after 105.3] Submitter Information Verification Submitter Full Name: Louis Barrios Organization: Shell Global Solutions Affilliation: American Petroleum Institute Street Address: City: State: Zip: Submittal Date: Fri May 13 14:57:52 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-10-NFPA 70E-2016 Statement: Article 105 is revised to provide clarity and consistency with current wording found in Section Sections 105.3(A)(1) and were reviewed and revised for grammatical accuracy.

57 3 of 403 9/2/2016 9:49 AM Public Comment No. 38-NFPA 70E-2016 [ Section No ] See Statement for CC Note Priority. Hazard elimination shall be the first priority in implementation of safety-related work practices. Informational Note: Elimination is the first risk control method listed in the hierarchy of risk control identified in 110.1(H). Statement of Problem and Substantiation for Public Comment The Correlating Committee directs that Section be reviewed for clarity and grammar as noted in the FD ballot comment(s). Related Item First Revision No. 17-NFPA 70E-2015 [New Section after 105.3] Submitter Information Verification Submitter Full Name: CC on NEC-AAC Organization: NFPA Street Address: City: State: Zip: Submittal Date: Mon Mar 14 15:38:37 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-10-NFPA 70E-2016 Statement: Article 105 is revised to provide clarity and consistency with current wording found in Section Sections 105.3(A)(1) and were reviewed and revised for grammatical accuracy.

58 4 of 403 9/2/2016 9:49 AM Public Comment No. 39-NFPA 70E-2016 [ Section No (B) ] See statement for CC Note (B) Inspection. The electrical safety program shall include a requirement to assess newly installed or modified electrical equipment or systems prior to normal operation of electrical equipment. Statement of Problem and Substantiation for Public Comment The Correlating Committee directs that the proposed new section be reviewed. It is unclear the reason newly installed or modified electrical equipment is being assessed. Related Item First Revision No. 21-NFPA 70E-2015 [New Section after 110.1(A)] Submitter Information Verification Submitter Full Name: CC on NEC-AAC Organization: NFPA Street Address: City: State: Zip: Submittal Date: Mon Mar 14 15:42:44 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-11-NFPA 70E-2016 Statement: This revision provides clarity by requiring the electrical safety program to include elements to verify that equipment is subjected to inspection for compliance with applicable installation codes and standards.

59 5 of 403 9/2/2016 9:49 AM Public Comment No. 84-NFPA 70E-2016 [ Section No (H) ] (H) Risk Assessment Procedure. The electrical safety program shall include a risk assessment procedure that includes all of the following: (1) An electrical safety program shall include a risk assessment procedure that addresses employee exposure to electrical hazards. The risk assessment procedure shall identify the process to be used by the employee before work is started to carry out the following: (1) Identify hazards (2) Assess risks (3) Implement risk control according to a hierarchy of methods (2) The risk assessment shall take into consideration the potential for human error and its negative consequences on people, processes, the work environment, and equipment. Informational Note: The potential for human error will vary with factors such as tasks and the work environment. (3) Preventive and protective risk control methods shall be implemented in accordance with the following hierarchy: (1) Elimination (2) Substitution (3) Engineering controls (4) Awareness (5) Administrative controls (6) PPE Informational Note No. 1: Elimination, substitution, and engineering controls are the most effective methods to reduce risk as they are usually applied at the source of possible injury or damage to health and they are less likely to be affected by human error. Awareness, administrative controls, and PPE are the least effective methods to reduce risk as they are not applied at the source and they are more likely to be affected by human error. Informational Note No. 2: See ANSI/AIHA Z10, American National Standard for Occupational Health and Safety Management Systems, for more information regarding the hierarchy of risk control methods. Informational Note No. 3: The risk assessment procedure could include identifying when a second person could be required and the training and equipment that person should have. Informational Note No. 4: For an example of a risk assessment procedure, see Informative Annex F. Statement of Problem and Substantiation for Public Comment This comment is editorial in nature. As written the revised text contains a first level subdivision title and list items. Parent text is necessary to require the program include all of the list items. Related Item First Revision No. 24-NFPA 70E-2015 [Section No (G)] Submitter Information Verification

60 6 of 403 9/2/2016 9:49 AM Submitter Full Name: James Dollard Organization: IBEW Local Union 98 Street Address: City: State: Zip: Submittal Date: Tue Apr 12 14:53:43 EDT 2016 Committee Statement Committee Action: Rejected but see related SR Resolution: SR-12-NFPA 70E-2016 Statement: Section 110.1(H) is editorially revised for style, consistency and clarity.

61 7 of 403 9/2/2016 9:49 AM Public Comment No. 144-NFPA 70E-2016 [ Section No (H)(1) ] (1) An electrical safety program shall include a risk assessment procedure that addresses employee exposure to electrical hazards. The risk assessment procedure shall identify the process to be used by the employee risk assessment team consisting of personnel with expertise in safety and electrical hazard identification before work is started to carry out the following: (1) Identify hazards (2) Assess risks (3) Implement risk control according to a hierarchy of methods Additional Proposed Changes File Name Description Approved ESW pdf See attachment # 1 on risk assessment Statement of Problem and Substantiation for Public Comment Statement that the process to be used by the employee to perform a risk assessment before work is started is not consistent with published and applicable OSHA requirements. Risk assessment is an employer s duty. OSHA standards such as 29 CFR (d)(1) and 29 CFR (l)(8)(i) and (l)(8)(ii) make it clear that it is the employer, not the employee, who is to perform the assessment. In addition, the worker is generally neither qualified nor informed enough to perform an adequate risk assessment. Employers are accountable for the safety of their employees therefore the risk assessment should be conducted by a team appointed by the employer. ANSI B11.0 recommends a team approach to risk assessment. 29CFR (d) require employers to assess the work place to determine if hazards are present, or are likely to be present. Employees may not be trained in the risk assessment process. Related Item First Revision No. 24-NFPA 70E-2015 [Section No (G)] Submitter Information Verification Submitter Full Name: Daryld Crow Organization: DRC Consulting, Ltd. Street Address: City: State: Zip: Submittal Date: Wed Apr 27 19:44:58 EDT 2016 Committee Statement Committee Action: Rejected but held Resolution: Public Comment No. 144 introduces new material that has not had public review.

62 8 of 403 9/2/2016 9:49 AM Public Comment No. 13-NFPA 70E-2016 [ Section No (I) [Excluding any Sub-Sections] ] Before starting each job that involves exposure to electrical hazards, the employee in charge shall complete a job safety plan and conduct a job briefing with the employees involved. A determination shall be made that the job to be performed satisfies the requirements of infeasablility, and/or does not create additional hazards or increased risks as defined by this Standard [see 130.2]. Statement of Problem and Substantiation for Public Comment OSHA and NFPA-70E prohibit work on exposed energized conductors or circuit parts 50-volts or greater unless the Employer can demonstrate that de-energizing is infeasible, or that de-energizing creates greater hazards or increased risks [29 CFR, Subpart S, (a)(2); 2015 NFPA 70E, Article 130.2; Proposed 2018 NFPA 70E Article 130.2]. For instance, before the arc flash PPE and shock tables are used, the job must satisfy Infeasibility or Greater Hazard/Increased Risk. Before crossing the Limited Approach Boundary and/or the Arc Flash Boundaries, infeasibility must be satisfied. The first step to working on energized conductors or circuit parts 50-V or greater is to establish that such work is permitted in the first place. Related Item First Revision No. 4-NFPA 70E-2015 [Definition: Arc Flash Hazard.] Submitter Information Verification Submitter Full Name: Steven Schuette Organization: Global Risk Consultants Street Address: City: State: Zip: Submittal Date: Thu Feb 25 14:16:09 EST 2016 Committee Statement Committee Action: Rejected Resolution: The proposed requirement is redundant as it is already addressed in Article 130

63 9 of 403 9/2/2016 9:49 AM Public Comment No. 153-NFPA 70E-2016 [ Section No (I)(1) ] (1) Job Safety Planning. The job safety plan shall be in accordance with the following: (1) Be completed by a qualified person (2) Be documented (3)? Exception: Where the job involves establishing a simple lockout/tagout, the job safety planning is not be required to be documented. (4) Include the following information: (5) A description of the job and the individual tasks (6) Identification of the electrical hazards associated with each task (7) A shock risk assessment in accordance with for tasks involving a shock hazard (8) An arc flash risk assessment in accordance with for tasks involving an arc flash hazard (9) Work procedures involved, special precautions, and energy source controls Statement of Problem and Substantiation for Public Comment The first draft revision requires the job safety planning to ALWAYS be documented. This is overly burdensome and does not add to safety for simple tasks. There are some instances where this should not be required. Simple lockout/tagout is one example where even a written procedure is not required. It is expected that a qualified person should be able to perform this type of task without documented work procedures. While a documented job safety analysis may be desired in some cases, it should not be required in all cases. Related Item First Revision No. 25-NFPA 70E-2015 [Section No (H)] Submitter Information Verification Submitter Full Name: Mark Scott Organization: Lawrence Berkeley National Laboratory Street Address: City: State: Zip: Submittal Date: Mon May 09 11:19:54 EDT 2016 Committee Statement Committee Action: Resolution: Rejected If a job involves exposure to an electrical hazard or hazards it is required to perform a risk assessment for that hazard or those hazards and document the assessment. Such requirements already exist elsewhere in the Standard. See the shock risk assessment documentation requirement in 130.4(B) and arc flash risk assessment documentation requirement in 130.5(A).

64 0 of 403 9/2/2016 9:49 AM Public Comment No. 56-NFPA 70E-2016 [ Section No (I)(1) ] (1) Job Safety Planning. The job safety plan shall be in accordance with the following: (1) Be completed by a qualified person (2) Be documented (3) (4) Include the following information: (5) A description of the job and the individual tasks (6) Identification of the electrical hazards associated with each task (7) A shock risk assessment in accordance with for tasks involving a shock hazard (8) An arc flash risk assessment in accordance with for tasks involving an arc flash hazard (9) Work procedures involved, special precautions, and energy source controls Informational Note: Job safety Plan documentation requirements shall determined based on the complexity of the work to be done and the severity of the electrical hazards present. Statement of Problem and Substantiation for Public Comment The requirement to document all Job Safety Plans is overly restrictive and not necessary. Many, if not most jobs involve the complexity and hazards that warrant requiring formal documentation. Most jobs involve well understood hazards and methods of protection for personnel. Requiring documentation for these jobs is not helpful and will not result in a safer work environment. This requirement simply will not be followed for these jobs. Related Item First Revision No. 25-NFPA 70E-2015 [Section No (H)] Submitter Information Verification Submitter Full Name: David Pace Organization: Olin Corporation Affilliation: Self Street Address: City: State: Zip: Submittal Date: Wed Mar 16 19:09:58 EDT 2016 Committee Statement Committee Action: Resolution: Rejected If a job involves exposure to an electrical hazard or hazards it is required to perform a risk assessment for that hazard or those hazards and document the assessment. Such requirements already exist elsewhere in the Standard. See the shock risk assessment documentation requirement in 130.4(B) and arc flash risk assessment documentation requirement in 130.5(A).

65 1 of 403 9/2/2016 9:49 AM Public Comment No. 57-NFPA 70E-2016 [ Section No (I)(2) ] (2) Job Briefing. The job briefing shall cover the job safety plan or plan and the information on the energized electrical work permit, if a permit is required. Statement of Problem and Substantiation for Public Comment A permit is not always required, but when it is, the information both in the Plan and the permit should be included is the job briefing. Many items on both are identical but not all so both should be included. The current text indicates that if a permit is required, then information on the Plan doesn't have to be covered, which I don't agree with. Both should be covered. Related Item First Revision No. 25-NFPA 70E-2015 [Section No (H)] Submitter Information Verification Submitter Full Name: David Pace Organization: Olin Corporation Affilliation: Self Street Address: City: State: Zip: Submittal Date: Thu Mar 17 10:57:13 EDT 2016 Committee Statement Committee Accepted Action: Resolution: SR-18-NFPA 70E-2016 Statement: The revised requirement clarifies that a job safety plan and an energized electrical work permit might be documented separately, and in such cases, both documents shall be included in the job briefing.

66 2 of 403 9/2/2016 9:49 AM Public Comment No. 132-NFPA 70E-2016 [ Section No (J) ] (J) Incident Investigations. The electrical safety program shall include a requirement to investigate investigate near miss and electrical incidents. Statement of Problem and Substantiation for Public Comment A near miss needs to be investigated to identify any gaps in the electrical safety program, training or procedures before an electrical incident occurs. Investigation of a near miss may prevent a serious electrical injury or fatality Related Item First Revision No. 26-NFPA 70E-2015 [New Section after 110.1(H)] Submitter Information Verification Submitter Full Name: Daleep Mohla Organization: DCM Electrical Consulting Serv Street Address: City: State: Zip: Submittal Date: Tue Apr 26 18:54:48 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-13-NFPA 70E-2016 Statement: The term requirement is replaced with element for consistency in The new informational note is added to clarify that electrical incidents include events or occurrences that result in, or could have resulted in, fatality, injury, or damage to health.

67 3 of 403 9/2/2016 9:49 AM Public Comment No. 207-NFPA 70E-2016 [ Section No (J) ] (J) Incident Investigations. The electrical safety program shall include a requirement to investigate electrical incidents. Statement of Problem and Substantiation for Public Comment Without defining the term "electrical incident," this provision could create confusion. Related Item First Revision No. 26-NFPA 70E-2015 [New Section after 110.1(H)] Submitter Information Verification Submitter Full Name: Sarah Amick Organization: Rubber Manufacturers Association Affilliation: Rubber Manufacturers Association Street Address: City: State: Zip: Submittal Date: Mon May 16 17:01:52 EDT 2016 Committee Statement Committee Action: Resolution: Rejected This standard incorporates the concepts of Occupational Health and Safety Management Systems and Risk Management. Incident investigation is a fundamental part of both concepts. See SR-13.

68 4 of 403 9/2/2016 9:49 AM Public Comment No. 199-NFPA 70E-2016 [ Section No (K)(2) ] (2) Field Electrical Work Audit. Field Electrical work shall be audited to verify that the requirements contained in the procedures of the electrical safety program are being followed. When the auditing determines that the principles and procedures of the electrical safety program are not being followed, the appropriate revisions to the training program or revisions to the procedures shall be made.audits shall be performed at intervals not to exceed 1 year. Statement of Problem and Substantiation for Public Comment Many facility people misunderstand the term "Field work", supposing it is work done outside of the facility. This section should to apply to all electrical work whether it inside the facility our out in the field. Some electrical manufacturers also misinterpret, thinking that can audit only when their technicians travel to the customer sites, instead have having internal audits of technicians assembling electrical equipment. Related Item First Revision No. 27-NFPA 70E-2015 [Section No (I)] Submitter Information Verification Submitter Full Name: Peter Walsh Organization: Mersen Street Address: City: State: Zip: Submittal Date: Mon May 16 13:58:54 EDT 2016 Committee Statement Committee Action: Resolution: Rejected The phrase "field work" is commonly understood in industry to refer to work performed in any work location.

69 5 of 403 9/2/2016 9:49 AM Public Comment No. 106-NFPA 70E-2016 [ Section No (A) ] (A) Electrical Safety Training. The training requirements contained in 110.2(A) shall apply to employees exposed to an electrical hazard when the risk associated with that hazard is not reduced to a safe level by the applicable electrical installation requirements. Such employees shall be trained to understand the specific hazards associated with electrical energy. They shall be trained in safety-related work practices and procedural requirements, as necessary, to provide protection from the electrical hazards associated with their respective job or task assignments. Employees shall be trained to identify and understand the relationship between electrical hazards and possible injury. Informational Note: For further information concerning installation requirements, see NFPA 70.

70 6 of 403 9/2/2016 9:49 AM (1) Qualified Person. A qualified person shall be trained and knowledgeable in the construction and operation of equipment or a specific work method and be trained to identify and avoid the electrical hazards that might be present with respect to that equipment or work method. (a) Such persons shall also be familiar with the proper use of the special precautionary techniques, applicable electrical policies and procedures, PPE, insulating and shielding materials, and insulated tools and test equipment. (b) A person can be considered qualified with respect to certain equipment and tasks but still be unqualified for others. (c) Such persons permitted to work within the limited approach boundary shall, at a minimum, be additionally trained in all of the following: (4) Skills and techniques necessary to distinguish exposed energized electrical conductors and circuit parts from other parts of electrical equipment (5) Skills and techniques necessary to determine the nominal voltage of exposed energized electrical conductors and circuit parts (6) Approach distances specified in Table 130.4(C)(a) and Table 130.4(C)(b) and the corresponding voltages to which the qualified person will be exposed (7) Decision-making process necessary to be able to do the following: (8) Perform the job safety planning (9) Identify electrical hazards (10) Assess the associated risk (11) Select the appropriate risk control methods from the hierarchy of controls identified in 110.1(G), including personal protective equipment (l) An employee who is undergoing on-the-job training for the purpose of obtaining the skills and knowledge necessary to be considered a qualified person, and who in the course of such training demonstrates an ability to perform specific duties safely at his or her level of training, and who is under the direct supervision of a qualified person shall be considered to be a qualified person for the performance of those specific duties. (m) Employees shall be trained to select an appropriate test instrument and shall demonstrate how to use a device to verify the absence of voltage, including interpreting indications provided by the device. The training shall include information that enables the employee to understand all limitations of each test instrument that might be used. (n) The employer shall determine through regular supervision or through inspections conducted on at least an annual basis that each employee is complying with the safety-related work practices required by this standard. (2) Unqualified Persons. Unqualified persons shall be trained in, and be familiar with, any electrical safety-related practices necessary for their safety.

71 7 of 403 9/2/2016 9:49 AM (3) Retraining. Retraining in safety-related work practices and applicable changes in this standard shall be performed at intervals not to exceed 3 years. An employee shall receive additional training (or retraining) if any of the following conditions exists: (1) The supervision or annual inspections indicate the employee is not complying with the safety-related work practices. (2) New technology, new types of equipment, or changes in procedures necessitate the use of safetyrelated work practices different from those that the employee would normally use. (3) The employee needs to review tasks that are performed less often than once per year. (4) The employee needs to review safety-related work practices not normally used by the employee during regular job duties. (5) The employee s job duties change. (4) Type of Training. The training required by 110.2(A) shall be classroom, on-the-job, or a combination of the two. The type and extent of the training provided shall be determined by the risk to the employee. (5) Electrical Safety Training Documentation. The employer shall document that each employee has received the training required by 110.2(A). This documentation shall be in accordance with the following: (1) Be made when the employee demonstrates proficiency in the work practices involved (2) Be retained for the duration of the employee s employment (3) Contain the content of the training, each employee s name, and dates of training Informational Note No. 1: Content of the training could include one or more of the following: course syllabus, course curriculum, outline, table of contents, or training objectives. Informational Note No. 2: Employment records that indicate that an employee has received the required training are an acceptable means of meeting this requirement. Statement of Problem and Substantiation for Public Comment This Public Comment is submitted by Daniel Roberts in behalf of the Canadian Standards Association (CSA) Z462 Workplace Electrical Safety Technical Committee. Errata - The addition of the word Electrical to the title was missed by TerraView. Related Item First Revision No. 29-NFPA 70E-2015 [Sections 110.2(A), 110.2(B)] Public Input No. 328-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: Daniel Roberts Organization: Schneider Electric Affilliation: CSA Z462 Technical Committee Street Address: City: State: Zip: Submittal Date: Fri Apr 22 11:20:51 EDT 2016 Committee Statement

72 8 of 403 9/2/2016 9:49 AM Committee Action: Resolution: Statement: Rejected but see related SR SR-14-NFPA 70E-2016 Response to PC 40: The Technical Committee has reviewed the reference to 110.2(A) in the first sentence and affirms that it does not include parts of (B) or (C). Article has been restructured so that sections (A), (B) and (C) are stand-alone requirements. The word "Electrical" was added to the title of 110.2(A) to clarify that the requirements of this standard relate specifically to electrical safety training as opposed to safety training in general. The title "National Electrical Code" is restored in the informational note in accordance with NEC style manual

73 9 of 403 9/2/2016 9:49 AM Public Comment No. 40-NFPA 70E-2016 [ Section No (A) [Excluding any Sub-Sections] ] See Staement for CC Note The training requirements contained in 110.2(A) shall apply to employees exposed to an electrical hazard when the risk associated with that hazard is not reduced to a safe level by the applicable electrical installation requirements. Such employees shall be trained to understand the specific hazards associated with electrical energy. They shall be trained in safety-related work practices and procedural requirements, as necessary, to provide protection from the electrical hazards associated with their respective job or task assignments. Employees shall be trained to identify and understand the relationship between electrical hazards and possible injury. Informational Note: For further information concerning installation requirements, see NFPA 70. Statement of Problem and Substantiation for Public Comment The Correlating Committee directs the Committee to review the Style Manual and clarify if the removal of National Electrical Code is appropriate. The Committee is also directed to review the reference to 110.2(A) in the first sentence and clarify if it includes all or parts of (B) and (C). Related Item First Revision No. 29-NFPA 70E-2015 [Sections 110.2(A), 110.2(B)] Submitter Information Verification Submitter Full Name: CC on NEC-AAC Organization: NFPA Street Address: City: State: Zip: Submittal Date: Mon Mar 14 15:45:04 EDT 2016 Committee Statement Committee Action: Resolution: Statement: Rejected but see related SR SR-14-NFPA 70E-2016 Response to PC 40: The Technical Committee has reviewed the reference to 110.2(A) in the first sentence and affirms that it does not include parts of (B) or (C). Article has been restructured so that sections (A), (B) and (C) are stand-alone requirements. The word "Electrical" was added to the title of 110.2(A) to clarify that the requirements of this standard relate specifically to electrical safety training as opposed to safety training in general. The title "National Electrical Code" is restored in the informational note in accordance with NEC style manual

74 0 of 403 9/2/2016 9:49 AM Public Comment No. 58-NFPA 70E-2016 [ Section No (A)(3) ] (3) Retraining. Retraining in safety-related work practices and applicable changes in this standard shall be performed at intervals not to exceed 3 exceed 2 years. An employee shall receive additional training (or retraining) if any of the following conditions exists: (1) The supervision or annual inspections indicate the employee is not complying with the safety-related work practices. (2) New technology, new types of equipment, or changes in procedures necessitate the use of safetyrelated work practices different from those that the employee would normally use. (3) The employee needs to review tasks that are performed less often than once per year. (4) The employee needs to review safety-related work practices not normally used by the employee during regular job duties. (5) The employee s job duties change. Statement of Problem and Substantiation for Public Comment Studies show that forget what we learn as time goes on, especially if the learning is not put into practice. Some studies indicate a majority of what is learned to be lost in as little as a few weeks. If not used regularly, most of what is learned will be forgotten long before 3 years. Reducing the frequency from 3 to 2 years will help people retain more of the learned information. Related Item First Revision No. 29-NFPA 70E-2015 [Sections 110.2(A), 110.2(B)] Submitter Information Verification Submitter Full Name: David Pace Organization: Olin Corporation Affilliation: Self Street Address: City: State: Zip: Submittal Date: Thu Mar 17 11:05:48 EDT 2016 Committee Statement Committee Action: Resolution: Rejected The three year retraining interval has been in the Standard for several cycles and coincides with the three year revision cycle of the standard. In accordance with 110.2(A)(3), retraining must occur more frequently if any of the listed conditions apply, including lack of worker compliance with the employer's safety related work practices.

75 1 of 403 9/2/2016 9:49 AM Public Comment No. 59-NFPA 70E-2016 [ Section No (A)(5) ] (5) Electrical Safety Training Documentation. The employer shall document that each employee has received the training required by 110.2(A). This documentation shall be in accordance with the following: (1) Be made when the employee demonstrates proficiency in the work practices involved (2) Be retained for the duration of the employee s employment (3) Contain the content of the training, each employee s name, qualifications of the trainer and dates of of the training Informational Note No. 1: Content of the training could include one or more of the following: course syllabus, course curriculum, outline, table of contents, or training objectives. Informational Note No. 2: Employment records that indicate that an employee has received the required training are an acceptable means of meeting this requirement. Statement of Problem and Substantiation for Public Comment There are literally thousands of people/companies out there that do electrical safety training. Some trainers are very knowledgeable and qualified to train, many are not. I ran into a case a month or so back where a small motor rewind shop near Atlanta had been hired to do training for a Steel Mill. They were offering their lead electrical technician, who had a copy of 70E and had read it, as the trainer. The Mill chose them because "its pretty cheep at $95 per student and only takes four hours. In a day we have all of our required Qualified Persons Training done and for a lot less money than using other people". Unless the trainer is qualified the training is useless and people will not know how to recognize hazards and/or protect themselves. The more I look into this problem, the more frightening it is how many cases like this are out there. This needs to be a requirement. Related Item First Revision No. 29-NFPA 70E-2015 [Sections 110.2(A), 110.2(B)] Submitter Information Verification Submitter Full Name: David Pace Organization: Olin Corporation Affilliation: Self Street Address: City: State: Zip: Submittal Date: Thu Mar 17 13:34:46 EDT 2016 Committee Statement Committee Action: Rejected Resolution: Documenting the qualifications of trainers is outside the scope of this requirement.

76 2 of 403 9/2/2016 9:49 AM Public Comment No. 96-NFPA 70E-2016 [ Section No (B)(1) ] (1) Initial Training. Employees that could be involved in or affected by the lockout/tagout procedures required by shall be trained in the following: (1) The lockout/tagout procedures (2) Their responsibility in the execution of the procedures Statement of Problem and Substantiation for Public Comment The word "could" is being deleted. Table of the NEC Style Manual indicates that "could" should not be used. Related Item First Revision No. 29-NFPA 70E-2015 [Sections 110.2(A), 110.2(B)] Submitter Information Verification Submitter Full Name: Palmer Hickman Organization: Electrical Training Alliance Street Address: City: State: Zip: Submittal Date: Wed Apr 20 13:33:21 EDT 2016 Committee Statement Committee Action: Accepted Resolution: SR-19-NFPA 70E-2016 Statement: The term "that could be" in this context was subjective and has been removed.

77 3 of 403 9/2/2016 9:49 AM Public Comment No. 60-NFPA 70E-2016 [ Section No (B)(2) ] (2) Retraining. Retraining in the lockout/tagout procedures shall be performed as follows: (1) When the procedures are revised (2) At intervals not to exceed 3 exceed 2 years (3) When supervision or annual inspections indicate that the employee is not complying with the lockout/tagout procedures Statement of Problem and Substantiation for Public Comment Studies show that forget what we learn as time goes on, especially if the learning is not put into practice. Some studies indicate a majority of what is learned to be lost in as little as a few weeks. If not used regularly, most of what is learned will be forgotten long before 3 years. Reducing the frequency from 3 to 2 years will help people retain more of the learned information. Related Item First Revision No. 29-NFPA 70E-2015 [Sections 110.2(A), 110.2(B)] Submitter Information Verification Submitter Full Name: David Pace Organization: Olin Corporation Affilliation: Self Street Address: City: State: Zip: Submittal Date: Thu Mar 17 13:49:05 EDT 2016 Committee Statement Committee Action: Resolution: Rejected The three year retraining interval has been in the Standard for several cycles. In accordance with 110.2(B)(3), retraining must occur more frequently if supervision or annual inspections indicate that workers are not complying with the lockout/tagout procedures. Additionally, the Standard does not prohibit an employer from performing retraining at more frequent intervals.

78 4 of 403 9/2/2016 9:49 AM Public Comment No. 107-NFPA 70E-2016 [ Section No (C)(1) ] (1) Contact Release. Employees responsible for the safe release of victims from contact with energized electrical conductors or circuit parts shall be trained in methods of safe release. Refresher training shall occur annually. Employees exposed to shock hazards shall be trained in methods of safe release of victims from contact with exposed energized electrical conductors or circuit parts. Refresher training shall occur annually. Statement of Problem and Substantiation for Public Comment This Public Comment is submitted by Daniel Roberts in behalf of the Canadian Standards Association (CSA) Z462 Workplace Electrical Safety Technical Committee. Errata: TerraView software inaccurately captured the revision of this section that was presented and agreed to at the TC meeting. The third and fourth sentences are redundant. This section should have been revised as shown. Related Item First Revision No. 35-NFPA 70E-2015 [Section No (C)] Public Input No. 535-NFPA 70E-2015 [Section No (C)(1)] Submitter Information Verification Submitter Full Name: Daniel Roberts Organization: Schneider Electric Affilliation: CSA Z462 Technical Committee Street Address: City: State: Zip: Submittal Date: Fri Apr 22 11:34:00 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-15-NFPA 70E-2016 Statement: The existing Section 110.2(C)(1) contained redundant text. The phrase "exposed to shock hazards and those " is added to the first sentence to permit the deletion of the redundant text.

79 5 of 403 9/2/2016 9:49 AM Public Comment No. 173-NFPA 70E-2016 [ Section No (C)(1) ] (1) Contact Release. Employees exposed to shock hazards or responsible for the safe release of victims from contact with energized electrical conductors or circuit parts shall be trained in methods of safe release. Refresher training shall occur annually. Employees exposed to shock hazards shall be trained in methods of safe release of victims from contact with exposed energized electrical conductors or circuit parts. Refresher training shall occur annually. Statement of Problem and Substantiation for Public Comment Adding the phrase "exposed to shock hazards" in the first sentence, permits deleting redundant text. Related Item First Revision No. 35-NFPA 70E-2015 [Section No (C)] Submitter Information Verification Submitter Full Name: Louis Barrios Organization: Shell Global Solutions Affilliation: American Petroleum Institute Street Address: City: State: Zip: Submittal Date: Fri May 13 15:13:55 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-15-NFPA 70E-2016 Statement: The existing Section 110.2(C)(1) contained redundant text. The phrase "exposed to shock hazards and those " is added to the first sentence to permit the deletion of the redundant text.

80 6 of 403 9/2/2016 9:49 AM Public Comment No. 41-NFPA 70E-2016 [ Section No (C)(1) ] See Statement for CC Note (1) Contact Release. Employees responsible for the safe release of victims from contact with energized electrical conductors or circuit parts shall be trained in methods of safe release. Refresher training shall occur annually. Employees exposed to shock hazards shall be trained in methods of safe release of victims from contact with exposed energized electrical conductors or circuit parts. Refresher training shall occur annually. Statement of Problem and Substantiation for Public Comment The Correlating Committee directs that 110.2(C)(1) be reviewed for clarity since the first two sentences appear to be repeated in sentence three and four with only minor changes. Related Item First Revision No. 35-NFPA 70E-2015 [Section No (C)] Submitter Information Verification Submitter Full Name: CC on NEC-AAC Organization: NFPA Street Address: City: State: Zip: Submittal Date: Mon Mar 14 15:49:38 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-15-NFPA 70E-2016 Statement: The existing Section 110.2(C)(1) contained redundant text. The phrase "exposed to shock hazards and those " is added to the first sentence to permit the deletion of the redundant text.

81 7 of 403 9/2/2016 9:49 AM Public Comment No. 208-NFPA 70E-2016 [ Section No (C)(2) ] (2) First Aid, Emergency Response, and Resuscitation. (a) Employees responsible for responding to medical emergencies shall be trained in first aid and emergency procedures. (b) Employees responsible for responding to medical emergencies shall be trained in cardiopulmonary resuscitation (CPR). (c) Employees responsible for responding to medical emergencies shall be trained in the use of an automated external defibrilator (AED) if an employer s emergency response plan includes the use of this device. (d) Refresher Recertification training shall occur at a frequency that satisfies the requirements of the certifying body. Informational Note: Employees responsible for responding to medical emergencies might not be first responders or medical professionals. Such employees could be a second person, a safety watch, or a craftsperson. Statement of Problem and Substantiation for Public Comment Requiring refresher training is not as protective as requiring recertification training. Related Item First Revision No. 35-NFPA 70E-2015 [Section No (C)] Submitter Information Verification Submitter Full Name: Sarah Amick Organization: Rubber Manufacturers Association Affilliation: Rubber Manufacturers Association Street Address: City: State: Zip: Submittal Date: Mon May 16 17:13:24 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-16-NFPA 70E-2016 Statement: Deleting the qualifier refresher before the activity training is consistent with the phrase used in the rest of the section and eliminates the need to specify the nature of the training, whether retraining, refresher or recertification.

82 8 of 403 9/2/2016 9:49 AM Public Comment No. 61-NFPA 70E-2016 [ Section No (C)(2) ] (2) First Aid, Emergency Response, and Resuscitation. (a) Employees responsible for responding to medical emergencies shall be trained in first aid and emergency procedures. (b) Employees responsible for responding to medical emergencies shall be trained in cardiopulmonary resuscitation (CPR). (c) Employees responsible for responding to medical emergencies shall be trained in the use of an automated external defibrilator (AED) if an employer s emergency response plan includes the use of this device. (d) Refresher training shall occur at a frequency that satisfies the requirements of the certifying body that establishes the frequency of the training, such as The Red Cross or The American Heart Association. Informational Note: Employees responsible for responding to medical emergencies might not be first responders or medical professionals. Such employees could be a second person, a safety watch, or a craftsperson. Statement of Problem and Substantiation for Public Comment The "certifying body" can be interpreted as many things including the occupational safety and health people at a company, or the training department at a company, etc. that would not involve the Red Cross or American Heart Association, which I believe to be the intent of the Committee. Adding the proposed text clarifies who the certifying body must be. Related Item First Revision No. 29-NFPA 70E-2015 [Sections 110.2(A), 110.2(B)] Submitter Information Verification Submitter Full Name: David Pace Organization: Olin Corporation Affilliation: Self Street Address: City: State: Zip: Submittal Date: Thu Mar 17 13:50:27 EDT 2016 Committee Statement Committee Action: Rejected Resolution: It is inappropriate to identify individual certifying bodies in the standard.

83 9 of 403 9/2/2016 9:49 AM Public Comment No. 7-NFPA 70E-2016 [ Section No (C)(2) ] (2) First Aid, Emergency Response, and Resuscitation. (a) Employees responsible for responding to medical emergencies shall be trained in first aid and emergency procedures. (b) Employees responsible for responding to medical emergencies shall be trained in cardiopulmonary resuscitation (CPR). (c) Employees responsible for responding to medical emergencies shall be trained in the use of an automated external defibrilator (AED) if an employer s emergency response plan includes the use of this device. (d) Refresher training shall occur at annually. Recertification shall occur at a frequency that satisfies the requirements of the certifying body. Informational Note: Employees responsible for responding to medical emergencies might not be first responders or medical professionals. Such employees could be a second person, a safety watch, or a craftsperson. Additional Proposed Changes File Name Description Approved ARC_CPR_2_.pdf American Red Cross recommendation LOI_CPR_2_.pdf OSHA Letter of Interpretation OSHA_CPR_2_.pdf OSHA Recommendation Statement of Problem and Substantiation for Public Comment Bring back the annual refresher language for CPR and AED use. The use of CPR and AED skills are infrequently performed tasks requiring practice to ensure proficiency. A skills refresher is a condensed version of the initial training conducted internally, it is not intended as a recertification. The removal of this requirement decreases safety. See attachments. Related Item First Revision No. 35-NFPA 70E-2015 [Section No (C)] Submitter Information Verification Submitter Full Name: Drake Drobnick Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Wed Feb 24 21:43:11 EST 2016 Committee Statement Committee Action: Rejected Resolution: Employers can choose to retrain more frequently than required by the certifying body.

84 0 of 403 9/2/2016 9:49 AM Public Comment No. 97-NFPA 70E-2016 [ Section No (C)(3) ] (3) Training Verification. Employers shall verify at least annually that employee training required by 110.2(C) is current. Statement of Problem and Substantiation for Public Comment At least annually may not be often enough to verify that the required training is current. Verification needs to be made before a worker is assigned to or be expected to act in the capacity. Related Item First Revision No. 35-NFPA 70E-2015 [Section No (C)] Submitter Information Verification Submitter Full Name: Palmer Hickman Organization: Electrical Training Alliance Street Address: City: State: Zip: Submittal Date: Wed Apr 20 13:53:01 EDT 2016 Committee Statement Committee Action: Resolution: Rejected Specifying a minimum frequency to verify training is current is an important criterion. It does not mean that the employer needs to wait until the certification lapses to verify that the certification is current.

85 1 of 403 9/2/2016 9:49 AM Public Comment No. 108-NFPA 70E-2016 [ Section No (E) ] (E) Operation Verification. When test instruments are used for testing, the absence of voltage on conductors or circuit parts operating at voltages equal to or greater than 50 Vac or 100 Vdc, the operation of the test instrument shall be verified on a known voltage source of the same frequency (ac or dc) before and after an absence of voltage test is performed. Informational Note: Verifying the operation of an auto ranging test instrument rated 1000 V or less can be done on a known voltage source operating at a voltage other than that of the conductors or circuit parts that will be tested for the absence of voltage. Statement of Problem and Substantiation for Public Comment This Public Comment is submitted by Daniel Roberts in behalf of the Canadian Standards Association (CSA) Z462 Workplace Electrical Safety Technical Committee. Errata: TerraView software inadvertently deleted the word a. Related Item First Revision No. 23-NFPA 70E-2015 [Section No ] Public Input No. 329-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: Daniel Roberts Organization: Schneider Electric Affilliation: CSA Z462 Technical Committee Street Address: City: State: Zip: Submittal Date: Fri Apr 22 11:43:14 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-24-NFPA 70E-2016 Statement: Establishing a voltage threshold of 100 Vdc in Chapter 1 conflicts with the OSHA regulations, such as (a)(1). The comma after the phrase used for testing is deleted for grammatical accuracy. The word any is inserted before the phrase known voltage source to clarify that the voltage source used to verify the operation of the test instrument is permitted to be different than that the conductors or circuit parts that will be tested for absence of voltage. The informational note is deleted as the addition of the word any to the requirement of 110.4(E) made the note redundant.

86 2 of 403 9/2/2016 9:49 AM Public Comment No. 176-NFPA 70E-2016 [ Section No (E) ] (E) Operation Verification. When test instruments are used for testing, the absence of voltage on conductors or circuit parts operating at voltages equal to or greater than 50 Vac or 100 Vdc, the operation of the test instrument shall be verified on known a known voltage source of the same frequency (ac or dc) before and after an absence of voltage test is performed. Informational Note: Verifying the operation of an auto ranging test instrument rated 1000 V or less can be done on a known voltage source operating at a voltage other than that of the conductors or circuit parts that will be tested for the absence of voltage. Statement of Problem and Substantiation for Public Comment The comma was deleted and "a" was added to improve grammar. The informational note is deleted because it is not necessary and may introduce additional confusion. The informational note indicates that verifying test instrument operation on a known voltage other than the voltage of the conductors and circuit parts to be verified is permitted for auto-ranging instruments rated 1000V or less (which sounds more like an exception). However, 110.4(E) does not require the test voltage to be the same as the voltage of the conductors to be verified. Therefore the informational note does not add additional clarification. To be more technically correct, test instruments rated greater than 1000V should be permitted to be verified on voltages other than the voltage of the conductors and circuits to be verified. Related Item First Revision No. 23-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: Louis Barrios Organization: Shell Global Solutions Affilliation: American Petroleum Institute Street Address: City: State: Zip: Submittal Date: Fri May 13 15:28:33 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-24-NFPA 70E-2016 Statement: Establishing a voltage threshold of 100 Vdc in Chapter 1 conflicts with the OSHA regulations, such as (a)(1). The comma after the phrase used for testing is deleted for grammatical accuracy. The word any is inserted before the phrase known voltage source to clarify that the voltage source used to verify the operation of the test instrument is permitted to be different than that the conductors or circuit parts that will be tested for absence of voltage. The informational note is deleted as the addition of the word any to the requirement of 110.4(E) made the note redundant.

87 3 of 403 9/2/2016 9:49 AM Public Comment No. 42-NFPA 70E-2016 [ Section No (E) ] See Statement for CC Note (E) Operation Verification. When test instruments are used for testing, the absence of voltage on conductors or circuit parts operating at voltages equal to or greater than 50 Vac or 100 Vdc, the operation of the test instrument shall be verified on known voltage source of the same frequency (ac or dc) before and after an absence of voltage test is performed. Informational Note: Verifying the operation of an auto ranging test instrument rated 1000 V or less can be done on a known voltage source operating at a voltage other than that of the conductors or circuit parts that will be tested for the absence of voltage. Statement of Problem and Substantiation for Public Comment The Correlating Committee directs the Committee to review Section 110.4(E) with regard to the proper use of the term frequency as noted in the affirmative ballot comments and with regard to punctuation and clarity. The committee is also directed to review 110.4(B)(2) and clarify what purpose the requirement applies. Section should also be reviewed in its entirety with regard to compliance with the Style Manual. Certain first level subdivisions are provided without any parent text. Related Item First Revision No. 23-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: CC on NEC-AAC Organization: NFPA Street Address: City: State: Zip: Submittal Date: Mon Mar 14 15:52:03 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-24-NFPA 70E-2016 Statement: Establishing a voltage threshold of 100 Vdc in Chapter 1 conflicts with the OSHA regulations, such as (a)(1). The comma after the phrase used for testing is deleted for grammatical accuracy. The word any is inserted before the phrase known voltage source to clarify that the voltage source used to verify the operation of the test instrument is permitted to be different than that the conductors or circuit parts that will be tested for absence of voltage. The informational note is deleted as the addition of the word any to the requirement of 110.4(E) made the note redundant.

88 4 of 403 9/2/2016 9:49 AM Public Comment No. 78-NFPA 70E-2016 [ Section No (E) ] (E) Operation Verification. When test instruments are used for testing, the absence of voltage on conductors or circuit parts operating at voltages equal to or greater than 50 Vac or 100 Vdc -volts, the operation of the test instrument shall be verified on known voltage source of the same frequency (ac or dc) before and after an absence of voltage test is performed. Informational Note: Verifying the operation of an auto ranging test instrument rated 1000 V or less can be done on a known voltage source operating at a voltage other than that of the conductors or circuit parts that will be tested for the absence of voltage. Statement of Problem and Substantiation for Public Comment OSHA 29 CFR 1910 Subpart S, etc. makes reference simply to 50-V (fifty volts). Neither AC (alternating current) or DC (direct current current) is specified in the federal regulations. The law is simply 50-V. By revising 2018 NFPA 70E to state '50VAC or 100VDC' puts user of this Standard into a citable posture with respect to OSHA. Simply put, by following the 2018 NFPA 70E as the proposed wording is written, one would be breaking the law since OSHA does not recognize 100VDC. Fifty volts means fifty volts. Period. NFPA 70E must not be in conflict with the law. Rather, the Standard needs to be in harmony with the law. And yes, the DC voltage table as it stands (100VDC) has been violation of the law for quite some time. To be in compliance with the law, this table should start at 50VDC and not 100VDC. Related Item Public Input No. 4-NFPA 70E-2015 [Section No (C)(15)(A)] Submitter Information Verification Submitter Full Name: Steven Schuette Organization: Global Risk Consultants Street Address: City: State: Zip: Submittal Date: Wed Mar 23 15:56:34 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-24-NFPA 70E-2016 Statement: Establishing a voltage threshold of 100 Vdc in Chapter 1 conflicts with the OSHA regulations, such as (a)(1). The comma after the phrase used for testing is deleted for grammatical accuracy. The word any is inserted before the phrase known voltage source to clarify that the voltage source used to verify the operation of the test instrument is permitted to be different than that the conductors or circuit parts that will be tested for absence of voltage. The informational note is deleted as the addition of the word any to the requirement of 110.4(E) made the note redundant.

89 5 of 403 9/2/2016 9:49 AM Public Comment No. 85-NFPA 70E-2016 [ Section No (E) ] (E) Operation Verification. When test instruments are used for testing, the absence of voltage on conductors or circuit parts operating at voltages equal to or greater than 50 Vac or 100 Vdc, the operation of the test instrument shall be verified on known voltage source of the same frequency (ac or dc) before and after an absence of voltage test is performed. Informational Note: Verifying the operation of an auto ranging test instrument rated 1000 V or less can be done on a known voltage source operating at a voltage other than that of the conductors or circuit parts that will be tested for the absence of voltage. Statement of Problem and Substantiation for Public Comment No technical substantiation was provided in any PI or the FR for requiring a test instrument to be verified at the same frequency. Related Item First Revision No. 23-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: James Dollard Organization: IBEW Local Union 98 Street Address: City: State: Zip: Submittal Date: Tue Apr 12 15:13:22 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-24-NFPA 70E-2016 Statement: Establishing a voltage threshold of 100 Vdc in Chapter 1 conflicts with the OSHA regulations, such as (a)(1). The comma after the phrase used for testing is deleted for grammatical accuracy. The word any is inserted before the phrase known voltage source to clarify that the voltage source used to verify the operation of the test instrument is permitted to be different than that the conductors or circuit parts that will be tested for absence of voltage. The informational note is deleted as the addition of the word any to the requirement of 110.4(E) made the note redundant.

90 6 of 403 9/2/2016 9:49 AM Public Comment No. 17-NFPA 70E-2016 [ Section No ] Ground-Fault Circuit-Interrupter (GFCI) Protection. (A) General. Employees shall be provided with ground-fault circuit-interrupter (GFCI) protection where required by applicable state, federal, or local codes and standards. Listed cord sets or devices incorporating listed GFCI protection for personnel identified for portable use shall be permitted. (B) Maintenance and Construction. GFCI protection shall be provided where an employee is operating or using cord sets (extension cords) or cord- and plug-connected tools related to maintenance and construction activity supplied by 125-volt, 15-, 20-, or 30-ampere circuits. Where employees operate or use equipment supplied by greater than 125-volt, 15-, 20-, or 30-ampere circuits, GFCI protection or an assured equipment grounding conductor program shall be implemented. Exception: Where GFCI protection rated for the application does not exist, a listed special purpose ground-fault circuit-interrupter (SPGFCI) shall be permitted to be used. (C) Outdoors. GFCI protection shall be provided when an employee is outdoors and operating or using cord sets (extension cords) or cord- and plug-connected equipment supplied by 125-volt, 15-, 20-, or 30-ampere circuits. Where employees working outdoors operate or use equipment supplied by greater than 125-volt, 15-, 20-, or 30-ampere circuits, GFCI protection or an assured equipment grounding conductor program shall be implemented. Exception: Where GFCI protection rated for the application does not exist, a listed SPGFCI shall be permitted to be used. (D) Testing Ground-Fault Circuit-Interrupter Protection Devices. GFCI and SPGFCI protection devices shall be tested in accordance with the manufacturer s instructions. Statement of Problem and Substantiation for Public Comment EXCEPTION: In industrial establishments only, where conditions of maintenance and supervision ensure that only qualified personnel are involved, and Assured Equipment Grounding Conductor Program (AEGCP) as specified in 110.4(C) shall be permitted for only those receptacle outlets used to supply equipment that would create a greater hazard if power were interrupted or having a design that is not compatible with GFCI protection. INFORMATIONAL NOTE: The AEGCP shall be implemented according to NFPA 70, NEC Article 590.6(B)(2). Related Public Comments for This Document Related Comment Public Comment No. 14-NFPA 70E-2016 [New Definition after Definition: Ground Fault.] Related Item Relationship additional information is needed First Revision No. 28-NFPA 70E-2015 [New Definition after Definition: Ground-Fault Circuit Inter...] Submitter Information Verification Submitter Full Name: George Cole Organization: Aps Palo Verde Nuclear Gen Sta Street Address: City:

91 7 of 403 9/2/2016 9:49 AM State: Zip: Submittal Date: Thu Feb 25 17:00:44 EST 2016 Committee Statement Committee Action: Resolution: Rejected An exception that permits the use of an assured equipment grounding conductor program is unnecessary as Section 110.6(B) and (C) already permits the use of an assured equipment grounding conductor program.

92 8 of 403 9/2/2016 9:49 AM Public Comment No. 134-NFPA 70E-2016 [ Section No (B) ] (B) Maintenance and Construction. GFCI protection shall be provided where an employee is operating or using cord sets (extension cords) or cord- and plug-connected tools related to maintenance and construction activity supplied by 125-volt, 15-, 20-, or 30-ampere circuits. Where employees operate or use equipment supplied by greater than 125-volt, 15-, 20-, or 30-ampere circuits, GFCI protection or an assured equipment grounding conductor program shall be implemented. Exception: Where GFCI protection rated for the application does not exist, a listed special purpose ground-fault circuit-interrupter (SPGFCI) shall be permitted to be used. Additional Proposed Changes File Name Description Approved 70E_2018_Comment_to_FR_23_Delete_the_exception_for_SPGFCI.docx Statement of Problem and Substantiation for Public Comment See attached file Related Item First Revision No. 23-NFPA 70E-2015 [Section No ] Submitter Information Verification Delete the Exception permitting use of SPGFCI Submitter Full Name: Daleep Mohla Organization: DCM Electrical Consulting Serv Street Address: City: State: Zip: Submittal Date: Tue Apr 26 20:48:55 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-20-NFPA 70E-2016 Statement: The exception was deleted because a Special Purpose Ground Fault Circuit Interrupter does not provide the same level of protection as a Class A GFCI. The informational note points to use of Special Purpose Ground Fault Circuit Interrupters in Informative Annex O indicating that this could supplement the current provision for an assured equipment grounding conductor program.

93 Delete the exception permitting use of SPGFCI for personnel protection As both Type A and Type C,D, and E are termed GFCI for personnel protection, users may not realize the difference in protection provided by Type A ( GFCI) and Type C,D, and E ( SPGFCI). Type C,D, and E have special installation instructions that may not be clear to users. For example the SPGFCI requires a laarger equipment grounding conductor to provide protection Recognizing the installation concerns NEC CMP-2 created 2017-NEC second revisions that deleted the references to the Special Purpose GFCI in Art Their reasons had to do with special installation requirements for these GFCIs (Class C, D and E) that may not be apparent to the installer or user. Type A provides both ventricular fibrillation and let go protection with no and special enhancements. Type C, D and E, may or may not provide let go protection Type C, can only to be used where voltage to ground is greater than 150 Voltsbut does not exceed 300 volts to ground and requires a low impedance equipment grounding conductor or double insulation. Class D can only be used with one or more conductors over 300 volts to ground, and with specially sized, reliable grounding, to provide a low impedance path so that the voltage across the body during a fault does not exceed 150 volts. Even though these stipulations and conditions are mentioned in UL 943C, but it may be readily accessible to every user. The following details should be added in 70E to advise users on key requirements and conditions of use of such devices. This covers ground-fault circuit-interrupters intended for use in one of the following applications: a) Where the voltage to ground is greater than 150 volts and equipment grounding or double insulation is required by the National Electrical Code, ANSI/NFPA 70 CLASS C GROUND-FAULT CIRCUIT-INTERRUPTER A ground-fault circuit-interrupter that is intended to be used in circuits with no conductor over 300 V AC to ground where reliable equipment grounding or double insulation is provided. CLASS D GROUND-FAULT CIRCUIT-INTERRUPTER A ground-fault circuit-interrupter that is intended to be used in circuits with one or more conductors over 300 volts to ground, and with specially sized, reliable grounding, to provide a low impedance path so that the voltage across the body during a fault does not exceed 150 volts. 2 CLASS E GROUND-FAULT CIRCUIT-INTERRUPTER A ground-fault circuit-interrupter that is intended to be used in circuits with one or more conductors over 300 volts to ground but with conventional equipment grounding provided for the protected equipment in the system or double insulation. These ground-fault circuit-interrupters respond rapidly to open the circuit before the magnitude and duration of the current flowing through the person s body exceeds the limits for ventricular fibrillation. Informational Note:, 1. 1Classes C, D, and E ground-fault circuit interrupters trip when the current to ground is 20 ma or higher and do not trip when the leakage current to ground is less than 15 ma. For further information, see UL 943C, Outline of Investigation for Special Purpose Ground-Fault Circuit Interrupters 2. Class C devices provide ventricular fibrillation protection and may not provide let go protection 3. For Class D devices The grounding conductor may need to be a larger gauge than would normally be selected in order to provide protection to personnel in event of a ground-fault. Rationale: Using the same term as GFCI used for class A devices without an adequate explanation to users may result in incorrect application. The additional language proposed was extracted from UL 943C.

94 9 of 403 9/2/2016 9:49 AM Public Comment No. 162-NFPA 70E-2016 [ Sections 110.6(B), 110.6(C), 110.6(D) ] Sections 110.6(B), 110.6(C), 110.6(D) (B) Maintenance and Construction. GFCI protection shall be provided where an employee is operating or using cord sets (extension cords) or cord- and plug-connected tools related to maintenance and construction activity supplied by 125-volt, 15-, 20-, or 30-ampere circuits. Where employees operate or use equipment supplied by greater than 125-volt, 15-, 20-, or 30-ampere circuits, GFCI protection or an assured equipment grounding conductor program shall be implemented. Exception: Where GFCI protection rated for the application does not exist, a listed special purpose ground-fault circuit-interrupter ( SPGFCI) shall be permitted to be used. ( C) Outdoors. GFCI protection shall be provided when an employee is outdoors and operating or using cord sets (extension cords) or cord- and plug-connected equipment supplied by 125-volt, 15-, 20-, or 30-ampere circuits. Where employees working outdoors operate or use equipment supplied by greater than 125-volt, 15-, 20-, or 30-ampere circuits, GFCI protection or an assured equipment grounding conductor program shall be implemented. Exception: Where GFCI protection rated for the application does not exist, a listed SPGFCI shall be permitted to be used. (D) Testing Ground-Fault Circuit-Interrupter Protection Devices. GFCI and SPGFCI protection devices shall be tested in accordance with the manufacturer s instructions. Statement of Problem and Substantiation for Public Comment SPGFCI devices are listed to UL 943C - Outline of Investigation for Special Purpose Ground-Fault Circuit- Interrupters. According to UL 943C, in applications where the voltage to ground exceeds 150 volts but does not exceed 300 volts, a Class C SPGFCI is to be used. In applications where the voltage to ground exceeds 300 volts, a Class D SPGFCI may be used if an oversized equipment grounding conductor is installed. If an oversized equipment grounding conductor is not installed, a Class E SPGFCI is to be used. These requirements are not mentioned in the new exceptions, creating the possibility of these devices being misapplied. In order to avoid potential confusion with Class A GFCI protection, the committee should mention SPGFCI devices in Annex O instead of as an exception in Suggested language as follows and is being submitted as a seperate public comment: "O.2.4(13) Class C, D, and E special purpose ground fault circuit interrupters exist for circuits operating at voltages outside the range for Class A GFCI protection. See UL 943C for additional information." The definition for SPGFCI should also be removed. Related Item First Revision No. 23-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: Rodney West Organization: Schneider Electric USA Street Address: City: State: Zip: Submittal Date: Thu May 12 10:46:18 EDT 2016

95 0 of 403 9/2/2016 9:49 AM Committee Statement Committee Rejected but see related SR Action: Resolution: SR-20-NFPA 70E-2016 Statement: The exception was deleted because a Special Purpose Ground Fault Circuit Interrupter does not provide the same level of protection as a Class A GFCI. The informational note points to use of Special Purpose Ground Fault Circuit Interrupters in Informative Annex O indicating that this could supplement the current provision for an assured equipment grounding conductor program.

96 1 of 403 9/2/2016 9:49 AM Public Comment No. 62-NFPA 70E-2016 [ Sections 110.6(B), 110.6(C), 110.6(D) ] Sections 110.6(B), 110.6(C), 110.6(D) (B) Maintenance and Construction. GFCI protection shall be provided where an employee is operating or using cord sets (extension cords) or cord- and plug-connected tools related to maintenance and construction activity supplied by 125-volt, 15-, 20-, or 30-ampere circuits. Where employees operate or use equipment supplied by greater than 125-volt, 15-, 20-, or 30-ampere circuits, GFCI protection or an assured equipment grounding conductor program shall be implemented. Exception: Where GFCI protection rated for the application does not exist, a listed special purpose ground-fault circuit-interrupter ( SPGFCI) shall be permitted to be used. ( C) Outdoors. GFCI protection shall be provided when an employee is outdoors and operating or using cord sets (extension cords) or cord- and plug-connected equipment supplied by 125-volt, 15-, 20-, or 30-ampere circuits. Where employees working outdoors operate or use equipment supplied by greater than 125-volt, 15-, 20-, or 30-ampere circuits, GFCI protection or an assured equipment grounding conductor program shall be implemented. Exception: Where GFCI protection rated for the application does not exist, a listed SPGFCI shall be permitted to be used. (D) Testing Ground-Fault Circuit-Interrupter Protection Devices. GFCI and SPGFCI protection devices shall be tested in accordance with the manufacturer s instructions. Statement of Problem and Substantiation for Public Comment The definition and all other text relating to SPGFCI devices should be deleted from the standard. Allowing ground fault protection for personnel through the use of two devices with very different levels of protection will not be understood or applied correctly by the majority of the readers of this document. The reader will be left with the question of whether or not the "unsafe" current level is 4 to 6 ma or 15 to 20 ma. If a Class A GFCI device is not available, protection should be provided using an assured equipment grounding conductor program as stated in the existing text. If added, the SPGFCI will cause confusion and will certainly create a potential unsafe condition. Related Item First Revision No. 23-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: David Pace Organization: Olin Corporation Affilliation: Self Street Address: City: State: Zip: Submittal Date: Thu Mar 17 13:59:55 EDT 2016 Committee Statement Committee Rejected but see related SR

97 2 of 403 9/2/2016 9:49 AM Action: Resolution: SR-20-NFPA 70E-2016 Statement: The exception was deleted because a Special Purpose Ground Fault Circuit Interrupter does not provide the same level of protection as a Class A GFCI. The informational note points to use of Special Purpose Ground Fault Circuit Interrupters in Informative Annex O indicating that this could supplement the current provision for an assured equipment grounding conductor program.

98 3 of 403 9/2/2016 9:49 AM Public Comment No. 197-NFPA 70E-2016 [ New Section after ] Use of Equipment Instructions. Listed or labeled equipment shall be used in accordance with any instructions included in the listing or labeling. Statement of Problem and Substantiation for Public Comment The instructions for listed and labeled equipment needs to be mandatory in NFPA 70E just as it is in 110.3(B) of the NEC. Chapter 2 contains requirements for instructions. Related Item Public Input No. 200-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: Paul Dobrowsky Organization: Innovative Technology Services Street Address: City: State: Zip: Submittal Date: Mon May 16 10:37:24 EDT 2016 Committee Statement Committee Action: Resolution: Rejected A requirement to use test instruments and equipment in accordance with manufacturer s instructions is addressed by Section 110.4(B)(3). A similar requirement for portable cord- and-plugconnected electric equipment and is already addressed in 110.5(F) and a requirement to test GFCI s is already addressed in 110.6(D).

99 4 of 403 9/2/2016 9:49 AM Public Comment No. 63-NFPA 70E-2016 [ Section No ] Overcurrent Protection Modification. Overcurrent protection of circuits and conductors shall not be modified, even on a temporary basis, beyond what is permitted by applicable portions of electrical codes and standards dealing with overcurrent protection. Informational Note: For further information concerning electrical codes and standards dealing with overcurrent protection, refer to Article 240 of NFPA 70, National Electrical Code. Statement of Problem and Substantiation for Public Comment The National Electrical Code and the NEC are so common that most people don't know it by NFPA 70. The words should stay in the standard. Related Item First Revision No. 23-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: David Pace Organization: Olin Corporation Affilliation: Self Street Address: City: State: Zip: Submittal Date: Thu Mar 17 14:01:44 EDT 2016 Committee Statement Committee Accepted Action: Resolution: SR-21-NFPA 70E-2016 Statement: The title "National Electrical Code" is restored to the informational note in accordance with NEC style manual

100 5 of 403 9/2/2016 9:49 AM Public Comment No. 158-NFPA 70E-2016 [ Article 120 ] Article 120 Establishing an Electrically Safe Work Condition Lockout/Tagout Program. (A) General. Each employer shall establish, document, and implement a lockout/tagout program. The lockout/tagout program shall specify lockout/tagout procedures to safeguard workers from exposure to electrical hazards. The lockout/tagout program and procedures shall also incorporate the following: (1) Be appropriate for the experience and training of the workers and conditions as they exist in the workplace (2) Meet the requirements of Article 120 (3) Apply to fixed, permanently installed equipment, temporarily installed equipment, and portable equipment

101 6 of 403 9/2/2016 9:49 AM (B) Employer Responsibilities. The employer shall be responsible for the following: (1) Providing the equipment necessary to execute lockout/tagout procedures (2) Providing lockout/tagout training to workers in accordance with (3) Auditing the lockout/tagout program in accordance with (4) Auditing execution of the lockout/tagout procedures in accordance with Informational Note: For an example of a lockout/tagout program, see Informative Annex G. (B) Elements of Control. The program shall identify elements of control. (8) Shift Change. A method shall be identified in the program to transfer responsibility for lockout/tagout to another person or to the person in charge when the job or task extends beyond one shift. (9) Coordination. The program shall establish how coordination is accomplished with other jobs or tasks in progress, including related jobs or tasks at remote locations, including the person responsible for coordination. (10) Accountability for Personnel. A method shall be identified in the program to account for all persons who could be exposed to hazardous energy during the lockout/tagout. (11) Lockout/Tagout Application. The program shall clearly identify when and where lockout applies, in addition to when and where tagout applies, and shall address the following: (1) Lockout shall be defined as installing a lockout device on all sources of hazardous energy such that operation of the disconnecting means is prohibited and forcible removal of the lock is required to operate the disconnecting means. (2) Tagout shall be defined as installing a tagout device on all sources of hazardous energy, such that operation of the disconnecting means is prohibited. The tagout device shall be installed in the same position available for the lockout device. (3) Where it is not possible to attach a lock to existing disconnecting means, the disconnecting means shall not be used as the only means to put the circuit in an electrically safe work condition. (4) The use of tagout procedures without a lock shall be permitted only in cases where equipment design precludes the installation of a lock on an energy isolation device(s). When tagout is employed, at least one additional safety measure shall be employed. In such cases, the procedure shall clearly establish responsibilities and accountability for each person who might be exposed to electrical hazards. Informational Note: Examples of additional safety measures include the removal of an isolating circuit element such as fuses, blocking of the controlling switch, or opening an extra disconnecting device to reduce the likelihood of inadvertent energization. (12) Removal of Lockout/Tagout Devices. The program shall identify the details for removing locks or tags when the installing individual is unavailable. When locks or tags are removed by someone other than the installer, the employer shall attempt to locate that person prior to removing the lock or tag. When the lock or tag is removed because the installer is unavailable, the installer shall be informed prior to returning to work.

102 7 of 403 9/2/2016 9:49 AM Lockout/Tagout Principles. (A) General. Electrical conductors and circuit parts shall not be considered to be in an electrically safe work condition until all of the requirements of Article 120 have been met. Informational Note: See for the steps to establish and verify an electrically safe work condition. Safe work practices appropriate for the circuit voltage and energy level shall be used in accordance with Article 130 until such time that electrical conductors and circuit parts are in an electrically safety work condition. (B) Employee Involvement. Each person who could be exposed directly or indirectly to a source of electrical energy shall be involved in the lockout/tagout process. Informational Note: An example of direct exposure is the qualified electrician who works on the motor starter control, the power circuits, or the motor. An example of indirect exposure is the person who works on the coupling between the motor and compressor. (C) Lockout/Tagout Procedure. A lockout/tagout procedure shall be developed on the basis of the existing electrical equipment and system and shall use suitable documentation including up-to-date drawings and diagrams. (D) Control of Energy. All sources of electrical energy shall be controlled in such a way as to minimize employee exposure to electrical hazards. (E) Electrical Circuit Interlocks. Suitable documentation, including up-to-date drawings and diagrams, shall be consulted to ensure that no electrical circuit interlock operation can result in reenergizing the circuit being worked on. (F) Control Devices. Locks/tags shall be installed only on circuit disconnecting means. Control devices, such as push-buttons or selector switches, shall not be used as the primary isolating device. (E) Identification. The lockout/tagout device shall be unique and readily identifiable as a lockout/tagout device. (F) Voltage. Voltage shall be removed and absence of voltage verified. (G) Coordination. (1) The established electrical lockout/tagout procedure shall be coordinated with all other employer s procedures for control of exposure to electrical energy sources such that all employer s procedural requirements are adequately addressed on a site basis. (2) The procedure for control of exposure to electrical hazards shall be coordinated with other procedures for control of other hazardous energy sources such that they are based on similar/identical concepts. (3) The electrical lockout/tagout procedure shall always include voltage testing requirements where there might be direct exposure to electrical hazards. (4) Electrical lockout/tagout devices shall be permitted to be similar to lockout/tagout devices for control of other hazardous energy sources, such as pneumatic, hydraulic, thermal, and mechanical, if such devices are used only for control of hazardous energy and for no other purpose. (H) Forms of Control of Hazardous Electrical Energy.

103 8 of 403 9/2/2016 9:49 AM Two forms of hazardous electrical energy control shall be permitted: simple lockout/tagout and complex lockout/tagout [see 120.3]. For the simple lockout/tagout, the qualified person shall be in charge. For the complex lockout/tagout, the person in charge shall have overall responsibility. (1) Simple Lockout/Tagout Procedure. All lockout/tagout procedures that involve only a qualified person(s) de-energizing one set of conductors or circuit part source for the sole purpose of safeguarding employees from exposure to electrical hazards shall be considered to be a simple lockout/tagout. Simple lockout/tagout procedures shall not be required to be written for each application. Each worker shall be responsible for his or her own lockout/tagout. Exception: Lockout/tagout is not required for work on cord-and plug-connected equipment for which exposure to the hazards of unexpected energization of the equipment is controlled by the unplugging of the equipment from the energy source, provided that the plug is under the exclusive control of the employee performing the servicing and maintenance for the duration of the work. (2) Complex Lockout/Tagout Procedure. (a) A complex lockout/tagout procedure shall be permitted where one or more of the following exist: (2) Multiple energy sources (3) Multiple crews (4) Multiple crafts (5) Multiple locations (6) Multiple employers (7) Multiple disconnecting means (8) Particular sequences (9) Job or task that continues for more than one work period (j) All complex lockout/tagout procedures shall require a written plan of execution that identifies the person in charge. (k) The complex lockout/tagout procedure shall vest primary responsibility in an authorized employee for employees working under the protection of a group lockout or tagout device, such as an operation lock or lockbox. The person in charge shall be held accountable for safe execution of the complex lockout/tagout. (l) Each authorized employee shall affix a personal lockout or tagout device to the group lockout device, group lockbox, or comparable mechanism when he or she begins work and shall remove those devices when he or she stops working on the machine or equipment being serviced or maintained. (m) All complex lockout/tagout plans shall identify the method to account for all persons who might be exposed to electrical hazards in the course of the lockout/tagout Lockout/Tagout Equipment. (A) Lock Application. Energy isolation devices for machinery or equipment installed after January 2, 1990, shall be capable of accepting a lockout device. (B) Lockout/Tagout Device. Each employer shall supply, and employees shall use, lockout/tagout devices and equipment necessary to execute the requirements of Locks and tags used for control of exposure to electrical hazards shall be unique, shall be readily identifiable as lockout/tagout devices, and shall be used for no other purpose. (C) Lockout Device. (1) A lockout device shall include a lock either keyed or combination.

104 9 of 403 9/2/2016 9:49 AM (2) The lockout device shall include a method of identifying the individual who installed the lockout device. (3) A lockout device shall be permitted to be only a lock, if the lock is readily identifiable as a lockout device, in addition to having a means of identifying the person who installed the lock. (4) Lockout devices shall be attached to prevent operation of the disconnecting means without resorting to un-due force or the use of tools. (5) Where a tag is used in conjunction with a lockout device, the tag shall contain a statement prohibiting unauthorized operation of the disconnecting means or unauthorized removal of the device. (6) Lockout devices shall be suitable for the environment and for the duration of the lockout. (7) Whether keyed or combination locks are used, the key or combination shall remain in the possession of the individual installing the lock or the person in charge, when provided by the established procedure. (D) Tagout Device. (1) A tagout device shall include a tag together with an attachment means. (2) The tagout device shall be readily identifiable as a tagout device and suitable for the environment and duration of the tagout. (3) A tagout device attachment means shall be capable of withstanding at least N (50 lb) of force exerted at a right angle to the disconnecting means surface. The tag attachment means shall be nonreusable, attachable by hand, self-locking, nonreleasable, and equal to an all-environmental tolerant nylon cable tie. (4) Tags shall contain a statement prohibiting unauthorized operation of the disconnecting means or removal of the tag. (5) A hold card tagging tool on an overhead conductor in conjunction with a hotline tool to install the tagout device safely on a disconnect that is isolated from the work(s) shall be permitted. Where a hold card is used, the tagout procedure shall include the method of accounting for personnel who are working under the protection of the hold card. (E) Electrical Circuit Interlocks. Suitable documentation, including up-to-date drawings and diagrams, shall be consulted to ensure that no electrical circuit interlock operation can result in reenergizing the circuit being worked on. (F) Control Devices. Locks/tags shall be installed only on circuit disconnecting means. Control devices, such as push-buttons or selector switches, shall not be used as the primary isolating device Lockout/Tagout Procedures. The employer shall maintain a copy of the procedures required by this section and shall make the procedures available to all employees. (A) Planning. The procedure shall require planning, including the requirements of 120.4(A)(1) through 120.4(B)(14).

105 0 of 403 9/2/2016 9:49 AM (1) Locating Sources. Up-to-date single-line drawings shall be considered a primary reference source for such information. When up-to-date drawings are not available, the employer shall be responsible for ensuring that an equally effective means of locating all sources of energy is employed. (2) Exposed Persons. The plan shall identify persons who might be exposed to an electrical hazard and the PPE required during the execution of the job or task. (3) Person In Charge. The plan shall identify the person in charge and his or her responsibility in the lockout/tagout. 4 ( 1 ) Simple Lockout/Tagout Procedure. All lockout/tagout procedures that involve only a qualified person(s) de-energizing one set of conductors or circuit part source for the sole purpose of safeguarding employees from exposure to electrical hazards shall be considered to be a simple lockout/tagout. Simple lockout/tagout procedures shall be in accordance with 120.2(H)(1). (5) Complex Lockout/Tagout. Complex lockout/tagout procedures shall be in accordance with 120.2(H)(2). (B) not be required to be written for each application. Each worker shall be responsible for his or her own lockout/tagout. Exception: Lockout/tagout is not required for work on cord-and plug-connected equipment for which exposure to the hazards of unexpected energization of the equipment is controlled by the unplugging of the equipment from the energy source, provided that the plug is under the exclusive control of the employee performing the servicing and maintenance for the duration of the work. (2) Complex Lockout/Tagout Procedure. (a) A complex lockout/tagout procedure shall be permitted where one or more of the following exist: (2) Multiple energy sources (3) Multiple crews (4) Multiple crafts (5) Multiple locations (6) Multiple employers (7) Multiple disconnecting means (8) Particular sequences (9) Job or task that continues for more than one work period (j) All complex lockout/tagout procedures shall require a written plan of execution that identifies the person in charge. (k) The complex lockout/tagout procedure shall vest primary responsibility in an authorized employee for employees working under the protection of a group lockout or tagout device, such as an operation lock or lockbox. The person in charge shall be held accountable for safe execution of the complex lockout/tagout. (l) Each authorized employee shall affix a personal lockout or tagout device to the group lockout device, group lockbox, or comparable mechanism when he or she begins work and shall remove those devices when he or she stops working on the machine or equipment being serviced or maintained. (m) All complex lockout/tagout plans shall identify the method to account for all persons who might be exposed to electrical hazards in the course of the lockout/tagout.

106 1 of 403 9/2/2016 9:49 AM (B) Elements of Control. The procedure shall identify elements of control. (1) De-energizing Equipment (Shutdown). The procedure shall establish the person who performs the switching and where and how to de-energize the load. (2) Stored Energy. The procedure shall include requirements for releasing stored electric or mechanical energy that might endanger personnel. All capacitors shall be discharged, and high-capacitance elements shall also be shortcircuited and grounded before the associated equipment is touched or worked on. Springs shall be released or physical restraint shall be applied when necessary to immobilize mechanical equipment and pneumatic and hydraulic pressure reservoirs. Other sources of stored energy shall be blocked or otherwise relieved. (3) Disconnecting Means. The procedure shall identify how to verify that the circuit is de-energized (open). (4) Responsibility. The procedure shall identify the person who is responsible for verifying that the lockout/tagout procedure is implemented and who is responsible for ensuring that the task is completed prior to removing locks/tags. A mechanism to accomplish lockout/tagout for multiple (complex) jobs/tasks where required, including the person responsible for coordination, shall be included. (5) Verification. The procedure shall verify that equipment cannot be restarted. The equipment operating controls, such as push-buttons, selector switches, and electrical interlocks, shall be operated or otherwise it shall be verified that the equipment cannot be restarted. (6) Testing. The procedure shall establish the following: (1) Test instrument to be used, the required PPE, and the person who will use it to verify proper operation of the test instrument on a known voltage source before and after use (2) Requirement to define the boundary of the electrically safe work condition (3) Requirement to test before touching every exposed conductor or circuit part(s) within the defined boundary of the work area (4) Requirement to retest for absence of voltage when circuit conditions change or when the job location has been left unattended (5) Planning considerations that include methods of verification where there is no accessible exposed point to take voltage measurements (7) Grounding. Grounding requirements for the circuit shall be established, including whether the temporary protective grounding equipment shall be installed for the duration of the task or is temporarily established by the procedure. Grounding needs or requirements shall be permitted to be covered in other work rules and might not be part of the lockout/tagout procedure. ( 8) Shift Change. A method shall be identified in the procedure to transfer responsibility for lockout/tagout to another person or to the person in charge when the job or task extends beyond one shift. (9) Coordination. The procedure shall establish how coordination is accomplished with other jobs or tasks in progress, including related jobs or tasks at remote locations, including the person responsible for coordination.

107 2 of 403 9/2/2016 9:49 AM (10) Accountability for Personnel. A method shall be identified in the procedure to account for all persons who could be exposed to hazardous energy during the lockout/tagout. (11) Lockout/Tagout Application. The procedure shall clearly identify when and where lockout applies, in addition to when and where tagout applies, and shall address the following: (1) Lockout shall be defined as installing a lockout device on all sources of hazardous energy such that operation of the disconnecting means is prohibited and forcible removal of the lock is required to operate the disconnecting means. (2) Tagout shall be defined as installing a tagout device on all sources of hazardous energy, such that operation of the disconnecting means is prohibited. The tagout device shall be installed in the same position available for the lockout device. (3) Where it is not possible to attach a lock to existing disconnecting means, the disconnecting means shall not be used as the only means to put the circuit in an electrically safe work condition. (4) The use of tagout procedures without a lock shall be permitted only in cases where equipment design precludes the installation of a lock on an energy isolation device(s). When tagout is employed, at least one additional safety measure shall be employed. In such cases, the procedure shall clearly establish responsibilities and accountability for each person who might be exposed to electrical hazards. Informational Note: Examples of additional safety measures include the removal of an isolating circuit element such as fuses, blocking of the controlling switch, or opening an extra disconnecting device to reduce the likelihood of inadvertent energization. (12) Removal of Lockout/Tagout Devices. The procedure shall identify the details for removing locks or tags when the installing individual is unavailable. When locks or tags are removed by someone other than the installer, the employer shall attempt to locate that person prior to removing the lock or tag. When the lock or tag is removed because the installer is unavailable, the installer shall be informed prior to returning to work. ( 13) Release for Return to Service. The procedure shall identify steps to be taken when the job or task requiring lockout/tagout is completed. Before electric circuits or equipment are reenergized, appropriate tests and visual inspections shall be conducted to verify that all tools, mechanical restraints and electrical jumpers, short circuits, and temporary protective grounding equipment have been removed, so that the circuits and equipment are in a condition to be safely energized. Where appropriate, the employees responsible for operating the machines or process shall be notified when circuits and equipment are ready to be energized, and such employees shall provide assistance as necessary to safely energize the circuits and equipment. The procedure shall contain a statement requiring the area to be inspected to ensure that nonessential items have been removed. One such step shall ensure that all personnel are clear of exposure to dangerous conditions resulting from reenergizing the service and that blocked mechanical equipment or grounded equipment is cleared and prepared for return to service. (14) Temporary Release for Testing/Positioning. The procedure shall clearly identify the steps and qualified persons responsibilities when the job or task requiring lockout/tagout is to be interrupted temporarily for testing or positioning of equipment; then the steps shall be identical to the steps for return to service. Informational Note: See for requirements when using test instruments and equipment.

108 3 of 403 9/2/2016 9:49 AM Elements of Establishing and Verifying an Electrically Safe Work Condition. Establishing and verifying an electrically safe work condition shall include all of the following steps, which shall be performed in the order presented, if feasible: (1) Determine all possible sources of electrical supply to the specific equipment. Check applicable up-to-date drawings, diagrams, and identification tags. (2) After properly interrupting the load current, open the disconnecting device(s) for each source. (3) Wherever possible, visually verify that all blades of the disconnecting devices are fully open or that drawout-type circuit breakers are withdrawn to the fully disconnected position. (4) Release stored electrical energy. (5) Release or block stored mechanical energy. (6) Apply lockout/tagout devices in accordance with a documented and established policy. (7) Use an adequately rated test instrument to test each phase conductor or circuit part to verify it is de-energized. Test each phase conductor or circuit part both phase-to-phase and phase-to-ground. Before and after each test, determine that the test instrument is operating satisfactorily through verification on a known voltage source. Exception: On electrical systems over 1000 volts, noncontact test instruments shall be permitted to be used to test each phase conductor. Informational Note No. 1: See UL , Safety Requirements for Electrical Equipment for Measurement, Control, and Laboratory Use, Part 1: General Requirements, for rating, overvoltage category, and design requirements for voltage measurement and test instruments intended for use on electrical systems 1000 volts and below. Informational Note No. 2: For additional information on rating and design requirements for voltage detectors, refer to IEC , Live Working Voltage Detectors Part 1: Capacitive type to be used for voltages exceeding 1kV a.c., or IEC , Live Working Voltage Detectors Part 2: Resistive type to be used for voltages of 1kV to 36 kv a.c., or IEC , Live Working Voltage Detectors Part 3: Two-pole low voltage type. (8) Where the possibility of induced voltages or stored electrical energy exists, ground the phase conductors or circuit parts before touching them. Where it could be reasonably anticipated that the conductors or circuit parts being de-energized could contact other exposed energized conductors or circuit parts, apply temporary protective grounding equipment in accordance with the following: (9) Placement. Temporary protective grounding equipment shall be placed at such locations and arranged in such a manner as to prevent each employee from being exposed to a shock hazard (i.e., hazardous differences in electrical potential). The location, sizing, and application of temporary protective grounding equipment shall be identified as part of the employer's job planning. (10) Capacity. Temporary protective grounding equipment shall be capable of conducting the maximum fault current that could flow at the point of grounding for the time necessary to clear the fault. (11) Equipment Approval. Temporary protective grounding equipment shall meet the requirements of ASTM F855, Standard Specification for Temporary Protective Grounds to be Used on De-energized Electric Power Lines and Equipment. (12) Impedance. Temporary protective grounding equipment and connections shall have an impedance low enough to cause immediate operation of protective devices in case of unintentional energizing of the electric conductors or circuit parts. Statement of Problem and Substantiation for Public Comment With the reorganization of Article 120, two sections appear to be in the wrong order and should be placed in their respective locations. 1. The part about Electrical Circuit Interlocks and Control Devices does not belong in 120.3, Lockout/Tagout Equipment, and has been moved to 120.2, Lockout/Tagout Principles. 2. The detailed requirements about simple and complex lockout/tagout do not belong in 120.2, Lockout/Tagout

109 4 of 403 9/2/2016 9:49 AM Principles, and are better located under 120.4, Lockout/Tagout Procedures. Additionally, some of the Elements of Control in 120.4, Lockout/Tagout Procedures, should be placed in the overall program, and so have been moved to 120.1, Lockout/Tagout Program. This includes processes for shift change, coordination, accountability for personnel, when to use lockout vs. tagout, and removal of lockout/tagout devices. Repeating these standard processes in each complex lockout/tagout procedure is unnecessary and burdensome. This change is to attempt alignment with the stated definitions in FR-30: Practice - to do something customarily (e.g. work practice ) Procedure a series of steps followed in a regular definite order (e.g. lockout/tagout procedure ) Process a series of actions or operations conducing to an end (e.g. Risk Assessment an overall process that ) Program a plan or system under which action may be taken toward a goal (e.g. electrical safety program ) Related Item First Revision No. 30-NFPA 70E-2015 [Article 120] Submitter Information Verification Submitter Full Name: Mark Scott Organization: Lawrence Berkeley National Laboratory Street Address: City: State: Zip: Submittal Date: Mon May 09 18:15:20 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-25-NFPA 70E-2016 Statement: Sections 120.3(E) and 120.3(F) are relocated to (E) and (F), respectively, because electrical circuit interlocks and control devices are more appropriately addressed in lockout/tagout principles. Sections 120.2(H)(1) and 120.2(H)(2) are relocated to 120.4(A)(4) and 120.4(A)(5), respectively, because the more descriptive requirements for simple and complex lockout/tagout are more appropriately addressed in lockout/tagout procedures. Established is removed from 120.2(G)(1) because it is unnecessary. Section 120.2(G)(3) is deleted because it is not related to the coordination of hazardous energy control procedures. The informational note in 120.2(A) is moved below the requirement. Section replaces Elements of to Process for in verifying because it is a more descriptive phrase for the procedure. List item 120.5(7) is revised to address any known voltage source to correlate with revisions in 110.4(E). A new exception was added to 120.5(7) recognizing that a permanently mounted test device that is listed and labeled can be used at the point where work is to be performed. The word policy was changed to procedure in 120.5(6) because it describes action to be taken.

110 5 of 403 9/2/2016 9:49 AM Section 120.5(8)(C) is revised to relocate the mandatory reference into an informational note in compliance with the NEC Style Manual.

111 6 of 403 9/2/2016 9:49 AM Public Comment No. 137-NFPA 70E-2016 [ Section No (A) ] (A) General. Electrical conductors and circuit parts shall not be considered to be in an electrically safe work condition until all of the applicable requirements of Article 120 have been met. Informational Note: See for the steps to establish and verify an electrically safe work condition. Safe work practices appropriate for the circuit voltage and energy level shall be used in accordance with Article 130 until such time that electrical conductors and circuit parts are in an electrically safety work condition. Statement of Problem and Substantiation for Public Comment According to OSHA, lockout/tagout is intended protect the worker while they are performing servicing and maintenance on a machine or equipment. This is supported by the scope description in 29 CFR (a)(1)(i), the preamble to Standard 147, and numerous formal interpretations by OSHA. The 1995 NFPA 70E Technical Committee realized that lockout alone is not enough to keep a workplace safe from all electrical hazards so they introduced the concept of an electrically safe work condition. The substantiation to NFPA 70E F94 TCR, 70E-155 Log #CP122 states: absence of voltage with lockout/tagout devices in place does not, in and of itself, establish an electrically safe condition.lockout/tagout is but one part of a necessary process to establish a workplace free from hazards associated with electrical energy. This concept was intended by the founding group to be a process separate from lockout/tagout because they placed in the general section of the standard, not in the lockout/tagout chapter. That it was intended to be separate was reinforced by the substantiation to the committee proposal NFPA 70E F94 TCR, 70E-97 Log #CP74, which introduces the six-step procedure to achieve and verify an electrically safe work condition. The final sentence of that substantiation states: Note that lockout/tagout device application is only one step of such a procedure. Actions taken by subsequent technical committees have blurred the independence of the two concepts: lockout/tagout intended to protect a worker from unexpected release of hazardous energy, and an electrically safe work condition intended to make the workplace free of electrical hazards for all workers. The actions taken by the 2018 NFPA 70E Technical Committee with First Revision No. 30 has completed the merger that essentially makes the concept different than lockout in name only. Not only has it been merged with lockout/tagout, but it has been delegated to the end of the article as if it is an afterthought to be considered after the job is complete. By removing the word applicable from 120.2(A) the employer can no longer establish an electrically safe work condition unless servicing and maintenance requiring lockout/tagout must be performed. For example, since an electrically safe work condition cannot be established until all the requirements of Article 120 (not just the application of devices as was originally intended), custodians in the workplace must be involved in the lockout/tagout process according to 120.2(B) since they will be protected indirectly through the electrically safe work condition, even though they would not be performing servicing and maintenance of the electrical equipment. The TC should consider replacing the word applicable back into 120.2(A) and placing the process of establishing and verifying an electrically safe work condition to its original position of preparing the workplace for lockout/tagout and controlling hazards for all workers, not just those using lockout/tagout. Related Item First Revision No. 30-NFPA 70E-2015 [Article 120] Submitter Information Verification Submitter Full Name: Bobby Gray Organization: Hoydar/Buck, Inc. Affilliation: None Street Address:

112 7 of 403 9/2/2016 9:49 AM City: State: Zip: Submittal Date: Wed Apr 27 16:22:47 EDT 2016 Committee Statement Committee Action: Resolution: Rejected The proposed change would create confusion in the requirements of the Standard. All of the requirements in Article 120 are applicable when establishing an electrically safe work condition.

113 8 of 403 9/2/2016 9:49 AM Public Comment No. 177-NFPA 70E-2016 [ Section No (A) ] (A) General. Electrical conductors and circuit parts shall not be considered to be in an electrically safe work condition until all of the requirements of Article 120 have been met. Informational Note: See for the steps to establish and verify an electrically safe work condition. Safe work practices appropriate for the circuit voltage and energy level shall be used in accordance with Article 130 until such time that electrical conductors and circuit parts are in an electrically safety work condition. Statement of Problem and Substantiation for Public Comment No changes in content are made, only formatting. The clause, "Safe work practices appropriate for the circuit voltage and energy level shall be used in accordance with Article 130 until such time that electrical conductors and circuit parts are in an electrically safety work condition." is moved so that it is not a part of the Informational Note. Related Item First Revision No. 30-NFPA 70E-2015 [Article 120] Submitter Information Verification Submitter Full Name: Louis Barrios Organization: Shell Global Solutions Affilliation: American Petroleum Institute Street Address: City: State: Zip: Submittal Date: Fri May 13 15:59:24 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-25-NFPA 70E-2016 Statement: Sections 120.3(E) and 120.3(F) are relocated to (E) and (F), respectively, because electrical circuit interlocks and control devices are more appropriately addressed in lockout/tagout principles. Sections 120.2(H)(1) and 120.2(H)(2) are relocated to 120.4(A)(4) and 120.4(A)(5), respectively, because the more descriptive requirements for simple and complex lockout/tagout are more appropriately addressed in lockout/tagout procedures. Established is removed from 120.2(G)(1) because it is unnecessary. Section 120.2(G)(3) is deleted because it is not related to the coordination of hazardous energy control procedures. The informational note in 120.2(A) is moved below the requirement.

114 9 of 403 9/2/2016 9:49 AM Section replaces Elements of to Process for in verifying because it is a more descriptive phrase for the procedure. List item 120.5(7) is revised to address any known voltage source to correlate with revisions in 110.4(E). A new exception was added to 120.5(7) recognizing that a permanently mounted test device that is listed and labeled can be used at the point where work is to be performed. The word policy was changed to procedure in 120.5(6) because it describes action to be taken. Section 120.5(8)(C) is revised to relocate the mandatory reference into an informational note in compliance with the NEC Style Manual.

115 00 of 403 9/2/2016 9:49 AM Public Comment No. 98-NFPA 70E-2016 [ Section No (A) ] (A) General. Electrical conductors and circuit parts shall not be considered to be in an electrically safe work condition until all of the requirements of Article 120 have been met. Informational Note: See for the steps to establish and verify an electrically safe work condition. Safe work practices appropriate for the circuit voltage and energy level shall be used in accordance with Article 130 until such time that electrical conductors and circuit parts are in an electrically safety work condition. Statement of Problem and Substantiation for Public Comment The 8 steps listed are incomplete and do not establish an electrically safe work condition. They are an additional step in verifying that an electrically safe work condition has been established. It is inaccurate and misleading as written. Related Item First Revision No. 30-NFPA 70E-2015 [Article 120] Submitter Information Verification Submitter Full Name: Palmer Hickman Organization: Electrical Training Alliance Street Address: City: State: Zip: Submittal Date: Wed Apr 20 14:11:13 EDT 2016 Committee Statement Committee Action: Resolution: Rejected The committee reaffirms that the steps included in include both steps to establish and verify that an electrically safe work condition is established.

116 01 of 403 9/2/2016 9:49 AM Public Comment No. 178-NFPA 70E-2016 [ Section No (G) ] (G) (1) Coordination. The established electrical The electrical lockout/tagout procedure shall be coordinated with all other employer s procedures for control of exposure to electrical energy sources such that all employer s procedural requirements are adequately addressed on a site basis. (2) The procedure for control of exposure to electrical hazards shall be coordinated with other procedures for control of other hazardous energy sources such that they are based on similar/identical concepts. (3) The electrical lockout/tagout procedure shall always include voltage testing requirements where there might be direct exposure to electrical hazards. (4) Electrical lockout/tagout devices shall be permitted to be similar to lockout/tagout devices for control of other hazardous energy sources, such as pneumatic, hydraulic, thermal, and mechanical, if such devices are used only for control of hazardous energy and for no other purpose. Statement of Problem and Substantiation for Public Comment "Established" is removed in 120.2(G)(1) because it is unnecessary (G)(3) is deleted because it is not related to the coordination of hazardous energy control procedures. Related Item First Revision No. 30-NFPA 70E-2015 [Article 120] Submitter Information Verification Submitter Full Name: Louis Barrios Organization: Shell Global Solutions Affilliation: American Petroleum Institute Street Address: City: State: Zip: Submittal Date: Fri May 13 16:11:30 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-25-NFPA 70E-2016 Statement: Sections 120.3(E) and 120.3(F) are relocated to (E) and (F), respectively, because electrical circuit interlocks and control devices are more appropriately addressed in lockout/tagout principles. Sections 120.2(H)(1) and 120.2(H)(2) are relocated to 120.4(A)(4) and 120.4(A)(5), respectively, because the more descriptive requirements for simple and complex lockout/tagout are more

117 02 of 403 9/2/2016 9:49 AM appropriately addressed in lockout/tagout procedures. Established is removed from 120.2(G)(1) because it is unnecessary. Section 120.2(G)(3) is deleted because it is not related to the coordination of hazardous energy control procedures. The informational note in 120.2(A) is moved below the requirement. Section replaces Elements of to Process for in verifying because it is a more descriptive phrase for the procedure. List item 120.5(7) is revised to address any known voltage source to correlate with revisions in 110.4(E). A new exception was added to 120.5(7) recognizing that a permanently mounted test device that is listed and labeled can be used at the point where work is to be performed. The word policy was changed to procedure in 120.5(6) because it describes action to be taken. Section 120.5(8)(C) is revised to relocate the mandatory reference into an informational note in compliance with the NEC Style Manual.

118 03 of 403 9/2/2016 9:49 AM Public Comment No. 145-NFPA 70E-2016 [ Section No (H) ] (H) Forms of Control of Hazardous Electrical Energy. Two forms of hazardous electrical energy control shall be permitted: simple lockout/tagout and complex lockout/tagout [see 120.3]. For the simple lockout/tagout, the qualified person shall be in charge. For the complex lockout/tagout, the person in charge shall have overall responsibility. (1) Simple Lockout/Tagout Procedure. All lockout/tagout procedures that involve only a qualified person(s) de-energizing one set of conductors or circuit part source for the sole purpose of safeguarding employees from exposure to electrical hazards, and do not require a complex lockout/tagout procedure per 120.2(H)(2)(a), shall be considered to be a simple lockout/tagout. Simple lockout/tagout procedures shall not be required to be written for each application. Each worker shall be responsible for his or her own lockout/tagout. Exception: Lockout/tagout is not required for work on cord-and plug-connected equipment for which exposure to the hazards of unexpected energization of the equipment is controlled by the unplugging of the equipment from the energy source, provided that the plug is under the exclusive control of the employee performing the servicing and maintenance for the duration of the work.

119 04 of 403 9/2/2016 9:49 AM (2) Complex Lockout/Tagout Procedure. (a) A complex lockout/tagout procedure shall be permitted where one or more not be required when all of the following elements exist: (2) Multiple energy sources (3) Multiple crews (4) Multiple crafts (5) Multiple locations (6) Multiple employers (7) Multiple disconnecting means (8) Particular sequences (9) Job or task that continues for more than one work period (1) (1) The machine or equipment has no potential for stored or residual energy or reaccumulation of stored energy after shut down which could endanger employees; (2) the machine or equipment has a single energy source which can be readily identified and isolated; (3) the isolation and locking out of that energy source will completely deenergize and deactivate the machine or equipment; (4) the machine or equipment is isolated from that energy source and locked out during servicing or maintenance; (5) a single lockout device will achieve a locked-out condition; (6) the lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance; (7) the servicing or maintenance does not create hazards for other employees; and (8) the employer, in utilizing this exception, has had no accidents involving the unexpected activation or reenergization of the machine or equipment during servicing or maintenance. (j) All complex lockout/tagout procedures shall require a written plan of execution that identifies the person in charge. (k) The complex lockout/tagout procedure shall vest primary responsibility in an authorized employee for employees working under the protection of a group lockout or tagout device, such as an operation lock or lockbox. The person in charge shall be held accountable for safe execution of the complex lockout/tagout. (l) Each authorized employee shall affix a personal lockout or tagout device to the group lockout device, group lockbox, or comparable mechanism when he or she begins work and shall remove those devices when he or she stops working on the machine or equipment being serviced or maintained. (m) All complex lockout/tagout plans shall identify the method to account for all persons who might be exposed to electrical hazards in the course of the lockout/tagout. Statement of Problem and Substantiation for Public Comment The current use of "permitted", and the conditions listed that would permit a complex lockout/tagout procedure, conflict significantly with the requirements of OSHA (c)(4)(i). OSHA (c)(4)(i): "Procedures shall be developed, documented and utilized for the control of potentially hazardous energy when employees are engaged in the activities covered by this section. Note: Exception: The employer need not document the required procedure for a particular machine or equipment, when all of the following elements exist: (1) The machine or equipment has no potential for stored or residual energy or reaccumulation of stored energy after shut down which could endanger employees; (2) the machine or

120 05 of 403 9/2/2016 9:49 AM equipment has a single energy source which can be readily identified and isolated; (3) the isolation and locking out of that energy source will completely deenergize and deactivate the machine or equipment; (4) the machine or equipment is isolated from that energy source and locked out during servicing or maintenance; (5) a single lockout device will achieve a locked-out condition; (6) the lockout device is under the exclusive control of the authorized employee performing the servicing or maintenance; (7) the servicing or maintenance does not create hazards for other employees; and (8) the employer, in utilizing this exception, has had no accidents involving the unexpected activation or reenergization of the machine or equipment during servicing or maintenance." OSHA clearly requires the use of written procedures unless all of the (8) conditions listed in its exception are satisfied. The current NFPA 70E language allows multiple OSHA violations while giving ambiguous guidance. For example, simple lockout/tagout would be permitted even if there were stored energy hazards, without a written procedure. Article 120.4(B)(2) states that procedures should include requirements for stored energy. These should be written procedures because stored energy hazards and controls are not readily apparent, even to Qualified Persons. Most equipment with stored energy may not give any instructions on how to properly and safely discharge the stored energy. For capacitors a well-written procedure would specify wait times, grounding sticks and PPE. Proper lockout/tagout therefore necessitates a detailed written procedure, as required by OSHA. Furthermore, the word "permitted" essentially makes written complex lockout/tagout procedures completely optional without any restrictions. This renders the NFPA 70E conditions listed virtually meaningless. Some jurisdictions have chosen to enforce the conditions listed as if they were intended to be "required" instead of just "permitted", on top of an almost completely different set of conditions listed by OSHA. Requiring a complex LOTO just because the work continues for more than one work period, even if all other conditions are satisfied, does not increase safety and is completely unenforceable. Similarly, requiring a complex LOTO just because there are multiple crews, crafts or employers does not increase safety where a simple lockout/tagout would suffice. This is further supported by the Committee's response to Public Input No. 546-NFPA 70E-2015 [ Section No (D)(2) ], stating "The proposed revision is overly restrictive because it requires a complex lockout/tagout procedure even if only one of the conditions exists in 120.2(D)(2). Having multiple crafts does not necessarily require a complex lockout/tagout when this situation can be more effectively managed by multiple simple lockout/tagouts." With this response the purpose of Article 120.2(H)(2)(a) is now completely inscrutable. The disparity between the current NFPA 70E language and the OSHA requirements make it nearly impossible to integrate the two sets of standards and implement an effective employer control of hazardous energy program. Adopting the same language as OSHA (c)(4)(i) increases safety in needed areas, increases alignment to the regulatory requirements, and removes unnecessary and unenforceable language in the NFPA 70E standard. Related Item Public Input No. 140-NFPA 70E-2015 [Section No (D)] Public Input No. 23-NFPA 70E-2015 [Section No (D)(2)] Public Input No. 546-NFPA 70E-2015 [Section No (D)(2)] Submitter Information Verification Submitter Full Name: Mark Scott Organization: Lawrence Berkeley National Laboratory Street Address: City: State: Zip: Submittal Date: Tue May 03 18:14:49 EDT 2016 Committee Statement Committee Action: Rejected

121 06 of 403 9/2/2016 9:49 AM Resolution: The proposed revision is overly restrictive because it requires a complex lockout/tagout procedure even if only one of the conditions exists in 120.2(D)(2). As an example, the proposed text would require a complex lockout/tagout for a single isolation point that is not within site of the equipment being worked upon. The proposed revision also requires a complex lockout/tagout procedure where a simple lockout/tagout procedure would suffice where there is the potential for creating gaps in communication about the condition of the lockout/tagout. This would be a vague and unenforceable requirement.

122 07 of 403 9/2/2016 9:49 AM Public Comment No. 156-NFPA 70E-2016 [ Section No (H)(1) ] (1) Simple Lockout/Tagout Procedure. All lockout/tagout procedures that involve only a qualified person(s) de-energizing one set of conductors or circuit part source for the sole purpose of safeguarding employees from exposure to electrical hazards shall be considered to be a simple lockout/tagout. Simple lockout/tagout procedures shall not be required to be written for each application. Each worker shall be responsible for his or her own lockout/tagout. Exception: Lockout/tagout is not required for work on cord - and plug - connected equipment for which exposure to the hazards of unexpected energization of the equipment is controlled by the unplugging of the equipment mains from the energy mains source, provided that the single mains plug is under the exclusive control of the employee performing the servicing and maintenance for the duration of the work. Statement of Problem and Substantiation for Public Comment This change clarifies the OSHA language and adopts the more technically correct terminology of UL standards for cord and plug equipment. See for example the UL definitions of "MAINS", "MAINS CIRCUIT". UL : MAINS : low-voltage electricity supply system to which the equipment concerned is designed to be connected for the purpose of powering the equipment MAINS CIRCUIT : circuit which is intended to be directly connected to the MAINS for the purpose of powering the equipment. See also Figure 9, which explains the terminology for MAINS supply cords. The change prevents the exception from being incorrectly applied to equipment with multiple power cords, whether having alternate MAINS supply or other foreign sources. Equipment with more than one energy source should be controlled under a written complex lockout/tagout procedure. Related Item First Revision No. 30-NFPA 70E-2015 [Article 120] Submitter Information Verification Submitter Full Name: Mark Scott Organization: Lawrence Berkeley National Laboratory Street Address: City: State: Zip: Submittal Date: Mon May 09 14:00:00 EDT 2016 Committee Statement Committee Action: Rejected Resolution: The proposed change does not improve clarity.

123 08 of 403 9/2/2016 9:49 AM Public Comment No. 105-NFPA 70E-2016 [ Section No ]

124 09 of 403 9/2/2016 9:49 AM Elements of Establishing and Verifying an Electrically Safe Work Condition. Establishing and verifying an electrically safe work condition shall include all of the following steps, which shall be performed in the order presented, if feasible: (1) Determine all possible sources of electrical supply to the specific equipment. Check applicable up-to-date drawings, diagrams, and identification tags. (2) After properly interrupting the load current, open the disconnecting device(s) for each source. (3) Wherever possible, visually verify that all blades of the disconnecting devices are fully open or that drawout-type circuit breakers are withdrawn to the fully disconnected position. Informational Note: A visual inspection of disconnecting blades is usually possible for an open air configuration or when a listed inspection window is provided for an enclosed switch. (1) Release stored electrical energy. (2) Release or block stored mechanical energy. (3) Apply lockout/tagout devices in accordance with a documented and established policy. (4) Use an adequately rated test instrument to test each phase conductor or circuit part to verify it is de-energized. Test each phase conductor or circuit part both phase-to-phase and phase-to-ground. Before and after each test, determine that the test instrument is operating satisfactorily through verification on a known voltage source. Exception: On electrical systems over 1000 volts, noncontact test instruments shall be permitted to be used to test each phase conductor. Informational Note No. 1: See UL , Safety Requirements for Electrical Equipment for Measurement, Control, and Laboratory Use, Part 1: General Requirements, for rating, overvoltage category, and design requirements for voltage measurement and test instruments intended for use on electrical systems 1000 volts and below. Informational Note No. 2: For additional information on rating and design requirements for voltage detectors, refer to IEC , Live Working Voltage Detectors Part 1: Capacitive type to be used for voltages exceeding 1kV a.c., or IEC , Live Working Voltage Detectors Part 2: Resistive type to be used for voltages of 1kV to 36 kv a.c., or IEC , Live Working Voltage Detectors Part 3: Two-pole low voltage type. (5) Where the possibility of induced voltages or stored electrical energy exists, ground the phase conductors or circuit parts before touching them. Where it could be reasonably anticipated that the conductors or circuit parts being de-energized could contact other exposed energized conductors or circuit parts, apply temporary protective grounding equipment in accordance with the following: (6) Placement. Temporary protective grounding equipment shall be placed at such locations and arranged in such a manner as to prevent each employee from being exposed to a shock hazard (i.e., hazardous differences in electrical potential). The location, sizing, and application of temporary protective grounding equipment shall be identified as part of the employer's job planning. (7) Capacity. Temporary protective grounding equipment shall be capable of conducting the maximum fault current that could flow at the point of grounding for the time necessary to clear the fault. (8) Equipment Approval. Temporary protective grounding equipment shall meet the requirements of ASTM F855, Standard Specification for Temporary Protective Grounds to be Used on De-energized Electric Power Lines and Equipment. (9) Impedance. Temporary protective grounding equipment and connections shall have an impedance low enough to cause immediate operation of protective devices in case of unintentional energizing of the electric conductors or circuit parts. Statement of Problem and Substantiation for Public Comment Substantiation: The term wherever possible as used in the context of this sentence for blade inspection is too subjective because blades can always be inspected given enough time and resources. For example, a lockout

125 10 of 403 9/2/2016 9:49 AM installer may determine it is not possible to visually inspect blades because they are physically guarded, but a lockout assessor, on the other hand, may believe it s possible to remove the guards for inspection. A new Informational Note will clarify the intent by providing examples of when blades should be visibly inspected. Related Item Public Input No. 435-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: John McAlhaney Organization: Savannah River Nuclear Sol. Affilliation: Savannah River Nuclear Solutions, Department of Energy Street Address: City: State: Zip: Submittal Date: Fri Apr 22 11:08:46 EDT 2016 Committee Statement Committee Action: Resolution: Rejected The standard requires visual verification where possible. The proposed informational note is unnecessary.

126 11 of 403 9/2/2016 9:49 AM Public Comment No. 138-NFPA 70E-2016 [ Section No ] Elements of Establishing and Verifying an Electrically Safe Work Condition. Establishing and verifying an electrically safe work condition shall include all of the following steps, which shall be performed in the order presented, if feasible: (1) Determine all possible sources of electrical supply to the specific equipment. Check applicable up-to-date drawings, diagrams, and identification tags. (2) After properly interrupting the load current, open the disconnecting device(s) for each source. (3) Wherever possible the design of equipment permits hinged covers to be opened or inspection windows are installed, visually verify that all blades of the disconnecting devices are fully open or that drawout-type circuit breakers are withdrawn to the fully disconnected position. (4) Release stored electrical energy. (5) Release or block stored mechanical energy. (6) Apply lockout/tagout devices in accordance with a documented and established policy. (7) Use an adequately rated test instrument to test each phase conductor or circuit part to verify it is de-energized. Test each phase conductor or circuit part both phase-to-phase and phase-to-ground. Before and after each test, determine that the test instrument is operating satisfactorily through verification on a known voltage source. Exception: On electrical systems over 1000 volts, noncontact test instruments shall be permitted to be used to test each phase conductor. Informational Note No. 1: See UL , Safety Requirements for Electrical Equipment for Measurement, Control, and Laboratory Use, Part 1: General Requirements, for rating, overvoltage category, and design requirements for voltage measurement and test instruments intended for use on electrical systems 1000 volts and below. Informational Note No. 2: For additional information on rating and design requirements for voltage detectors, refer to IEC , Live Working Voltage Detectors Part 1: Capacitive type to be used for voltages exceeding 1kV a.c., or IEC , Live Working Voltage Detectors Part 2: Resistive type to be used for voltages of 1kV to 36 kv a.c., or IEC , Live Working Voltage Detectors Part 3: Two-pole low voltage type. (8) Where the possibility of induced voltages or stored electrical energy exists, ground the phase conductors or circuit parts before touching them. Where it could be reasonably anticipated that the conductors or circuit parts being de-energized could contact other exposed energized conductors or circuit parts, apply temporary protective grounding equipment in accordance with the following: (9) Placement. Temporary protective grounding equipment shall be placed at such locations and arranged in such a manner as to prevent each employee from being exposed to a shock hazard (i.e., hazardous differences in electrical potential). The location, sizing, and application of temporary protective grounding equipment shall be identified as part of the employer's job planning. (10) Capacity. Temporary protective grounding equipment shall be capable of conducting the maximum fault current that could flow at the point of grounding for the time necessary to clear the fault. (11) Equipment Approval. Temporary protective grounding equipment shall meet the requirements of ASTM F855, Standard Specification for Temporary Protective Grounds to be Used on De-energized Electric Power Lines and Equipment. (12) Impedance. Temporary protective grounding equipment and connections shall have an impedance low enough to cause immediate operation of protective devices in case of unintentional energizing of the electric conductors or circuit parts.

127 12 of 403 9/2/2016 9:49 AM Statement of Problem and Substantiation for Public Comment The TC response to PI 435 did not adequately address the legitimate concern that the language is subjective and unenforceable. The PI submitter is correct that it is always "possible" by going to extraordinary actions that may be unsafe. The proposed language provides a possible clarification of the intent of the rule and should be modified if the language does not meet the intent of the TC. Some action should be taken based on the substantiation in the PI. Related Item Public Input No. 435-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: Bobby Gray Organization: Hoydar/Buck, Inc. Affilliation: None Street Address: City: State: Zip: Submittal Date: Wed Apr 27 17:09:57 EDT 2016 Committee Statement Committee Action: Resolution: Rejected The standard requires visual verification where possible. The proposed informational note is unnecessary.

128 13 of 403 9/2/2016 9:49 AM Public Comment No. 147-NFPA 70E-2016 [ Section No ]

129 14 of 403 9/2/2016 9:49 AM Elements of Establishing and Verifying an Electrically Safe Work Condition. Establishing and verifying an electrically safe work condition shall include all of the following steps, which shall be performed in the order presented, if feasible: (1) Determine all possible sources of electrical supply to the specific equipment. Check applicable up-to-date drawings, diagrams, and identification tags. (2) After properly interrupting the load current, open the disconnecting device(s) for each source. (3) Wherever possible, visually verify that all blades of the disconnecting devices are fully open or that drawout-type circuit breakers are withdrawn to the fully disconnected position. (4) Release stored electrical energy. (5) Release or block stored mechanical energy. (6) Apply lockout/tagout devices in accordance with a documented and established policy. (7) Use an adequately rated test instrument to test each phase conductor or circuit part to verify it is de-energized. Test each phase conductor or circuit part both phase-to-phase and phase-to-ground. Before and after each test, determine that the test instrument is operating satisfactorily through verification on a known voltage source. Exception: A permanently-mounted tester listed and labeled for the purpose of verifying the absence of voltage shall be permitted as the test instrument for the equipment being tested. Informational Note: See UL 1436, Outlet Circuit Testers and Similar Indicating Devices for permanently-mounted Absence of Voltage Testers. Exception: On electrical systems over 1000 volts, noncontact test instruments shall be permitted to be used to test each phase conductor. Informational Note No. 1: See UL , Safety Requirements for Electrical Equipment for Measurement, Control, and Laboratory Use, Part 1: General Requirements, for rating, overvoltage category, and design requirements for voltage measurement and test instruments intended for use on electrical systems 1000 volts and below. Informational Note No. 2: For additional information on rating and design requirements for voltage detectors, refer to IEC , Live Working Voltage Detectors Part 1: Capacitive type to be used for voltages exceeding 1kV a.c., or IEC , Live Working Voltage Detectors Part 2: Resistive type to be used for voltages of 1kV to 36 kv a.c., or IEC , Live Working Voltage Detectors Part 3: Two-pole low voltage type. (8) Where the possibility of induced voltages or stored electrical energy exists, ground the phase conductors or circuit parts before touching them. Where it could be reasonably anticipated that the conductors or circuit parts being de-energized could contact other exposed energized conductors or circuit parts, apply temporary protective grounding equipment in accordance with the following: (9) Placement. Temporary protective grounding equipment shall be placed at such locations and arranged in such a manner as to prevent each employee from being exposed to a shock hazard (i.e., hazardous differences in electrical potential). The location, sizing, and application of temporary protective grounding equipment shall be identified as part of the employer's job planning. (10) Capacity. Temporary protective grounding equipment shall be capable of conducting the maximum fault current that could flow at the point of grounding for the time necessary to clear the fault. (11) Equipment Approval. Temporary protective grounding equipment shall meet the requirements of ASTM F855, Standard Specification for Temporary Protective Grounds to be Used on De-energized Electric Power Lines and Equipment. (12) Impedance. Temporary protective grounding equipment and connections shall have an impedance low enough to cause immediate operation of protective devices in case of unintentional energizing of the electric conductors or circuit parts. Statement of Problem and Substantiation for Public Comment

130 15 of 403 9/2/2016 9:49 AM The committee had concerns regarding panel-mounted voltage test instruments. Since the proposal was submitted, UL has proposed new listing requirements for permanently-mounted absence of voltage testers in UL 1436 that are intended to ensure such testers will safely and reliably perform the absence of voltage verification described in NFPA 70E. The requirements address product and functional safety and are intended to be certification requirements for permanently-mounted tester that performs this function as a built-in tester at point of use. Related Item Public Input No. 144-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: Rachel Bugaris Organization: Panduit Corp Affilliation: Panduit Corp Street Address: City: State: Zip: Submittal Date: Wed May 04 10:50:54 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-25-NFPA 70E-2016 Statement: Sections 120.3(E) and 120.3(F) are relocated to (E) and (F), respectively, because electrical circuit interlocks and control devices are more appropriately addressed in lockout/tagout principles. Sections 120.2(H)(1) and 120.2(H)(2) are relocated to 120.4(A)(4) and 120.4(A)(5), respectively, because the more descriptive requirements for simple and complex lockout/tagout are more appropriately addressed in lockout/tagout procedures. Established is removed from 120.2(G)(1) because it is unnecessary. Section 120.2(G)(3) is deleted because it is not related to the coordination of hazardous energy control procedures. The informational note in 120.2(A) is moved below the requirement. Section replaces Elements of to Process for in verifying because it is a more descriptive phrase for the procedure. List item 120.5(7) is revised to address any known voltage source to correlate with revisions in 110.4(E). A new exception was added to 120.5(7) recognizing that a permanently mounted test device that is listed and labeled can be used at the point where work is to be performed. The word policy was changed to procedure in 120.5(6) because it describes action to be taken. Section 120.5(8)(C) is revised to relocate the mandatory reference into an informational note in compliance with the NEC Style Manual.

131 16 of 403 9/2/2016 9:49 AM Public Comment No. 159-NFPA 70E-2016 [ Section No ] Elements of Process for Establishing and Verifying an Electrically Safe Work Condition. Establishing and verifying an electrically safe work condition shall include all of the following steps, which shall be performed in the order presented, if feasible: (1) Determine all possible sources of electrical supply to the specific equipment. Check applicable up-to-date drawings, diagrams, and identification tags. (2) After properly interrupting the load current, open the disconnecting device(s) for each source. (3) Wherever possible, visually verify that all blades of the disconnecting devices are fully open or that drawout-type circuit breakers are withdrawn to the fully disconnected position. (4) Release stored electrical energy. (5) Release or block stored mechanical energy. (6) Apply lockout/tagout devices in accordance with a documented and established policy lockout/tagout program. (7) Use an adequately rated test instrument to test each phase conductor or circuit part to verify it is de-energized. Test each phase conductor or circuit part both phase-to-phase and phase-to-ground. Before and after each test, determine that the test instrument is operating satisfactorily through verification on a known voltage source. Exception: On electrical systems over 1000 volts, noncontact test instruments shall be permitted to be used to test each phase conductor. Informational Note No. 1: See UL , Safety Requirements for Electrical Equipment for Measurement, Control, and Laboratory Use, Part 1: General Requirements, for rating, overvoltage category, and design requirements for voltage measurement and test instruments intended for use on electrical systems 1000 volts and below. Informational Note No. 2: For additional information on rating and design requirements for voltage detectors, refer to IEC , Live Working Voltage Detectors Part 1: Capacitive type to be used for voltages exceeding 1kV a.c., or IEC , Live Working Voltage Detectors Part 2: Resistive type to be used for voltages of 1kV to 36 kv a.c., or IEC , Live Working Voltage Detectors Part 3: Two-pole low voltage type. (8) Where the possibility of induced voltages or stored electrical energy exists, ground the phase conductors or circuit parts before touching them. Where it could be reasonably anticipated that the conductors or circuit parts being de-energized could contact other exposed energized conductors or circuit parts, apply temporary protective grounding equipment in accordance with the following: (9) Placement. Temporary protective grounding equipment shall be placed at such locations and arranged in such a manner as to prevent each employee from being exposed to a shock hazard (i.e., hazardous differences in electrical potential). The location, sizing, and application of temporary protective grounding equipment shall be identified as part of the employer's job planning. (10) Capacity. Temporary protective grounding equipment shall be capable of conducting the maximum fault current that could flow at the point of grounding for the time necessary to clear the fault. (11) Equipment Approval. Temporary protective grounding equipment shall meet the requirements of ASTM F855, Standard Specification for Temporary Protective Grounds to be Used on De-energized Electric Power Lines and Equipment. (12) Impedance. Temporary protective grounding equipment and connections shall have an impedance low enough to cause immediate operation of protective devices in case of unintentional energizing of the electric conductors or circuit parts.

132 17 of 403 9/2/2016 9:49 AM Statement of Problem and Substantiation for Public Comment A specific series of steps prescribed in a certain order is called a "procedure" or a "process", not "elements", which do not have an order. Using "process" differentiates from the simple or complex lockout/tagout "procedure. Conversely, having defined a lockout/tagout program in 120.1, it should be referenced accordingly in step 6. This change aligns more closely with the definitions given in FR-30: Practice - to do something customarily (e.g. work practice ) Procedure a series of steps followed in a regular definite order (e.g. lockout/tagout procedure ) Process a series of actions or operations conducing to an end (e.g. Risk Assessment anoverall process that ) Program a plan or system under which action may be taken toward a goal (e.g. electrical safety program ) Related Item First Revision No. 30-NFPA 70E-2015 [Article 120] Submitter Information Verification Submitter Full Name: Mark Scott Organization: Lawrence Berkeley National Laboratory Street Address: City: State: Zip: Submittal Date: Mon May 09 18:38:51 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-25-NFPA 70E-2016 Statement: Sections 120.3(E) and 120.3(F) are relocated to (E) and (F), respectively, because electrical circuit interlocks and control devices are more appropriately addressed in lockout/tagout principles. Sections 120.2(H)(1) and 120.2(H)(2) are relocated to 120.4(A)(4) and 120.4(A)(5), respectively, because the more descriptive requirements for simple and complex lockout/tagout are more appropriately addressed in lockout/tagout procedures. Established is removed from 120.2(G)(1) because it is unnecessary. Section 120.2(G)(3) is deleted because it is not related to the coordination of hazardous energy control procedures. The informational note in 120.2(A) is moved below the requirement. Section replaces Elements of to Process for in verifying because it is a more descriptive phrase for the procedure. List item 120.5(7) is revised to address any known voltage source to correlate with revisions in 110.4(E). A new exception was added to 120.5(7) recognizing that a permanently mounted test device that is listed and labeled can be used at the point where work is to be performed. The word policy was changed to procedure in 120.5(6) because it describes action to be taken. Section 120.5(8)(C) is revised to relocate the mandatory reference into an informational note in

133 18 of 403 9/2/2016 9:49 AM compliance with the NEC Style Manual.

134 19 of 403 9/2/2016 9:49 AM Public Comment No. 160-NFPA 70E-2016 [ Section No ] Elements of Establishing and Verifying an Electrically Safe Work Condition. Establishing and verifying an electrically safe work condition shall include all of the following steps, which shall be performed in the order presented, if feasible: (1) Determine all possible sources of electrical supply to the specific equipment. Check applicable up-to-date drawings, diagrams, and identification tags. (2) After properly interrupting the load current, open the disconnecting device(s) for each source. (3) Wherever possible, visually verify that all blades of the disconnecting devices are fully open or that drawout-type circuit breakers are withdrawn to the fully disconnected position. (4) Release stored electrical energy. (5) Release or block stored mechanical energy. (6) Apply lockout/tagout devices in accordance with a documented and established policy. (7) Use an adequately rated test instrument to test each phase conductor or circuit part to verify it is de-energized. Test each phase conductor or circuit part both phase-to-phase and phase-to-ground. Before and after each test, determine that the test instrument is operating satisfactorily through verification on a known voltage source. Exception: On electrical systems over 1000 volts, noncontact test instruments shall be permitted to be used to test each phase conductor. Informational Note No. 1: See UL , Safety Requirements for Electrical Equipment for Measurement, Control, and Laboratory Use, Part 1: General Requirements, for rating, overvoltage category, and design requirements for voltage measurement and test instruments intended for use on electrical systems 1000 volts and below. Informational Note No. 2: For additional information on rating and design requirements for voltage detectors, refer to IEC , Live Working Voltage Detectors Part 1: Capacitive type to be used for voltages exceeding 1kV a.c., or IEC , Live Working Voltage Detectors Part 2: Resistive type to be used for voltages of 1kV to 36 kv a.c., or IEC , Live Working Voltage Detectors Part 3: Two-pole low voltage type. (8) Where the possibility of induced voltages or stored electrical energy exists, ground the phase conductors or circuit parts before touching them. Where it could be reasonably anticipated that the conductors or circuit parts being de-energized could contact other exposed energized conductors or circuit parts, apply temporary protective grounding equipment in accordance with the following: (9) Placement. Temporary protective grounding equipment shall be placed at such locations and arranged in such a manner as to prevent each employee from being exposed to a shock hazard (i.e., hazardous differences in electrical potential). The location, sizing, and application of temporary protective grounding equipment shall be identified as part of the employer's job planning. (10) Capacity. Temporary protective grounding equipment shall be capable of conducting the maximum fault current that could flow at the point of grounding for the time necessary to clear the fault. (11) Equipment Approval. Temporary protective grounding equipment shall meet the requirements of ASTM F855, Standard Specification for Temporary Protective Grounds to be Used on De-energized Electric Power Lines and Equipment. (12) Impedance. Temporary protective grounding equipment and connections shall have an impedance low enough to cause immediate operation of protective devices in case of unintentional energizing of the electric conductors or circuit parts.

135 20 of 403 9/2/2016 9:49 AM Statement of Problem and Substantiation for Public Comment While releasing stored mechanical energy is an important part of an overall control of hazardous energy program, it is not a step in establishing an electrically safe work condition and should be removed from this process. Related Item First Revision No. 30-NFPA 70E-2015 [Article 120] Submitter Information Verification Submitter Full Name: Mark Scott Organization: Lawrence Berkeley National Laboratory Street Address: City: State: Zip: Submittal Date: Mon May 09 18:50:47 EDT 2016 Committee Statement Committee Action: Resolution: Rejected Failure to release stored mechanical energy, such as springs, may result in inadvertent operation and energization of electrical circuits.

136 21 of 403 9/2/2016 9:49 AM Public Comment No. 161-NFPA 70E-2016 [ Section No ]

137 22 of 403 9/2/2016 9:49 AM Elements of Establishing and Verifying an Electrically Safe Work Condition. Establishing and verifying an electrically safe work condition shall include all of the following steps, which shall be performed in the order presented, if feasible: (1) Determine all possible sources of electrical supply to the specific equipment. Check applicable up-to-date drawings, diagrams, and identification tags. (2) After properly interrupting the load current, open the disconnecting device(s) for each source. (3) Wherever possible, visually verify that all blades of the disconnecting devices are fully open or that drawout-type circuit breakers are withdrawn to the fully disconnected position. (4) Release stored electrical energy. (5) Release or block stored mechanical energy. (6) Apply lockout/tagout devices in accordance with a documented and established policy. (7) Use an adequately rated test instrument to test each phase conductor or circuit part to verify it is de-energized. Test each phase conductor or circuit part both phase-to-phase and phase-to-ground. Before and after each test, determine that the test instrument is operating satisfactorily through verification on a known voltage source. Exception: On electrical systems over 1000 volts, noncontact test instruments shall be permitted to be used to test each phase conductor. Informational Note No. 1: See UL , Safety Requirements for Electrical Equipment for Measurement, Control, and Laboratory Use, Part 1: General Requirements, for rating, overvoltage category, and design requirements for voltage measurement and test instruments intended for use on electrical systems 1000 volts and below. Informational Note No. 2: For additional information on rating and design requirements for voltage detectors, refer to IEC , Live Working Voltage Detectors Part 1: Capacitive type to be used for voltages exceeding 1kV a.c., or IEC , Live Working Voltage Detectors Part 2: Resistive type to be used for voltages of 1kV to 36 kv a.c., or IEC , Live Working Voltage Detectors Part 3: Two-pole low voltage type. (8) Where the possibility of induced voltages or stored electrical energy exists, ground the phase conductors or circuit parts before touching them. Where it could be reasonably anticipated that the conductors or circuit parts being de-energized could contact other exposed energized conductors or circuit parts, apply temporary protective grounding equipment in accordance with the following: (9) Placement. Temporary protective grounding equipment shall be placed at such locations and arranged in such a manner as to prevent each employee from being exposed to a shock hazard (i.e., hazardous differences in electrical potential). The location, sizing, and application of temporary protective grounding equipment shall be identified as part of the employer's job planning. (10) Capacity. Temporary protective grounding equipment shall be capable of conducting the maximum fault current that could flow at the point of grounding for the time necessary to clear the fault. (11) Equipment Approval. Temporary a. Where applicable, temporary protective grounding equipment shall meet the requirements of ASTM F855, Standard Specification for Temporary Protective Grounds to be Used on De-energized Electric Power Lines and Equipment. b. Impedance. Temporary protective grounding equipment and connections shall have an impedance low enough to cause immediate operation of protective devices in case of unintentional energizing of the electric conductors or circuit parts. Statement of Problem and Substantiation for Public Comment ASTM F855 typically applies to "electric power lines, electric supply stations, and equipment". There are conditions

138 23 of 403 9/2/2016 9:49 AM where hazardous stored energy may be present on systems where ASTM F855 style clamps and cables are not applicable. For example, stored energy may be present in capacitor banks where a different type of temporary personal protective grounding may be more suited. Related Item First Revision No. 30-NFPA 70E-2015 [Article 120] Submitter Information Verification Submitter Full Name: Mark Scott Organization: Lawrence Berkeley National Laboratory Street Address: City: State: Zip: Submittal Date: Mon May 09 18:55:12 EDT 2016 Committee Statement Committee Action: Resolution: Rejected The proposed change does not add clarity to the Standard. This section is not referring to the dissipation of stored energy and the proposal is not dealing with the same hazards as personal protective grounds.

139 24 of 403 9/2/2016 9:49 AM Public Comment No. 64-NFPA 70E-2016 [ Section No ] Elements of Establishing and Verifying an Electrically Safe Work Condition. Establishing and verifying an electrically safe work condition shall include all of the following steps, which shall be performed in the order presented, if feasible: (1) Determine all possible sources of electrical supply to the specific equipment. Check applicable up-to-date drawings, diagrams, and identification tags. (2) After properly interrupting the load current, open the disconnecting device(s) for each source. (3) Wherever possible, visually verify that all blades of the disconnecting devices are fully open or that drawout-type circuit breakers are withdrawn to the fully disconnected position. (4) Release stored electrical energy. (5) Release or block stored mechanical energy. (6) Apply lockout/tagout devices in accordance with a documented and established policy procedure. (7) Use an adequately rated test instrument to test each phase conductor or circuit part to verify it is de-energized. Test each phase conductor or circuit part both phase-to-phase and phase-to-ground. Before and after each test, determine that the test instrument is operating satisfactorily through verification on a known voltage source. Exception: On electrical systems over 1000 volts, noncontact test instruments shall be permitted to be used to test each phase conductor. Informational Note No. 1: See UL , Safety Requirements for Electrical Equipment for Measurement, Control, and Laboratory Use, Part 1: General Requirements, for rating, overvoltage category, and design requirements for voltage measurement and test instruments intended for use on electrical systems 1000 volts and below. Informational Note No. 2: For additional information on rating and design requirements for voltage detectors, refer to IEC , Live Working Voltage Detectors Part 1: Capacitive type to be used for voltages exceeding 1kV a.c., or IEC , Live Working Voltage Detectors Part 2: Resistive type to be used for voltages of 1kV to 36 kv a.c., or IEC , Live Working Voltage Detectors Part 3: Two-pole low voltage type. (8) Where the possibility of induced voltages or stored electrical energy exists, ground the phase conductors or circuit parts before touching them. Where it could be reasonably anticipated that the conductors or circuit parts being de-energized could contact other exposed energized conductors or circuit parts, apply temporary protective grounding equipment in accordance with the following: (9) Placement. Temporary protective grounding equipment shall be placed at such locations and arranged in such a manner as to prevent each employee from being exposed to a shock hazard (i.e., hazardous differences in electrical potential). The location, sizing, and application of temporary protective grounding equipment shall be identified as part of the employer's job planning. (10) Capacity. Temporary protective grounding equipment shall be capable of conducting the maximum fault current that could flow at the point of grounding for the time necessary to clear the fault. (11) Equipment Approval. Temporary protective grounding equipment shall meet the requirements of ASTM F855, Standard Specification for Temporary Protective Grounds to be Used on De-energized Electric Power Lines and Equipment. (12) Impedance. Temporary protective grounding equipment and connections shall have an impedance low enough to cause immediate operation of protective devices in case of unintentional energizing of the electric conductors or circuit parts.

140 25 of 403 9/2/2016 9:49 AM Statement of Problem and Substantiation for Public Comment Procedure rather than policy is consistent with text in the balance of the document. Related Item First Revision No. 30-NFPA 70E-2015 [Article 120] Submitter Information Verification Submitter Full Name: David Pace Organization: Olin Corporation Affilliation: Self Street Address: City: State: Zip: Submittal Date: Thu Mar 17 14:05:43 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-25-NFPA 70E-2016 Statement: Sections 120.3(E) and 120.3(F) are relocated to (E) and (F), respectively, because electrical circuit interlocks and control devices are more appropriately addressed in lockout/tagout principles. Sections 120.2(H)(1) and 120.2(H)(2) are relocated to 120.4(A)(4) and 120.4(A)(5), respectively, because the more descriptive requirements for simple and complex lockout/tagout are more appropriately addressed in lockout/tagout procedures. Established is removed from 120.2(G)(1) because it is unnecessary. Section 120.2(G)(3) is deleted because it is not related to the coordination of hazardous energy control procedures. The informational note in 120.2(A) is moved below the requirement. Section replaces Elements of to Process for in verifying because it is a more descriptive phrase for the procedure. List item 120.5(7) is revised to address any known voltage source to correlate with revisions in 110.4(E). A new exception was added to 120.5(7) recognizing that a permanently mounted test device that is listed and labeled can be used at the point where work is to be performed. The word policy was changed to procedure in 120.5(6) because it describes action to be taken. Section 120.5(8)(C) is revised to relocate the mandatory reference into an informational note in compliance with the NEC Style Manual.

141 26 of 403 9/2/2016 9:49 AM Public Comment No. 99-NFPA 70E-2016 [ Section No ] Elements of Establishing and Verifying an Electrically Safe Work Condition. Establishing and verifying Verifying an electrically safe work condition shall include all of the following steps, which shall be performed in the order presented, if feasible: (1) Determine all possible sources of electrical supply to the specific equipment. Check applicable up-to-date drawings, diagrams, and identification tags. (2) After properly interrupting the load current, open the disconnecting device(s) for each source. (3) Wherever possible, visually verify that all blades of the disconnecting devices are fully open or that drawout-type circuit breakers are withdrawn to the fully disconnected position. (4) Release stored electrical energy. (5) Release or block stored mechanical energy. (6) Apply lockout/tagout devices in accordance with a documented and established policy. (7) Use an adequately rated test instrument to test each phase conductor or circuit part to verify it is de-energized. Test each phase conductor or circuit part both phase-to-phase and phase-to-ground. Before and after each test, determine that the test instrument is operating satisfactorily through verification on a known voltage source. Exception: On electrical systems over 1000 volts, noncontact test instruments shall be permitted to be used to test each phase conductor. Informational Note No. 1: See UL , Safety Requirements for Electrical Equipment for Measurement, Control, and Laboratory Use, Part 1: General Requirements, for rating, overvoltage category, and design requirements for voltage measurement and test instruments intended for use on electrical systems 1000 volts and below. Informational Note No. 2: For additional information on rating and design requirements for voltage detectors, refer to IEC , Live Working Voltage Detectors Part 1: Capacitive type to be used for voltages exceeding 1kV a.c., or IEC , Live Working Voltage Detectors Part 2: Resistive type to be used for voltages of 1kV to 36 kv a.c., or IEC , Live Working Voltage Detectors Part 3: Two-pole low voltage type. (8) Where the possibility of induced voltages or stored electrical energy exists, ground the phase conductors or circuit parts before touching them. Where it could be reasonably anticipated that the conductors or circuit parts being de-energized could contact other exposed energized conductors or circuit parts, apply temporary protective grounding equipment in accordance with the following: (9) Placement. Temporary protective grounding equipment shall be placed at such locations and arranged in such a manner as to prevent each employee from being exposed to a shock hazard (i.e., hazardous differences in electrical potential). The location, sizing, and application of temporary protective grounding equipment shall be identified as part of the employer's job planning. (10) Capacity. Temporary protective grounding equipment shall be capable of conducting the maximum fault current that could flow at the point of grounding for the time necessary to clear the fault. (11) Equipment Approval. Temporary protective grounding equipment shall meet the requirements of ASTM F855, Standard Specification for Temporary Protective Grounds to be Used on De-energized Electric Power Lines and Equipment. (12) Impedance. Temporary protective grounding equipment and connections shall have an impedance low enough to cause immediate operation of protective devices in case of unintentional energizing of the electric conductors or circuit parts.

142 27 of 403 9/2/2016 9:49 AM Statement of Problem and Substantiation for Public Comment The 8 steps listed are incomplete and do not establish an electrically safe work condition. They are an additional step in verifying that an electrically safe work condition has been established. It is inaccurate and misleading as written. Related Item First Revision No. 30-NFPA 70E-2015 [Article 120] Submitter Information Verification Submitter Full Name: Palmer Hickman Organization: Electrical Training Alliance Street Address: City: State: Zip: Submittal Date: Wed Apr 20 14:18:17 EDT 2016 Committee Statement Committee Action: Resolution: Rejected The committee reaffirms that the steps included in include both steps to establish and verify that an electrically safe work condition is established.

143 28 of 403 9/2/2016 9:49 AM Public Comment No. 100-NFPA 70E-2016 [ Section No ] General. Article 130 covers the following: (1) When an electrically safe work condition must be established (2) The electrical Requirements for working involving electrical hazards such as the electrical safetyrelated work practices, assessments, precautions, and procedures when an electrically safe work condition cannot be established All requirements of this article shall apply whether an incident energy analysis is completed or if Table 130.5, Table 130.7(C)(15)(a), Table 130.7(C)(15)(b), and Table 130.7(C)(15)(c) are used in lieu of an incident energy analysis in accordance with Statement of Problem and Substantiation for Public Comment Article 130 covers more than the two items as presently set forth in (1) and (2). This comment attempts to correlate this scope statement in with examples of what else is covered in Article 130. "Such as" was added to recognize this is not a complete list of what is covered by Article 130. Related Item First Revision No. 65-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: Palmer Hickman Organization: Electrical Training Alliance Street Address: City: State: Zip: Submittal Date: Wed Apr 20 14:26:35 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-26-NFPA 70E-2016 Statement: The description of items covered in 130.1(1) has been correlated to better match the content. The reference to the new Table has been deleted as it is no longer part of the PPE Category method. The reference to has been deleted since is not necessary.

144 29 of 403 9/2/2016 9:49 AM Public Comment No. 109-NFPA 70E-2016 [ Section No ] General. Article 130 covers the following: (1) When an electrically safe work condition must be established (2) The electrical safety-related work practices when an electrically safe work condition cannot be established All requirements of this article shall apply whether an incident energy analysis is completed or if Table 130.5, Table (C)(15)(a), Table 130.7(C)(15)(b), and Table 130.7(C)(15)(c) are used in lieu of an incident energy analysis in accordance with Statement of Problem and Substantiation for Public Comment This Public Comment is submitted by Daniel Roberts in behalf of the Canadian Standards Association (CSA) Z462 Workplace Electrical Safety Technical Committee. Errata: TerraView software added Table to this section. The associated PI # 335 did not add Table to this section. Section does not need to refer to the new Table as it is no longer part of the PPE Category method. Table is intended to be used when performing an arc flash risk assessment regardless of the method utilized to select PPE. There are two other references to Table in Section should also be deleted. Related Item First Revision No. 65-NFPA 70E-2015 [Section No ] Public Input No. 335-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: Daniel Roberts Organization: Schneider Electric Affilliation: CSA Z462 Technical Committee Street Address: City: State: Zip: Submittal Date: Fri Apr 22 11:58:28 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-26-NFPA 70E-2016 Statement: The description of items covered in 130.1(1) has been correlated to better match the content. The reference to the new Table has been deleted as it is no longer part of the PPE Category method. The reference to has been deleted since is not necessary.

145 30 of 403 9/2/2016 9:49 AM Public Comment No. 47-NFPA 70E-2016 [ Section No ] See Statement for CC Note General. Article 130 covers the following: (1) When an electrically safe work condition must be established (2) The electrical safety-related work practices when an electrically safe work condition cannot be established All requirements of this article shall apply whether an incident energy analysis is completed or if Table 130.5, Table 130.7(C)(15)(a), Table 130.7(C)(15)(b), and Table 130.7(C)(15)(c) are used in lieu of an incident energy analysis in accordance with Statement of Problem and Substantiation for Public Comment The Correlating Committee directs the committee to review the reference to and review all changes for clarity. Related Item First Revision No. 65-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: CC on NEC-AAC Organization: NFPA Street Address: City: State: Zip: Submittal Date: Mon Mar 14 16:19:41 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-26-NFPA 70E-2016 Statement: The description of items covered in 130.1(1) has been correlated to better match the content. The reference to the new Table has been deleted as it is no longer part of the PPE Category method. The reference to has been deleted since is not necessary.

146 31 of 403 9/2/2016 9:49 AM Public Comment No. 86-NFPA 70E-2016 [ Section No ] Electrically Safe Work Conditions. Energized electrical conductors and circuit parts operating at voltages equal to or greater than 50 Vac or 100 Vdc V shall be put into an electrically safe work condition before an employee performs work if any of the following conditions exist: (1) The employee is within the limited approach boundary. (2) The employee interacts with equipment where conductors or circuit parts are not exposed but an increased likelihood of injury from an exposure to an arc flash hazard exists. Exception: Where a disconnecting means or isolating element that has been properly installed and maintained is operated, opened, closed, removed, or inserted to achieve an electrically safe work condition for connected equipment or to return connected equipment to service that has been placed in an electrically safe work condition, the equipment supplying the disconnecting means or isolating element shall not be required to be placed in an electrically safe work condition provided a risk assessment is performed and does not identify unacceptable risks for the task. (A) Energized Work. (1) Additional Hazards or Increased Risk. Energized work shall be permitted where the employer can demonstrate that de-energizing introduces additional hazards or increased risk. Informational Note: Examples of additional hazards or increased risk include, but are not limited to, interruption of life-support equipment, deactivation of emergency alarm systems, and shutdown of hazardous location ventilation equipment. (2) Infeasibility. Energized work shall be permitted where the employer can demonstrate that the task to be performed is infeasible in a de-energized state due to equipment design or operational limitations. Informational Note: Examples of work that might be performed within the limited approach boundary of exposed energized electrical conductors or circuit parts because of infeasibility due to equipment design or operational limitations include performing diagnostics and testing (for example, start-up or troubleshooting) of electric circuits that can only be performed with the circuit energized and work on circuits that form an integral part of a continuous process that would otherwise need to be completely shut down in order to permit work on one circuit or piece of equipment. (3) Equipment Operating at Less Than 50 Vac or 100 Vdc V. Energized electrical conductors and circuit parts that operate at less than 50 Vac or 100 Vdc shall not be required to be de-energized where the capacity of the source and any overcurrent protection between the energy source and the worker are considered and it is determined that there will be no increased exposure to electrical burns or to explosion due to electric arcs.

147 32 of 403 9/2/2016 9:49 AM (4) Normal Operating Condition. Normal operation of electric equipment shall be permitted where a normal operating condition exists. A normal operating condition exists when all of the following conditions are satisfied: (1) The equipment is properly installed. (2) The equipment is properly maintained. (3) The equipment is used in accordance with instructions included in the listing and labeling and in accordance with manufacturer s instructions. (4) The equipment doors are closed and secured. (5) All equipment covers are in place and secured. (6) There is no evidence of impending failure. Informational Note: The phrase properly installed means that the equipment is installed in accordance with applicable industry codes and standards and the manufacturer's recommendations. The phrase properly maintained means that the equipment has been maintained in accordance with the manufacturer's recommendations and applicable industry codes and standards. The phrase evidence of impending failure means that there is evidence such as arcing, overheating, loose or bound equipment parts, visible damage, or deterioration. (B) Energized Electrical Work Permit. (1) When Required. When work is performed as permitted in accordance with 130.2(A), an energized electrical work permit shall be required and documented under the any of following conditions: (1) When work is performed within the restricted approach boundary (2) When the employee interacts with the equipment when conductors or circuit parts are not exposed but an increased likelihood of injury from an exposure to an arc flash hazard exists

148 33 of 403 9/2/2016 9:49 AM (2) Elements of Work Permit. The work permit shall include, but not be limited to, the following items: (1) Description of the circuit and equipment to be worked on and their location (2) Description of the work to be performed (3) Justification for why the work must be performed in an energized condition [see 130.2(A)] (4) Description of the safe work practices to be employed [see 130.3] (5) Results of the shock risk assessment [see 130.4(A)] (6) Voltage to which personnel will be exposed (7) Limited approach boundary [see 130.4(C), Table 130.4(C)(a), and Table 130.4(C)(b) ] (8) Restricted approach boundary [see 130.4(C), Table 130.4(C)(a), and Table 130.4(C)(b) ] (9) Personal and other protective equipment required by this standard to safely perform the assigned task and to protect against the shock hazard [see 130.4(D), 130.7(C)(1) through (C)(16), Table 130.5, Table 130.7(C)(15)(c), and 130.7(D) ] (10) Results of the arc flash risk assessment [see 130.5] (11) Available incident energy at the working distance or arc flash PPE category [see ] (12) Personal and other protective equipment required by this standard to protect against the arc flash [see 130.5(C), 130.7(C)(1) through (C)(16), Table 130.5, Table 130.7(C)(15)(c), and 130.7(D) ] (13) Arc flash boundary [see 130.5(B) ] (14) Means employed to restrict the access of unqualified persons from the work area [see 130.3] (15) Evidence of completion of a job briefing, including a discussion of any job-specific hazards [see 110.1(I)] (16) Energized work approval (authorizing or responsible management, safety officer, or owner, etc.) signature(s) Informational Note: For an example of an acceptable energized work permit, see Figure J.1. (3) Exemptions to Work Permit. Electrical work shall be permitted without an energized electrical work permit if a qualified person is provided with and uses appropriate safe work practices and PPE in accordance with Chapter 1 under any of the following conditions: (1) Testing, troubleshooting, or voltage measuring (2) Thermography, ultrasound, or visual inspections if the restricted approach boundary is not crossed (3) Access to and egress from an area with energized electrical equipment if no electrical work is performed and the restricted approach boundary is not crossed (4) General housekeeping and miscellaneous non-electrical tasks if the restricted approach boundary is not crossed Statement of Problem and Substantiation for Public Comment This comment is written to address Correlating Committee Note No. 19 which directs the Committee to review the 100V DC threshold with respect to correlation with OSHA and NEC requirements. No technical substantiation was provided to have NFPA 70E in direct conflict with NEC and OSHA requirements. Additionally, this action is in direct conflict with the reason NFPA 70E was created. In the Foreward to 70E, several problems areas are noted that drove the need "for a new standard, tailored to fulfill OSHA's responsibilities, that would still be fully consistent with the NEC."

149 34 of 403 9/2/2016 9:49 AM The action taken in FR 47 is in direct conflict with OSHA and NEC requirements. Related Public Comments for This Document Related Comment Relationship Public Comment No. 87-NFPA 70E-2016 [Section No ] Related Item First Revision No. 47-NFPA 70E-2015 [Section No ] Correlating Committee Note No. 19-NFPA 70E-2016 [Section No ] Submitter Information Verification Submitter Full Name: James Dollard Organization: IBEW Local Union 98 Street Address: City: State: Zip: Submittal Date: Tue Apr 12 15:51:42 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-27-NFPA 70E-2016 Statement: Establishing a voltage threshold of 100 Vdc in Chapter 1 conflicts with the OSHA regulations, such as (a)(1). The exception has been removed since normal operation is already permitted in 130.2(A)(4).

150 35 of 403 9/2/2016 9:49 AM Public Comment No. 139-NFPA 70E-2016 [ Section No [Excluding any Sub-Sections] ] Energized electrical conductors and circuit parts operating at voltages equal to or greater than 50 Vac or 100 Vdc shall be put into an electrically safe work condition before an employee performs work if any of the following conditions exist: (1) The employee is within the limited approach boundary. (2) The employee interacts with equipment where conductors or circuit parts are not exposed but an increased likelihood of injury from an exposure to an arc flash hazard exists. Exception: Where a disconnecting means or isolating element that, external to equipment being isolated, that has been properly installed and maintained is operated, opened, closed, removed, or inserted to achieve an electrically safe work condition for connected equipment or to return connected equipment to service that has been placed in an electrically safe work condition, the equipment supplying the disconnecting means or isolating element shall not be required to be placed in an electrically safe work condition provided a risk assessment is performed and does not identify unacceptable risks for the task. Statement of Problem and Substantiation for Public Comment The existing language has been misinterpreted to allow the line side of main circuit breakers to remain energized. This misunderstanding has led to at least one injury when the employer did not require the entire equipment to be deenergized. An arc flash hazard resulted and the worker was burned. There have been reports that NFPA 70E instructors are teaching this misapplication. PI 99 requested the entire exception be deleted since it no longer is needed and that remains the preferred action. But, if the TC continues to feel the language, which is redundant to 130.2(A)(4), is necessary, it should be clarified to prevent further injuries. Related Item Public Input No. 99-NFPA 70E-2015 [Section No [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: Bobby Gray Organization: Hoydar/Buck, Inc. Affilliation: None Street Address: City: State: Zip: Submittal Date: Wed Apr 27 17:40:17 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-27-NFPA 70E-2016 Statement: Establishing a voltage threshold of 100 Vdc in Chapter 1 conflicts with the OSHA regulations, such as (a)(1). The exception has been removed since normal operation is already permitted in 130.2(A)(4).

151 36 of 403 9/2/2016 9:49 AM Public Comment No. 172-NFPA 70E-2016 [ Section No [Excluding any Sub-Sections] ] Energized electrical conductors and circuit parts operating at voltages equal to or greater than 50 Vac or 100 Vdc shall be put into an electrically safe work condition before an employee performs work if any of the following conditions exist: (1) The employee is within the limited approach boundary. (2) The employee interacts with equipment where conductors or circuit parts are not exposed but an increased likelihood of injury from an exposure to an arc flash hazard exists. Exception: Where a disconnecting means or isolating element that has been properly installed and maintained is operated, opened, closed, removed, or inserted to achieve an electrically safe work condition for connected equipment or to return connected equipment to service that has been placed in an electrically safe work condition, the equipment supplying the disconnecting means or isolating element shall not be required to be placed in an electrically safe work condition provided a risk assessment is performed and does not identify unacceptable risks for the task. Statement of Problem and Substantiation for Public Comment The 100 volt DC threshold level is in conflict with existing OSHA standards. OSHA interprets all voltages above 50 volts as hazardous. Related Item First Revision No. 47-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: Jason Wolf Organization: Esco Group Street Address: City: State: Zip: Submittal Date: Fri May 13 15:06:43 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-27-NFPA 70E-2016 Statement: Establishing a voltage threshold of 100 Vdc in Chapter 1 conflicts with the OSHA regulations, such as (a)(1). The exception has been removed since normal operation is already permitted in 130.2(A)(4).

152 37 of 403 9/2/2016 9:49 AM Public Comment No. 45-NFPA 70E-2016 [ Section No [Excluding any Sub-Sections] ] See statment for CC Note Energized electrical conductors and circuit parts operating at voltages equal to or greater than 50 Vac or 100 Vdc shall be put into an electrically safe work condition before an employee performs work if any of the following conditions exist: (1) The employee is within the limited approach boundary. (2) The employee interacts with equipment where conductors or circuit parts are not exposed but an increased likelihood of injury from an exposure to an arc flash hazard exists. Exception: Where a disconnecting means or isolating element that has been properly installed and maintained is operated, opened, closed, removed, or inserted to achieve an electrically safe work condition for connected equipment or to return connected equipment to service that has been placed in an electrically safe work condition, the equipment supplying the disconnecting means or isolating element shall not be required to be placed in an electrically safe work condition provided a risk assessment is performed and does not identify unacceptable risks for the task. Statement of Problem and Substantiation for Public Comment The Correlating Committee directs the Committee to review the 100V DC threshold with respect to correlation with OSHA and NEC requirements. Related Item First Revision No. 47-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: CC on NEC-AAC Organization: NFPA Street Address: City: State: Zip: Submittal Date: Mon Mar 14 15:58:29 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-27-NFPA 70E-2016 Statement: Establishing a voltage threshold of 100 Vdc in Chapter 1 conflicts with the OSHA regulations, such as (a)(1). The exception has been removed since normal operation is already permitted in 130.2(A)(4).

153 38 of 403 9/2/2016 9:49 AM Public Comment No. 15-NFPA 70E-2016 [ Section No (A)(2) ] (2) Infeasibility. Energized work shall be permitted where the employer can demonstrate that the task to be performed is infeasible in a de-energized state due to equipment design or operational limitations. Informational Note: Examples of work that might be performed within the limited approach boundary of exposed energized electrical conductors or circuit parts because of infeasibility due to equipment design or operational limitations include performing visual inspections, infrared inspections, diagnostics and testing (for example, start-up or troubleshooting) of electric circuits that can only be performed with the circuit energized and work on circuits that form an integral part of a continuous process that would otherwise need to be completely shut down in order to permit work on one circuit or piece of equipment. Statement of Problem and Substantiation for Public Comment The example provided for Infeasibility was too narrow. Guidance with regard to visual and infrared inspections should be included so as to eliminate conjecture as to what is included in Infeasibility. Related Item First Revision No. 4-NFPA 70E-2015 [Definition: Arc Flash Hazard.] Submitter Information Verification Submitter Full Name: Steven Schuette Organization: Global Risk Consultants Street Address: City: State: Zip: Submittal Date: Thu Feb 25 16:34:08 EST 2016 Committee Statement Committee Action: Resolution: Rejected Visual inspections and infrared inspections, may or may not, be considered energized work, depending upon their demonstrated infeasibility.

154 39 of 403 9/2/2016 9:49 AM Public Comment No. 128-NFPA 70E-2016 [ Section No (A)(4) ] (4) Normal Operating Condition. Normal operation of electric equipment shall be permitted where a normal operating condition exists. A normal operating condition exists when all of the following conditions are satisfied are verfiied and documented by a qualified person : (1) The equipment is properly installed. (2) The equipment is properly maintained. (3) The equipment is used in accordance with instructions included in the listing and labeling and in accordance with manufacturer s instructions. (4) The equipment doors are closed and secured. (5) All equipment covers are in place and secured. (6) There is no evidence of impending failure. Informational Note: The phrase properly installed means that the equipment is installed in accordance with applicable industry codes and standards and the manufacturer's recommendations. The phrase properly maintained means that the equipment has been maintained in accordance with the manufacturer's recommendations and applicable industry codes and standards. The phrase evidence of impending failure means that there is evidence such as arcing, overheating, loose or bound equipment parts, visible damage, or deterioration. Additional Proposed Changes File Name NFPA_70E_2018_Public_Comment_to_FR_47_add_qualified_person_to_verify.docx Description Approved Verification of normal conditions by a qualified person Statement of Problem and Substantiation for Public Comment See attached file Related Item First Revision No. 47-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: Daleep Mohla Organization: DCM Electrical Consulting Serv Street Address: City: State: Zip: Submittal Date: Tue Apr 26 10:51:26 EDT 2016 Committee Statement

155 40 of 403 9/2/2016 9:49 AM Committee Action: Resolution: Rejected The proposed text would unnecessarily require documentation of the normal operating conditions. It already the responsibility of the employer to verify that equipment is in a normal operating condition.

156 FR-47, Section No , See FR-47 Revise the wording for Normal operation by adding verification by a qualified person as below.normal operation of electric equipment shall be permitted where a normal operating condition exists. A normal operating condition exists when all of the following conditions are verified and documented by a qualified person Comments: It may not be feasible for person operating the equipment to verify all the operating conditions are satisfied before conducting a normal operation. For example an operator trained and qualified to operate may not be qualified to determine if equipment has been properly installed and maintained. The added wording proposed would require a qualified person to verify and document that all the normal operating conditions are met before considering it as a normal operating condition ( (4) Normal Operation Operating Condition. Normal operation of electric equipment shall be permitted where a normal operating condition exists. A normal operating condition exists when all of the following conditions are verified and documented by a qualified person 1)The equipment is properly installed. (2)The equipment is properly maintained. (3)The equipment is used in accordance with instructions included in the listing and labeling and in accordance with manufacturer s instructions. (4)The equipment doors are closed and secured. (5)All equipment covers are in place and secured. (6)There is no evidence of impending failure. Informational Note: The phrase properly installed means that the equipment is installed inaccordance with applicable industry codesand standards and the manufacturer'srecommendations. The phrase properly maintainedmeans that the equipment has beenmaintained in accordance with the manufacturer's recommendations and applicable industry codes and standards. The phrase evidence of impending failure means that there is evidence such as arcing, overheating, loose or bound equipment parts, visible damage, or deterioration Rationale: This will enhance safety and make it clear that documentation of normal operating condition are verified and documented by a qualified person. (B) Energized Electrical Work Permit 3) Exemptions to Work Permit. An Electrical work shall be permitted without an energized electric al work permit under the following conditions (A ) Qualified Person shall not be required if a qualified person is provided with and uses appropriate safe work practices and PPE in accordance with Chapter 1 under any of the following conditions: (1)Testing, troubleshooting, and, or voltage measuring (2) Thermography And, ultrasound, or visual inspections if the restricted approach boundary is not crossed (B ) Unqualified Person (1) Access to and egress from an area with energized electrical equipment if no electrical work is performed and the limited approach boundary is not crossed (2) General housekeeping and miscellaneous non-electrical tasks if the limited approach boundary is not crossed Rationale: : This will enhance safety and make it clear that normal operating condition are verified and documented by a qualified person. As written only qualified persons wearing proper PPE can have access and egress or performing general house keeping and non electrical tasks. Unless these persons having egress and access are qualified, limit of approach has to be limited approach boundary consistent requirements for unqualified persons.

157 41 of 403 9/2/2016 9:49 AM Public Comment No. 65-NFPA 70E-2016 [ Section No (A)(4) ] (4) Normal Operating Condition. Normal operation of electric equipment shall be permitted where a normal operating condition exists. A normal operating condition exists when all of the following conditions are satisfied: (1) The equipment is properly installed. (2) The equipment is properly maintained. (3) The equipment is used in accordance with instructions included in the listing and labeling and in accordance with manufacturer s instructions. (4) The equipment doors are closed and secured. (5) All equipment covers are in place and secured. (6) There is no evidence of impending failure. (7) There are no other factors that would indicate an increased likelihood of failure such as equipment age, history of failures, manufacturers defects or design problems, etc. Informational Note: The phrase properly installed means that the equipment is installed in accordance with applicable industry codes and standards and the manufacturer's recommendations. The phrase properly maintained means that the equipment has been maintained in accordance with the manufacturer's recommendations and applicable industry codes and standards. The phrase evidence of impending failure means that there is evidence such as arcing, overheating, loose or bound equipment parts, visible damage, or deterioration. Statement of Problem and Substantiation for Public Comment I agree with the items listed would likely allow the equipment to be operated without incident but there are more factors to consider that what is listed. The added text will alert the reader to other factors to consider when deciding PPE and work practices when the equipment is considered to be in "Normal Condition". Related Item First Revision No. 47-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: David Pace Organization: Olin Corporation Affilliation: Self Street Address: City: State: Zip: Submittal Date: Thu Mar 17 15:39:26 EDT 2016 Committee Statement Committee Action: Rejected Resolution: The submitter s concerns are already adequately covered by list item 6.

158 42 of 403 9/2/2016 9:49 AM Public Comment No. 110-NFPA 70E-2016 [ Section No (B)(2) ] (2) Elements of Work Permit. The work permit shall include, but not be limited to, the following items: (1) Description of the circuit and equipment to be worked on and their location (2) Description of the work to be performed (3) Justification for why the work must be performed in an energized condition [see 130.2(A)] (4) Description of the safe work practices to be employed [see 130.3] (5) Results of the shock risk assessment [see 130.4(A)] (6) Voltage to which personnel will be exposed (7) Limited approach boundary [see 130.4( C a. D ), Table 130.4(C)(a), and Table 130.4(C)(b) ] b. Restricted approach boundary [see 130.4( C a. E ), Table 130.4(C)(a), and Table 130.4(C)(b) ] b. Personal and other protective equipment required by this standard to safely perform the assigned task and to protect against the shock hazard [see 130.4(D), 130.7(C)(1) through (C)(16), Table 130.5, Table 130.7(C)(15)(c), and 130.7(D) ] a. (8) Results of the arc flash risk assessment [see 130.5], Table 130. (9) Available incident energy at the working distance or arc flash PPE category [see ] (10) Personal and other protective equipment required by this standard to protect against the arc flash hazard [see 130.5(C), 130.7(C)(1) through (C)(16), Table a. 7(C)(15)(c), and 130.7(D) ] b. Arc flash boundary [see 130.5(B) ] (11) Means employed to restrict the access of unqualified persons from the work area [see 130.3] (12) Evidence of completion of a job briefing, including a discussion of any job-specific hazards [see 110.1(I)] (13) Energized work approval (authorizing or responsible management, safety officer, or owner, etc.) signature(s) Informational Note: For an example of an acceptable energized work permit, see Figure J.1. Statement of Problem and Substantiation for Public Comment This Public Comment is submitted by Daniel Roberts in behalf of the Canadian Standards Association (CSA) Z462 Workplace Electrical Safety Technical Committee. Errata

159 43 of 403 9/2/2016 9:49 AM Section 130.2(B)(2)(5)b The reference should be to Section 130.4(D) Section 130.2(B)(2)(5)c The reference should be to Section 130.4(E) Section 130.2(B)(2)(5)d Table 130.7(C)(15)(A)(a) and Table 130.7(C)(16) should be deleted as they do not apply to a shock risk assessment Section 130.2(B)(2)(6)b: The word hazard at the end of the sentence is not supposed to be deleted. The reference to Table should be deleted as this new Table does not describe or list arc flash PPE. Related Item First Revision No. 47-NFPA 70E-2015 [Section No ] Public Input No. 336-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: Daniel Roberts Organization: Schneider Electric Affilliation: CSA Z462 Technical Committee Street Address: City: State: Zip: Submittal Date: Fri Apr 22 12:16:41 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-28-NFPA 70E-2016 Statement: Section 130.2(B)(2)(5)b The reference is corrected to Section 130.4(D) Section 130.2(B)(2)(5)c The reference is corrected to Section 130.4(E) Section 130.2(B)(2)(5)(d) - The reference to Table has been deleted as this new Table does not describe or list arc flash PPE. Table 130.7(C)(15)(c) has been deleted as it does not apply to shock risk assessment. Section 130.2(B)(2)(6)b: The word hazard at the end of the sentence should not have been deleted in the first draft. The reference to Table has been deleted as this new Table does not describe or list arc flash PPE.

160 44 of 403 9/2/2016 9:49 AM Public Comment No. 205-NFPA 70E-2016 [ Section No (B)(3) ] (3) Exemptions to Work Permit. Electrical work shall be permitted without an energized electrical work permit if a under conditions A and B below: A. Diagnostic and Testing A qualified person is provided with and uses appropriate safe work practices and PPE in accordance with Chapter 1 under any of the following conditions: (1) Testing, troubleshooting, or voltage measuring (2) Thermography, ultrasound, or visual inspections if the restricted approach boundary is not crossed. B. Access, egress and Housekeeping (3) Acess to and egress from an area with energized electrical equipment if no electrical work is performed and the restricted approach (4) restricted approach boundary is not crossed (5) General housekeeping and miscellaneous non-electrical tasks if the restricted approach restricteed approach boundary is not crossed Statement of Problem and Substantiation for Public Comment The main text requires that the person is qualified and uses PPE for all items in the original text. Access and egriss from an area if no electrical work is performed and general housekeeping and miscellaneous non-electrical tasks do not require a person to be qualified or wear PPE if restricte approach boundary is not crossed. Related Item First Revision No. 47-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: Daryld Crow Organization: DRC Consulting, Ltd. Affilliation: DRC Consulting Street Address: City: State: Zip: Submittal Date: Mon May 16 16:36:45 EDT 2016 Committee Statement Committee Action: Rejected

161 45 of 403 9/2/2016 9:49 AM Resolution: The requirements of 130.2(B)(3) require compliance with Chapter 1 which would include but not be limited to application of 130.5(1) which requires an employer to determine if an arc flash hazard exists.

162 46 of 403 9/2/2016 9:49 AM Public Comment No. 66-NFPA 70E-2016 [ Section No (B)(3) ] (3) Exemptions to Work Permit. Electrical work shall be permitted without an energized electrical work permit if a qualified person is provided with and uses appropriate safe work practices and PPE in accordance with Chapter 1 under any of the following conditions: (1) Testing, troubleshooting, or voltage measuring (2) Thermography, ultrasound, or visual inspections if the restricted approach boundary is not crossed (3) Access to and egress from an area with energized electrical equipment if no electrical work is performed and the restricted approach boundary is not crossed (4) General housekeeping and miscellaneous non-electrical tasks if the restricted approach boundary is not crossed Statement of Problem and Substantiation for Public Comment There are plenty of cases where the Restricted Approach Boundary is crossed and the job does not require a permit, an example would be landing a wire on a terminal strip with only low capacity 120 Vac present, typical in machine control panels, lighting, controls, etc. This type work is done many times every day. There is no improved level of safety for this work by requiring a permit vs performing the work without a permit. As I have said many times, the trigger for requiring a permit is not what equipment is involved or where you are in relation to boundaries, the trigger is what type work is being done and what the impact is on the likelihood that the work will cause harm to the individual. The permit is intended for high risk, high likelihood jobs. As long as the Restricted Approach Boundary is in the text, there will continue to be problems in understanding how to apply the requirement and simply ignoring the requirement for those jobs that cross the boundary that do not require a permit. we will have to add more and more text to allow work without a permit for more and more specific tasks, the list will never end, and this is not the correct application of the permit requirement. Related Item First Revision No. 47-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: David Pace Organization: Olin Corporation Affilliation: Self Street Address: City: State: Zip: Submittal Date: Thu Mar 17 15:47:31 EDT 2016 Committee Statement Committee Action: Rejected Resolution: The restricted approach boundary is an appropriate trigger for the tasks described.

163 47 of 403 9/2/2016 9:49 AM Public Comment No. 46-NFPA 70E-2016 [ Section No (A) ] See statment for CC Note (A) General. A shock risk assessment shall be performed as follows: (1) To identify shock hazards. (2) To estimate the likelihood of occurrence of injury or damage to health and the potential severity of injury or damage to health. (3) To determine if additional protective measures are required, including the use of PPE. If additional protective measures are required, including the use of PPE, the following shall be identified: (4) The voltage to which personnel will be exposed (5) The boundary requirements (6) The personal and other protective equipment required by this standard to protect against the shock hazard Statement of Problem and Substantiation for Public Comment The Correlating Committee directs the TC to review the terms identify and identified and clarify the method intended to identify. Related Item First Revision No. 32-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: CC on NEC-AAC Organization: NFPA Street Address: City: State: Zip: Submittal Date: Mon Mar 14 16:00:16 EDT 2016 Committee Statement Committee Action: Resolution: Statement: Rejected but see related SR SR-29-NFPA 70E-2016 PC-46 Additional Response: The Committee has reviewed the use of the term "identify" and confirms that it is used in accordance with the context of hazard identification. A risk assessment is a process that begins with hazard identification (See definition of risk assessment in Article 100). The term "identified" was changed to "determined" for clarity. The revision is made to correlate with the structure of Arc Flash Risk Assessment.

164 48 of 403 9/2/2016 9:49 AM Public Comment No. 9-NFPA 70E-2016 [ Section No (A) ] (A) General. A shock risk assessment shall be performed as follows: (1) To identify shock hazards. (2) To estimate the likelihood of occurrence of injury or damage to health and the potential severity of injury or damage to health. (3) To determine if additional protective measures are required, including the use of PPE. If additional protective measures are required, based upon (H) including the use of PPE, the following shall be identified: (4) The voltage to which personnel will be exposed (5) The boundary requirements (6) The personal and other protective equipment required by this standard to protect against the shock hazard Statement of Problem and Substantiation for Public Comment Add new sentence after required," "based upon (H) to (A)(3) for clarity or insert the 130.5(3) language If additional protective measures are required. Document clarity based upon a risk assessment. Related Item First Revision No. 32-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: Drake Drobnick Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Wed Feb 24 22:29:27 EST 2016 Committee Statement Committee Action: Resolution: Statement: Rejected but see related SR SR-29-NFPA 70E-2016 PC-46 Additional Response: The Committee has reviewed the use of the term "identify" and confirms that it is used in accordance with the context of hazard identification. A risk assessment is a process that begins with hazard identification (See definition of risk assessment in Article 100). The term "identified" was changed to "determined" for clarity. The revision is made to correlate with the structure of Arc Flash Risk Assessment.

165 49 of 403 9/2/2016 9:49 AM Public Comment No. 135-NFPA 70E-2016 [ Section No (E) ]

166 50 of 403 9/2/2016 9:49 AM (E) Restricted Approach Boundary.

167 51 of 403 9/2/2016 9:49 AM No qualified person shall approach or take any conductive object closer to exposed energized electrical conductors or circuit parts than the restricted approach boundary set forth in Table 130.4(C)(a) and Table 130.4(C)(b), unless one of the following conditions applies: (1) The qualified person is insulated or guarded from energized electrical conductors or circuit parts. (2) The energized electrical conductors or circuit parts are insulated from the qualified person and from any other conductive object at a different potential. Table 130.4(C)(a) Shock Protection Approach Boundaries to Exposed Energized Electrical Conductors or Circuit Parts for Alternating-Current Systems (1) (2) (3) (4) Nominal System Voltage Range, Phase to Phase a Limited Approach Boundary b Exposed Movable Conductor c Exposed Fixed Circuit Part Less than 50 V Not specified Not specified Not specified 50 V 150 V d 3.0 m (10 ft 0 in.) 1.0 m (3 ft 6 in.) Avoid contact 151 V 750 V 3.0 m (10 ft 0 in.) 1.0 m (3 ft 6 in.) 0.3 m (1 ft 0 in.) 751 V 15 kv 3.0 m (10 ft 0 in.) 1.5 m (5 ft 0 in.) 0.7 m (2 ft 2 in.) 15.1 kv 36 kv 3.0 m (10 ft 0 in.) 1.8 m (6 ft 0 in.) 0.8 m (2 ft 7 in.) 36.1 kv 46 kv 3.0 m (10 ft 0 in.) 2.5 m (8 ft 0 in.) 0.8 m (2 ft 9 in.) 46.1 kv 72.5 kv 3.0 m (10 ft 0 in.) 2.5 m (8 ft 0 in.) 1.0 m (3 ft 3 in.) 72.6 kv 121 kv 3.3 m (10 ft 8 in.) 2.5 m (8 ft 0 in.) 1.0 m (3 ft 4 in.) 138 kv 145 kv 3.4 m (11 ft 0 in.) 3.0 m (10 ft 0 in.) 1.2 m (3 ft 10 in.) 161 kv 169 kv 3.6 m (11 ft 8 in.) 3.6 m (11 ft 8 in.) 1.3 m (4 ft 3 in.) 230 kv 242 kv 4.0 m (13 ft 0 in.) 4.0 m (13 ft 0 in.) 1.7 m (5 ft 8 in.) 345 kv 362 kv 4.7 m (15 ft 4 in.) 4.7 m (15 ft 4 in.) 2.8 m (9 ft 2 in.) Restricted Approach Boundary b ; Includes Inadvertent Movement Adder 500 kv 550 kv 5.8 m (19 ft 0 in.) 5.8 m (19 ft 0 in.) 3.6 m (11 ft 10 in.) 765 kv 800 kv 7.2 m (23 ft 9 in.) 7.2 m (23 ft 9 in.) 4.9 m (15 ft 11 in.) Note(1): For arc flash boundary, see 130.5(A). Note (2): All dimensions are distance from exposed energized electrical conductors or circuit part to employee. a For single-phase systems above 250V, select the range that is equal to the system s maximum phaseto-ground voltage multiplied by b See definition in Article 100 and text in 130.4(D)(2) and Informative Annex C for elaboration. c Exposed movable conductors describes a condition in which the distance between the conductor and a person is not under the control of the person. The term is normally applied to overhead line conductors supported by poles. d This includes circuits where the exposure does not exceed 120V nominal. Table 130.4(C)(b) Shock Protection Approach Boundaries to Exposed Energized Electrical Conductors or Circuit Parts for Direct-Current Voltage Systems (1) (2) (3) (4) Nominal Potential Difference Limited Approach Boundary Exposed Movable Conductor * Exposed Fixed Circuit Part Less than 100 V Not specified Not specified Not specified Restricted Approach Boundary; Includes Inadvertent Movement Adder

168 52 of 403 9/2/2016 9:49 AM (1) (2) (3) (4) Nominal Potential Difference Limited Approach Boundary Exposed Movable Conductor * Exposed Fixed Circuit Part 100 V 300 V 3.0 m (10 ft 0 in.) 1.0 m (3 ft 6 in.) Avoid contact 301 V 1 kv 3.0 m (10 ft 0 in.) 1.0 m (3 ft 6 in.) 0.3 m (1 ft 0 in.) 1.1 kv 5 kv 3.0 m (10 ft 0 in.) 1.5 m (5 ft 0 in.) 0.5 m (1 ft 5 in.) 5 kv 15 kv 3.0 m (10 ft 0 in.) 1.5 m (5 ft 0 in.) 0.7 m (2 ft 2 in.) 15.1 kv 45 kv 3.0 m (10 ft 0 in.) 2.5 m (8 ft 0 in.) 0.8 m (2 ft 9 in.) 45.1 kv 75 kv 3.0 m (10 ft 0 in.) 2.5 m (8 ft 0 in.) 1.0 m (3 ft 2 in.) 75.1 kv 150 kv 3.3 m (10 ft 8 in.) 3.0 m (10 ft 0 in.) 1.2 m (4 ft 0 in.) kv 250 kv 3.6 m (11 ft 8 in.) 3.6 m (11 ft 8 in.) 1.6 m (5 ft 3 in.) kv 500 kv 6.0 m (20 ft 0 in.) 6.0 m (20 ft 0 in.) 3.5 m (11 ft 6 in.) kv 800 kv 8.0 m (26 ft 0 in.) 8.0 m (26 ft 0 in.) 5.0 m (16 ft 5 in.) Restricted Approach Boundary; Includes Inadvertent Movement Adder Note: All dimensions are distance from exposed energized electrical conductors or circuit parts to worker. * Exposed movable conductor describes a condition in which the distance between the conductor and a person is not under the control of the person. The term is normally applied to overhead line conductors supported by poles. Statement of Problem and Substantiation for Public Comment The 100 Volt DC shock threshold should be maintained and not revised back to 50VDC. There is no substantiation for changing this shock threshold to 50 VDC. The 100 V for DC as a shock threshold is well substantiated by 70 years of published research by Charles F. Dalziel who performed 1000s of let-go-threshold tests on 100s of men, women and children, for DC, and from 1 to Hz.. Dalziel used extreme conditions for testing, hand-to-hand tests used hands soaked with salt water, hands-to-feet used subjects standing barefoot in 1 inch of salt water. Under these extreme conditions, he proposed the following let-go- threshold and "reasonably safe" voltage levels: 50/60 Hz rms AC threshold for let-go, 36.9 V, 50/60 Hz AC reasonably safe, 21 V rms AC for reasonably safe; DC threshold for let-go, V; DC reasonably safe, V. ["Let-Go Currents and Voltages" C.F. Dalziel and F.P. Massoglia, Transactions of the American Institute of Electrical Engineers, Part II Vol. 75, pp , May 1956] OSHA and UL later developed various thresholds for 60 HZ AC safety based on Dalziel's work, of levels such as 50 V and 30 V. But, remember that OSHA is considering the standard workplace and not standing barefoot in salt water. Note that the DC voltage levels for safety, provided by Dalziel are 3 to 4 times that of 60 Hz AC. The IEC standard does quote and use Dalziel's work. Also note that there is no true let-gothreshold for DC. Dalziel chose the values based on the pain experienced by the test subjects upon letting go. Related Item First Revision No. 76-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: John McAlhaney Organization: Savannah River Nuclear Sol. Affilliation: Savannah River Nuclear Solutions Street Address: City: State: Zip: Submittal Date: Wed Apr 27 04:43:34 EDT 2016 Committee Statement

169 53 of 403 9/2/2016 9:49 AM Committee Rejected but see related SR Action: Resolution: SR-70-NFPA 70E-2016 Statement: The restricted approach boundary distances were adjusted for consistency throughout the tables. In Table 130.4(D)(b), 100 Vdc was changed to 50 Vdc to be in compliance with the OSHA regulations, such as (a)(1).

170 54 of 403 9/2/2016 9:49 AM Public Comment No. 171-NFPA 70E-2016 [ Section No (E) ]

171 55 of 403 9/2/2016 9:49 AM (E) Restricted Approach Boundary.

172 56 of 403 9/2/2016 9:49 AM No qualified person shall approach or take any conductive object closer to exposed energized electrical conductors or circuit parts than the restricted approach boundary set forth in Table 130.4(C)(a) and Table 130.4(C)(b), unless one of the following conditions applies: (1) The qualified person is insulated or guarded from energized electrical conductors or circuit parts operating at 50 volts or more. Insulating gloves and sleeves are considered insulation only with regard to the energized parts upon which work is performed. (2) The energized electrical conductors or circuit parts are insulated from the qualified person and from any other conductive object at a different potential. Table 130.4(C)(a) Shock Protection Approach Boundaries to Exposed Energized Electrical Conductors or Circuit Parts for Alternating-Current Systems (1) (2) (3) (4) Nominal System Voltage Range, Phase to Phase a Limited Approach Boundary b Exposed Movable Conductor c Exposed Fixed Circuit Part Less than 50 V Not specified Not specified Not specified 50 V 150 V d 3.0 m (10 ft 0 in.) 1.0 m (3 ft 6 in.) Avoid contact 151 V 750 V 3.0 m (10 ft 0 in.) 1.0 m (3 ft 6 in.) 0.3 m (1 ft 0 in.) 751 V 15 kv 3.0 m (10 ft 0 in.) 1.5 m (5 ft 0 in.) 0.7 m (2 ft 2 in.) 15.1 kv 36 kv 3.0 m (10 ft 0 in.) 1.8 m (6 ft 0 in.) 0.8 m (2 ft 7 in.) 36.1 kv 46 kv 3.0 m (10 ft 0 in.) 2.5 m (8 ft 0 in.) 0.8 m (2 ft 9 in.) 46.1 kv 72.5 kv 3.0 m (10 ft 0 in.) 2.5 m (8 ft 0 in.) 1.0 m (3 ft 3 in.) 72.6 kv 121 kv 3.3 m (10 ft 8 in.) 2.5 m (8 ft 0 in.) 1.0 m (3 ft 4 in.) 138 kv 145 kv 3.4 m (11 ft 0 in.) 3.0 m (10 ft 0 in.) 1.2 m (3 ft 10 in.) 161 kv 169 kv 3.6 m (11 ft 8 in.) 3.6 m (11 ft 8 in.) 1.3 m (4 ft 3 in.) 230 kv 242 kv 4.0 m (13 ft 0 in.) 4.0 m (13 ft 0 in.) 1.7 m (5 ft 8 in.) 345 kv 362 kv 4.7 m (15 ft 4 in.) 4.7 m (15 ft 4 in.) 2.8 m (9 ft 2 in.) 500 kv 550 kv 5.8 m (19 ft 0 in.) 5.8 m (19 ft 0 in.) 3.6 m (11 ft 10 in.) 765 kv 800 kv 7.2 m (23 ft 9 in.) 7.2 m (23 ft 9 in.) 4.9 m (15 ft 11 in.) Restricted Approach Boundary b ; Includes Inadvertent Movement Adder Note(1): For arc flash boundary, see 130.5(A). Note (2): All dimensions are distance from exposed energized electrical conductors or circuit part to employee. a For single-phase systems above 250V, select the range that is equal to the system s maximum phaseto-ground voltage multiplied by b See definition in Article 100 and text in 130.4(D)(2) and Informative Annex C for elaboration. c Exposed movable conductors describes a condition in which the distance between the conductor and a person is not under the control of the person. The term is normally applied to overhead line conductors supported by poles. d This includes circuits where the exposure does not exceed 120V nominal. Table 130.4(C)(b) Shock Protection Approach Boundaries to Exposed Energized Electrical Conductors or Circuit Parts for Direct-Current Voltage Systems (1) (2) (3) (4) Nominal Potential Limited Approach Boundary Restricted Approach Boundary;

173 57 of 403 9/2/2016 9:49 AM Difference Exposed Movable Conductor * Exposed Fixed Circuit Part Less than 100 V Not specified Not specified Not specified 100 V 300 V 3.0 m (10 ft 0 in.) 1.0 m (3 ft 6 in.) Avoid contact 301 V 1 kv 3.0 m (10 ft 0 in.) 1.0 m (3 ft 6 in.) 0.3 m (1 ft 0 in.) 1.1 kv 5 kv 3.0 m (10 ft 0 in.) 1.5 m (5 ft 0 in.) 0.5 m (1 ft 5 in.) 5 kv 15 kv 3.0 m (10 ft 0 in.) 1.5 m (5 ft 0 in.) 0.7 m (2 ft 2 in.) 15.1 kv 45 kv 3.0 m (10 ft 0 in.) 2.5 m (8 ft 0 in.) 0.8 m (2 ft 9 in.) 45.1 kv 75 kv 3.0 m (10 ft 0 in.) 2.5 m (8 ft 0 in.) 1.0 m (3 ft 2 in.) 75.1 kv 150 kv 3.3 m (10 ft 8 in.) 3.0 m (10 ft 0 in.) 1.2 m (4 ft 0 in.) kv 250 kv 3.6 m (11 ft 8 in.) 3.6 m (11 ft 8 in.) 1.6 m (5 ft 3 in.) kv 500 kv 6.0 m (20 ft 0 in.) 6.0 m (20 ft 0 in.) 3.5 m (11 ft 6 in.) kv 800 kv 8.0 m (26 ft 0 in.) 8.0 m (26 ft 0 in.) 5.0 m (16 ft 5 in.) Includes Inadvertent Movement Adder Note: All dimensions are distance from exposed energized electrical conductors or circuit parts to worker. * Exposed movable conductor describes a condition in which the distance between the conductor and a person is not under the control of the person. The term is normally applied to overhead line conductors supported by poles. Statement of Problem and Substantiation for Public Comment With the removal of the 50 volt threshold and the reference to insulating gloves, it is unclear when insulating gloves/sleeves are required. New language in the shock risk assessment, clearly reference other protective measures and PPE, but does not specifically reference insulated gloves as PPE (C)(7) Hand and Arm Protection, references insulated gloves..where there is a danger of hand injury from electric shock.. However this section does not reference the restricted approach. The definition for restricted approach boundary uses the statement increased likelihood of electric shock.. The meaning of danger and increased likelihood is not the same, and may add to the confusion as to when insulated gloves are required. Related Item First Revision No. 32-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: Jason Wolf Organization: Esco Group Street Address: City: State: Zip: Submittal Date: Fri May 13 15:01:39 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-30-NFPA 70E-2016 Statement: Establishing a voltage threshold where insulation for personal protection is required adds clarity to the standard.

174 58 of 403 9/2/2016 9:49 AM Public Comment No. 111-NFPA 70E-2016 [ Section No ] Arc Flash Risk Assessment.

175 59 of 403 9/2/2016 9:49 AM An arc flash risk assessment shall be performed and shall comply with 130.5(1) through 130.5(3). (1) General. An arc flash risk assessment shall be performed as follows: (2) To identify arc flash hazards (3) To estimate the likelihood of occurrence of injury or damage to health and the potential severity of injury or damage to health (4) To determine if additional protective measures are required, including the use of PPE (5) Estimate of Likelihood and Severity. The estimate of the likelihood of occurrence of injury or damage to health and the potential severity of injury or damage to health shall take into consideration the following: (6) The design of the electrical equipment, including its overcurrent protective device and its operating time (7) The electrical equipment operating condition and condition of maintenance Table shall be permitted to be used to estimate the likelihood of occurrence of an arc flash event. (8) Additional Protective Measures. If additional protective measures are required they shall be selected and implemented according to the hierarchy of risk control identified in 110.1(G). When the additional protective measures include the use of PPE, the following shall be identified: (9) Appropriate safety-related work practices (10) The arc flash boundary (11) The PPE to be used within the arc flash boundary Informational Note No. 1: Improper or inadequate maintenance can result in increased fault clearing time of the overcurrent protective device, thus increasing the incident energy. Where equipment is not properly installed or maintained, PPE selection based on incident energy analysis or the PPE category method might not provide adequate protection from arc flash hazards. Informational Note No. 2: Both larger and smaller available fault currents could result in higher incident energy. If the available fault current increases without a decrease in the fault clearing time of the overcurrent protective device, the incident energy will increase. If the available fault current decreases, resulting in a longer fault clearing time for the overcurrent protective device, incident energy could also increase. Informational Note No. 3: 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. Equipment and design practices are available to minimize the energy levels and the number of procedures that could expose an employee to high levels of incident energy. Proven designs such as arc-resistant switchgear, remote racking (insertion or removal), remote opening and closing of switching devices, high-resistance grounding of low-voltage and 5000 volts (nominal) systems, current limitation, and specification of covered bus or covered conductors within equipment are available to reduce the risk associated with an arc flash incident. See Informative Annex O for Safety-Related Design Requirements. Informational Note No. 4: For additional direction for performing maintenance on overcurrent protective devices, see Chapter 2, Safety-Related Maintenance Requirements. Informational Note No. 5: See IEEE 1584, Guide for Performing Arc Flash Calculations, for more information regarding incident energy and the arc flash boundary for three-phase systems. Table Estimate of the Likelihood of Occurrence of an Arc Flash Incident for ac and dc Systems Task Equipment Condition* Likelihood of Occurrence

176 Task Equipment Condition* Likelihood of Occurrence Reading a panel meter while operating a meter switch. No Low Any Performing infrared thermography and other non-contact inspections outside the restricted approach boundary. This activity does not include opening of doors or covers. Working on control circuits with exposed energized electrical conductors and circuit parts, nominal 125 volts ac or dc, or below without any other exposed energized equipment over nominal 125 volts ac or dc, including opening of hinged covers to gain access. Examination of insulated cable with no manipulation of cable. For dc systems, insertion or removal of individual cells or multi-cell units of a battery system in an open rack. For dc systems, maintenance on a single cell of a battery system or multi-cell units in an open rack. For dc systems, working on energized electrical conductors and circuit parts of series-connected battery cells, including voltage testing. Any Yes high Removal or installation of CBs or switches. Opening hinged door(s) or cover(s) or removal of bolted covers (to expose bare, energized electrical conductors and circuit parts). For dc systems, this includes bolted covers, such as battery terminal covers. Application of temporary protective grounding equipment, after voltage test. Working on control circuits with exposed energized electrical conductors and circuit parts, greater than 120 volts. Insertion or removal of individual starter buckets from MCC. Insertion or removal (racking) of CBs or starters from cubicles, doors open or closed. Insertion or removal of plug-in devices into or from busways. Examination of insulated cable with manipulation of cable. Working on exposed energized electrical conductors and circuit parts of equipment directly supplied by a panelboard or motor control center. Insertion or removal of revenue meters (kw-hour, at primary voltage and current). Removal of battery conductive intercell connector covers. For dc systems, working on exposed energized electrical conductors and circuit parts of utilization equipment directly supplied by a dc source. Opening voltage transformer or control power transformer compartments. Operation of outdoor disconnect switch (hookstick operated) at 1 kv through 15 kv. Operation of outdoor disconnect switch (gang-operated, from grade) at 1 kv through 15 kv. Operation of a circuit breaker (CB), switch, contactor or starter. No Voltage testing on individual battery cells or individual multi-cell units. low Removal or installation of covers for equipment such as wireways, junction boxes, and cable trays that does not expose bare, energized electrical conductors and circuit parts. Opening a panelboard hinged door or cover to access dead front overcurrent devices. Normal 60 of 403 9/2/2016 9:49 AM

177 Removal of battery nonconductive intercell connector covers. Maintenance and testing on individual battery cells or individual multi-cell units in an open rack Yes Insertion or removal of individual cells or multi-cell units of a battery system in an open rack. high Abnormal Arc-resistant switchgear Type 1 or 2 (for clearing times of < 0.5 sec with a prospective fault current not to exceed the arc-resistant rating of the equipment) and metal enclosed interrupter switchgear, fused or unfused of arc resistant type construction, tested in accordance with CSA C22.2 No. 022 or IEEE C : Insertion or removal (racking) of CBs from cubicles; Insertion or removal (racking) of ground and test device; or Insertion or removal (racking) of voltage transformers on or off the bus Notes: *Equipment condition is considered to be normal if all of the following circumstances apply: (1) The equipment is properly installed in accordance with the manufacturer's recommendations and applicable industry codes and standards. (2) The equipment is properly maintained in accordance with the manufacturer's recommendations and applicable industry codes and standards. (3) The equipment is used in accordance with instructions included in the listing and labeling and in accordance with manufacturer s instructions. (4) Equipment doors are closed and secured. (5) Equipment covers are in place and secured. (6) There is no evidence of impending failure such as arcing, overheating, loose or bound equipment parts, visible damage, or deterioration As defined in this standard, the two components of risk are the likelihood of occurrence of injury or damage to health and the severity of injury or damage to health that results from a hazard. Risk assessment is an overall process that includes estimates of the likelihood of occurrence of injury or damage to health. The estimate of the likelihood of occurrence contained in this table does not cover every possible condition or situation. Where this table identifies No Low for likelihood of occurrence, it means that an arc flash incident is not likely to occur and additional protective measures are discretionary. Where this table identifies Yes High for likelihood of occurrence, it means that additional protective measures are required to be selected and implemented according to the hierarchy of risk control identified in 110.1(G). (A) Documentation. The results of the arc flash risk assessment shall be documented. (B) Arc Flash Boundary. (1) The arc flash boundary shall be the distance at which the incident energy equals1.2 cal/cm 2 (5 J/cm 2 ). Informational Note: For information on estimating the arc flash boundary, see Informative Annex D. (2) The arc flash boundary shall be permitted to be determined by Table 130.7(C)(15)(a) or Table 130.7(C) (15)(b) when the requirements of these tables apply. 61 of 403 9/2/2016 9:49 AM

178 62 of 403 9/2/2016 9:49 AM (C) Arc Flash PPE. One of the following methods shall be used for the selection of arc flash PPE: (1) The incident energy analysis method in accordance with 130.5(D) (2) The arc flash PPE category method in accordance with 130.7(C)(15) Either, but not both, methods shall be permitted to be used on the same piece of equipment. The results of an incident energy analysis to specify an arc flash PPE Category in Table 130.7(C)(15)(c) shall not be permitted.

179 63 of 403 9/2/2016 9:49 AM (D) Incident Energy Analysis Method. The incident energy exposure level shall be based on the working distance of the employee s face and chest areas from a prospective arc source for the specific task to be performed. Arc-rated clothing and other PPE shall be used by the employee based on the incident energy exposure associated with the specific task. Recognizing that incident energy increases as the distance from the arc flash decreases, additional PPE shall be used for any parts of the body that are closer than the working distance at which the incident energy was determined. The incident energy analysis shall take into consideration the characteristics of the overcurrent protective device and its fault clearing time, including its condition of maintenance. The incident energy analysis shall be updated when changes occur in the electrical distribution system that could affect the results of the analysis. The incident energy analysis shall also be reviewed for accuracy at intervals not to exceed 5 years. Table 130.5(D) identifies the arc-rated clothing and other PPE requirements of Article 130 and shall be permitted to be used with the incident energy analysis method of selecting arc flash PPE. Informational Note: For information on estimating the incident energy, see Informative Annex D. For information on selection of arc-rated clothing and other PPE, see Table H.3(b) in Informative Annex H. Table 130.5(D) Selection of Arc-Rated Clothing and Other PPE When the Incident Energy Analysis Method Is Used Incident energy exposures equal to 1.2 cal/cm 2 up to 12 cal/cm 2 Arc-rated clothing with an arc rating equal to or greater than the estimated incident energy a 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 Leather 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/cm 2 Arc-rated clothing with an arc rating equal to or greater than the estimated incident energy a Long-sleeve shirt and pants or coverall or arc flash suit (SR) Arc-rated arc flash suit hood 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 in group is required. a Arc ratings can be for a single layer, such as an arc-rated shirt and pants or a coverall, or for an arc 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. b Face 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. c Rubber 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.

180 64 of 403 9/2/2016 9:49 AM (E) Equipment Labeling. Electrical equipment such as switchboards, panelboards, industrial control panels, meter socket enclosures, and motor control centers that are in other than dwelling units and that are likely to require examination, adjustment, servicing, or maintenance while energized shall be marked with a label containing all the following information: (1) Nominal system voltage (2) Arc flash boundary (3) At least one of the following: (4) 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 (5) Minimum arc rating of clothing (6) Site-specific level of PPE Exception No. 1: Unless changes in 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 the standard in effect at the time the labels were applied. Exception No. 2: In supervised industrial installations where conditions of maintenance and engineering supervision ensure that only qualified persons monitor and service the system, the information required in (E)(1) through (E)(3) shall be permitted to be documented in a manner that is readily available to persons likely to perform examination, servicing, maintenance, and operation of the equipment while energized. The method of calculating and the data to support the information for the label shall be documented. The data shall be reviewed for accuracy at intervals not to exceed 5 years. Where the review of the data identifies a change that renders the label inaccurate, the label shall be updated. The owner of the electrical equipment shall be responsible for the documentation, installation, and maintenance of the marked label. Additional Proposed Changes File Name Description Approved 0B_Low_Probability_High_Risk.pptx see attachment # 1 review in note form for details Risk_Assessment_Paper.pdf Risk Assessment Paper attachment Statement of Problem and Substantiation for Public Comment Using no and yes provides misleading guidance to the users of this document. No is an absolute term signifying an arc flash will not occur. Notes under the table explain that the term no means an arc flash is not likely to occur. Low is a better term and correctly conveys the intent that an arc flash is not likely to occur. Similarly yes is an absolute term which implies an arc flash will occur. Instead of using the word yes, high is a better term to indicate the likelihood of an arc flash is high. Change the Likelihood of Occurrence column in table Change no to low and yes to high. This change will agree with the language in annex F and articles and papers written on risk assessment. Change the notes as proposed in this comment from no and yes to the terms low and high respectively. This will provide clarity and explicit guidance to the users on how to use this table to clarify the terms low and high The revised wording will be consistent with the wording used in annex F and multiple technical papers on this topic. Not likely (or low) does not mean an arc flash will not occur. Low likelihood/high Consequence situations cause the same injuries as High Likelihood/ High Consequences when the event happens and prudent avoidance and PPE are not used when the incident energy is 1.2 cal/cm2 and above.

181 65 of 403 9/2/2016 9:49 AM Add an additional note stating employer is accountable to decide when additional measures are required. Ultimately OSHA holds the employer accountable for the action of their employees, therefore the employer should decide how much risk their employees are allowed to take. Related Item Public Input No. 190-NFPA 70E-2015 [Section No (C)(15)(A)] Submitter Information Verification Submitter Full Name: Daryld Crow Organization: DRC Consulting, Ltd. Street Address: City: State: Zip: Submittal Date: Sun Apr 24 17:25:47 EDT 2016 Committee Statement Committee Action: Resolution: Rejected The use of Yes or No in Table Column 3 provides significant clarity and is consistent with the title of Column 3 and will be more useful to users of the document than "Low" or "High" or similar terms. The intent of Yes or No is adequately explained in the Table Note. The use of these suggested terms would introduce significant ambiguity and confusion. The use of the term Low for example would infer that any interaction with any component of an electrical system, is inherently dangerous and would require additional protective measures.

182 RISK MANAGEMENT Where are you today? Where will you be tomorrow? D. Ray Crow DRC Consulting, Ltd. Phone:

183 Risk. A combination of the likelihood of occurrence of injury or damage to health and the severity of injury or damage to health that results from a hazard. 2

184 Risk Assessment. An overall process that identifies hazards, estimates the potential severity of injury or damage to health, estimates the likelihood of occurrence of injury or damage to health, and determines if protective measures are required. 3

185 Risk Assessment. Informational Note: As used in this standard, arc flash risk assessment and shock risk assessment are types of risk assessments. 4

186 Risk Assessment R I S K Low Probability High Consequence High Consequence Low Probability Low Consequence High Probability High Consequence High Probability Low Consequence Frequency

187 Risk Assessment R I S K Low Probability High Consequence Low Probability Low Consequence High Probability High Consequence High Probability Low Consequence Frequency

188 Low Probability/High Consequence Low Probability/High Consequence situations produce the same injuries as High Probability/High Consequence situations if the risk has not been mitigated and the event happens. To indicate NO (zero) risk, when there is low risk or even extremely low risk, is simply inaccurate and dangerous to the employee.

189 Low Probability/High Consequence If an arc flash does occur this will provide a high risk of injury to the person interacting with the equipment. It is not correct to state that no arc flash PPE is required when one interacts with energized equipment that has an incident energy exposure of 1.2 cal/cm 2 and above. Arc flash PPE protection and prudent avoidance should be used to mitigate the risk.

190 Risk Assessment Low Probability High Consequence High Probability High Consequence Low Probability Low Consequence High Probability Low Consequence Do you believe that if the energized equipment is properly installed, properly maintained, all doors are closed, and there is no evidence of impending failure then arc flash PPE is not required? Your Beliefs will Drive Your Behavior!

191 Low Probability/High Consequence How can you determine the equipment is properly installed? Just because it has been in service for 20 years does not guarantee that it was installed properly. How can you know the equipment is properly maintained? Even if records or labels indicate recommended maintenance was done, this does not assure it was done properly. The possibility of human error can exist in the installation, inspection, and maintenance of electrical installations.

192 Low Probability/High Consequence We all know arc flashes are not caused by improper installations and lack of or improper maintenance alone. Unfortunately, things outside of the worker's control can also cause arc flashes and accidents and these issues require the need for minimal PPE above 1.2 cal/cm 2.

193 Low Probability/High Consequence

194 Risk Assessment High Consequence Low Probability High Consequence High Probability Low Consequence Low Probability Low Consequence High Probability

195 66 of 403 9/2/2016 9:49 AM Public Comment No. 101-NFPA 70E-2016 [ Section No [Excluding any Sub-Sections] ]

196 67 of 403 9/2/2016 9:49 AM An arc flash risk assessment shall be performed and shall comply with 130.5(1) through 130.5(3). (1) General. An arc flash risk assessment shall be performed as follows: (2) To identify arc flash hazards (3) To estimate the likelihood of occurrence of injury or damage to health and the potential severity of injury or damage to health (4) To determine if additional protective measures are required, including the use of PPE (5) Estimate of Likelihood and Severity. The estimate of the likelihood of occurrence of injury or damage to health and the potential severity of injury or damage to health shall take into consideration the following: (6) The design of the electrical equipment, including its overcurrent protective device and its operating time (7) The electrical equipment operating condition and condition of maintenance Table shall be permitted to be used to estimate the likelihood of occurrence of an arc flash event. (8) Additional Protective Measures. If additional protective measures are required they shall be selected and implemented according to the hierarchy of risk control identified in 110.1(G). When the additional protective measures include the use of PPE, the following shall be identified: (9) Appropriate safety-related work practices (10) The arc flash boundary (11) The PPE to be used within the arc flash boundary Informational Note No. 1: Improper or inadequate maintenance can result in increased fault clearing time of the overcurrent protective device, thus increasing the incident energy. Where equipment is not properly installed or maintained, PPE selection based on incident energy analysis or the PPE category method might not provide adequate protection from arc flash hazards. Informational Note No. 2: Both larger and smaller available fault currents could result in higher incident energy. If the available fault current increases without a decrease in the fault clearing time of the overcurrent protective device, the incident energy will increase. If the available fault current decreases, resulting in a longer fault clearing time for the overcurrent protective device, incident energy could also increase. Informational Note No. 3: 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. Equipment and design practices are available to minimize the energy levels and the number of procedures that could expose an employee to high levels of incident energy. Proven designs such as arc-resistant switchgear, remote racking (insertion or removal), remote opening and closing of switching devices, high-resistance grounding of low-voltage and 5000 volts (nominal) systems, current limitation, and specification of covered bus or covered conductors within equipment are available to reduce the risk associated with an arc flash incident. See Informative Annex O for Safety-Related Design Requirements. Informational Note No. 4: For additional direction for performing maintenance on overcurrent protective devices, see Chapter 2, Safety-Related Maintenance Requirements. Informational Note No. 5: See IEEE 1584, Guide for Performing Arc Flash Calculations, for more information regarding incident energy and the arc flash boundary for three-phase systems. Table Estimate of the 5 Likelihood of Occurrence of an Arc Flash Incident for ac and dc Systems Task Equipment Condition* Likelihood of Occurrence

197 68 of 403 9/2/2016 9:49 AM Task Reading a panel meter while operating a meter switch. Equipment Condition* Likelihood of Occurrence Performing infrared thermography and other non-contact inspections outside the restricted approach boundary. This activity does not include opening of doors or covers. Working on control circuits with exposed energized electrical conductors and circuit parts, nominal 125 volts ac or dc, or below without any other exposed energized equipment over nominal 125 volts ac or dc, including opening of hinged covers to gain access. Examination of insulated cable with no manipulation of cable. For dc systems, insertion or removal of individual cells or multi-cell units of a battery system in an open rack. For dc systems, maintenance on a single cell of a battery system or multi-cell units in an open rack. For dc systems, working on energized electrical conductors and circuit parts of series-connected battery cells, including voltage testing. Any Any No Yes Removal or installation of CBs or switches. Opening hinged door(s) or cover(s) or removal of bolted covers (to expose bare, energized electrical conductors and circuit parts). For dc systems, this includes bolted covers, such as battery terminal covers. Application of temporary protective grounding equipment, after voltage test. Working on control circuits with exposed energized electrical conductors and circuit parts, greater than 120 volts. Insertion or removal of individual starter buckets from MCC. Insertion or removal (racking) of CBs or starters from cubicles, doors open or closed. Insertion or removal of plug-in devices into or from busways. Examination of insulated cable with manipulation of cable. Working on exposed energized electrical conductors and circuit parts of equipment directly supplied by a panelboard or motor control center. Insertion or removal of revenue meters (kw-hour, at primary voltage and current). Removal of battery conductive intercell connector covers. For dc systems, working on exposed energized electrical conductors and circuit parts of utilization equipment directly supplied by a dc source. Opening voltage transformer or control power transformer compartments. Operation of outdoor disconnect switch (hookstick operated) at 1 kv through 15 kv. Operation of outdoor disconnect switch (gang-operated, from grade) at 1 kv through 15 kv. Operation of a circuit breaker (CB), switch, contactor or starter. Normal No Voltage testing on individual battery cells or individual multi-cell units. Removal or installation of covers for equipment such as wireways, junction boxes, and cable trays that does not expose bare, energized electrical conductors and circuit parts. Opening a panelboard hinged door or cover to access dead front overcurrent devices. Removal of battery nonconductive intercell connector covers.

198 69 of 403 9/2/2016 9:49 AM Task Maintenance and testing on individual battery cells or individual multi-cell units in an open rack Insertion or removal of individual cells or multi-cell units of a battery system in an open rack. Arc-resistant switchgear Type 1 or 2 (for clearing times of < 0.5 sec with a prospective fault current not to exceed the arc-resistant rating of the equipment) and metal enclosed interrupter switchgear, fused or unfused of arc resistant type construction, tested in accordance with CSA C22.2 No. 022 or IEEE C : Insertion or removal (racking) of CBs from cubicles; Insertion or removal (racking) of ground and test device; or Insertion or removal (racking) of voltage transformers on or off the bus Notes: Equipment Condition* Abnormal Likelihood of Occurrence Yes *Equipment condition is considered to be normal if all of the following circumstances apply: (1) The equipment is properly installed in accordance with the manufacturer's recommendations and applicable industry codes and standards. (2) The equipment is properly maintained in accordance with the manufacturer's recommendations and applicable industry codes and standards. (3) The equipment is used in accordance with instructions included in the listing and labeling and in accordance with manufacturer s instructions. (4) Equipment doors are closed and secured. (5) Equipment covers are in place and secured. (6) There is no evidence of impending failure such as arcing, overheating, loose or bound equipment parts, visible damage, or deterioration As defined in this standard, the two components of risk are the likelihood of occurrence of injury or damage to health and the severity of injury or damage to health that results from a hazard. Risk assessment is an overall process that includes estimates of the likelihood of occurrence of injury or damage to health. The estimate of the likelihood of occurrence contained in this table does not cover every possible condition or situation. Where this table identifies No for likelihood of occurrence, it means that an arc flash incident is not likely to occur. Where this table identifies Yes for likelihood of occurrence, it means that additional protective measures are required to be selected and implemented according to the hierarchy of risk control identified in 110.1(G). Statement of Problem and Substantiation for Public Comment "Estimate of" was removed in two locations for correlation. Likelihood was used in columns and notes without "estimate of" and it appears the intent was that likelihood was intended to replace an estimate and that using both might be somewhat redundant. In any case the use of the term and phrase should probably be correlated either way for usability. Related Item First Revision No. 60-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: Palmer Hickman Organization: Electrical Training Alliance Street Address: City: State:

199 70 of 403 9/2/2016 9:49 AM Zip: Submittal Date: Wed Apr 20 14:46:50 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-31-NFPA 70E-2016 ADDITIONAL RESPONSE TO PC 44: In accordance with the direction from the Correlating Committee, the committee has reviewed the list of requirements in 130.5(2) and concludes that no revisions are required. The committee has also reviewed the phrase "incident energy analysis method of selecting arc flash PPE" and concludes that no revisions are required as this phrase is understood and has been used in the document for some time. ADDITIONAL RESPONSE TO PC 68: The suggested revision to mandate a new incident energy analysis be performed each time a method is revised or developed is not included in this revision. This requirement would mandate a new incident energy analysis if an existing method is revised or a new method is introduced for consideration. Statement: Section has been revised into eight first level subdivisions for compliance with the NEC style manual. The redundant use of the phrase an arc flash risk assessment shall be performed is eliminated. The committee has revised the reference to Table for clarity and has relocated the reference to Table to immediately precede the Table. Section Informational Notes 1 through 5 have been relocated below Table and the Table note in order to avoid separating the Table from the driving text. The Note for Normal Equipment Condition is relocated into Table to facilitate correlation to the Normal and Abnormal equipment conditions identified in Column 2. Table Note has been revised for clarity and to correlate use of the term estimate with its use in 130.5(A) and 130.5(B). The term estimate is used as both a verb (i.e. to estimate likelihood or estimating the likelihood ) and a noun (i.e. the estimate of ) in the document. Table 130.5: several First Revision Draft errors are corrected: In the second horizontal Table section the first listed task For ac systems, work on energized electrical conductors and circuit parts, including voltage testing is restored The horizontal line between the tasks Removal of battery nonconductive intercell connector covers and Maintenance and testing on individual battery cells or individual multi-cell units in an open rack is removed. The tasks in Table in the First Revision Draft were incorrectly divided into four horizontal sections; however, there are intended to be only three horizontal sections. The third section includes 11 tasks beginning with Operation of a circuit breaker (CB), switch, contactor or starter and finishing with Insertion or removal (racking) of voltage transformers on or off the bus. The less than numerical symbol in the arc-resistant switchgear task has been replaced by the phrase less than in accordance with the Global First Revision # (D) Incident Energy Analysis Method Informational Note now references all of Annex H to correlate with the relocation of Table H.3(b) into Table 130.5(G): Revised "Leather gloves" to "Heavy duty leather gloves" to correlate with 130.7(C) (10)(d)(1). Add a line in each section of Table 130.5(G) regarding arc rated outerwear (e.g. jacket, parka, rainwear, hard hat liner) (AN).

200 71 of 403 9/2/2016 9:49 AM Public Comment No. 112-NFPA 70E-2016 [ Section No [Excluding any Sub-Sections] ]

201 72 of 403 9/2/2016 9:49 AM An arc flash risk assessment shall be performed and shall comply comply with 130.5(1) through 130.5(3). (1) General. An arc flash risk assessment shall be performed as follows: (2) To identify arc flash hazards (3) To estimate the likelihood of occurrence of injury or damage to health and the potential severity of injury or damage to health (4) To determine if additional protective measures are required, including the use of PPE (5) Estimate of Likelihood and Severity. The estimate of the likelihood of occurrence of injury or damage to health and the potential severity of injury or damage to health shall take into consideration the following: (6) The design of the electrical equipment, including its overcurrent protective device and its operating time (7) The electrical equipment operating condition and condition of maintenance Table shall be permitted to be used to estimate the likelihood of occurrence of an arc flash event. (8) Additional Protective Measures. If additional protective measures are required they shall be selected and implemented according to the hierarchy of risk control identified in 110.1(G). When the additional protective measures include the use of PPE, the following shall be identified: (9) Appropriate safety-related work practices (10) The arc flash boundary (11) The PPE to be used within the arc flash boundary Informational Note No. 1: Improper or inadequate maintenance can result in increased fault clearing time of the overcurrent protective device, thus increasing the incident energy. Where equipment is not properly installed or maintained, PPE selection based on incident energy analysis or the PPE category method might not provide adequate protection from arc flash hazards. Informational Note No. 2: Both larger and smaller available fault currents could result in higher incident energy. If the available fault current increases without a decrease in the fault clearing time of the overcurrent protective device, the incident energy will increase. If the available fault current decreases, resulting in a longer fault clearing time for the overcurrent protective device, incident energy could also increase. Informational Note No. 3: 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. Equipment and design practices are available to minimize the energy levels and the number of procedures that could expose an employee to high levels of incident energy. Proven designs such as arc-resistant switchgear, remote racking (insertion or removal), remote opening and closing of switching devices, high-resistance grounding of low-voltage and 5000 volts (nominal) systems, current limitation, and specification of covered bus or covered conductors within equipment are available to reduce the risk associated with an arc flash incident. See Informative Annex O for Safety-Related Design Requirements. Informational Note No. 4: For additional direction for performing maintenance on overcurrent protective devices, see Chapter 2, Safety-Related Maintenance Requirements. Informational Note No. 5: See IEEE 1584, Guide for Performing Arc Flash Calculations, for more information regarding incident energy and the arc flash boundary for three-phase systems. Table Estimate of the Likelihood of Occurrence of an Arc Flash Incident for ac and dc Systems Task Equipment Condition* Likelihood of Occurrence

202 73 of 403 9/2/2016 9:49 AM Task Reading a panel meter while operating a meter switch. Performing infrared thermography and other non-contact inspections outside the restricted approach boundary. This activity does not include opening of doors or covers. Working on control circuits with exposed energized electrical conductors and circuit parts, nominal 125 volts ac or dc, or below without any other exposed energized equipment over nominal 125 volts ac or dc, including opening of hinged covers to gain access. Examination of insulated cable with no manipulation of cable. For dc systems, insertion or removal of individual cells or multi-cell units of a battery system in an open rack. For dc systems, maintenance on a single cell of a battery system or multi-cell units in an open rack. For ac systems, work on energized electrical condustors and circuit parts, including voltage testing For dc systems, working on energized electrical conductors and circuit parts of series-connected battery cells, including voltage testing. Equipment Condition* Any Any Likelihood of Occurrence No Yes Removal or installation of CBs or switches. Opening hinged door(s) or cover(s) or removal of bolted covers (to expose bare, energized electrical conductors and circuit parts). For dc systems, this includes bolted covers, such as battery terminal covers. Application of temporary protective grounding equipment, after voltage test. Working on control circuits with exposed energized electrical conductors and circuit parts, greater than 120 volts. Insertion or removal of individual starter buckets from MCC. Insertion or removal (racking) of CBs or starters from cubicles, doors open or closed. Insertion or removal of plug-in devices into or from busways. Examination of insulated cable with manipulation of cable. Working on exposed energized electrical conductors and circuit parts of equipment directly supplied by a panelboard or motor control center. Insertion or removal of revenue meters (kw-hour, at primary voltage and current). Removal of battery conductive intercell connector covers. For dc systems, working on exposed energized electrical conductors and circuit parts of utilization equipment directly supplied by a dc source. Opening voltage transformer or control power transformer compartments. Operation of outdoor disconnect switch (hookstick operated) at 1 kv through 15 kv. Operation of outdoor disconnect switch (gang-operated, from grade) at 1 kv through 15 kv. Operation of a circuit breaker (CB), switch, contactor or starter. Normal No Voltage testing on individual battery cells or individual multi-cell units. Removal or installation of covers for equipment such as wireways, junction boxes, and cable trays that does not expose bare, energized electrical conductors and circuit parts. Opening a panelboard hinged door or cover to access dead front overcurrent devices.

203 74 of 403 9/2/2016 9:49 AM Task Removal of battery nonconductive intercell connector covers. [Errata: Delete the horizontal line below. All rows from "Operation of a circuit breaker (CB)... up to " Insertion or removal (racking) of voltage transformers on or off the bus" is one table section, not two] Maintenance and testing on individual battery cells or individual multi-cell units in an open rack Insertion or removal of individual cells or multi-cell units of a battery system in an open rack. Arc-resistant switchgear Type 1 or 2 (for clearing times of < 0 less than 0.5 sec with a prospective fault current not to exceed the arc-resistant rating of the equipment) and metal enclosed interrupter switchgear, fused or unfused of arc resistant type construction, tested in accordance with CSA C22.2 No. 022 or IEEE C : Insertion or removal (racking) of CBs from cubicles; Insertion or removal (racking) of ground and test device; or Insertion or removal (racking) of voltage transformers on or off the bus Notes: Equipment Condition* Abnormal Likelihood of Occurrence Yes *Equipment condition is considered to be normal if all of the following circumstances apply: (1) The equipment is properly installed in accordance with the manufacturer's recommendations and applicable industry codes and standards. (2) The equipment is properly maintained in accordance with the manufacturer's recommendations and applicable industry codes and standards. (3) The equipment is used in accordance with instructions included in the listing and labeling and in accordance with manufacturer s instructions. (4) Equipment doors are closed and secured. (5) Equipment covers are in place and secured. (6) There is no evidence of impending failure such as arcing, overheating, loose or bound equipment parts, visible damage, or deterioration As defined in this standard, the two components of risk are the likelihood of occurrence of injury or damage to health and the severity of injury or damage to health that results from a hazard. Risk assessment is an overall process that includes estimates of the likelihood of occurrence of injury or damage to health. The estimate of the likelihood of occurrence contained in this table does not cover every possible condition or situation. Where this table identifies No for likelihood of occurrence, it means that an arc flash incident is not likely to occur. Where this table identifies Yes for likelihood of occurrence, it means that additional protective measures are required to be selected and implemented according to the hierarchy of risk control identified in 110.1(G). Statement of Problem and Substantiation for Public Comment This Public Comment is submitted by Daniel Roberts in behalf of the Canadian Standards Association (CSA) Z462 Workplace Electrical Safety Technical Committee. Errata (1) The phrase shall be performed and was supposed to be deleted in Article lead in sentence as it was moved to the first level subdivision (1) General. (2) In the second horizontal Table section the first listed task For ac systems, work on energized electrical conductors and circuit parts, including voltage testing is missing. (3) The tasks in Table appears to be divided into four horizontal sections; however, there are intended to be only three horizontal sections. The third section includes 11 tasks beginning with Operation of a circuit breaker (CB), switch, contactor or starter and finishing with Insertion or removal (racking) of voltage transformers on or off the bus. The horizontal line

204 75 of 403 9/2/2016 9:49 AM between the tasks Removal of battery nonconductive intercell connector covers and Maintenance and testing on individual battery cells or individual multi-cell units in an open rack needs to be removed. The horizontal line between Normal No and Abnormal Yes needs to remain. (4) The less than operator in the Arc-resistant switchgear task wasn t replaced by text (See FR # 88). Related Item First Revision No. 60-NFPA 70E-2015 [Section No ] Public Input No. 340-NFPA 70E-2015 [Section No ] First Revision No. 88-NFPA 70E-2015 [Global Input] Submitter Information Verification Submitter Full Name: Daniel Roberts Organization: Schneider Electric Affilliation: CSA Z462 Technical Committee Street Address: City: State: Zip: Submittal Date: Mon Apr 25 10:20:50 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-31-NFPA 70E-2016 ADDITIONAL RESPONSE TO PC 44: In accordance with the direction from the Correlating Committee, the committee has reviewed the list of requirements in 130.5(2) and concludes that no revisions are required. The committee has also reviewed the phrase "incident energy analysis method of selecting arc flash PPE" and concludes that no revisions are required as this phrase is understood and has been used in the document for some time. ADDITIONAL RESPONSE TO PC 68: The suggested revision to mandate a new incident energy analysis be performed each time a method is revised or developed is not included in this revision. This requirement would mandate a new incident energy analysis if an existing method is revised or a new method is introduced for consideration. Statement: Section has been revised into eight first level subdivisions for compliance with the NEC style manual. The redundant use of the phrase an arc flash risk assessment shall be performed is eliminated. The committee has revised the reference to Table for clarity and has relocated the reference to Table to immediately precede the Table. Section Informational Notes 1 through 5 have been relocated below Table and the Table note in order to avoid separating the Table from the driving text. The Note for Normal Equipment Condition is relocated into Table to facilitate correlation to the Normal and Abnormal equipment conditions identified in Column 2. Table Note has been revised for clarity and to correlate use of the term estimate with its use in 130.5(A) and 130.5(B). The term estimate is used as both a verb (i.e. to estimate likelihood or estimating the likelihood ) and a noun (i.e. the estimate of ) in the document. Table 130.5: several First Revision Draft errors are corrected: In the second horizontal Table section the first listed task For ac systems, work on energized electrical conductors and circuit parts, including voltage testing is restored The horizontal line between the tasks Removal of battery nonconductive intercell connector covers and Maintenance and testing on individual battery cells or individual multi-cell units in an

205 76 of 403 9/2/2016 9:49 AM open rack is removed. The tasks in Table in the First Revision Draft were incorrectly divided into four horizontal sections; however, there are intended to be only three horizontal sections. The third section includes 11 tasks beginning with Operation of a circuit breaker (CB), switch, contactor or starter and finishing with Insertion or removal (racking) of voltage transformers on or off the bus. The less than numerical symbol in the arc-resistant switchgear task has been replaced by the phrase less than in accordance with the Global First Revision # (D) Incident Energy Analysis Method Informational Note now references all of Annex H to correlate with the relocation of Table H.3(b) into Table 130.5(G): Revised "Leather gloves" to "Heavy duty leather gloves" to correlate with 130.7(C) (10)(d)(1). Add a line in each section of Table 130.5(G) regarding arc rated outerwear (e.g. jacket, parka, rainwear, hard hat liner) (AN).

206 77 of 403 9/2/2016 9:49 AM Public Comment No. 143-NFPA 70E-2016 [ Section No [Excluding any Sub-Sections] ]

207 78 of 403 9/2/2016 9:49 AM An arc flash risk assessment shall be performed and shall comply with 130.5(1) through 130.5(3). (1) General. An arc flash risk assessment shall be performed as follows: (2) To identify arc flash hazards (3) To estimate the likelihood of occurrence of injury or damage to health and the potential severity of injury or damage to health (4) To determine if additional protective measures are required, including the use of PPE (5) Estimate of Likelihood and Severity. The estimate of the likelihood of occurrence of injury or damage to health and the potential severity of injury or damage to health shall take into consideration the following: (6) The design of the electrical equipment, including its overcurrent protective device and its operating time (7) The electrical equipment operating condition and condition of maintenance Table shall be permitted to be used to estimate the likelihood of occurrence of an arc flash event. (8) Additional Protective Measures. If additional protective measures are required they shall be selected and implemented according to the hierarchy of risk control identified in 110.1(G). When the additional protective measures include the use of PPE, the following shall be identified: (9) Appropriate safety-related work practices (10) The arc flash boundary (11) The PPE to be used within the arc flash boundary Informational Note No. 1: Improper or inadequate maintenance can result in increased fault clearing time of the overcurrent protective device, thus increasing the incident energy. Where equipment is not properly installed or maintained, PPE selection based on incident energy analysis or the PPE category method might not provide adequate protection from arc flash hazards. Informational Note No. 2: Both larger and smaller available fault currents could result in higher incident energy. If the available fault current increases without a decrease in the fault clearing time of the overcurrent protective device, the incident energy will increase. If the available fault current decreases, resulting in a longer fault clearing time for the overcurrent protective device, incident energy could also increase. Informational Note No. 3: 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. Equipment and design practices are available to minimize the energy levels and the number of procedures that could expose an employee to high levels of incident energy. Proven designs such as arc-resistant switchgear, remote racking (insertion or removal), remote opening and closing of switching devices, high-resistance grounding of low-voltage and 5000 volts (nominal) systems, current limitation, and specification of covered bus or covered conductors within equipment are available to reduce the risk associated with an arc flash incident. See Informative Annex O for Safety-Related Design Requirements. Informational Note No. 4: For additional direction for performing maintenance on overcurrent protective devices, see Chapter 2, Safety-Related Maintenance Requirements. Informational Note No. 5: See IEEE 1584, Guide for Performing Arc Flash Calculations, for more information regarding incident energy and the arc flash boundary for three-phase systems. Table Estimate of the Likelihood of Occurrence of an Arc Flash Incident for ac and dc Systems Task Equipment Condition* Likelihood of Occurrence

208 79 of 403 9/2/2016 9:49 AM Task Reading a panel meter while operating a meter switch. Performing infrared thermography and other non-contact inspections outside the restricted approach boundary. This activity does not include opening of doors or covers. Working on control circuits with exposed energized electrical conductors and circuit parts, nominal 125 volts ac or dc, or below without any other exposed energized equipment over nominal 125 volts ac or dc, including opening of hinged covers to gain access. Examination of insulated cable with no manipulation of cable. For dc systems, insertion or removal of individual cells or multi-cell units of a battery system in an open rack. For dc systems, maintenance on a single cell of a battery system or multi-cell units in an open rack. For dc systems, working on energized electrical conductors and circuit parts of series-connected battery cells, including voltage testing. Removal or installation of CBs or switches. Opening hinged door(s) or cover(s) or removal of bolted covers (to expose bare, energized electrical conductors and circuit parts). For dc systems, this includes bolted covers, such as battery terminal covers. Application of temporary protective grounding equipment, after voltage test. Working on control circuits with exposed energized electrical conductors and circuit parts, greater than 120 volts. Insertion or removal of individual starter buckets from MCC. Insertion or removal (racking) of CBs or starters from cubicles, doors open or closed. Insertion or removal of plug-in devices into or from busways. Examination of insulated cable with manipulation of cable. Working on exposed energized electrical conductors and circuit parts of equipment directly supplied by a panelboard or motor control center. Insertion or removal of revenue meters (kw-hour, at primary voltage and current). Removal of battery conductive intercell connector covers. For dc systems, working on exposed energized electrical conductors and circuit parts of utilization equipment directly supplied by a dc source. Opening voltage transformer or control power transformer compartments. Operation of outdoor disconnect switch (hookstick operated) at 1 kv through 15 kv. Operation of outdoor disconnect switch (gang-operated, from grade) at 1 kv through 15 kv. Equipment Condition* Any Any Likelihood of Occurrence Operation of a circuit breaker (CB), switch, contactor or starter. Normal No Voltage testing on individual battery cells or individual multi-cell units. Removal or installation of covers for equipment such as wireways, junction boxes, and cable trays that does not expose bare, energized electrical conductors and circuit parts. Opening a panelboard hinged door or cover to access dead front overcurrent devices. Removal of battery nonconductive intercell connector covers. No Yes

209 80 of 403 9/2/2016 9:49 AM Task Maintenance and testing on individual battery cells or individual multi-cell units in an open rack Insertion or removal of individual cells or multi-cell units of a battery system in an open rack. Arc-resistant switchgear Type 1 or 2 (for clearing times of < 0.5 sec with a prospective fault current not to exceed the arc-resistant rating of the equipment) and metal enclosed interrupter switchgear, fused or unfused of arc resistant type construction, tested in accordance with CSA C22.2 No. 022 or IEEE C : Insertion or removal (racking) of CBs from cubicles; Insertion or removal (racking) of ground and test device; or Insertion or removal (racking) of voltage transformers on or off the bus Notes: Equipment Condition* Abnormal Likelihood of Occurrence Yes *Equipment condition is considered to be normal if all of the following circumstances apply: (1) The equipment is properly installed in accordance with the manufacturer's recommendations and applicable industry codes and standards. (2) The equipment is properly maintained in accordance with the manufacturer's recommendations and applicable industry codes and standards. (3) The equipment is used in accordance with instructions included in the listing and labeling and in accordance with manufacturer s instructions. (4) Equipment doors are closed and secured. (5) Equipment covers are in place and secured. (6) There is no evidence of impending failure such as arcing, overheating, loose or bound equipment parts, visible damage, or deterioration The employer is accountable for the safety of employees. The employer shall ensure equipment is properly installed and maintained T he employer should require arc flash PPE and ensure that each of these conditions are proven before allowing employees to perform the task without PPE As defined in this standard, the two components of risk are the likelihood of occurrence of injury or damage to health and the severity of injury or damage to health that results from a hazard. Risk assessment is an overall process that includes estimates of the likelihood of occurrence of injury or damage to health. The estimate of the likelihood of occurrence contained in this table does not cover every possible condition or situation. Where this table identifies No for likelihood of occurrence, it means that an arc flash incident is not likely to occur. Where this table identifies Yes for likelihood of occurrence, it means that additional protective measures are required to be selected and implemented according to the hierarchy of risk control identified in 110.1(G). Additional Proposed Changes File Name Description Approved OSHA_269_Letter_to_DRC_ doc Attachment # 1 Statement of Problem and Substantiation for Public Comment requires the employer to ensure equipment is properly installed and maintained. Adding the statement as proposed in public input 441 will make 70E language consistent with OSHA The committee statement on resolution states that applies only to generation, transmission, and distribution. This is a common misconception that only applies to utilities. This understanding is not correct. See attached OSHA letter of interpretation 08/29/1995 clarifying that does apply to industrial installations with generation, transmission, or distribution.

210 81 of 403 9/2/2016 9:49 AM Related Item Public Input No. 441-NFPA 70E-2015 [Section No (C)(15)(A)] Submitter Information Verification Submitter Full Name: Daryld Crow Organization: DRC Consulting, Ltd. Street Address: City: State: Zip: Submittal Date: Wed Apr 27 19:19:28 EDT 2016 Committee Statement Committee Action: Resolution: Rejected The proposed revision does not add clarity. It is well understood that the employer is responsible (see section 105.3) for safety in the workplace. The adequacy of personal protective equipment is addressed elsewhere in this standard including but not limited to section The adequacy of electrical equipment is addressed by the installation standard NFPA 70 (NEC) and referenced in first level subdivision 110.1(B). Maintenance is the responsibility of the equipment owner.

211 82 of 403 9/2/2016 9:49 AM Public Comment No. 194-NFPA 70E-2016 [ Section No [Excluding any Sub-Sections] ]

212 83 of 403 9/2/2016 9:49 AM An arc flash risk assessment shall be performed and shall comply with 130.5(1) through 130.5(3). (1) General. An arc flash risk assessment shall be performed as follows: (2) To identify arc flash hazards (3) To estimate the likelihood of occurrence of injury or damage to health and the potential severity of injury or damage to health (4) To determine if additional protective measures are required, including the use of PPE (5) Estimate of Likelihood and Severity. The estimate of the likelihood of occurrence of injury or damage to health and the potential severity of injury or damage to health shall take into consideration the following: (6) The design of the electrical equipment, including its overcurrent protective device and its operating time (7) The electrical equipment operating condition and condition of maintenance Table shall be permitted to be used to estimate the likelihood of occurrence of an arc flash event. (8) Additional Protective Measures. If additional protective measures are required they shall be selected and implemented according to the hierarchy of risk control identified in 110.1(G). When the additional protective measures include the use of PPE, the following shall be identified: (9) Appropriate safety-related work practices (10) The arc flash boundary (11) The PPE to be used within the arc flash boundary Informational Note No. 1: Improper or inadequate maintenance can result in increased fault clearing time of the overcurrent protective device, thus increasing the incident energy. Where equipment is not properly installed or maintained, PPE selection based on incident energy analysis or the PPE category method might not provide adequate protection from arc flash hazards. Informational Note No. 2: Both larger and smaller available fault currents could result in higher incident energy. If the available fault current increases without a decrease in the fault clearing time of the overcurrent protective device, the incident energy will increase. If the available fault current decreases, resulting in a longer fault clearing time for the overcurrent protective device, incident energy could also increase. Informational Note No. 3: 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. Equipment and design practices are available to minimize the energy levels and the number of procedures that could expose an employee to high levels of incident energy. Proven designs such as arc-resistant switchgear, remote racking (insertion or removal), remote opening and closing of switching devices, high-resistance grounding of low-voltage and 5000 volts (nominal) systems, current limitation, and specification of covered bus or covered conductors within equipment are available to reduce the risk associated with an arc flash incident. See Informative Annex O for Safety-Related Design Requirements. Informational Note No. 4: For additional direction for performing maintenance on overcurrent protective devices, see Chapter 2, Safety-Related Maintenance Requirements. Informational Note No. 5: See IEEE 1584, Guide for Performing Arc Flash Calculations, for more information regarding incident energy and the arc flash boundary for three-phase systems. Table Estimate of the Likelihood of Occurrence of an Arc Flash Incident for ac and dc Systems Task Equipment Condition* Likelihood of Occurrence

213 84 of 403 9/2/2016 9:49 AM Task Reading a panel meter while operating a meter switch. Equipment Condition* Likelihood of Occurrence Performing infrared thermography and other non-contact inspections outside the restricted approach boundary. This activity does not include opening of doors or covers. Working on control circuits with exposed energized electrical conductors and circuit parts, nominal 125 volts ac or dc, or below without any other exposed energized equipment over nominal 125 volts ac or dc, including opening of hinged covers to gain access. Examination of insulated cable with no manipulation of cable. For dc systems, insertion or removal of individual cells or multi-cell units of a battery system in an open rack. For dc systems, maintenance on a single cell of a battery system or multi-cell units in an open rack. For dc systems, working on energized electrical conductors and circuit parts of series-connected battery cells, including voltage Any Any No Yes testing. conductors Removal or installation of CBs or switches. Opening hinged door(s) or cover(s) or removal of bolted covers (to expose bare, energized electrical conductors and circuit parts). For dc systems, this includes bolted covers, such as battery terminal covers. Application of temporary protective grounding equipment, after voltage test. Working on control circuits with exposed energized electrical conductors and circuit parts, greater than 120 volts. Insertion or removal of individual starter buckets from MCC. Insertion or removal (racking) of CBs or starters from cubicles, doors open or closed. Insertion or removal of plug-in devices into or from busways. Examination of insulated cable with manipulation of cable. Working on exposed energized electrical conductors and circuit parts of equipment directly supplied by a panelboard or motor control center. Insertion or removal of revenue meters (kw-hour, at primary voltage and current). Removal of battery conductive intercell connector covers. For dc systems, working on exposed energized electrical conductors and circuit parts of utilization equipment directly supplied by a dc source. Opening voltage transformer or control power transformer compartments. Operation of outdoor disconnect switch (hookstick operated) at 1 kv through 15 kv. Operation of outdoor disconnect switch (gang-operated, from grade) at 1 kv through 15 kv. Operation of a circuit breaker (CB), switch, contactor or starter. Normal No Voltage testing on individual battery cells or individual multi-cell units. Removal or installation of covers for equipment such as wireways, junction boxes, and cable trays that does not expose bare, energized electrical conductors and circuit parts. Opening a panelboard hinged door or cover to access dead front overcurrent devices. Removal of battery nonconductive intercell connector covers.

214 85 of 403 9/2/2016 9:49 AM Task Maintenance and testing on individual battery cells or individual multi-cell units in an open rack Insertion or removal of individual cells or multi-cell units of a battery system in an open rack. Arc-resistant switchgear Type 1 or 2 (for clearing times of < 0.5 sec with a prospective fault current not to exceed the arc-resistant rating of the equipment) and metal enclosed interrupter switchgear, fused or unfused of arc resistant type construction, tested in accordance with CSA C22.2 No. 022 or IEEE C : Insertion or removal (racking) of CBs from cubicles; Insertion or removal (racking) of ground and test device; or Insertion or removal (racking) of voltage transformers on or off the bus Notes: Equipment Condition* Abnormal Likelihood of Occurrence Yes *Equipment condition is considered to be normal if all of the following circumstances apply: (1) The equipment is properly installed in accordance with the manufacturer's recommendations and applicable industry codes and standards. (2) The equipment is properly maintained in accordance with the manufacturer's recommendations and applicable industry codes and standards. (3) The equipment is used in accordance with instructions included in the listing and labeling and in accordance with manufacturer s instructions. (4) Equipment doors are closed and secured. (5) Equipment covers are in place and secured. (6) There is no evidence of impending failure such as arcing, overheating, loose or bound equipment parts, visible damage, or deterioration As defined in this standard, the two components of risk are the likelihood of occurrence of injury or damage to health and the severity of injury or damage to health that results from a hazard. Risk assessment is an overall process that includes estimates of the likelihood of occurrence of injury or damage to health. The estimate of the likelihood of occurrence contained in this table does not cover every possible condition or situation. Where this table identifies No for likelihood of occurrence, it means that an arc flash incident is not likely to occur. Where this table identifies Yes for likelihood of occurrence, it means that additional protective measures are required to be selected and implemented according to the hierarchy of risk control identified in 110.1(G). Statement of Problem and Substantiation for Public Comment The line For dc systems, working on energized conductors and circuit parts of series-connected battery cells, including voltage testing is in direct conflict with these other statements: 1. In the section where Equipment Condition = ANY and Likelihood of Occurrence = NO, the line For dc systems, maintenance on a single cell of a battery system or multi-cell units in an open rack. 2. In the section where Equipment Condition = NORMAL and Likelihood of Occurrence = NO, the line Voltage testing on individual battery cells or individual multi-cell units. In the stationary battery community, maintenance on batteries includes activities such as voltage measurements, specific gravity measurements, connection resistance measurements among other similar activities. The line in question is stating that taking voltages on series-connected batteries (which can easily be interpreted as individual cells), has a high likelihood of occurrence which is in direct conflict with the other statements listed above. If you are working on the main conductors of a battery (over 100 volts) or any energized dc conductors over 100 volts, there is a much higher likelihood of occurrence. Truncating this line as suggested will clarify the intent of the line in question. Related Item Public Input No. 369-NFPA 70E-2015 [Section No (C)(15)(A)]

215 86 of 403 9/2/2016 9:49 AM Submitter Information Verification Submitter Full Name: William Cantor Organization: TPI Corporation Street Address: City: State: Zip: Submittal Date: Mon May 16 09:29:01 EDT 2016 Committee Statement Committee Action: Rejected Resolution: The proposed revision is not necessary. No conflict exists.

216 87 of 403 9/2/2016 9:49 AM Public Comment No. 200-NFPA 70E-2016 [ Section No [Excluding any Sub-Sections] ]

217 88 of 403 9/2/2016 9:49 AM An arc flash risk assessment shall be performed and shall comply with 130.5(1) through 130.5(3). (1) General. An arc flash risk assessment shall be performed as follows: (2) To identify arc flash hazards (3) To estimate the likelihood of occurrence of injury or damage to health and the potential severity of injury or damage to health (4) To determine if additional protective measures are required, including the use of PPE (5) Estimate of Likelihood and Severity. The estimate of the likelihood of occurrence of injury or damage to health and the potential severity of injury or damage to health shall take into consideration the following: (6) The design of the electrical equipment, including its overcurrent protective device and its operating time (7) The electrical equipment operating condition and condition of maintenance Table shall be permitted to be used to estimate the likelihood of occurrence of an arc flash event. (8) Additional Protective Measures. If additional protective measures are required they shall be selected and implemented according to the hierarchy of risk control identified in 110.1(G). When the additional protective measures include the use of PPE, the following shall be identified: (9) Appropriate safety-related work practices (10) The arc flash boundary (11) The PPE to be used within the arc flash boundary Informational Note No. 1: Improper or inadequate maintenance can result in increased fault clearing time of the overcurrent protective device, thus increasing the incident energy. Where equipment is not properly installed or maintained, PPE selection based on incident energy analysis or the PPE category method might not provide adequate protection from arc flash hazards. Informational Note No. 2: Both larger and smaller available fault currents could result in higher incident energy. If the available fault current increases without a decrease in the fault clearing time of the overcurrent protective device, the incident energy will increase. If the available fault current decreases, resulting in a longer fault clearing time for the overcurrent protective device, incident energy could also increase. Informational Note No. 3: 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. Equipment and design practices are available to minimize the energy levels and the number of procedures that could expose an employee to high levels of incident energy. Proven designs such as arc-resistant switchgear, remote racking (insertion or removal), remote opening and closing of switching devices, high-resistance grounding of low-voltage and 5000 volts (nominal) systems, current limitation, and specification of covered bus or covered conductors within equipment are available to reduce the risk associated with an arc flash incident. See Informative Annex O for Safety-Related Design Requirements. Informational Note No. 4: For additional direction for performing maintenance on overcurrent protective devices, see Chapter 2, Safety-Related Maintenance Requirements. Informational Note No. 5: See IEEE 1584, Guide for Performing Arc Flash Calculations, for more information regarding incident energy and the arc flash boundary for three-phase systems. Table Estimate of the Likelihood of Occurrence of an Arc Flash Incident for ac and dc Systems Task Equipment Condition*Likelihood of Occurrence Additional Protective Measures Required

218 89 of 403 9/2/2016 9:49 AM Task Reading a panel meter while operating a meter switch. Performing infrared thermography and other non-contact inspections outside the restricted approach boundary. This activity does not include opening of doors or covers. Working on control circuits with exposed energized electrical conductors and circuit parts, nominal 125 volts ac or dc, or below without any other exposed energized equipment over nominal 125 volts ac or dc, including opening of hinged covers to gain access. Examination of insulated cable with no manipulation of cable. For dc systems, insertion or removal of individual cells or multi-cell units of a battery system in an open rack. For dc systems, maintenance on a single cell of a battery system or multi-cell units in an open rack. For dc systems, working on energized electrical conductors and circuit parts of series-connected battery cells, including voltage testing. Removal or installation of CBs or switches. Opening hinged door(s) or cover(s) or removal of bolted covers (to expose bare, energized electrical conductors and circuit parts). For dc systems, this includes bolted covers, such as battery terminal covers. Application of temporary protective grounding equipment, after voltage test. Working on control circuits with exposed energized electrical conductors and circuit parts, greater than 120 volts. Insertion or removal of individual starter buckets from MCC. Insertion or removal (racking) of CBs or starters from cubicles, doors open or closed. Insertion or removal of plug-in devices into or from busways. Examination of insulated cable with manipulation of cable. Working on exposed energized electrical conductors and circuit parts of equipment directly supplied by a panelboard or motor control center. Insertion or removal of revenue meters (kw-hour, at primary voltage and current). Removal of battery conductive intercell connector covers. For dc systems, working on exposed energized electrical conductors and circuit parts of utilization equipment directly supplied by a dc source. Opening voltage transformer or control power transformer compartments. Operation of outdoor disconnect switch (hookstick operated) at 1 kv through 15 kv. Operation of outdoor disconnect switch (gang-operated, from grade) at 1 kv through 15 kv. Operation of a circuit breaker (CB), switch, contactor or starter. Equipment Condition*Likelihood of Occurrence Any Any Normal Additional Protective Measures Required No Yes No

219 90 of 403 9/2/2016 9:49 AM Task Voltage testing on individual battery cells or individual multi-cell units. Removal or installation of covers for equipment such as wireways, junction boxes, and cable trays that does not expose bare, energized electrical conductors and circuit parts. Opening a panelboard hinged door or cover to access dead front overcurrent devices. Removal of battery nonconductive intercell connector covers. Maintenance and testing on individual battery cells or individual multi-cell units in an open rack Insertion or removal of individual cells or multi-cell units of a battery system in an open rack. Arc-resistant switchgear Type 1 or 2 (for clearing times of < 0.5 sec with a prospective fault current not to exceed the arc-resistant rating of the equipment) and metal enclosed interrupter switchgear, fused or unfused of arc resistant type construction, tested in accordance with CSA C22.2 No. 022 or IEEE C : Insertion or removal (racking) of CBs from cubicles (with the doors open) ; Insertion or removal (racking) of ground and test device; or Insertion or removal (racking) of voltage transformers on or off the bus Notes: Equipment Condition*Likelihood of Occurrence Abnormal Additional Protective Measures Required Yes *Equipment condition is considered to be normal if all of the following circumstances apply: (1) The equipment is properly installed in accordance with the manufacturer's recommendations and applicable industry codes and standards. (2) The equipment is properly maintained in accordance with the manufacturer's recommendations and applicable industry codes and standards. (3) The equipment is used in accordance with instructions included in the listing and labeling and in accordance with manufacturer s instructions. (4) Equipment doors are closed and secured. (5) Equipment covers are in place and secured. (6) There is no evidence of impending failure such as arcing, overheating, loose or bound equipment parts, visible damage, or deterioration As defined in this standard, the two components of risk are the likelihood of occurrence of injury or damage to health and the severity of injury or damage to health that results from a hazard. Risk assessment is an overall process that includes estimates of the likelihood of occurrence of injury or damage to health. The estimate of the likelihood of occurrence contained in this table does not cover every possible condition or situation. Where this table identifies No for likelihood of occurrence, it means that an arc flash incident is not likely to occur. Where this table identifies Yes for likelihood of occurrence, it means that additional protective measures are required to be selected and implemented according to the hierarchy of risk control identified in 110.1(G). Statement of Problem and Substantiation for Public Comment 1. Changing the heading of the third column of Table from "Likelihood of Occurrence" to "Additional

220 91 of 403 9/2/2016 9:49 AM Protective Measures Required" simplifies the use of the table and eliminates the need for the long note at the bottom of the table explaining what is meant by "Likelihood of Occurrence". The phrase "additional protective measures are required" is already used in the notes to Table This comment suggests using this same statement as the column heading, which should permit deleting the last note to the table. 2. The phrase "(with the doors open)" is added to "Insertion or removal (racking) of CBs from cubicles;" to acknowledge that closed door racking of CBs in arc resistant switchgear should not require additional protective measures provided the equipment was designed and tested for such operation. Related Item First Revision No. 60-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: Louis Barrios Organization: Shell Global Solutions Affilliation: American Petroleum Institute Street Address: City: State: Zip: Submittal Date: Mon May 16 14:05:50 EDT 2016 Committee Statement Committee Rejected Action: Resolution: Revising the title of Table and Column 3 to Additional Protective Measures Required is not consistent with the content of the table and the risk assessment process. The second step in the risk assessment process is risk analysis where the likelihood of occurrence of injury or damage to health and the severity of injury or damage to health are estimated to establish a level of risk. Then the level of risk is evaluated to determine whether or not the level of risk is acceptable, or if risk reduction is required. Table is based on a matrix of activities and equipment conditions that affect likelihood of occurrence of an arc flash incident. Table does not contain estimates of severity of injury or damage to health. As noted, likelihood of occurrence is only one half of risk analysis, and precedes risk evaluation. See the modified text in SR 31 that clearly informs the user of this standard that Table may be used to estimate the likelihood of occurrence in order to determine if additional protective measures are necessary. The existing Informational Notes are relocated after the Table Note to Table for clarity. This places the new sentence that addresses additional protective measures immediately before Table The phrase "with the doors open" was not added to the arc resistant section of Table because racking a circuit breaker in arc resistant equipment with doors closed is considered normal operation. The Note for Normal Equipment Condition is relocated into the Table for clarity.

221 92 of 403 9/2/2016 9:49 AM Public Comment No. 44-NFPA 70E-2016 [ Section No [Excluding any Sub-Sections] ]

222 93 of 403 9/2/2016 9:49 AM See Statmenet for CC Note An arc flash risk assessment shall be performed and shall comply with 130.5(1) through 130.5(3). (1) General. An arc flash risk assessment shall be performed as follows: (2) To identify arc flash hazards (3) To estimate the likelihood of occurrence of injury or damage to health and the potential severity of injury or damage to health (4) To determine if additional protective measures are required, including the use of PPE (5) Estimate of Likelihood and Severity. The estimate of the likelihood of occurrence of injury or damage to health and the potential severity of injury or damage to health shall take into consideration the following: (6) The design of the electrical equipment, including its overcurrent protective device and its operating time (7) The electrical equipment operating condition and condition of maintenance Table shall be permitted to be used to estimate the likelihood of occurrence of an arc flash event. (8) Additional Protective Measures. If additional protective measures are required they shall be selected and implemented according to the hierarchy of risk control identified in 110.1(G). When the additional protective measures include the use of PPE, the following shall be identified: (9) Appropriate safety-related work practices (10) The arc flash boundary (11) The PPE to be used within the arc flash boundary Informational Note No. 1: Improper or inadequate maintenance can result in increased fault clearing time of the overcurrent protective device, thus increasing the incident energy. Where equipment is not properly installed or maintained, PPE selection based on incident energy analysis or the PPE category method might not provide adequate protection from arc flash hazards. Informational Note No. 2: Both larger and smaller available fault currents could result in higher incident energy. If the available fault current increases without a decrease in the fault clearing time of the overcurrent protective device, the incident energy will increase. If the available fault current decreases, resulting in a longer fault clearing time for the overcurrent protective device, incident energy could also increase. Informational Note No. 3: 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. Equipment and design practices are available to minimize the energy levels and the number of procedures that could expose an employee to high levels of incident energy. Proven designs such as arc-resistant switchgear, remote racking (insertion or removal), remote opening and closing of switching devices, high-resistance grounding of low-voltage and 5000 volts (nominal) systems, current limitation, and specification of covered bus or covered conductors within equipment are available to reduce the risk associated with an arc flash incident. See Informative Annex O for Safety-Related Design Requirements. Informational Note No. 4: For additional direction for performing maintenance on overcurrent protective devices, see Chapter 2, Safety-Related Maintenance Requirements. Informational Note No. 5: See IEEE 1584, Guide for Performing Arc Flash Calculations, for more information regarding incident energy and the arc flash boundary for three-phase systems. Table Estimate of the Likelihood of Occurrence of an Arc Flash Incident for ac and dc Systems Task Equipment Condition* Likelihood of Occurrence

223 94 of 403 9/2/2016 9:49 AM Task Reading a panel meter while operating a meter switch. Equipment Condition* Likelihood of Occurrence Performing infrared thermography and other non-contact inspections outside the restricted approach boundary. This activity does not include opening of doors or covers. Working on control circuits with exposed energized electrical conductors and circuit parts, nominal 125 volts ac or dc, or below without any other exposed energized equipment over nominal 125 volts ac or dc, including opening of hinged covers to gain access. Examination of insulated cable with no manipulation of cable. For dc systems, insertion or removal of individual cells or multi-cell units of a battery system in an open rack. For dc systems, maintenance on a single cell of a battery system or multi-cell units in an open rack. For dc systems, working on energized electrical conductors and circuit parts of series-connected battery cells, including voltage testing. Any Any No Yes Removal or installation of CBs or switches. Opening hinged door(s) or cover(s) or removal of bolted covers (to expose bare, energized electrical conductors and circuit parts). For dc systems, this includes bolted covers, such as battery terminal covers. Application of temporary protective grounding equipment, after voltage test. Working on control circuits with exposed energized electrical conductors and circuit parts, greater than 120 volts. Insertion or removal of individual starter buckets from MCC. Insertion or removal (racking) of CBs or starters from cubicles, doors open or closed. Insertion or removal of plug-in devices into or from busways. Examination of insulated cable with manipulation of cable. Working on exposed energized electrical conductors and circuit parts of equipment directly supplied by a panelboard or motor control center. Insertion or removal of revenue meters (kw-hour, at primary voltage and current). Removal of battery conductive intercell connector covers. For dc systems, working on exposed energized electrical conductors and circuit parts of utilization equipment directly supplied by a dc source. Opening voltage transformer or control power transformer compartments. Operation of outdoor disconnect switch (hookstick operated) at 1 kv through 15 kv. Operation of outdoor disconnect switch (gang-operated, from grade) at 1 kv through 15 kv. Operation of a circuit breaker (CB), switch, contactor or starter. Normal No Voltage testing on individual battery cells or individual multi-cell units. Removal or installation of covers for equipment such as wireways, junction boxes, and cable trays that does not expose bare, energized electrical conductors and circuit parts. Opening a panelboard hinged door or cover to access dead front overcurrent devices. Removal of battery nonconductive intercell connector covers.

224 95 of 403 9/2/2016 9:49 AM Task Maintenance and testing on individual battery cells or individual multi-cell units in an open rack Insertion or removal of individual cells or multi-cell units of a battery system in an open rack. Arc-resistant switchgear Type 1 or 2 (for clearing times of < 0.5 sec with a prospective fault current not to exceed the arc-resistant rating of the equipment) and metal enclosed interrupter switchgear, fused or unfused of arc resistant type construction, tested in accordance with CSA C22.2 No. 022 or IEEE C : Insertion or removal (racking) of CBs from cubicles; Insertion or removal (racking) of ground and test device; or Insertion or removal (racking) of voltage transformers on or off the bus Notes: Equipment Condition* Abnormal Likelihood of Occurrence Yes *Equipment condition is considered to be normal if all of the following circumstances apply: (1) The equipment is properly installed in accordance with the manufacturer's recommendations and applicable industry codes and standards. (2) The equipment is properly maintained in accordance with the manufacturer's recommendations and applicable industry codes and standards. (3) The equipment is used in accordance with instructions included in the listing and labeling and in accordance with manufacturer s instructions. (4) Equipment doors are closed and secured. (5) Equipment covers are in place and secured. (6) There is no evidence of impending failure such as arcing, overheating, loose or bound equipment parts, visible damage, or deterioration As defined in this standard, the two components of risk are the likelihood of occurrence of injury or damage to health and the severity of injury or damage to health that results from a hazard. Risk assessment is an overall process that includes estimates of the likelihood of occurrence of injury or damage to health. The estimate of the likelihood of occurrence contained in this table does not cover every possible condition or situation. Where this table identifies No for likelihood of occurrence, it means that an arc flash incident is not likely to occur. Where this table identifies Yes for likelihood of occurrence, it means that additional protective measures are required to be selected and implemented according to the hierarchy of risk control identified in 110.1(G). Statement of Problem and Substantiation for Public Comment The Correlating Committee directs the committee to review the text in 130.5(2) with regard to the list of requirements and the last sentence that references The Correlating Committee further directs the Committee to review the phrase incident energy analysis method of selecting arc flash PPE for clarity. Related Item First Revision No. 60-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: CC on NEC-AAC Organization: NFPA Street Address: City: State:

225 96 of 403 9/2/2016 9:49 AM Zip: Submittal Date: Mon Mar 14 15:56:40 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-31-NFPA 70E-2016 ADDITIONAL RESPONSE TO PC 44: In accordance with the direction from the Correlating Committee, the committee has reviewed the list of requirements in 130.5(2) and concludes that no revisions are required. The committee has also reviewed the phrase "incident energy analysis method of selecting arc flash PPE" and concludes that no revisions are required as this phrase is understood and has been used in the document for some time. ADDITIONAL RESPONSE TO PC 68: The suggested revision to mandate a new incident energy analysis be performed each time a method is revised or developed is not included in this revision. This requirement would mandate a new incident energy analysis if an existing method is revised or a new method is introduced for consideration. Statement: Section has been revised into eight first level subdivisions for compliance with the NEC style manual. The redundant use of the phrase an arc flash risk assessment shall be performed is eliminated. The committee has revised the reference to Table for clarity and has relocated the reference to Table to immediately precede the Table. Section Informational Notes 1 through 5 have been relocated below Table and the Table note in order to avoid separating the Table from the driving text. The Note for Normal Equipment Condition is relocated into Table to facilitate correlation to the Normal and Abnormal equipment conditions identified in Column 2. Table Note has been revised for clarity and to correlate use of the term estimate with its use in 130.5(A) and 130.5(B). The term estimate is used as both a verb (i.e. to estimate likelihood or estimating the likelihood ) and a noun (i.e. the estimate of ) in the document. Table 130.5: several First Revision Draft errors are corrected: In the second horizontal Table section the first listed task For ac systems, work on energized electrical conductors and circuit parts, including voltage testing is restored The horizontal line between the tasks Removal of battery nonconductive intercell connector covers and Maintenance and testing on individual battery cells or individual multi-cell units in an open rack is removed. The tasks in Table in the First Revision Draft were incorrectly divided into four horizontal sections; however, there are intended to be only three horizontal sections. The third section includes 11 tasks beginning with Operation of a circuit breaker (CB), switch, contactor or starter and finishing with Insertion or removal (racking) of voltage transformers on or off the bus. The less than numerical symbol in the arc-resistant switchgear task has been replaced by the phrase less than in accordance with the Global First Revision # (D) Incident Energy Analysis Method Informational Note now references all of Annex H to correlate with the relocation of Table H.3(b) into Table 130.5(G): Revised "Leather gloves" to "Heavy duty leather gloves" to correlate with 130.7(C) (10)(d)(1). Add a line in each section of Table 130.5(G) regarding arc rated outerwear (e.g. jacket, parka, rainwear, hard hat liner) (AN).

226 97 of 403 9/2/2016 9:49 AM Public Comment No. 67-NFPA 70E-2016 [ Section No [Excluding any Sub-Sections] ]

227 98 of 403 9/2/2016 9:49 AM An arc flash risk assessment shall be performed and shall comply with 130.5(1) through 130.5(3). (1) General. An arc flash risk assessment shall be performed as follows: (2) To identify arc flash hazards (3) To estimate the likelihood of occurrence of injury or damage to health and the potential severity of injury or damage to health (4) To determine if additional protective measures are required, including the use of PPE (5) Estimate of Likelihood and Severity. The estimate of the likelihood of occurrence of injury or damage to health and the potential severity of injury or damage to health shall take into consideration the following: (6) The design of the electrical equipment, including its overcurrent protective device and its operating time (7) The electrical equipment operating condition and condition of maintenance Table shall be permitted to be used to estimate the likelihood of occurrence of an arc flash event. (8) Additional Protective Measures. If additional protective measures are required they shall be selected and implemented according to the hierarchy of risk control identified in 110.1(G). When the additional protective measures include the use of PPE, the following shall be identified: (9) Appropriate safety-related work practices (10) The arc flash boundary (11) The PPE to be used within the arc flash boundary Informational Note No. 1: Improper or inadequate maintenance can result in increased fault clearing time of the overcurrent protective device, thus increasing the incident energy. Where equipment is not properly installed or maintained, PPE selection based on incident energy analysis or the PPE category method might not provide adequate protection from arc flash hazards. Informational Note No. 2: Both larger and smaller available fault currents could result in higher incident energy. If the available fault current increases without a decrease in the fault clearing time of the overcurrent protective device, the incident energy will increase. If the available fault current decreases, resulting in a longer fault clearing time for the overcurrent protective device, incident energy could also increase. Informational Note No. 3: 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. Equipment and design practices are available to minimize the energy levels and the number of procedures that could expose an employee to high levels of incident energy. Proven designs such as arc-resistant switchgear, remote racking (insertion or removal), remote opening and closing of switching devices, high-resistance grounding of low-voltage and 5000 volts (nominal) systems, current limitation, and specification of covered bus or covered conductors within equipment are available to reduce the risk associated with an arc flash incident. See Informative Annex O for Safety-Related Design Requirements. Informational Note No. 4: For additional direction for performing maintenance on overcurrent protective devices, see Chapter 2, Safety-Related Maintenance Requirements. Informational Note No. 5: See IEEE 1584, Guide for Performing Arc Flash Calculations, for more information regarding incident energy and the arc flash boundary for three-phase systems. Table Estimate of the Likelihood of Occurrence of an Arc Flash Incident for ac and dc Systems Task Reading a panel meter while operating a meter Equipment Condition* Any Likelihood of Occurrence

228 99 of 403 9/2/2016 9:49 AM switch. No Improbable Task For dc systems, working on energized electrical conductors and circuit parts of series-connected battery cells, including voltage testing. Yes Removal or installation of CBs or switches. Equipment Condition* Likelihood of Occurrence Performing infrared thermography and other non-contact inspections outside the restricted approach boundary. This activity does not include opening of doors or covers. Working on control circuits with exposed energized electrical conductors and circuit parts, nominal 125 volts ac or dc, or below without any other exposed energized equipment over nominal 125 volts ac or dc, including opening of hinged covers to gain access. Examination of insulated cable with no manipulation of cable. For dc systems, insertion or removal of individual cells or multi-cell units of a battery system in an open rack. For dc systems, maintenance on a single cell of a battery system or multi-cell units in an open rack. Possible Opening hinged door(s) or cover(s) or removal of bolted covers (to expose bare, energized electrical conductors and circuit parts). For dc systems, this includes bolted covers, such as battery terminal covers. Application of temporary protective grounding equipment, after voltage test. Working on control circuits with exposed energized electrical conductors and circuit parts, greater than 120 volts. Insertion or removal of individual starter buckets from MCC. Insertion or removal (racking) of CBs or starters from cubicles, doors open or closed. Insertion or removal of plug-in devices into or from busways. Examination of insulated cable with manipulation of cable. Working on exposed energized electrical conductors and circuit parts of equipment directly supplied by a panelboard or motor control center. Insertion or removal of revenue meters (kw-hour, at primary voltage and current). Removal of battery conductive intercell connector covers. For dc systems, working on exposed energized electrical conductors and circuit parts of utilization equipment directly supplied by a dc source. Opening voltage transformer or control power transformer compartments. Operation of outdoor disconnect switch (hookstick operated) at 1 kv through 15 kv. Operation of outdoor disconnect switch (gang-operated, from grade) at 1 kv through 15 kv. Operation of a circuit breaker (CB), switch, contactor or starter. No Improbable Voltage testing on individual battery cells or individual multi-cell units. Removal or installation of covers for equipment such as wireways, junction boxes, and cable trays that does not expose bare, energized electrical conductors and circuit parts. Opening a panelboard hinged door or cover to access dead front overcurrent devices. Removal of battery nonconductive intercell connector covers. Any Normal

229 Maintenance and testing on individual battery cells or individual multi-cell units in an open rack Yes Possible Insertion or removal of individual cells or multi-cell units of a battery system in an open rack. Abnormal Arc-resistant switchgear Type 1 or 2 (for clearing times of < 0.5 sec with a prospective fault current not to exceed the arc-resistant rating of the equipment) and metal enclosed interrupter switchgear, fused or unfused of arc resistant type construction, tested in accordance with CSA C22.2 No. 022 or IEEE C : Insertion or removal (racking) of CBs from cubicles; Insertion or removal (racking) of ground and test device; or Insertion or removal (racking) of voltage transformers on or off the bus Notes: *Equipment condition is considered to be normal if all of the following circumstances apply: (1) The equipment is properly installed in accordance with the manufacturer's recommendations and applicable industry codes and standards. (2) The equipment is properly maintained in accordance with the manufacturer's recommendations and applicable industry codes and standards. (3) The equipment is used in accordance with instructions included in the listing and labeling and in accordance with manufacturer s instructions. (4) Equipment doors are closed and secured. (5) Equipment covers are in place and secured. (6) There is no evidence of impending failure such as arcing, overheating, loose or bound equipment parts, visible damage, or deterioration As defined in this standard, the two components of risk are the likelihood of occurrence of injury or damage to health and the severity of injury or damage to health that results from a hazard. Risk assessment is an overall process that includes estimates of the likelihood of occurrence of injury or damage to health. The estimate of the likelihood of occurrence contained in this table does not cover every possible condition or situation. Where this table identifies No for likelihood of occurrence, it means that an arc flash incident is not likely to occur. Where this table identifies Yes for likelihood of occurrence, it means that additional protective measures are required to be selected and implemented according to the hierarchy of risk control identified in 110.1(G). Statement of Problem and Substantiation for Public Comment Three points related to this comment. 1) "No" and "Yes" are not the correct words to be under the header "Likelihood of Occurrence". No likelihood of occurrence cannot be guaranteed with any equipment or situation unless the equipment is proven to be in an electrically safe work condition, in which case this table is not even in the conversation. If the answer is Yes there is a likelihood of occurrence, then the question is "OK then, what is the likelihood of occurrence?" 2) Under the + footnote, an explanation is offered as to what the committee means by No and Yes. Why not just state what we mean in the table. And, the explanation indicates low and high likelihood of occurrence which re better than No and Yes at least. 3) No and Yes are not consistent with the information in Figure F.6 in Annex F, an Annex intended to help the reader understand the Risk Assessment and Risk Control requirements in the standard. I used the words from Annex F, Figure F.6 which are Improbable and Possible for inclusion in Table We have talked about this several times and we need to both fix this and to be consistent in all parts of the standard where this issue appears. Related Item First Revision No. 60-NFPA 70E-2015 [Section No ] Submitter Information Verification 00 of 403 9/2/2016 9:49 AM

230 01 of 403 9/2/2016 9:49 AM Submitter Full Name: David Pace Organization: Olin Corporation Affilliation: Self Street Address: City: State: Zip: Submittal Date: Thu Mar 17 16:07:42 EDT 2016 Committee Statement Committee Action: Resolution: Rejected The use of Yes or No in Table Column 3 provides significant clarity and is consistent with the title of Column 3 and will be more useful to users of the document than "Low" or "High" or similar terms. The intent of Yes or No is adequately explained in the Table Note. The use of these suggested terms would introduce significant ambiguity and confusion. The use of the term Low for example would infer that any interaction with any component of an electrical system, is inherently dangerous and would require additional protective measures.

231 02 of 403 9/2/2016 9:49 AM Public Comment No. 8-NFPA 70E-2016 [ Section No [Excluding any Sub-Sections] ]

232 03 of 403 9/2/2016 9:49 AM An arc flash risk assessment shall be performed and shall comply with 130.5(1) through 130.5(3). (1) General. An arc flash risk assessment shall be performed as follows: (2) To identify arc flash hazards (3) To estimate the likelihood of occurrence of injury or damage to health and the potential severity of injury or damage to health (4) To determine if additional protective measures are required, including the use of PPE (5) Estimate of Likelihood and Severity. The estimate of the likelihood of occurrence of injury or damage to health and the potential severity of injury or damage to health shall take into consideration the following: (6) The design of the electrical equipment, including its overcurrent protective device and its operating time (7) The electrical equipment operating condition and condition of maintenance Table shall be permitted to be used to estimate the likelihood of occurrence of an arc flash event. (8) Additional Protective Measures. If additional protective measures are required they shall be selected and implemented according to the hierarchy of risk control identified in 110.1(G). When the additional protective measures include the use of PPE, the following shall be identified: (9) Appropriate safety-related work practices (10) The arc flash boundary (11) The PPE to be used within the arc flash boundary Informational Note No. 1: Improper or inadequate maintenance can result in increased fault clearing time of the overcurrent protective device, thus increasing the incident energy. Where equipment is not properly installed or maintained, PPE selection based on incident energy analysis or the PPE category method might not provide adequate protection from arc flash hazards. Informational Note No. 2: Both larger and smaller available fault currents could result in higher incident energy. If the available fault current increases without a decrease in the fault clearing time of the overcurrent protective device, the incident energy will increase. If the available fault current decreases, resulting in a longer fault clearing time for the overcurrent protective device, incident energy could also increase. Informational Note No. 3: 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. Equipment and design practices are available to minimize the energy levels and the number of procedures that could expose an employee to high levels of incident energy. Proven designs such as arc-resistant switchgear, remote racking (insertion or removal), remote opening and closing of switching devices, high-resistance grounding of low-voltage and 5000 volts (nominal) systems, current limitation, and specification of covered bus or covered conductors within equipment are available to reduce the risk associated with an arc flash incident. See Informative Annex O for Safety-Related Design Requirements. Informational Note No. 4: For additional direction for performing maintenance on overcurrent protective devices, see Chapter 2, Safety-Related Maintenance Requirements. Informational Note No. 5: See IEEE 1584, Guide for Performing Arc Flash Calculations, for more information regarding incident energy and the arc flash boundary for three-phase systems. Table Estimate of the Likelihood of Occurrence of an Arc Flash Incident for ac and dc Systems Task Equipment Condition* Likelihood of Occurrence

233 04 of 403 9/2/2016 9:49 AM Task Reading a panel meter while operating a meter switch. Equipment Condition* Likelihood of Occurrence Performing infrared thermography and other non-contact inspections outside the restricted approach boundary. This activity does not include opening of doors or covers. Working on control circuits with exposed energized electrical conductors and circuit parts, nominal 125 volts ac or dc, or below without any other exposed energized equipment over nominal 125 volts ac or dc, including opening of hinged covers to gain access. Examination of insulated cable with no manipulation of cable. For dc systems, insertion or removal of individual cells or multi-cell units of a battery system in an open rack. For dc systems, maintenance on a single cell of a battery system or multi-cell units in an open rack. For dc systems, working on energized electrical conductors and circuit parts of series-connected battery cells, including voltage testing. AnyNo AnyYes Unlikely Likely Removal or installation of CBs or switches. Opening hinged door(s) or cover(s) or removal of bolted covers (to expose bare, energized electrical conductors and circuit parts). For dc systems, this includes bolted covers, such as battery terminal covers. Application of temporary protective grounding equipment, after voltage test. Working on control circuits with exposed energized electrical conductors and circuit parts, greater than 120 volts. Insertion or removal of individual starter buckets from MCC. Insertion or removal (racking) of CBs or starters from cubicles, doors open or closed. Insertion or removal of plug-in devices into or from busways. Examination of insulated cable with manipulation of cable. Working on exposed energized electrical conductors and circuit parts of equipment directly supplied by a panelboard or motor control center. Insertion or removal of revenue meters (kw-hour, at primary voltage and current). Removal of battery conductive intercell connector covers. For dc systems, working on exposed energized electrical conductors and circuit parts of utilization equipment directly supplied by a dc source. Opening voltage transformer or control power transformer compartments. Operation of outdoor disconnect switch (hookstick operated) at 1 kv through 15 kv. Operation of outdoor disconnect switch (gang-operated, from grade) at 1 kv through 15 kv. Operation of a circuit breaker (CB), switch, contactor or starter. NormalNo Unlikely Voltage testing on individual battery cells or individual multi-cell units. Removal or installation of covers for equipment such as wireways, junction boxes, and cable trays that does not expose bare, energized electrical conductors and circuit parts. Opening a panelboard hinged door or cover to access dead front overcurrent devices. Removal of battery nonconductive intercell connector covers.

234 05 of 403 9/2/2016 9:49 AM Task Maintenance and testing on individual battery cells or individual multi-cell units in an open rack Insertion or removal of individual cells or multi-cell units of a battery system in an open rack. Arc-resistant switchgear Type 1 or 2 (for clearing times of < 0.5 sec with a prospective fault current not to exceed the arc-resistant rating of the equipment) and metal enclosed interrupter switchgear, fused or unfused of arc resistant type construction, tested in accordance with CSA C22.2 No. 022 or IEEE C : Insertion or removal (racking) of CBs from cubicles; Insertion or removal (racking) of ground and test device; or Insertion or removal (racking) of voltage transformers on or off the bus Notes: Equipment Condition* AbnormalYes Likelihood of Occurrence Likely *Equipment condition is considered to be normal if all of the following circumstances apply: (1) The equipment is properly installed in accordance with the manufacturer's recommendations and applicable industry codes and standards. (2) The equipment is properly maintained in accordance with the manufacturer's recommendations and applicable industry codes and standards. (3) The equipment is used in accordance with instructions included in the listing and labeling and in accordance with manufacturer s instructions. (4) Equipment doors are closed and secured. (5) Equipment covers are in place and secured. (6) There is no evidence of impending failure such as arcing, overheating, loose or bound equipment parts, visible damage, or deterioration As defined in this standard, the two components of risk are the likelihood of occurrence of injury or damage to health and the severity of injury or damage to health that results from a hazard. Risk assessment is an overall process that includes estimates of the likelihood of occurrence of injury or damage to health. The estimate of the likelihood of occurrence contained in this table does not cover every possible condition or situation. Where this table identifies No for likelihood of occurrence, it means that an arc flash incident is not likely to occur. Where this table identifies Yes for likelihood of occurrence, it means that additional protective measures are required to be selected and implemented according to the hierarchy of risk control identified in 110.1(G). Statement of Problem and Substantiation for Public Comment Change the Table terms in the Likelihood of Occurrence column from yes/no to likely/unlikely. As accepted, the term no could be misinterpreted to mean never which is not what the Table notes relate. No is defined as not likely. Document clarity, precise language. Related Item First Revision No. 60-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: Drake Drobnick Organization: [ Not Specified ] Street Address: City: State:

235 06 of 403 9/2/2016 9:49 AM Zip: Submittal Date: Wed Feb 24 22:11:26 EST 2016 Committee Statement Committee Action: Resolution: Rejected The use of Yes or No in Table Column 3 provides significant clarity and is consistent with the title of Column 3 and will be more useful to users of the document than "Low" or "High" or similar terms. The intent of Yes or No is adequately explained in the Table Note. The use of these suggested terms would introduce significant ambiguity and confusion. The use of the term Low for example would infer that any interaction with any component of an electrical system, is inherently dangerous and would require additional protective measures.

236 07 of 403 9/2/2016 9:49 AM Public Comment No. 140-NFPA 70E-2016 [ Section No (C) ] (C) Arc Flash PPE. One of the following methods shall be used for the selection of arc flash PPE: (1) The incident energy analysis method in accordance with 130.5(D) (2) The arc flash PPE category method in accordance with 130.7(C)(15) Either, but not both, methods shall be permitted to be used on the same piece of equipment, unless condition or system changes necessitate a revised arc flash risk assessment. The results of an incident energy analysis to specify an arc flash PPE Category in Table 130.7(C)(15)(c) shall not be permitted. Statement of Problem and Substantiation for Public Comment The TC did not provide a technical substantiation for resolving PI 108. This Public Comment attempts different language to clarify the intent of the rule. Consider a situation where the equipment is within the parameters necessary to use the PPE category method. So, the employer chooses the PPE Category method for a piece of equipment. Then, the transformer is replaced with one that places one of the parameters outside that allowed by the tables. Now, the user of the document is faced with a dilemma. They cannot use the table method because they are outside the parameters and they cannot use the incident energy method because 130.5(C) prohibits a different method on the same piece of equipment. They are forced to choose which rule to violate in order to protect the worker. Related Item Public Input No. 108-NFPA 70E-2015 [Section No (C) [Excluding any Sub-Sections]] Submitter Information Verification Submitter Full Name: Bobby Gray Organization: Hoydar/Buck, Inc. Affilliation: None Street Address: City: State: Zip: Submittal Date: Wed Apr 27 18:10:58 EDT 2016 Committee Statement Committee Action: Resolution: Rejected If an equipment label becomes invalid due to a change in the distribution system, the employer can choose another method to determine PPE requirements. The committee continues to affirm that there is no conflict in this requirement. When an arc flash risk assessment is revised the employer is free to choose whichever of the methods apply. The intent of this requirement is that both methods not be used at the same time on the same piece of equipment.

237 08 of 403 9/2/2016 9:49 AM Public Comment No. 21-NFPA 70E-2016 [ Section No (C) ] (C) Arc Flash PPE. One of the following methods shall be used for the selection of arc flash PPE: (1) The incident energy analysis method in accordance with 130.5(D) (2) The arc flash PPE category method in accordance with 130.7(C)(15) Either, but not both, methods shall be permitted to be used on the same piece of equipment. The results of an incident energy analysis to specify an arc flash PPE Category in Table 130.7(C)(15)(c) shall not be permitted. Statement of Problem and Substantiation for Public Comment Remove The results of an incident energy analysis to specify an arc flash PPE Category in Table 130.7(C)(15)(c) shall not be permitted. This is a legacy issue that no longer applies to the new use of the Table Method. Document usability Related Item First Revision No. 60-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: Drake Drobnick Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Fri Feb 26 07:59:05 EST 2016 Committee Statement Committee Action: Rejected Resolution: The committee continues to affirm that this prohibition is still warranted.

238 09 of 403 9/2/2016 9:49 AM Public Comment No. 141-NFPA 70E-2016 [ Section No (D) ]

239 10 of 403 9/2/2016 9:49 AM (D) Incident Energy Analysis Method. The incident energy exposure level shall be based on the working distance of the employee s face and chest areas from a prospective arc source for the specific task to be performed. Arc-rated clothing and other PPE shall be used by the employee based on the incident energy exposure associated with the specific task. Recognizing that incident energy increases as the distance from the arc flash decreases, additional PPE shall be used for any parts of the body that are closer than the working distance at which the incident energy was determined. The incident energy analysis shall take into consideration the characteristics of the overcurrent protective device and its fault clearing time, including its condition of maintenance. The incident energy analysis shall be updated when changes occur in the electrical distribution system that could affect the results of the analysis. The incident energy analysis shall also be reviewed for accuracy at intervals not to exceed 5 years. Table 130.5(D) identifies the arc-rated clothing and other PPE requirements of Article 130 and shall be permitted to be used with the incident energy analysis method of selecting arc flash PPE. Informational Note: For information on estimating the incident energy, see Informative Annex D. For information on selection of arc-rated clothing and other PPE, see Table H (bC) in Informative Annex H. Table 130.5(D) Selection of Arc-Rated Clothing and Other PPE When the Incident Energy Analysis Method Is Used Incident energy exposures equal to 1.2 cal/cm 2 up to 12 cal/cm 2 Arc-rated clothing with an arc rating equal to or greater than the estimated incident energy a 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 Leather 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/cm 2 Arc-rated clothing with an arc rating equal to or greater than the estimated incident energy a Long-sleeve shirt and pants or coverall or arc flash suit (SR) Arc-rated arc flash suit hood 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 in group is required. a Arc ratings can be for a single layer, such as an arc-rated shirt and pants or a coverall, or for an arc 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. b Face 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. c Rubber 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.

240 11 of 403 9/2/2016 9:49 AM Statement of Problem and Substantiation for Public Comment The table in Annex H has been moved into 130.5(D). The mandatory rules regarding selection and use of electrical PPE is found in 130.7(C) and should be based on the task performed as well as the calculated exposure. This new table is permitted to be referenced, but it is based solely on incident energy values. The fundamental rules for PPE are in and should be referenced either in the mandatory language or in the informational note. Related Item First Revision No. 60-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: Bobby Gray Organization: Hoydar/Buck, Inc. Affilliation: None Street Address: City: State: Zip: Submittal Date: Wed Apr 27 18:27:53 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-31-NFPA 70E-2016 ADDITIONAL RESPONSE TO PC 44: In accordance with the direction from the Correlating Committee, the committee has reviewed the list of requirements in 130.5(2) and concludes that no revisions are required. The committee has also reviewed the phrase "incident energy analysis method of selecting arc flash PPE" and concludes that no revisions are required as this phrase is understood and has been used in the document for some time. ADDITIONAL RESPONSE TO PC 68: The suggested revision to mandate a new incident energy analysis be performed each time a method is revised or developed is not included in this revision. This requirement would mandate a new incident energy analysis if an existing method is revised or a new method is introduced for consideration. Statement: Section has been revised into eight first level subdivisions for compliance with the NEC style manual. The redundant use of the phrase an arc flash risk assessment shall be performed is eliminated. The committee has revised the reference to Table for clarity and has relocated the reference to Table to immediately precede the Table. Section Informational Notes 1 through 5 have been relocated below Table and the Table note in order to avoid separating the Table from the driving text. The Note for Normal Equipment Condition is relocated into Table to facilitate correlation to the Normal and Abnormal equipment conditions identified in Column 2. Table Note has been revised for clarity and to correlate use of the term estimate with its use in 130.5(A) and 130.5(B). The term estimate is used as both a verb (i.e. to estimate likelihood or estimating the likelihood ) and a noun (i.e. the estimate of ) in the document. Table 130.5: several First Revision Draft errors are corrected: In the second horizontal Table section the first listed task For ac systems, work on energized electrical conductors and circuit parts, including voltage testing is restored The horizontal line between the tasks Removal of battery nonconductive intercell connector

241 12 of 403 9/2/2016 9:49 AM covers and Maintenance and testing on individual battery cells or individual multi-cell units in an open rack is removed. The tasks in Table in the First Revision Draft were incorrectly divided into four horizontal sections; however, there are intended to be only three horizontal sections. The third section includes 11 tasks beginning with Operation of a circuit breaker (CB), switch, contactor or starter and finishing with Insertion or removal (racking) of voltage transformers on or off the bus. The less than numerical symbol in the arc-resistant switchgear task has been replaced by the phrase less than in accordance with the Global First Revision # (D) Incident Energy Analysis Method Informational Note now references all of Annex H to correlate with the relocation of Table H.3(b) into Table 130.5(G): Revised "Leather gloves" to "Heavy duty leather gloves" to correlate with 130.7(C) (10)(d)(1). Add a line in each section of Table 130.5(G) regarding arc rated outerwear (e.g. jacket, parka, rainwear, hard hat liner) (AN).

242 13 of 403 9/2/2016 9:49 AM Public Comment No. 154-NFPA 70E-2016 [ Section No (D) ]

243 14 of 403 9/2/2016 9:49 AM (D) Incident Energy Analysis Method.

244 15 of 403 9/2/2016 9:49 AM The incident energy exposure level shall be based on the working distance of the employee s face and chest areas from a prospective arc source for the specific task to be performed. Arc-rated clothing and other PPE shall be used by the employee based on the incident energy exposure associated with the specific task. Recognizing that incident energy increases as the distance from the arc flash decreases, additional PPE shall be used for any parts of the body that are closer than the working distance at which the incident energy was determined. The incident energy analysis shall take into consideration the characteristics of the overcurrent protective device and its fault clearing time, including its condition of maintenance. The incident energy analysis shall be updated when changes occur in the electrical distribution system that could affect the results of the analysis. The incident energy analysis shall also be reviewed for accuracy at intervals not to exceed 5 years. Table 130.5(D) identifies the arc-rated clothing and other PPE requirements of Article 130 and shall be permitted to be used with the incident energy analysis method of selecting arc flash PPE. Informational Note: For information on estimating the incident energy, see Informative Annex D. For information on selection of arc-rated clothing and other PPE, see Table H.3(b) in Informative Annex H. Table 130.5(D) Selection of Arc-Rated Clothing and Other PPE When the Incident Energy Analysis Method Is Used Incident energy exposures equal to 1.2 cal/cm 2 up to 12 cal/cm 2 Arc-rated clothing with an arc rating equal to or greater than the estimated incident energy a 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 Leather gloves or Heavy-duty leather gloves c, arc-rated gloves or rubber insulating gloves with leather protectors (SR) c d Hard hat Safety glasses or safety goggles (SR) Hearing protection Leather footwear Incident energy exposures greater than 12 cal/cm 2 Arc-rated clothing with an arc rating equal to or greater than the estimated incident energy a Long-sleeve shirt and pants or coverall or arc flash suit (SR) Arc-rated arc flash suit hood 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 in group is required. a Arc ratings can be for a single layer, such as an arc-rated shirt and pants or a coverall, or for an arc 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. b Face 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. c Heavy-duty leather gloves are suitable up to 10 cal/cm 2, see Informational Note in 130.7(C)(10)4. d Rubber 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

245 16 of 403 9/2/2016 9:49 AM thickness, provide increased arc flash protection. Statement of Problem and Substantiation for Public Comment The proposed change in the first revision draft conflicts with the requirement given in 130.7(C)(10)4. This states that "heavy-duty" leather gloves or arc-rated gloves SHALL be worn where required for arc flash protection. Standard leather gloves should not be used for arc flash protection. Additionally, the informational note would lead the reader to believe that even heavy-duty leather gloves may not be sufficient above 10 cal/cm2. Arc-rated gloves should therefore also be permitted below 12 cal/cm2. Clarification of the informational note would also be helpful. Related Item First Revision No. 60-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: Mark Scott Organization: Lawrence Berkeley National Laboratory Street Address: City: State: Zip: Submittal Date: Mon May 09 12:05:03 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-31-NFPA 70E-2016 ADDITIONAL RESPONSE TO PC 44: In accordance with the direction from the Correlating Committee, the committee has reviewed the list of requirements in 130.5(2) and concludes that no revisions are required. The committee has also reviewed the phrase "incident energy analysis method of selecting arc flash PPE" and concludes that no revisions are required as this phrase is understood and has been used in the document for some time. ADDITIONAL RESPONSE TO PC 68: The suggested revision to mandate a new incident energy analysis be performed each time a method is revised or developed is not included in this revision. This requirement would mandate a new incident energy analysis if an existing method is revised or a new method is introduced for consideration. Statement: Section has been revised into eight first level subdivisions for compliance with the NEC style manual. The redundant use of the phrase an arc flash risk assessment shall be performed is eliminated. The committee has revised the reference to Table for clarity and has relocated the reference to Table to immediately precede the Table. Section Informational Notes 1 through 5 have been relocated below Table and the Table note in order to avoid separating the Table from the driving text. The Note for Normal Equipment Condition is relocated into Table to facilitate correlation to the Normal and Abnormal equipment conditions identified in Column 2. Table Note has been revised for clarity and to correlate use of the term estimate with its use in 130.5(A) and 130.5(B). The term estimate is used as both a verb (i.e. to estimate likelihood or estimating the likelihood ) and a noun (i.e. the estimate of ) in the document. Table 130.5: several First Revision Draft errors are corrected: In the second horizontal Table section the first listed task For ac systems, work on energized

246 17 of 403 9/2/2016 9:49 AM electrical conductors and circuit parts, including voltage testing is restored The horizontal line between the tasks Removal of battery nonconductive intercell connector covers and Maintenance and testing on individual battery cells or individual multi-cell units in an open rack is removed. The tasks in Table in the First Revision Draft were incorrectly divided into four horizontal sections; however, there are intended to be only three horizontal sections. The third section includes 11 tasks beginning with Operation of a circuit breaker (CB), switch, contactor or starter and finishing with Insertion or removal (racking) of voltage transformers on or off the bus. The less than numerical symbol in the arc-resistant switchgear task has been replaced by the phrase less than in accordance with the Global First Revision # (D) Incident Energy Analysis Method Informational Note now references all of Annex H to correlate with the relocation of Table H.3(b) into Table 130.5(G): Revised "Leather gloves" to "Heavy duty leather gloves" to correlate with 130.7(C) (10)(d)(1). Add a line in each section of Table 130.5(G) regarding arc rated outerwear (e.g. jacket, parka, rainwear, hard hat liner) (AN).

247 18 of 403 9/2/2016 9:49 AM Public Comment No. 189-NFPA 70E-2016 [ Section No (D) ]

248 19 of 403 9/2/2016 9:49 AM (D) Incident Energy Analysis Method. The incident energy exposure level shall be based on the working distance of the employee s face and chest areas from a prospective arc source for the specific task to be performed. Arc-rated clothing and other PPE shall be used by the employee based on the incident energy exposure associated with the specific task. Recognizing that incident energy increases as the distance from the arc flash decreases, additional PPE shall be used for any parts of the body that are closer than the working distance at which the incident energy was determined. The incident energy analysis shall take into consideration the characteristics of the overcurrent protective device and its fault clearing time, including its condition of maintenance. The incident energy analysis estimations shall be updated when changes occur in the electrical distribution system that could affect the results of the analysis. The incident energy analysis shall also be reviewed for accuracy at intervals not to exceed 5 years. Table 130.5(D) identifies the arc-rated clothing and other PPE requirements of Article 130 and shall be permitted to be used with the incident energy analysis method of selecting arc flash PPE. Informational Note: For information on estimating the incident energy, see Informative Annex D. For information on selection of arc-rated clothing and other PPE, see Table H.3(b) in Informative Annex H. Table 130.5(D) Selection of Arc-Rated Clothing and Other PPE When the Incident Energy Analysis Method Is Used Incident energy exposures equal to 1.2 cal/cm 2 up to 12 cal/cm 2 Arc-rated clothing with an arc rating equal to or greater than the estimated incident energy a 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 Leather 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/cm 2 Arc-rated clothing with an arc rating equal to or greater than the estimated incident energy a Long-sleeve shirt and pants or coverall or arc flash suit (SR) Arc-rated arc flash suit hood 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 in group is required. a Arc ratings can be for a single layer, such as an arc-rated shirt and pants or a coverall, or for an arc 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. b Face 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. c Rubber 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.

249 20 of 403 9/2/2016 9:49 AM Statement of Problem and Substantiation for Public Comment An incident energy analysis is an estimation. The revised format of section now clarifies that an arc flash risk assessment is an estimation. The review and audit of an incident energy analysis is simply a review of an estimate and should be clarified for the reader of this standard. The comment seeks to add the reference to estimation as seen in Public Input 340. Related Item Public Input No. 340-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: James Dollard Organization: IBEW Local Union 98 Street Address: City: State: Zip: Submittal Date: Mon May 16 08:57:30 EDT 2016 Committee Statement Committee Action: Resolution: Rejected The inclusion of "estimations" is not necessary as the defined term "incident energy analysis" clearly illustrates that it is a prediction. Section 130.5(C)(1) Informational Note also clarifies that it is an estimation.

250 21 of 403 9/2/2016 9:49 AM Public Comment No. 27-NFPA 70E-2016 [ Section No (D) ]

251 22 of 403 9/2/2016 9:49 AM (D) Incident Energy Analysis Method. The incident energy exposure level shall be based on the working distance of the employee s face and chest areas from a prospective arc source for the specific task to be performed. Arc-rated clothing and other PPE shall be used by the employee based on the incident energy exposure associated with the specific task. Recognizing that incident energy increases as the distance from the arc flash decreases, additional PPE shall be used for any parts of the body that are closer than the working distance at which the incident energy was determined. The incident energy analysis shall take into consideration the characteristics of the overcurrent protective device and its fault clearing time, including its condition of maintenance. The incident energy analysis shall be updated when changes occur in the electrical distribution system that could affect the results of the analysis. The incident energy analysis shall also be reviewed for accuracy at intervals not to exceed 5 years. Table 130.5(D) identifies the arc-rated clothing and other PPE requirements of Article 130 and shall be permitted to be used with the incident energy analysis method of selecting arc flash PPE. Informational Note: For information on estimating the incident energy, see Informative Annex D. For information on selection of arc-rated clothing and other PPE, see Table H.3(b) in Informative Annex H. Table 130.5(D) Selection of Arc-Rated Clothing and Other PPE When the Incident Energy Analysis Method Is Used Incident energy exposures equal to 1.2 cal/cm 2 up to 12 cal 20 cal /cm 2 Arc-rated clothing with an arc rating equal to or greater than the estimated incident energy a 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 Leather 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 20 cal /cm 2 Arc-rated clothing with an arc rating equal to or greater than the estimated incident energy a Long-sleeve shirt and pants or coverall or arc flash suit (SR) Arc-rated arc flash suit hood 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 in group is required. a Arc ratings can be for a single layer, such as an arc-rated shirt and pants or a coverall, or for an arc 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. b Face 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. c Rubber 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.

252 23 of 403 9/2/2016 9:49 AM Statement of Problem and Substantiation for Public Comment The ranges in Table (D) should be expanded upward to 20 cals. and greater than 20 cals. to accommodate new PPE protection factors. Document useability. Related Item First Revision No. 60-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: Drake Drobnick Organization: [ Not Specified ] Street Address: City: State: Zip: Submittal Date: Tue Mar 01 00:19:06 EST 2016 Committee Statement Committee Action: Resolution: Rejected The 12 cal/cm2 threshold specified in Table correlates to 130.7(C)(10)(b)(2) and the threshold above which it is required to use an arc flash suit hood. The submitter did not provide any technical substantiation.

253 24 of 403 9/2/2016 9:49 AM Public Comment No. 68-NFPA 70E-2016 [ Section No (D) ]

254 25 of 403 9/2/2016 9:49 AM (D) Incident Energy Analysis Method.

255 26 of 403 9/2/2016 9:49 AM The incident energy exposure level shall be based on the working distance of the employee s face and chest areas from a prospective arc source for the specific task to be performed. Arc-rated clothing and other PPE shall be used by the employee based on the incident energy exposure associated with the specific task. Recognizing that incident energy increases as the distance from the arc flash decreases, additional PPE shall be used for any parts of the body that are closer than the working distance at which the incident energy was determined. The incident energy analysis shall take into consideration the characteristics of the overcurrent protective device and its fault clearing time, including its condition of maintenance. The incident energy analysis shall be updated when changes occur in the electrical distribution system that could affect the results of the analysis or when methods used to calculate the predicted incident energy are revised such that the revision would change the predicted incident energy. The incident energy analysis shall also be reviewed for accuracy at intervals not to exceed 5 years. Table 130.5(D) identifies the arc-rated clothing and other PPE requirements of Article 130 and shall be permitted to be used with the incident energy analysis method of selecting arc flash PPE. Informational Note: For information on estimating the incident energy, see Informative Annex D. For information on selection of arc-rated clothing and other PPE, see Table H.3(b) in Informative Annex H. Table 130.5(D) Selection of Arc-Rated Clothing and Other PPE When the Incident Energy Analysis Method Is Used Incident energy exposures equal to 1.2 cal/cm 2 up to 12 cal/cm 2 Arc-rated clothing with an arc rating equal to or greater than the estimated incident energy a 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 Leather gloves or rubber insulating gloves with leather protectors (SR) c Hard hat Safety glasses or safety goggles (SR) Hearing protection Arc-rated jacket, parka, rainwear or hard hat liner, as needed Leather footwear Incident energy exposures greater than 12 cal/cm 2 Arc-rated clothing with an arc rating equal to or greater than the estimated incident energy a Long-sleeve shirt and pants or coverall or arc flash suit (SR) Arc-rated arc flash suit hood Arc-rated gloves or rubber insulating gloves with leather protectors (SR) c Hard hat Safety glasses or safety goggles (SR) Hearing protection Arc-rated jacket, parka, rainwear or hard hat liner, as needed Leather footwear SR: Selection of one in group is required. a Arc ratings can be for a single layer, such as an arc-rated shirt and pants or a coverall, or for an arc 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. b Face 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.

256 27 of 403 9/2/2016 9:49 AM c Rubber 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. Statement of Problem and Substantiation for Public Comment Text to require an update of the incident energy analysis when calculation methods are revised was added. IEEE 1584 is primarily used to calculate incident energy and based on the information collected by the IEEE and NFPA collaborative effort, revisions to the 1584 calculations are likely to occur. this needs to be in the standard to alert the reader that calculation methods are constantly changing as more is learned about the arc flash phenomenon. Text was added to include "Arc-rated jacket, parka, rainwear or hard hat liner, as needed" to the list of PPE since this PPE is commonly used and to be consistent with the required PPE found in Table 130.7(C)(15)(C). Related Item First Revision No. 60-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: David Pace Organization: Olin Corporation Affilliation: Self Street Address: City: State: Zip: Submittal Date: Thu Mar 17 16:21:40 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-31-NFPA 70E-2016 ADDITIONAL RESPONSE TO PC 44: In accordance with the direction from the Correlating Committee, the committee has reviewed the list of requirements in 130.5(2) and concludes that no revisions are required. The committee has also reviewed the phrase "incident energy analysis method of selecting arc flash PPE" and concludes that no revisions are required as this phrase is understood and has been used in the document for some time. ADDITIONAL RESPONSE TO PC 68: The suggested revision to mandate a new incident energy analysis be performed each time a method is revised or developed is not included in this revision. This requirement would mandate a new incident energy analysis if an existing method is revised or a new method is introduced for consideration. Statement: Section has been revised into eight first level subdivisions for compliance with the NEC style manual. The redundant use of the phrase an arc flash risk assessment shall be performed is eliminated. The committee has revised the reference to Table for clarity and has relocated the reference to Table to immediately precede the Table. Section Informational Notes 1 through 5 have been relocated below Table and the Table note in order to avoid separating the Table from the driving text. The Note for Normal Equipment Condition is relocated into Table to facilitate correlation to the Normal and Abnormal equipment conditions identified in Column 2. Table Note has been revised for clarity and to correlate use of the term estimate with its use in 130.5(A) and 130.5(B). The term estimate is used as both a verb (i.e. to estimate likelihood or estimating the likelihood ) and a noun (i.e. the estimate of ) in the document.

257 28 of 403 9/2/2016 9:49 AM Table 130.5: several First Revision Draft errors are corrected: In the second horizontal Table section the first listed task For ac systems, work on energized electrical conductors and circuit parts, including voltage testing is restored The horizontal line between the tasks Removal of battery nonconductive intercell connector covers and Maintenance and testing on individual battery cells or individual multi-cell units in an open rack is removed. The tasks in Table in the First Revision Draft were incorrectly divided into four horizontal sections; however, there are intended to be only three horizontal sections. The third section includes 11 tasks beginning with Operation of a circuit breaker (CB), switch, contactor or starter and finishing with Insertion or removal (racking) of voltage transformers on or off the bus. The less than numerical symbol in the arc-resistant switchgear task has been replaced by the phrase less than in accordance with the Global First Revision # (D) Incident Energy Analysis Method Informational Note now references all of Annex H to correlate with the relocation of Table H.3(b) into Table 130.5(G): Revised "Leather gloves" to "Heavy duty leather gloves" to correlate with 130.7(C) (10)(d)(1). Add a line in each section of Table 130.5(G) regarding arc rated outerwear (e.g. jacket, parka, rainwear, hard hat liner) (AN).

258 29 of 403 9/2/2016 9:49 AM Public Comment No. 168-NFPA 70E-2016 [ Section No (E) ] (E) Equipment Labeling. Electrical equipment such as switchboards, panelboards, industrial control panels, meter socket enclosures, and motor control centers that are in other than dwelling units and that are likely to require examination, adjustment, servicing, or maintenance while energized shall be marked with a label containing all the following information: (1) Nominal system voltage (2) Arc flash boundary (3) At least one of the following: (4) 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 (5) Minimum arc rating of clothing (6) Site-specific level of PPE Exception No. 1: Unless changes in 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 the standard in effect at the time the labels were applied. Exception No. 2: In supervised industrial installations where conditions of maintenance and engineering supervision ensure that only qualified persons monitor and service the system, the information required in (E)(1) through (E)(3) shall be permitted to be documented in a manner that is readily available to persons likely to perform examination, servicing, maintenance, and operation of the equipment while energized. The method of calculating and the data to support the information for the label shall be documented. The data shall be reviewed for accuracy at intervals not to exceed 5 years. Where the review of the data identifies a change that renders the label inaccurate, the label shall be updated. The owner of the electrical equipment shall be responsible for the documentation, installation, and maintenance of the marked label. Statement of Problem and Substantiation for Public Comment Exemption No. 2 directly contradicts the OSHA requirements of 29CFR (a)(1) states: These specifications apply to the design, application, and use of signs or symbols (as included in paragraphs (c) through (e) of this section) that indicate and, insofar as possible, define specific hazards that could harm workers or the public, or both, or to property damage. These specifications are intended to cover all safety signs except those designed for streets, highways, and railroads. These specifications do not apply to plant bulletin boards or to safety posters (f) (4) (iv) states: All employees shall be informed as to the meaning of the various tags used throughout the workplace and what special precautions are necessary. Exemption No. 2 should only apply to supervised industrial installations where the arc flash hazard has been mitigated to levels where injury from arc flash is not likely. As written in the current exemption, this does not appear to be an effective way to manage complex industrial distribution systems where multiple PPE levels and approach boundaries may be present. This may also leave employers open to OSHA citations for not applying proper safety and warning signs. Related Item First Revision No. 60-NFPA 70E-2015 [Section No ] Submitter Information Verification

259 30 of 403 9/2/2016 9:49 AM Submitter Full Name: Jason Wolf Organization: Esco Group Street Address: City: State: Zip: Submittal Date: Fri May 13 12:34:39 EDT 2016 Committee Statement Committee Action: Resolution: Rejected The purpose of 130.5(E) Exception No. 2 is to permit the information that is required to be on a label to be communicated in a manner other than a label. This is a reasonable exception in supervised industrial installations. The requirements of 29 CFR , as referenced in the submitter s substantiation, are met in the generic arc flash hazard warning requirement found in the installation code NFPA 70 (NEC) section

260 31 of 403 9/2/2016 9:49 AM Public Comment No. 3-NFPA 70E-2016 [ Section No (E) ] (E) Equipment Labeling. Electrical equipment such as switchboards, panelboards, industrial control panels, meter socket enclosures, and motor control centers that are in other than dwelling units and that are likely to require examination, adjustment, servicing, or maintenance while energized shall be marked with a label containing all the following information: (1) Nominal system voltage (2) Arc flash boundary (3) At least one of the following: (4) 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 (5) Minimum arc rating of clothing (6) Site-specific level of PPE (A Site specific more conservative (Higher PPE Level) that is directed in lieu of using a lower calculated number or selection from a table) Exception No. 1: Unless changes in 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 the standard in effect at the time the labels were applied. Exception No. 2: In supervised industrial installations where conditions of maintenance and engineering supervision ensure that only qualified persons monitor and service the system, the information required in (E)(1) through (E)(3) shall be permitted to be documented in a manner that is readily available to persons likely to perform examination, servicing, maintenance, and operation of the equipment while energized. The method of calculating and the data to support the information for the label shall be documented. The data shall be reviewed for accuracy at intervals not to exceed 5 years. Where the review of the data identifies a change that renders the label inaccurate, the label shall be updated. The owner of the electrical equipment shall be responsible for the documentation, installation, and maintenance of the marked label. Statement of Problem and Substantiation for Public Comment Makes it clear to the reader what the intent of the Site Specific PPE really is intended for Related Item Public Input No. 70-NFPA 70E-2015 [Annex G] Submitter Information Verification Submitter Full Name: Steve Weyenberg Organization: Foth Production Solutions Street Address: City: State: Zip: Submittal Date: Wed Feb 24 13:44:18 EST 2016 Committee Statement

261 32 of 403 9/2/2016 9:49 AM Committee Action: Resolution: Rejected The standard already requires that arc flash PPE be rated at least equal to or greater than the estimated arc flash exposure. This requirement applies to a site specific level of PPE. See 130.5(C). The reference to site specific level of PPE is not a mandate for a higher level of PPE.

262 33 of 403 9/2/2016 9:49 AM Public Comment No. 33-NFPA 70E-2016 [ Section No (E) ] (E) Equipment Labeling. Electrical equipment such as switchboards, panelboards, industrial control panels, meter socket enclosures, and motor control centers that are in other than dwelling units and that are likely to require examination, adjustment, servicing, or maintenance while energized shall be marked with a label containing all the following information: (1) Nominal system voltage (2) Arc flash boundary (3) At least one of the following: (4) Available incident energy and the corresponding working distance a. at 18 inches, 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 b. Minimum arc rating of clothing c. Site-specific level of PPE Exception No. 1: Unless changes in 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 the standard in effect at the time the labels were applied. Exception No. 2: In supervised industrial installations where conditions of maintenance and engineering supervision ensure that only qualified persons monitor and service the system, the information required in (E)(1) through (E)(3) shall be permitted to be documented in a manner that is readily available to persons likely to perform examination, servicing, maintenance, and operation of the equipment while energized. The method of calculating and the data to support the information for the label shall be documented. The data shall be reviewed for accuracy at intervals not to exceed 5 years. Where the review of the data identifies a change that renders the label inaccurate, the label shall be updated. The owner of the electrical equipment shall be responsible for the documentation, installation, and maintenance of the marked label. Statement of Problem and Substantiation for Public Comment Arc flash calculation software defaults to 18 inches based on the typical working distance of an employee's face and chest area. Changing the labeling of equipment requirement to a fixed distance of 18 inches will make it consistent with the arc flash calculation software default incident energy at 18 inches and help to clarify a proposed new definition (Incident Energy Exposure) and a proposed change to the (Incident Energy) definition. Related Public Comments for This Document Related Comment Public Comment No. 31-NFPA 70E-2016 [New Definition after Definition: Incident Energy Analysis.] Public Comment No. 32-NFPA 70E-2016 [Definition: Incident Energy.] Related Item Public Input No. 143-NFPA 70E-2015 [New Definition after Definition: Incident Energy Analysis.] Relationship Interrelated Interrelated Submitter Information Verification

263 34 of 403 9/2/2016 9:49 AM Submitter Full Name: Richard Waters Organization: Batelle Energy Alliance Street Address: City: State: Zip: Submittal Date: Mon Mar 14 13:39:14 EDT 2016 Committee Statement Committee Action: Rejected Resolution: Working distance is not always 18 inches.

264 35 of 403 9/2/2016 9:49 AM Public Comment No. 87-NFPA 70E-2016 [ Section No ] Other Precautions for Personnel Activities. (A) Alertness. (1) When Electrical Hazards Might Exist. Employees shall be instructed to be alert at all times when they are working within the limited approach boundary of energized electrical conductors or circuit parts operating at voltages equal to or greater than 50 Vac or 100 Vdc V and in work situations when electrical hazards might exist. (2) When Impaired. Employees shall not be permitted to work within the limited approach boundary of energized electrical conductors or circuit parts operating at voltages equal to or greater than 50 Vac or 100 Vdc V, or where other electrical hazards exist, while their alertness is recognizably impaired due to illness, fatigue, or other reasons. (3) Changes in Scope. Employees shall be instructed to be alert for changes in the job or task that could lead the person outside of the electrically safe work condition or expose the person to additional hazards that were not part of the original plan. (B) Blind Reaching. Employees shall be instructed not to reach blindly into areas that might contain exposed energized electrical conductors or circuit parts where an electrical hazard exists. (C) Illumination. (1) General. Employees shall not enter spaces where electrical hazards exist unless illumination is provided that enables the employees to perform the work safely. (2) Obstructed View of Work Area. Where lack of illumination or an obstruction precludes observation of the work to be performed, employees shall not perform any task within the limited approach boundary of energized electrical conductors or circuit parts operating at voltages equal to or greater than 50 Vac V or 100 Vdc or where an electrical hazard exists. (D) Conductive Articles Being Worn. Conductive articles of jewelry and clothing (such as watchbands, bracelets, rings, key chains, necklaces, metalized aprons, cloth with conductive thread, metal headgear, or metal frame glasses) shall not be worn within the restricted approach boundary or where they present an electrical contact hazard with exposed energized electrical conductors or circuit parts. (E) Conductive Materials, Tools, and Equipment Being Handled. (1) General. Conductive materials, tools, and equipment that are in contact with any part of an employee s body shall be handled in a manner that prevents unintentional contact with energized electrical conductors or circuit parts. Such materials and equipment shall include, but are not limited to, long conductive objects, such as ducts, pipes and tubes, conductive hose and rope, metal-lined rules and scales, steel tapes, pulling lines, metal scaffold parts, structural members, bull floats, and chains. (2) Approach to Energized Electrical Conductors and Circuit Parts. Means shall be employed to ensure that conductive materials approach exposed energized electrical conductors or circuit parts no closer than that permitted by

265 36 of 403 9/2/2016 9:49 AM (F) Confined or Enclosed Work Spaces. When an employee works in a confined or enclosed space (such as a manhole or vault) that contains exposed energized electrical conductors or circuit parts operating at voltages equal to or greater than 50 Vac or 100 Vdc V, or where an electrical hazard exists, the employer shall provide, and the employee shall use, protective shields, protective barriers, or insulating materials as necessary to avoid inadvertent contact with these parts and the effects of the electrical hazards. (G) Doors and Hinged Panels. Doors, hinged panels, and the like shall be secured to prevent their swinging into an employee and causing the employee to contact exposed energized electrical conductors or circuit parts operating at voltages equal to or greater than 50 Vac or 100 Vdc or where an electrical hazard exists if movement of the door, hinged panel, and the like is likely to create a hazard. (H) Clear Spaces. Working space required by other codes and standards shall not be used for storage. This space shall be kept clear to permit safe operation and maintenance of electrical equipment. (I) Housekeeping Duties. Employees shall not perform housekeeping duties inside the limited approach boundary where there is a possibility of contact with energized electrical conductors or circuit parts, unless adequate safeguards (such as insulating equipment or barriers) are provided to prevent contact. Electrically conductive cleaning materials (including conductive solids such as steel wool, metalized cloth, and silicone carbide, as well as conductive liquid solutions) shall not be used inside the limited approach boundary unless procedures to prevent electrical contact are followed. (J) Occasional Use of Flammable Materials. Where flammable materials are present only occasionally, electric equipment capable of igniting them shall not be permitted to be used, unless measures are taken to prevent hazardous conditions from developing. Such materials shall include, but are not limited to, flammable gases, vapors, or liquids, combustible dust, and ignitible fibers or flyings. Informational Note: Electrical installation requirements for locations where flammable materials are present on a regular basis are contained in NFPA 70. (K) Anticipating Failure. When there is evidence that electric equipment could fail and injure employees, the electric equipment shall be de-energized, unless the employer can demonstrate that de-energizing introduces additional hazards or increased risk or is infeasible because of equipment design or operational limitation. Until the equipment is de-energized or repaired, employees shall be protected from hazards associated with the impending failure of the equipment by suitable barricades and other alerting techniques necessary for safety of the employees. Informational Note: See 130.7(E) for alerting techniques. (L) Routine Opening and Closing of Circuits. Load-rated switches, circuit breakers, or other devices specifically designed as disconnecting means shall be used for the opening, reversing, or closing of circuits under load conditions. Cable connectors not of the load-break type, fuses, terminal lugs, and cable splice connections shall not be permitted to be used for such purposes, except in an emergency. (M) Reclosing Circuits After Protective Device Operation. After a circuit is de-energized by the automatic operation of a circuit protective device, the circuit shall not be manually re-energized until it has been determined that the equipment and circuit can be safely energized. The repetitive manual reclosing of circuit breakers or re-energizing circuits through replaced fuses shall be prohibited. When it is determined from the design of the circuit and the overcurrent devices involved that the automatic operation of a device was caused by an overload rather than a fault condition, examination of the circuit or connected equipment shall not be required before the circuit is re-energized.

266 37 of 403 9/2/2016 9:49 AM (N) Safety Interlocks. Only qualified persons following the requirements for working inside the restricted approach boundary as covered by 130.4(C) shall be permitted to defeat or bypass an electrical safety interlock over which the person has sole control, and then only temporarily while the qualified person is working on the equipment. The safety interlock system shall be returned to its operable condition when the work is completed. Statement of Problem and Substantiation for Public Comment This comment is written to address Correlating Committee Note No. 19 which directs the Committee to review the 100V DC threshold with respect to correlation with OSHA and NEC requirements. No technical substantiation was provided to have NFPA 70E in direct conflict with NEC and OSHA requirements. Additionally, this action is in direct conflict with the reason NFPA 70E was created. In the Foreward to 70E, several problems areas are noted that drove the need "for a new standard, tailored to fulfill OSHA's responsibilities, that would still be fully consistent with the NEC." The action taken in FR 76 is in direct conflict with OSHA and NEC requirements. Related Public Comments for This Document Related Comment Public Comment No. 86-NFPA 70E-2016 [Section No ] Related Item Correlating Committee Note No. 19-NFPA 70E-2016 [Section No ] First Revision No. 47-NFPA 70E-2015 [Section No ] Submitter Information Verification Relationship Submitter Full Name: James Dollard Organization: IBEW Local Union 98 Street Address: City: State: Zip: Submittal Date: Wed Apr 13 09:42:10 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-32-NFPA 70E-2016 Statement: Establishing a voltage threshold of 100 Vdc in Chapter 1 conflicts with the OSHA regulations, such as (a)(1).

267 38 of 403 9/2/2016 9:49 AM Public Comment No. 69-NFPA 70E-2016 [ Section No (J) ] (J) Occasional Use of Flammable Materials. Where flammable materials are present only occasionally, electric equipment capable of igniting them shall not be permitted to be used, unless measures are taken to prevent hazardous conditions from developing. Such materials shall include, but are not limited to, flammable gases, vapors, or liquids, combustible dust, and ignitible fibers or flyings. Informational Note: Electrical installation requirements for locations where flammable materials are present on a regular basis are contained in NFPA 70, National Electrical Code. Statement of Problem and Substantiation for Public Comment The National Electrical Code and the NEC are so common that most people don't know it by NFPA 70. The words should stay in the standard. Related Item First Revision No. 76-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: David Pace Organization: Olin Corporation Affilliation: Self Street Address: City: State: Zip: Submittal Date: Thu Mar 17 16:34:57 EDT 2016 Committee Statement Committee Accepted Action: Resolution: SR-9-NFPA 70E-2016 Statement: The words National Electrical Code are retained as they appear in this section of the standard to maintain clarity for users of the document.

268 39 of 403 9/2/2016 9:49 AM Public Comment No. 48-NFPA 70E-2016 [ Section No (A) ] See Statement for CC Note (A) General. Employees exposed to electrical hazards when the risk associated with that hazard is not adequately reduced by the applicable electrical installation requirements shall be provided with, and shall use, protective equipment that is designed and constructed for the specific part of the body to be protected and for the work to be performed. Informational Note: The PPE requirements of are intended to protect a person from arc flash and shock hazards. While some situations could result in burns to the skin, even with the protection selected, burn injury should be reduced and survivable. Due to the explosive effect of some arc events, physical trauma injuries could occur. The PPE requirements of do not address protection against physical trauma other than exposure to the thermal effects of an arc flash. Statement of Problem and Substantiation for Public Comment The Correlating Committee directs the Committee to review the phrase adequately reduced and revise for compliance with the Style Manual. Related Item First Revision No. 36-NFPA 70E-2015 [Section No (A)] Submitter Information Verification Submitter Full Name: CC on NEC-AAC Organization: NFPA Street Address: City: State: Zip: Submittal Date: Mon Mar 14 16:25:03 EDT 2016 Committee Statement Committee Action: Resolution: Rejected The use of the word adequately is not prohibited by the NEC Style Manual and the use is appropriate for this requirement.

269 40 of 403 9/2/2016 9:49 AM Public Comment No. 70-NFPA 70E-2016 [ Section No (A) ] (A) General. Employees exposed to electrical hazards when the risk associated with that hazard is not adequately reduced by the applicable electrical installation requirements shall be provided with, and shall use, protective equipment that is designed and constructed for the specific part of the body to be protected and for the work to be performed. Informational Note No 1 : The PPE requirements of are intended to protect a person from arc flash and shock hazards. While some situations could result in burns to the skin, even with the protection selected, burn injury should be reduced and survivable. Due to the explosive effect of some arc events, physical trauma injuries could occur. The PPE requirements of do not address protection against physical trauma other than exposure to the thermal effects of an arc flash. Informational Note No. 2: When incident energy exceeds 40 cal/cm2 at the working distasnce, greateer enphasis may be necessary with respect to de-energizing when exposed to electrical hazards. Statement of Problem and Substantiation for Public Comment The informational note relating to greater emphasis placed on de-energizing when incident energy is greater than 40 cal/cm2 should stay in the document. The 40 cal/cm2 "cutoff" is widely used. Every incident energy analysis includes prohibiting energized work where the person would be exposed to greater than 40 cal/cm2. Labels indicate energized work is prohibited or not allowed. This is imbedded into thousands of policies and procedures that are part of electrical safety programs. This is viewed as the Committee setting a limit on what we allow people to be exposed to. To remove this text would say the Committee is OK with increasing risk and exposure, something we are not supposed to be doing. A proposal was submitted to the 2004 revision cycle to add a new HRC 5 which would include maximum incident energy of 100 cal/cm2. After much discussion, the proposal was defeated with the Committee (lead by Vince Saporita) decision that we have to stop somewhere and at these incident energy levels, protecting from the heat may be less of a concern that protecting from arc blast effects, something the PPE does not claim to protect against. The next cycle, I submitted a proposal to prohibit energized work where the person would be exposed to greater than 40cal/cm2. This was not accepted but a compromise position was to create the Informational Note. We do not need to remove this note, it sends the wrong message. It is not a requirement, companies have always been able to exceed 40 if they want, and still could with the note remaining in the text. This needs to remain in the standard. Related Item First Revision No. 36-NFPA 70E-2015 [Section No (A)] Submitter Information Verification Submitter Full Name: David Pace Organization: Olin Corporation Affilliation: Self Street Address: City: State: Zip: Submittal Date: Thu Mar 17 16:38:23 EDT 2016 Committee Statement

270 41 of 403 9/2/2016 9:49 AM Committee Action: Resolution: Rejected The Technical Committee reaffirms that greater emphasis should always be placed on de-energizing regardless of the incident energy level.

271 42 of 403 9/2/2016 9:49 AM Public Comment No. 167-NFPA 70E-2016 [ Section No (B) ] (B) Care of Equipment. Protective equipment shall be maintained in a safe, sanitary, clean, and reliable condition in accordance with manufacturers' instructions. The protective equipment shall be visually inspected before each use. Protective equipment shall be stored in a manner to prevent damage from physically damaging conditions and from moisture, dust, or other deteriorating agents. Informational Note: Specific requirements for periodic testing of electrical protective equipment are given in 130.7(C)(14) and 130.7(G). Statement of Problem and Substantiation for Public Comment The change to this section added the term clean to maintenance requirements for protective equipment. Clean may be interpreted as just the physical appearance of the protective equipment. Whereas; sanitary would capture infection and disease. OSHA standard 29 CFR (a) specifically uses the term sanitary. The term sanitary would require employers to address issues when employees have to share protective equipment, such as rubber insulated gloves. Related Item First Revision No. 37-NFPA 70E-2015 [Section No (B)] Submitter Information Verification Submitter Full Name: Jason Wolf Organization: Esco Group Street Address: City: State: Zip: Submittal Date: Fri May 13 12:21:16 EDT 2016 Committee Statement Committee Action: Resolution: Rejected Maintaining PPE in a sanitary condition is required by OSHA ( (a) and (a)). The submitter did not provide substantiation for requiring other protective equipment, such as insulating blankets, to be maintained in a sanitary condition.

272 43 of 403 9/2/2016 9:49 AM Public Comment No. 49-NFPA 70E-2016 [ Section No (B) ] See Statment for CC Note (B) Care of Equipment. Protective equipment shall be maintained in a safe, clean, and reliable condition in accordance with manufacturers' instructions. The protective equipment shall be visually inspected before each use. Protective equipment shall be stored in a manner to prevent damage from physically damaging conditions and from moisture, dust, or other deteriorating agents. Informational Note: Specific requirements for periodic testing of electrical protective equipment are given in 130.7(C)(14) and 130.7(G). Statement of Problem and Substantiation for Public Comment The Correlating Committee directs the committee to review the revisions to 130.7(B) to clarify if the conditions mentioned are included in any manufacturer s instructions. Related Item First Revision No. 37-NFPA 70E-2015 [Section No (B)] Submitter Information Verification Submitter Full Name: CC on NEC-AAC Organization: NFPA Street Address: City: State: Zip: Submittal Date: Mon Mar 14 16:26:10 EDT 2016 Committee Statement Committee Action: Rejected but see related SR Resolution: SR-38-NFPA 70E-2016 Statement: Manufacturer s instructions also need be followed in maintaining protective equipment.

273 44 of 403 9/2/2016 9:49 AM Public Comment No. 129-NFPA 70E-2016 [ Section No (C)(7) ] (7) Hand and Arm Protection. Hand and arm protection shall be provided in accordance with 130.7(C)(7) (a), (b), and (c). (a) Shock Protection. Employees shall wear rubber insulating gloves with leather protectors where there is a danger of hand injury from electric shock due to contact with exposed energized electrical conductors or circuit parts. Employees shall wear rubber insulating gloves with leather protectors and rubber insulating sleeves where there is a danger of hand and arm injury from electric shock due to contact with exposed energized electrical conductors or circuit parts. Rubber insulating gloves shall be rated for the voltage for which the gloves will be exposed. Exception: Where it is necessary to use rubber insulating gloves without leather protectors, the requirements of ASTM F496, Standard Specification for In-Service Care of Insulating Gloves and Sleeves, shall be met. (b) Arc Flash Protection. Hand and arm protection shall be worn where there is possible exposure to arc flash burn. The apparel described in 130.7(C)(10) (d) shall be required for protection of hands from burns. Arm protection shall be accomplished by the apparel described in 130.7(C)(6). (c) Maintenance and Use. Electrical protective equipment shall be maintained in a safe, reliable condition. Insulating equipment shall be inspected for damage before each day s use and immediately following any incident that can reasonably be suspected of having caused damage. Insulating gloves shall be given an air test, along with the inspection. Electrical protective equipment shall be subjected to periodic electrical tests. Test voltages and the maximum intervals between tests shall be in accordance with Table 130.7(C)(7)(c). Informational Note: See OSHA , Personal Protective Equipmentand ASTM F496, Standard Specification for In-Service Care of Insulating Gloves and Sleeves. Table 130.7(C)(7)(c) Rubber Insulating Equipment, Maximum Test Intervals Rubber Insulating Equipment When to Test Governing Standard for Test Voltage * Blankets Before first issue; every 12 months thereafter ASTM F479 Covers If insulating value is suspect ASTM F478 Gloves Before first issue; every 6 months thereafter ASTM F496 Line hose If insulating value is suspect ASTM F478 Sleeves Before first issue; every 12 months thereafter ASTM F496 *ASTM F478, Standard Specification for In-Service Care of Insulating Line Hose and Covers; ASTM F479, Standard Specification for In-Service Care of Insulating Blankets; ASTM F496, Standard Specification for In-Service Care of Insulating Gloves and Sleeves. If the insulating equipment has been electrically tested but not issued for service, it is not permitted to be placed into service unless it has been electrically tested within the previous 12 months. Issued for Service means a brand new glove issued and tested by the manufacturer for the first time Additional Proposed Changes File Name Description Approved NFPA_70E_2018_Public_Comment_to_FR38_Testing_of_rubber_gloves.docx Clarification on term first issue

274 45 of 403 9/2/2016 9:49 AM Statement of Problem and Substantiation for Public Comment See attached file Related Item First Revision No. 38-NFPA 70E-2015 [Section No (C)(7)] Submitter Information Verification Submitter Full Name: Daleep Mohla Organization: DCM Electrical Consulting Serv Street Address: City: State: Zip: Submittal Date: Tue Apr 26 11:07:37 EDT 2016 Committee Statement Committee Action: Resolution: Statement: Rejected but see related SR SR-39-NFPA 70E-2016 Additional response to PC-34 and PC-151: Mandatory references has been removed and relocated into informational notes, informational tables and positive text in conformance with the NEC Style Manual. Also see SR-25, 36, 35, 40, 42, 43, 44, 45, 62, 63, 65, 66, 67 and 68. The table note on test intervals is modified for clarity. The mandatory reference in Table 130.7(C) (7)(c) and the first note to the table are removed and relocated to an informational note. Positive text was inserted and the exception deleted in 130.7(C)(7)(a) to insert requirements previously addressed with a mandatory reference.

275 FR-38, Section No (C)(7), See FR-38 Affirmative with Comment Comments: There is a confusion in the user community on what is considered issued for service and when gloves are required to be di-electrically tested. The additional wording below will provide necessary guidance to users. If the insulating equipment has been electrically tested but not issued for service, it is not permitted to be placed into service unless it has been electrically tested within the previous 12 month. Issued for service means a brand new glove issued and tested by manufacturer. After the first issue, the gloves must be dielectrically tested within a maximum interval of 6 months from the last test date Retesting for confirmation of arc rating of the gloves is not required after initial testing by the manufacturer if no repairs or alterations are done. Rationale: this addition will clarify when rubber gloves need to be electrically restested. It also clarifies retesting to confirm arc rating of gloves is not required after initial testing by the manufacturer if no repairs or alternations have been done to the original glove tested by the manufacturer.

276 46 of 403 9/2/2016 9:49 AM Public Comment No. 142-NFPA 70E-2016 [ Section No (C)(10) ] (10) Arc Flash Protective Equipment. (a) Arc Flash Suits. Arc flash suit design shall permit easy and rapid removal by the wearer. The entire arc flash suit, including the hood s face shield, shall have an arc rating that is suitable for the arc flash exposure. When exterior air is supplied into the hood, the air hoses and pump housing shall be either covered by arc-rated materials or constructed of nonmelting and nonflammable materials. (b) Head Protection. (3) An arc-rated hood or an arc-rated balaclava with an arc-rated face shield shall be used when the back of the head is within the arc flash boundary. (4) An arc-rated hood shall be used when the anticipated incident energy exposure exceeds 12 cal/cm 2 (50.2 J/cm 2 ). (e) Face Protection. Face shields shall have an arc rating suitable for the arc flash exposure. Face shields with a wrap-around guarding to protect the face, chin, forehead, ears, and neck area shall be used. Face shields without an arc rating shall not be used. Eye Where the face shield does not meet the appropriate standard for shatter resistent, additional eye protection (safety glasses or goggles) shall always be worn under face shields or hoods. Informational Note: Face shields made with energy-absorbing formulations that can provide higher levels of protection from the radiant energy of an arc flash are available, but these shields are tinted and can reduce visual acuity and color perception. Additional illumination of the task area might be necessary when these types of arc-protective face shields are used. (f) Hand Protection. (7) Heavy-duty leather gloves or arc-rated gloves shall be worn where required for arc flash protection. Informational Note: Heavy-duty leather gloves are made entirely of leather with minimum thickness of 0.03 in. (0.7 mm) and are unlined or lined with nonflammable, nonmelting fabrics. Heavy-duty leather gloves meeting this requirement have been shown to have ATPV values in excess of 10 cal/cm 2 (41.9 J/cm 2 ). (8) Where insulating rubber gloves are used for shock protection, leather protectors shall be worn over the rubber gloves. Informational Note: The leather protectors worn over rubber insulating gloves provide additional arc flash protection for the hands for arc flash protection exposure. (i) Foot Protection. Heavy-duty leather footwear or dielectric footwear or both provide some arc flash protection to the feet and shall be used in all exposures greater than 4 cal/cm 2 (16.75 J/cm 2 ). Statement of Problem and Substantiation for Public Comment The TC resolved PI 110, which attempted to allow eye protection that meets ANSI Z87 generally. This public comment applies the same approach specifically to face shield and hoods that are manufactured to the standards for eye protection. If the face shield has the Z87 rating, it is not necessary for additional eye protection. It is difficult for the worker to see through two layers of lenses and the likelihood of error is reduced if the single layer can provide adequate protection. This was the intent of PI 110.

277 47 of 403 9/2/2016 9:49 AM Related Item Public Input No. 110-NFPA 70E-2015 [Section No (C)(4)] Submitter Information Verification Submitter Full Name: Bobby Gray Organization: Hoydar/Buck, Inc. Affilliation: None Street Address: City: State: Zip: Submittal Date: Wed Apr 27 18:54:50 EDT 2016 Committee Statement Committee Action: Resolution: Rejected Eye protection is always required to be worn under face shields or hoods. Section 130.7(C)(14) has always required both eye and face protection to meet ANSI Z87.1. There is no technical substantiation to allow the use of a face shield without also requiring safety glasses even if they both meet ANSI Z87.1.

278 48 of 403 9/2/2016 9:49 AM Public Comment No. 71-NFPA 70E-2016 [ Section No (C)(10) ] (10) Arc Flash Protective Equipment. (a) Arc Flash Suits. Arc flash suit design shall permit easy and rapid removal by the wearer. The entire arc flash suit, including the hood s face shield, shall have an arc rating that is suitable for the arc flash exposure. When exterior air is supplied into the hood, the air hoses and pump housing shall be either covered by arc-rated materials or constructed of nonmelting and nonflammable materials. (b) Head Protection. (3) An arc-rated hood or an arc-rated balaclava, used in combination with an arc-rated face shield, shall be used when the back of the head is within the arc flash boundary. (4) An arc-rated hood shall be used when the anticipated incident energy exposure exceeds 12 cal/cm 2 (50.2 J/cm 2 ). (e) Face Protection. Face shields shall have an arc rating suitable for the arc flash exposure. Face shields with a wrap-around guarding to protect the face, chin, forehead, ears, and neck area shall be used. Face shields without an arc rating shall not be used. Eye protection (safety glasses or goggles) shall always be worn under face shields or hoods. Informational Note: Face shields made with energy-absorbing formulations that can provide higher levels of protection from the radiant energy of an arc flash are available, but these shields are tinted and can reduce visual acuity and color perception. Additional illumination of the task area might be necessary when these types of arc-protective face shields are used. (f) Hand Protection. (7) Heavy-duty leather gloves or arc-rated gloves shall be worn where required for arc flash protection. Informational Note: Heavy-duty leather gloves are made entirely of leather with minimum thickness of 0.03 in. (0.7 mm) and are unlined or lined with nonflammable, nonmelting fabrics. Heavy-duty leather gloves meeting this requirement have been shown to have ATPV values in excess of 10 cal/cm 2 (41.9 J/cm 2 ). (8) Where insulating rubber gloves are used for shock protection, leather protectors shall be worn over the rubber gloves. Informational Note: The leather protectors worn over rubber insulating gloves provide additional arc flash protection for the hands for arc flash protection exposure. (i) Foot Protection. Heavy-duty leather footwear or dielectric footwear or both provide some arc flash protection to the feet and shall be used in all exposures greater than 4 cal/cm 2 (16.75 J/cm 2 ). Statement of Problem and Substantiation for Public Comment The added text clarifies that the face shield and balaclava are to be worn together as a combination. Related Item First Revision No. 77-NFPA 70E-2015 [Section No (C)(10)] Submitter Information Verification

279 49 of 403 9/2/2016 9:49 AM Submitter Full Name: David Pace Organization: Olin Corporation Affilliation: Self Street Address: City: State: Zip: Submittal Date: Thu Mar 17 16:57:58 EDT 2016 Committee Statement Committee Action: Resolution: Rejected The existing text is clear. The recommended text does not add clarity or usability. The requirement presently requires that an arc-rated balaclava be used with an arc-rated face shield when both are required.

280 50 of 403 9/2/2016 9:49 AM Public Comment No. 116-NFPA 70E-2016 [ Section No (C)(14) ]

281 51 of 403 9/2/2016 9:49 AM (14) Standards for Personal Protective Equipment (PPE).

282 52 of 403 9/2/2016 9:49 AM PPE shall conform to the standards listed in Table 130.7(C)(14). Informational Note No. 1 : Non arc-rated or flammable fabrics are not covered by any of the standards in Table 130.7(C)(14). See 130.7(C)(11) and 130.7(C)(12). Informational Note No. 2: See Informative Annex H for informational material regarding conformity assessment of PPE. Table 130.7(C)(14) Standards For Personal Protective Equipment Subject Document Title Document Number Apparel Arc Rated Aprons Insulating Eye and Face Protection- General Face Arc Rated Fall Protection Standard Performance Specification for Flame Resistant and Arc Rated Textile Materials for Wearing Apparel for Use by Electrical Workers Exposed to Momentary Electric Arc and Related Thermal Hazards Standard Guide for Industrial Laundering of Flame, Thermal, and Arc Resistant Clothing Standard Guide for Home Laundering Care and Maintenance of Flame, Thermal and Arc Resistant Clothing Standard Specification for Electrically Insulating Aprons Eye and Face Protection General Occupational and Educational Professional Eye and Face Protection Devices Standard Test Method for Determining the Arc Rating and Standard Specification for Personal Eye or Face Protective Products Standard Specification for Personal Climbing Equipment Footwear Standard Specification for Dielectric Dielectric Footwear Specification Footwear Dielectric Test Method Standard Test Method for Determining Dielectric Strength of Dielectric Footwear Footwear Standard Specification for Standard Performance Requirements for Performance Protective (Safety) Toe Cap Specification Footwear Footwear Standard Test Method Gloves Arc Rated Standard Test Methods for Foot Protections Standard Test Method for Determining Arc Ratings of Hand Protective Products Developed and Used for Electrical Arc Flash Protection ASTM F1506 ASTM F1449 ASTM F2757 ASTM F2677 ANSI/ISEA Z87.1 ASTM F2178 ASTM F887 ASTM F1117 ASTM F1116 ASTM F2413 ASTM F2412 ASTM F2675/F2675M

283 53 of 403 9/2/2016 9:49 AM Gloves Leather Protectors Gloves Rubber Insulating Gloves and Sleeves In-Service Care Head Protection Hard Hats Rainwear Arc Rated Rubber Protective Products Visual Inspection Sleeves Insulating Standard Specification for Leather Protectors for Rubber Insulating Gloves and Mittens Standard Specification for Rubber Insulating Gloves ASTM F696 ASTM D120 Standard Specification for In-Service Care of Insulating Gloves ASTM F496 and Sleeves Industrial Head Protection ANSI/ISEA Z89.1 Standard Specification for Arc and Flame Resistant Rainwear Standard Guide for Visual Inspection of Electrical Protective Rubber Products Standard Specification for Rubber Insulating Sleeves ASTM F1891 ASTM F1236 ASTM D1051 Statement of Problem and Substantiation for Public Comment This Public Comment is submitted by Daniel Roberts in behalf of the Canadian Standards Association (CSA) Z462 Workplace Electrical Safety Technical Committee. Revise and relocate new section 130.7(C)(16) Conformity Assessment as Informational Note No. 2 in Section 130.7(C)(14) Standards for Personal Protective Equipment (PPE). An additional comment will be submitted to revise the First Revisions in Informative Annex H.4 related to conformity assessment. The information regarding conformity assessment is better suited as an informational note. On the surface the idea of conformity assessment seems like a good idea. However, upon closer examination it becomes evident that there are potential issues in both application and enforcement. 1. There is no evidence that this new requirement will be any more effective at eliminating counterfeit or non-compliant products than current self declaration. Manufacturers can continue to label their products according to the Standard even though their products are non-conformant. 2. The proposed wording within 130.7(C)(16)(b) requires marking of PPE, however this conflicts with the ANSI/ISEA 125 Standard which does not require product marking. ANSI/ISEA 125 allows for the marking to be separate, e.g. on the packaging, sales materials, etc. 3. The requirements will cause confusion for the general industry including both manufacturers and consumers. For example: a. The term level is often confused with Arc Flash PPE Categories and ASTM Rubber Insulating Glove Classifications. b. It is unclear whether Level 3 requires all items within Level 2, plus the addition of third party testing, or whether a third party certification in any form covers all Level 3 requirements. c. It is unclear whether Level 2 and 3 require that all components to be manufactured within an ISO 9001 certified manufacturing facility, or if only the final product has to be manufactured by an ISO 9001 registered company. Additionally, it is unclear whether the Third Party Certification Organization will certify a final product where not all components are manufactured within an ISO 9001 certified facilities. d. It is unclear whether Level 2 and 3 require all components to be tested within an ISO certified laboratory, or if only the final product is required to be manufactured within an ISO certified laboratory. e. It is unclear whether the higher level of conformity is needed when there is a higher hazard or a higher probability of occurrence. One example scenario is the difference between high and low energy arc flash energy potential exposures. High energy exposures will result in higher injury potential, however more employees in general industry are exposed to the hazards of low energy arcs. Reading H.4.3, one cannot determine which would necessitate the higher conformity assessment.

284 54 of 403 9/2/2016 9:49 AM While this is by no means an exhaustive listing of all issues or concerns, it is sufficient to either delete the new requirement entirely or revise and relocate as an informational note. Related Item First Revision No. 70-NFPA 70E-2015 [New Section after 130.7(C)(16)] Submitter Information Verification Submitter Full Name: Daniel Roberts Organization: Schneider Electric Affilliation: CSA Z462 Technical Committee Street Address: City: State: Zip: Submittal Date: Mon Apr 25 14:36:47 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-36-NFPA 70E-2016 Statement: Because mandatory references have become informational in nature, the document lacked any guidance for manufacturers of PPE with regard to product performance. The new language regarding conformity assessment and marking requirements provides a standard format for a manufacture to describe the performance and assure the quality of their products. The requirements for conformity assessment are more properly located in 130.7(C)(14) where "standards for personal protective equipment" are presently located. The mandatory reference in 130.7(C)(14) is removed and relocated to Informational Note No.1 and the table is retitled as "Informational Note Table 130.7(C)(14).

285 55 of 403 9/2/2016 9:49 AM Public Comment No. 113-NFPA 70E-2016 [ Section No (C)(15) ]

286 56 of 403 9/2/2016 9:49 AM (15) Arc Flash PPE Category Method.

287 57 of 403 9/2/2016 9:49 AM The requirements of 130.7(C)(15) shall apply when the arc flash PPE category method is used for the selection of arc flash PPE. (a) Alternating Current (ac) Equipment. When the arc flash risk assessment performed in accordance with indicates that arc flash PPE is required and the arc flash PPE category method is used for the selection of PPE for ac systems in lieu of the incident energy analysis of 130.5(B)(1), Table 130.7(C)(15)(a) shall be used to determine the arc flash PPE category. The estimated maximum available fault current, maximum fault-clearing times, and minimum working distances for various ac equipment types or classifications are listed in Table 130.7(C)(15)(a). An incident energy analysis shall be required in accordance with for the following: (2) Tasks not included in Table (1) (2) Power systems with greater than the estimated maximum available short-circuit current (3) Power systems with longer than the maximum fault clearing times Tasks (1) Specific tasks with less than the minimum working distance for the specific task to be performed from the (1) from the employee s face and chest areas to an arc source (c) Direct Current (dc) Equipment.When the arc flash risk assessment performed in accordance with indicates that arc flash PPE is required and the arc flash PPE category method is used for the selection of PPE for dc systems in lieu of the incident energy analysis of 130.5(B)(1), Table 130.7(C)(15)(b) shall be used to determine the arc flash PPE category. The estimated maximum available fault current, maximum arc duration, and working distances for dc equipment are listed in 130.7(C)(15)(b). An incident energy analysis shall be required in accordance with for the following: (4) Tasks not included in Table (1) (2) Power systems with greater than the estimated maximum available short-circuit current (3) Power systems with longer than the maximum fault clearing times Tasks (1) Specific tasks with less than the minimum working distance for the specific task to be performed from the (1) from the employee s face and chest areas to an arc source Informational Note No.1: The arc flash PPE category of the protective clothing and equipment is generally based on determination of the estimated exposure level. Informational Note No.2: In most cases, closed doors do not provide enough protection to eliminate the need for PPE in situations in which the state of the equipment is known to readily change (e.g., doors open or closed, rack in or rack out). Informational Note No.3: Short-circuit current, as used in this table, is determined from the dc power system maximum available short-circuit, including the effects of cables and any other impedances in the circuit. Power system modeling is the best method to determine the available short-circuit current at the point of the arc. Battery cell short-circuit current can be obtained from the battery manufacturer. See Informative Annex D.5 for the basis for table values and alternative methods to determine dc incident energy. Methods should be used with good engineering judgment. Informational Note No.4: The methods for estimating the dc arc-flash incident energy that were

288 58 of 403 9/2/2016 9:49 AM used to determine the categories for this table are based on open-air incident energy calculations. Open-air calculations were used because many battery systems and other dc process systems are in open areas or rooms. If the specific task is within in an enclosure, it would be prudent to consider additional PPE protection beyond the value shown in this table. Engineering judgment is necessary when reviewing the specific conditions of the equipment and task to be performed, including the dimensions of the enclosure and the working distance involved. (1) (e) Protective Clothing and Personal Protective Equipment (PPE). Once the arc flash PPE category has been identified from Table 130.7(C)(15)(a) or Table 130.7(C)(15)(b), Table 130.7(C)(15)(c) shall be used to determine the required PPE for the task. Table 130.7(C)(15)(c) lists the requirements for PPE based on arc flash PPE categories 1 through 4. This clothing and equipment shall be used when working within the arc flash boundary. Informational Note No. 1: See Informative Annex H for a suggested simplified approach to ensure adequate PPE for electrical workers within facilities with large and diverse electrical systems. Informational Note No. 2: The PPE requirements of this section are intended to protect a person from arc flash hazards. While some situations could result in burns to the skin, even with the protection described in Table 130.7(C)(15)(c), burn injury should be reduced and survivable. Due to the explosive effect of some arc events, physical trauma injuries could occur. The PPE requirements of this section do not address protection against physical trauma other than exposure to the thermal effects of an arc flash. Informational Note No. 3: The arc rating for a particular clothing system can be obtained from the arc-rated clothing manufacturer. Table 130.7(C)(15)(a) Arc-Flash PPE Categories for Alternating Current (ac) Systems Equipment Panelboards or other equipment rated 240 volts and below Parameters: Maximum of 25 ka available fault current; maximum of 0.03 s (2 cycles) fault clearing time; minimum working distance 455 mm (18 in.) Panelboards or other equipment rated greater than 240 volts and up to 600 volts Parameters: Maximum of 25 ka available fault current; maximum of 0.03 s (2 cycles) fault clearing time; minimum working distance 455 mm (18 in.) 600-volt class motor control centers (MCCs) Parameters: Maximum of 65 ka available fault current; maximum of 0.03 s (2 cycles) fault clearing time; minimum working distance 455 mm (18 in.) 600-volt class motor control centers (MCCs) Parameters: Maximum of 42 ka available fault current; maximum of 0.33 s (20 cycles) fault clearing time; minimum working distance 455 mm (18 in.) 600-volt class switchgear (with power circuit breakers or fused switches) and 600-volt class switchboards Parameters: Maximum of 35 ka available fault current; maximum of up to 0.5 s (30 cycles) fault clearing time; minimum working distance 455 Arc Flash PPE Category Arc-Flash Boundary 485 mm (19 in.) 900 mm (3 ft) 1.5 m (5 ft) 4.3 m (14 ft) 6 m (20 ft)

289 59 of 403 9/2/2016 9:49 AM Equipment mm (18 in.) Other 600-volt class (277 volts through 600 volts, nominal) equipment Parameters: Maximum of 65 ka available fault current; maximum of 0.03 s (2 cycles) fault clearing time; minimum working distance 455 mm (18 in.) NEMA E2 (fused contactor) motor starters, 2.3 kv through 7.2 kv Parameters: Maximum of 35 ka available fault current; maximum of up to 0.24 s (15 cycles) fault clearing time; minimum working distance 910 mm (36 in.) Metal-clad switchgear, 1 kv through 15 kv Parameters: Maximum of 35 ka available fault current; maximum of up to 0.24 s (15 cycles) fault clearing time; minimum working distance 910 mm (36 in.) Arc-resistant switchgear Type 1 or 2 [for clearing times of less than 0.5 s (30 cycles) with a perspective fault current not to exceed the arc-resistant rating of the equipment], and metalenclosed interrupter switchgear, fused or unfused of arc-resistant-type construction, tested in accordance with IEEE C , 1 kv through 15 kv Parameters: Maximum of 35 ka available fault current; maximum of up to 0.24 s (15 cycles) fault clearing time; minimum working distance 910 mm (36 in.) Other equipment 1 kv through 15 kv Parameters: Maximum of 35 ka available fault current; maximum of up to 0.24 s (15 cycles) fault clearing time; minimum working distance 910 mm (36 in.) Notes: Arc Flash PPE Category N/A (doors closed) 4 (doors open) 4 Arc-Flash Boundary 1.5 m (5 ft) 12 m (40 ft) 12 m (40 ft) N/A (doors closed) 12 m (40 ft) 12 m (40 ft) (1) Note: For equipment rated 600 volts and below and protected by upstream current-limiting fuses or current-limiting circuit breakers sized at 200 amperes or less, the arc flash PPE category can be reduced by one number but not below arc flash PPE category 1. (2) Informational Note: The following are typical fault clearing times of overcurrent protective devices: (a) 0.5 cycle fault clearing time is typical for current limiting fuses when the fault current is within the current limiting range. (b) 1.5 cycle fault clearing time is typical for molded case circuit breakers rated less than 1000 volts with an instantaneous integral trip. (c) 3.0 cycle fault clearing time is typical for insulated case circuit breakers rated less than 1000 volts with an instantaneous integral trip or relay operated trip. (d) 5.0 cycle fault clearing time is typical for relay operated circuit breakers rated 1 kv to 35 kv when the fault current is within the instantaneous operating range. (e) 20 cycle fault clearing time is typical for low-voltage power and insulated case circuit breakers with a short time fault clearing delay for motor inrush. (f) 30 cycle fault clearing time is typical for low-voltage power and insulated case circuit breakers with a

290 60 of 403 9/2/2016 9:49 AM short time fault clearing delay without instantaneous trip. (See IEEE Table 1 for further information regarding Informational Notes b through d.) Table 130.7(C)(15)(b) Arc-Flash PPE Categories for Direct Current (dc) Systems Equipment Storage batteries, dc switchboards, and other dc supply sources Parameters: Greater than or equal to 100 V and less than or equal to 250 V Arc Flash PPE Category Arc-Flash Boundary Maximum arc duration and minimum working distance: mm (18 in.) Short-circuit current less than 4 ka 1 2 Short-circuit current greater than or equal to 4 ka and less than 7 ka Short-circuit current greater than or equal to 7 ka and less than 15 ka Storage batteries, dc switchboards, and other dc supply sources Parameters: Greater than or equal to V and less than or equal to 600 V Maximum arc duration and minimum working distance: mm (18 in.) Short-circuit current less than 1.5 ka 1 2 Short-circuit current greater than or equal to 1.5 ka and less than 3 ka Short-circuit current greater than or equal to 3 ka and less than 7 ka Short-circuit current greater than or equal to 7 ka and less than 10 ka mm (3 ft) 1.2 m (4 ft) 1.8 m (6 ft) 900 mm (3 ft) 1.2 m (4 ft) 1.8 m (6 ft.) 2.5 m (8 ft) Note 1: Apparel that can be expected to be exposed to electrolyte must meet both of the following conditions: (1) Be evaluated for electrolyte protection in accordance with ASTM F1296, Standard Guide for Evaluating Chemical Protective Clothing (2) Be arc-rated in accordance with ASTM F1891, Standard Specification for Arc Rated and Flame Resistant Rainwear, or equivalent Note 2: A two-second arc duration is assumed if there is no OCPD or if the fault clearing time is not known. If the fault clearing time is known and is less than two seconds, an incident energy analysis could provide a more representative result. Informational Note No.1: Short-circuit current, as used in this table, is determined from the dc power system maximum available short-circuit, including the effects of cables and any other impedances in the circuit. Power system modeling is the best method to determine the available short-circuit current at the point of the arc. Battery cell short-circuit current can be obtained from the battery manufacturer. See Informative Annex D.5 for the basis for table values and alternative methods to determine dc incident energy. Methods should be used with good engineering

291 61 of 403 9/2/2016 9:49 AM judgment. Informational Note No.2: The methods for estimating the dc arc-flash incident energy that were used to determine the categories for this table are based on open-air incident energy calculations. Open-air calculations were used because many battery systems and other dc process systems are in open areas or rooms. If the specific task is within in an enclosure, it would be prudent to consider additional PPE protection beyond the value shown in this table. Engineering judgment is necessary when reviewing the specific conditions of the equipment and task to be performed, including the dimensions of the enclosure and the working distance involved. Table 130.7(C)(15)(c) Personal Protective Equipment (PPE) Arc Flash PPE Category PPE Arc-Rated Clothing, Minimum Arc Rating of 4 cal/cm 2 (16.75 J/cm 2 ) a Arc-rated long-sleeve shirt and pants or arc-rated coverall Arc-rated face shield b (see Note 2) or arc flash suit hood Arc-rated jacket, parka, rainwear, or hard hat liner (AN) 1 Protective Equipment Hard hat Safety glasses or safety goggles (SR) Hearing protection Heavy-duty leather gloves c Leather footwear (AN) Arc-Rated Clothing, Minimum Arc Rating of 8 cal/cm 2 (33.5 J/cm 2 ) a Arc-rated long-sleeve shirt and pants or arc-rated coverall Arc-rated flash suit hood or arc-rated face shield b and arc-rated balaclava Arc-rated jacket, parka, rainwear, or hard hat liner (AN) 2 Protective Equipment Hard hat Safety glasses or safety goggles (SR) Hearing protection Heavy-duty leather gloves c Leather footwear Arc-Rated Clothing Selected so That the System Arc Rating Meets the Required Minimum Arc Rating of 25 cal/cm 2 (104.7 J/cm 2 ) a Arc-rated long-sleeve shirt (AR) Arc-rated pants (AR) Arc-rated coverall (AR) 3 Arc-rated arc flash suit jacket (AR) Arc-rated arc flash suit pants (AR) Arc-rated arc flash suit hood Arc-rated gloves c Arc-rated jacket, parka, rainwear, or hard hat liner (AN) Protective Equipment

292 62 of 403 9/2/2016 9:49 AM Hard hat Safety glasses or safety goggles (SR) Hearing protection Leather footwear Arc-Rated Clothing Selected so That the System Arc Rating Meets the Required Minimum Arc Rating of 40 cal/cm 2 (167.5 J/cm 2 ) a Arc-rated long-sleeve shirt (AR) Arc-rated pants (AR) Arc-rated coverall (AR) Arc-rated arc flash suit jacket (AR) Arc-rated arc flash suit pants (AR) 4 Arc-rated arc flash suit hood Arc-rated gloves c Arc-rated jacket, parka, rainwear, or hard hat liner (AN) Protective Equipment Hard hat Safety glasses or safety goggles (SR) Hearing protection Leather footwear Notes: AN: as needed (optional). AR: as required. SR: selection required. a Arc rating is defined in Article 100. b Face 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. c If 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. Statement of Problem and Substantiation for Public Comment This Public Comment is submitted by Daniel Roberts in behalf of the Canadian Standards Association (CSA) Z462 Workplace Electrical Safety Technical Committee. (1) Delete list items 130.7(C)(15)(A)(1) and 130.7(C)(15)(B)(1) and renumber the remaining list items. The Arc Flash PPE Category method of selecting PPE is no longer task based; it is equipment based. (2) Rephrase list items 130.7(C)(15)(A)(4) and 130.7(C)(15)(B)(4) for clarity. As currently written the list item is awkwardly phrased. (3) Errata: 130.7(C)(15)(A) Informational Notes No. 3 and No. 4 belong to Table 130.7(C)(15)(B) and should be relocated below that Table. (4) Errata: Table 130.7(C)(15)(A) Note 2 was intended to be an informational note. See Tables Task Group document: 130.7(C)(15) & (16)_Rev_ jd.docx. (5) Table 130.7(C)(15)(A) Note 2: Add when the fault current is within to list items (a) and (d) to clarify when the specified fault clearing times apply. (6) Errata: Table 130.7(C)(15)(B) delete or equal to before 250 V in the second horizontal table section. The first horizontal table section already includes equal to 250 V. Both statements cannot be true. (7) Table 130.7(C)(15)(B): Revise both occurrences of PPE Category 1 to PPE Category 2. (See Public Input # 346) The two instances when PPE Category 1 is specified in Table 130.7(C)(15)(B) the arc flash boundary of 36 inches extends well past the specified working distance of 18 inches. This creates a conflict with the requirement to

293 63 of 403 9/2/2016 9:49 AM protect all parts of the body within the arc flash boundary as PPE Category 1 does not require the use of a balaclava. However, adding an arc-rated balaclava to PPE category 1 in Table 130.7(C)(16) to resolve this conflict will have the unintended consequence of requiring the use of a balaclava for tasks performed on ac panelboards rated up to 240 V where the arc flash boundary of 19 inches does not extend past the back of the head at the specified working distance of 18 inches. Revising the two references to PPE Category 1 to Category 2 in Table 130.7(C)(15)(B) rather than adding a balaclava to PPE Category 1 in Table 130.7(C)(16) resolves the conflict in a more pragmatic way. Related Item First Revision No. 48-NFPA 70E-2015 [Sections 130.7(C)(15), 130.7(C)(16)] Public Input No. 346-NFPA 70E-2015 [Sections 130.7(C)(15), 130.7(C)(16)] Submitter Information Verification Submitter Full Name: Daniel Roberts Organization: Schneider Electric Affilliation: CSA Z462 Technical Committee Street Address: City: State: Zip: Submittal Date: Mon Apr 25 10:50:07 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-35-NFPA 70E-2016 Statement: 1. List items 130.7(C)(15)(A)(1) and (B)(1) are deleted as Tables 130.7(C)(15(a) and 130.7(C)(15)(b) are no longer task based, rather, they are equipment based (C)(15(A)(2): The phrase short circuit current is revised to available fault current for correlation in the standard in AC systems. 3. List items 130.7(C)(15)(A)(4) and (B)(4) are editorially revised for clarity. 4. List item 130.7(C)(15)(B)(2) and Table 130.7(C)(15)(b): short circuit current is revised to available fault current for consistent use of terminology and to correlate with the definition of available fault current in Article (C)(15) Informational Notes 3 and 4 are relocated to below Table 130.7(C)(15)(b) as they only apply to that table. 6. Table 130.7(C)(15)(a) Note 2 is changed to an Informational Note in accordance to correlate with the action taken by the Committee in the first draft. 7. Table 130.7(C)(15)(a): Informational Note list items (a) and (d) are modified for clarity. 8. Table 130.7(C)(15)(b): The phrase or equal to is deleted from parameter Greater than or equal to 250 V and less than or equal to 600 V in the second section to correlate with the parameter Greater than or equal to 100 V and less than or equal to 250 V in the first section of the table. Both sections of the Table cannot apply to 250 V. 9. Table 130.7(C)(15)(b): Both references to Arc Flash PPE Category 1 are revised to Arc Flash PPE Category 2 because the arc flash boundaries are at 900 mm (36-inches). This action is necessary for correlation as the existing requirement is in direct conflict with 130.7(C)(10)(b)(1).

294 64 of 403 9/2/2016 9:49 AM 10. Table 130.7(C)(15)(c): The requirement for ear canal inserts is restored in the Second Revision. Specifically identifying ear canal inserts rather than a generic reference to hearing protection simplifies use of the table for the electrical worker. Ear canal inserts provide a similar if not greater Noise Reduction Rating (NRR) when compared to ear muffs, but without a large amount of meltable material in the ear and face area. Table Note (d) informs the user of the standard that other types of hearing protection are permitted to be used in lieu of or in addition to ear canal inserts provided it is worn under arc-rated arc flash suit hood. In order for hearing protection to achieve a reliable NRR it must form a seal within the ear canal or over the ear, and so cannot be worn over top of PPE. 11. The reference to Type 1 and Type 2 is deleted from the arc resistant portion of Table 130.7(C) (15)(a) as it is no longer necessary because it is only available in Type 1 and Type 2 as available and tested in accordance with IEEE C The voltage reference in this portion of the table was relocated for clarity.

295 65 of 403 9/2/2016 9:49 AM Public Comment No. 131-NFPA 70E-2016 [ Section No (C)(15) ]

296 66 of 403 9/2/2016 9:49 AM (15) Arc Flash PPE Category Method.

297 67 of 403 9/2/2016 9:49 AM The requirements of 130.7(C)(15) shall apply when the arc flash PPE category method is used for the selection of arc flash PPE. (a) Alternating Current (ac) Equipment. When the arc flash risk assessment performed in accordance with indicates that arc flash PPE is required and the arc flash PPE category method is used for the selection of PPE for ac systems in lieu of the incident energy analysis of 130.5(B)(1), Table 130.7(C)(15)(a) shall be used to determine the arc flash PPE category. The estimated maximum available fault current, maximum fault-clearing times, and minimum working distances for various ac equipment types or classifications are listed in Table 130.7(C)(15)(a). An incident energy analysis shall be required in accordance with for the following: (2) Tasks not included in Table (3) Power systems with greater than the estimated maximum available short-circuit current (4) Power systems with longer than the maximum fault clearing times (5) Tasks with less than the minimum working distance for the specific task to be performed from the employee s face and chest areas to an arc source (f) Direct Current (dc) Equipment.When the arc flash risk assessment performed in accordance with indicates that arc flash PPE is required and the arc flash PPE category method is used for the selection of PPE for dc systems in lieu of the incident energy analysis of 130.5(B)(1), Table 130.7(C)(15)(b) shall be used to determine the arc flash PPE category. The estimated maximum available fault current, maximum arc duration, and working distances for dc equipment are listed in 130.7(C)(15)(b). An incident energy analysis shall be required in accordance with for the following: (7) Tasks not included in Table (8) Power systems with greater than the estimated maximum available short-circuit current (9) Power systems with longer than the maximum fault clearing times (10) Tasks with less than the minimum working distance for the specific task to be performed from the employee s face and chest areas to an arc source Informational Note No.1: The arc flash PPE category of the protective clothing and equipment is generally based on determination of the estimated exposure level. Informational Note No.2: In most cases, closed doors do not provide enough protection to eliminate the need for PPE in situations in which the state of the equipment is known to readily change (e.g., doors open or closed, rack in or rack out). Informational Note No.3: Short-circuit current, as used in this table, is determined from the dc power system maximum available short-circuit, including the effects of cables and any other impedances in the circuit. Power system modeling is the best method to determine the available short-circuit current at the point of the arc. Battery cell short-circuit current can be obtained from the battery manufacturer. See Informative Annex D.5 for the basis for table values and alternative methods to determine dc incident energy. Methods should be used with good engineering judgment. Informational Note No.4: The methods for estimating the dc arc-flash incident energy that were used to determine the categories for this table are based on open-air incident energy calculations. Open-air calculations were used because many battery systems and other dc process systems are in open areas or rooms. If the specific task is within in an enclosure, it would be prudent to consider additional PPE protection beyond the value shown in this table. Engineering judgment is necessary when reviewing the specific conditions of the equipment and task to be performed, including the dimensions of the enclosure and the working distance involved. (k) Protective Clothing and Personal Protective Equipment (PPE). Once the arc flash PPE category has been identified from Table 130.7(C)(15)(a) or Table 130.7(C)(15)(b), Table 130.7(C)(15)(c) shall be used to determine the required PPE for the task. Table 130.7(C)(15)(c) lists the requirements for PPE based on arc flash PPE categories 1 through 4. This clothing and equipment shall be used when working within the

298 68 of 403 9/2/2016 9:49 AM arc flash boundary. Informational Note No. 1: See Informative Annex H for a suggested simplified approach to ensure adequate PPE for electrical workers within facilities with large and diverse electrical systems. Informational Note No. 2: The PPE requirements of this section are intended to protect a person from arc flash hazards. While some situations could result in burns to the skin, even with the protection described in Table 130.7(C)(15)(c), burn injury should be reduced and survivable. Due to the explosive effect of some arc events, physical trauma injuries could occur. The PPE requirements of this section do not address protection against physical trauma other than exposure to the thermal effects of an arc flash. Informational Note No. 3: The arc rating for a particular clothing system can be obtained from the arc-rated clothing manufacturer. Table 130.7(C)(15)(a) Arc-Flash PPE Categories for Alternating Current (ac) Systems Equipment Panelboards or other equipment rated 240 volts and below Parameters: Maximum of 25 ka available fault current; maximum of 0.03 s (2 cycles) fault clearing time; minimum working distance 455 mm (18 in.) Panelboards or other equipment rated greater than 240 volts and up to 600 volts Parameters: Maximum of 25 ka available fault current; maximum of 0.03 s (2 cycles) fault clearing time; minimum working distance 455 mm (18 in.) 600-volt class motor control centers (MCCs) Parameters: Maximum of 65 ka available fault current; maximum of 0.03 s (2 cycles) fault clearing time; minimum working distance 455 mm (18 in.) 600-volt class motor control centers (MCCs) Parameters: Maximum of 42 ka available fault current; maximum of 0.33 s (20 cycles) fault clearing time; minimum working distance 455 mm (18 in.) 600-volt class switchgear (with power circuit breakers or fused switches) and 600-volt class switchboards Parameters: Maximum of 35 ka available fault current; maximum of up to 0.5 s (30 cycles) fault clearing time; minimum working distance 455 mm (18 in.) 600 volt class arc-resistant switchgear (with power circuit breakers or fused switches) [ for clearing times of less than or equal to the tested arc duration of the equipment, tested in accordance with IEEE C volt class arc-resistant switchgear (with power circuit breakers or fused switches) [ for clearing times of less than or equal to the tested arc duration of the equipment, tested in accordance with IEEE C Parameters: Maximum of 35 ka available fault current; maximum of up to 0.5 sec s (30 cycles) fault clearing time; minimum working Arc Flash PPE Category N/A (doors closed) 4 (doors open) Arc-Flash Boundary 485 mm (19 in.) 900 mm (3 ft) 1.5 m (5 ft) 4.3 m (14 ft) 6 m (20 ft) N/A (doors closed) 6 m (20 ft)

299 Equipment Arc Flash PPE Category Arc-Flash Boundary distance 455 mm (18 in.) Other 600-volt class (277 volts through 600 volts, nominal) equipment Parameters: Maximum of 65 ka available fault current; maximum of 0.03 s (2 cycles) fault clearing time; minimum working distance 455 mm (18 in.) NEMA E2 (fused contactor) motor starters, 2.3 kv through 7.2 kv Parameters: Maximum of 35 ka available fault current; maximum of up to 0.24 s (15 cycles) fault clearing time; minimum working distance 910 mm (36 in.) m (5 ft) 12 m (40 ft) Metal-clad switchgear, 1 kv through 15 kv Parameters: Maximum of 35 ka available fault current; maximum of up to 0.24 s (15 cycles) fault clearing time; minimum working distance 910 mm (36 in.) Arc 1 kv through 15 kv arc -resistant switchgear Type 1 or 2 [for clearing times of less than 0.5 s (30 cycles) with a perspective fault current not to exceed the arc-resistant rating or equal to the tested arc duration of the equipment], and metal-enclosed interrupter switchgear, fused or unfused of arc-resistant-type construction, tested in accordance with IEEE C , 1 kv through 15 kv. 1 kv through 15 kv arc-resistant switchgear [ for clearing times of less than or equal to the tested arc duration of the equipment ] tested in accordance with IEEE C Parameters:. 4 N/A (doors closed) 12 m (40 ft) N/A (doors closed) Maximum of 35 ka available fault current; maximum of up to 0.24 s (15 cycles) fault clearing time; minimum working distance 910 mm (36 in.) 4 (doors open) 12 m. (40 ft) Other equipment 1 kv through 15 kv Parameters: Maximum of 35 ka available fault current; maximum of up to 0.24 s (15 cycles) fault clearing time; minimum working distance 910 mm (36 in.) Notes: 4 12 m (40 ft) (1) For equipment rated 600 volts and below and protected by upstream current-limiting fuses or current- 69 of 403 9/2/2016 9:49 AM

300 70 of 403 9/2/2016 9:49 AM limiting circuit breakers sized at 200 amperes or less, the arc flash PPE category can be reduced by one number but not below arc flash PPE category 1. (2) The following are typical fault clearing times of overcurrent protective devices: (a) 0.5 cycle fault clearing time is typical for current limiting fuses. (b) 1.5 cycle fault clearing time is typical for molded case circuit breakers rated less than 1000 volts with an instantaneous integral trip. (c) 3.0 cycle fault clearing time is typical for insulated case circuit breakers rated less than 1000 volts with an instantaneous integral trip or relay operated trip. (d) 5.0 cycle fault clearing time is typical for relay operated circuit breakers rated 1 kv to 35 kv. (e) 20 cycle fault clearing time is typical for low-voltage power and insulated case circuit breakers with a short time fault clearing delay for motor inrush. (f) 30 cycle fault clearing time is typical for low-voltage power and insulated case circuit breakers with a short time fault clearing delay without instantaneous trip. (See IEEE Table 1 for further information regarding Notes b through d.) Table 130.7(C)(15)(b) Arc-Flash PPE Categories for Direct Current (dc) Systems Equipment Storage batteries, dc switchboards, and other dc supply sources Parameters: Greater than or equal to 100 V and less than or equal to 250 V Arc Flash PPE Category Arc-Flash Boundary Maximum arc duration and minimum working distance: mm (18 in.) Short-circuit current less than 4 ka 1 Short-circuit current greater than or equal to 4 ka and less than 7 ka Short-circuit current greater than or equal to 7 ka and less than 15 ka Storage batteries, dc switchboards, and other dc supply sources Parameters: Greater than or equal to 250 V and less than or equal to 600 V Maximum arc duration and minimum working distance: mm (18 in.) Short-circuit current less than 1.5 ka 1 Short-circuit current greater than or equal to 1.5 ka and less than 3 ka Short-circuit current greater than or equal to 3 ka and less than 7 ka Short-circuit current greater than or equal to 7 ka and less than 10 ka mm (3 ft) 1.2 m (4 ft) 1.8 m (6 ft) 900 mm (3 ft) 1.2 m (4 ft) 1.8 m (6 ft.) 2.5 m (8 ft) Note 1: Apparel that can be expected to be exposed to electrolyte must meet both of the following conditions:

301 71 of 403 9/2/2016 9:49 AM (1) Be evaluated for electrolyte protection in accordance with ASTM F1296, Standard Guide for Evaluating Chemical Protective Clothing (2) Be arc-rated in accordance with ASTM F1891, Standard Specification for Arc Rated and Flame Resistant Rainwear, or equivalent Note 2: A two-second arc duration is assumed if there is no OCPD or if the fault clearing time is not known. If the fault clearing time is known and is less than two seconds, an incident energy analysis could provide a more representative result. Table 130.7(C)(15)(c) Personal Protective Equipment (PPE) Arc Flash PPE Category PPE Arc-Rated Clothing, Minimum Arc Rating of 4 cal/cm 2 (16.75 J/cm 2 ) a Arc-rated long-sleeve shirt and pants or arc-rated coverall Arc-rated face shield b (see Note 2) or arc flash suit hood Arc-rated jacket, parka, rainwear, or hard hat liner (AN) 1 Protective Equipment Hard hat Safety glasses or safety goggles (SR) Hearing protection Heavy-duty leather gloves c Leather footwear (AN) Arc-Rated Clothing, Minimum Arc Rating of 8 cal/cm 2 (33.5 J/cm 2 ) a Arc-rated long-sleeve shirt and pants or arc-rated coverall Arc-rated flash suit hood or arc-rated face shield b and arc-rated balaclava Arc-rated jacket, parka, rainwear, or hard hat liner (AN) 2 Protective Equipment Hard hat Safety glasses or safety goggles (SR) Hearing protection Heavy-duty leather gloves c Leather footwear Arc-Rated Clothing Selected so That the System Arc Rating Meets the Required Minimum Arc Rating of 25 cal/cm 2 (104.7 J/cm 2 ) a Arc-rated long-sleeve shirt (AR) Arc-rated pants (AR) Arc-rated coverall (AR) 3 Arc-rated arc flash suit jacket (AR) Arc-rated arc flash suit pants (AR) Arc-rated arc flash suit hood Arc-rated gloves c Arc-rated jacket, parka, rainwear, or hard hat liner (AN) Protective Equipment

302 72 of 403 9/2/2016 9:49 AM Hard hat Safety glasses or safety goggles (SR) Hearing protection Leather footwear Arc-Rated Clothing Selected so That the System Arc Rating Meets the Required Minimum Arc Rating of 40 cal/cm 2 (167.5 J/cm 2 ) a Arc-rated long-sleeve shirt (AR) Arc-rated pants (AR) Arc-rated coverall (AR) Arc-rated arc flash suit jacket (AR) Arc-rated arc flash suit pants (AR) 4 Arc-rated arc flash suit hood Arc-rated gloves c Arc-rated jacket, parka, rainwear, or hard hat liner (AN) Protective Equipment Hard hat Safety glasses or safety goggles (SR) Hearing protection Leather footwear Notes: AN: as needed (optional). AR: as required. SR: selection required. a Arc rating is defined in Article 100. b Face 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. c If 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. Additional Proposed Changes Table_130-7C15Ab_Eaton_markup_ docx File Name Description Approved Statement of Problem and Substantiation for Public Comment Proposed Comments to Table (C)(15) (A)(b) Substantiation: These Comments to FR-48 (Table 130.7(C)(15)(A)(b) addresses the following areas: 1) A clarification that for Medium Voltage Arc-resistant equipment, the test Parameters apply only with the equipment doors open (with the doors closed, the arc flash risk is diminished). 2) A clarification to highlight that where 600 volt class Arc-resistant Switchgear is used, that the test Parameters apply only with the equipment doors open. Related Item First Revision No. 48-NFPA 70E-2015 [Sections 130.7(C)(15), 130.7(C)(16)]

303 73 of 403 9/2/2016 9:49 AM Submitter Information Verification Submitter Full Name: Christopher Walker Organization: Eaton Corporation Street Address: City: State: Zip: Submittal Date: Tue Apr 26 13:15:04 EDT 2016 Committee Statement Committee Action: Rejected but held Resolution: The Public Comment introduces new material that has not had public review.

304 . Proposed Comments to Table (C)(15)(A)(b) Equipment 600-volt class switchgear (with power circuit breakers or fused switches) and 600-volt class switchboards.. Parameters: Maximum of 35 ka available fault current; maximum of up to 0.5 s (30 cycles) fault clearing time; minimum working distance 455 mm (18 in.) 600 volt class arc-resistant switchgear (with power circuit breakers or fused switches) [for clearing times of less than or equal to the tested arc duration of the equipment, tested in accordance with IEEE C Arc Flash PPE Category 4 N/A (doors closed) Arc-Flash Boundary 6 m (20 ft) N/A (doors closed) 600 volt class arc-resistant switchgear (with power circuit breakers or fused switches) [for clearing times of less than or equal to the tested arc duration of the equipment, tested in accordance with IEEE C Parameters: Maximum of 35 ka available fault current; maximum of up to 0.5 secs (30 cycles) fault clearing time; minimum working distance 455 mm (18 in.) 4 (doors open) 6 m (20 ft) 1 kv through 15 kv arc-resistant switchgear Type 1 or 2 [for clearing times of less than 0.5 s (30 cycles)] [for clearing times of less than or equal to the tested arc duration of the equipment], with a perspective fault current not to exceed the arcresistant rating of the equipment], and metal- closed) N/A (doors enclosed interrupter switchgear, fused or unfused of arc-resistant-type construction, tested in accordance with IEEE C , 1 kv through 15 kv Arc-resistant 1 kv through 15 kv arc-resistant switchgear [for clearing times of less than or equal to the tested arc duration of the equipment] tested in accordance with IEEE C Parameters: Maximum of 35 ka available fault current; maximum of up to 0.24 s (15 cycles) fault clearing time; minimum working distance 910 mm (36 in.) 4 (doors open) N/A (doors closed) 12 m (40 ft)

305 Substantiation: These Comments to FR 48 (Table 130.7(C)(15)(A)(b) addresses the following areas: 1) A clarification that for Medium Voltage Arc resistant equipment, the test Parameters apply only with the equipment doors open (with the doors closed, the arc flash risk is diminished). 2) A clarification to highlight that where 600 volt class Arc resistant Switchgear is used, that the test Parameters apply only with the equipment doors open.

306 74 of 403 9/2/2016 9:49 AM Public Comment No. 184-NFPA 70E-2016 [ Section No (C)(15) ]

307 75 of 403 9/2/2016 9:49 AM (15) Arc Flash PPE Category Method.

308 76 of 403 9/2/2016 9:49 AM The requirements of 130.7(C)(15) shall apply when the arc flash PPE category method is used for the selection of arc flash PPE. (a) Alternating Current (ac) Equipment. When the arc flash risk assessment performed in accordance with indicates that arc flash PPE is required and the arc flash PPE category method is used for the selection of PPE for ac systems in lieu of the incident energy analysis of 130.5(B)(1), Table 130.7(C)(15)(a) shall be used to determine the arc flash PPE category. The estimated maximum available fault current, maximum fault-clearing times, and minimum working distances for various ac equipment types or classifications are listed in Table 130.7(C)(15)(a). An incident energy analysis shall be required in accordance with for the following: (2) Tasks not included in Table (3) Power systems with greater than the estimated maximum available short-circuit (1) fault current (2) Power systems with longer than the maximum fault clearing times (3) Tasks with less than the minimum working distance for the specific task to be performed from the employee s face and chest areas to an arc source (d) Direct Current (dc) Equipment.When the arc flash risk assessment performed in accordance with indicates that arc flash PPE is required and the arc flash PPE category method is used for the selection of PPE for dc systems in lieu of the incident energy analysis of 130.5(B)(1), Table 130.7(C)(15)(b) shall be used to determine the arc flash PPE category. The estimated maximum available fault current, maximum arc duration, and working distances for dc equipment are listed in 130.7(C)(15)(b). An incident energy analysis shall be required in accordance with for the following: (5) Tasks not included in Table (6) Power systems with greater than the estimated maximum available short-circuit current (7) Power systems with longer than the maximum fault clearing times (8) Tasks with less than the minimum working distance for the specific task to be performed from the employee s face and chest areas to an arc source Informational Note No.1: The arc flash PPE category of the protective clothing and equipment is generally based on determination of the estimated exposure level. Informational Note No.2: In most cases, closed doors do not provide enough protection to eliminate the need for PPE in situations in which the state of the equipment is known to readily change (e.g., doors open or closed, rack in or rack out). Informational Note No.3: Short-circuit current, as used in this table, is determined from the dc power system maximum available short-circuit, including the effects of cables and any other impedances in the circuit. Power system modeling is the best method to determine the available short-circuit current at the point of the arc. Battery cell short-circuit current can be obtained from the battery manufacturer. See Informative Annex D.5 for the basis for table values and alternative methods to determine dc incident energy. Methods should be used with good engineering judgment. Informational Note No.4: The methods for estimating the dc arc-flash incident energy that were used to determine the categories for this table are based on open-air incident energy calculations. Open-air calculations were used because many battery systems and other dc process systems are in open areas or rooms. If the specific task is within in an enclosure, it would be prudent to consider additional PPE protection beyond the value shown in this table. Engineering judgment is necessary when reviewing the specific conditions of the equipment and task to be performed, including the dimensions of the enclosure and the working distance involved. (i) Protective Clothing and Personal Protective Equipment (PPE). Once the arc flash PPE category

309 77 of 403 9/2/2016 9:49 AM has been identified from Table 130.7(C)(15)(a) or Table 130.7(C)(15)(b), Table 130.7(C)(15)(c) shall be used to determine the required PPE for the task. Table 130.7(C)(15)(c) lists the requirements for PPE based on arc flash PPE categories 1 through 4. This clothing and equipment shall be used when working within the arc flash boundary. Informational Note No. 1: See Informative Annex H for a suggested simplified approach to ensure adequate PPE for electrical workers within facilities with large and diverse electrical systems. Informational Note No. 2: The PPE requirements of this section are intended to protect a person from arc flash hazards. While some situations could result in burns to the skin, even with the protection described in Table 130.7(C)(15)(c), burn injury should be reduced and survivable. Due to the explosive effect of some arc events, physical trauma injuries could occur. The PPE requirements of this section do not address protection against physical trauma other than exposure to the thermal effects of an arc flash. Informational Note No. 3: The arc rating for a particular clothing system can be obtained from the arc-rated clothing manufacturer. Table 130.7(C)(15)(a) Arc-Flash PPE Categories for Alternating Current (ac) Systems Equipment Panelboards or other equipment rated 240 volts and below Parameters: Maximum of 25 ka available fault current; maximum of 0.03 s (2 cycles) fault clearing time; minimum working distance 455 mm (18 in.) Panelboards or other equipment rated greater than 240 volts and up to 600 volts Parameters: Maximum of 25 ka available fault current; maximum of 0.03 s (2 cycles) fault clearing time; minimum working distance 455 mm (18 in.) Arc Flash PPE Category 1 2 Arc-Flash Boundary 485 mm (19 in.) 900 mm (3 ft) 600-volt class motor control centers (MCCs) Parameters: Maximum of 65 ka available fault current; maximum of 0.03 s (2 cycles) fault clearing time; minimum working distance 455 mm (18 in.) 600-volt class motor control centers (MCCs) Parameters: Maximum of 42 ka available fault current; maximum of 0.33 s (20 cycles) fault clearing time; minimum working distance 455 mm (18 in.) 600-volt class switchgear (with power circuit breakers or fused switches) and 600-volt class switchboards Parameters: Maximum of 35 ka available fault current; maximum of up to 0.5 s (30 cycles) fault clearing time; minimum working distance 455 mm (18 in.) Other 600-volt class (277 volts through 600 volts, nominal) equipment Parameters: Maximum of 65 ka available fault current; maximum of 0.03 s (2 cycles) fault clearing time; minimum working distance 455 mm (18 in.) NEMA E2 (fused contactor) motor starters, 2.3 kv through 7.2 kv 1.5 m 2 (5 ft) 4.3 m 4 (14 ft) 6 m 4 (20 ft) 1.5 m 2 (5 ft) 4 12 m

310 78 of 403 9/2/2016 9:49 AM Equipment Parameters: Maximum of 35 ka available fault current; maximum of up to 0.24 s (15 cycles) fault clearing time; minimum working distance 910 mm (36 in.) Metal-clad switchgear, 1 kv through 15 kv Parameters: Maximum of 35 ka available fault current; maximum of up to 0.24 s (15 cycles) fault clearing time; minimum working distance 910 mm (36 in.) Arc-resistant switchgear Type 1 or 2 [for clearing times of less than 0.5 s (30 cycles) with a perspective fault current not to exceed the arc-resistant rating of the equipment], and metalenclosed interrupter switchgear, fused or unfused of arc-resistant-type construction, tested in accordance with IEEE C , 1 kv through 15 kv Parameters: Maximum of 35 ka available fault current; maximum of up to 0.24 s (15 cycles) fault clearing time; minimum working distance 910 mm (36 in.) Other equipment 1 kv through 15 kv Parameters: Maximum of 35 ka available fault current; maximum of up to 0.24 s (15 cycles) fault clearing time; minimum working distance 910 mm (36 in.) Notes: Arc Flash PPE Category 4 N/A (doors closed) 4 (doors open) 4 Arc-Flash Boundary (40 ft) 12 m (40 ft) N/A (doors closed) 12 m (40 ft) 12 m (40 ft) (1) For equipment rated 600 volts and below and protected by upstream current-limiting fuses or currentlimiting circuit breakers sized at 200 amperes or less, the arc flash PPE category can be reduced by one number but not below arc flash PPE category 1. (2) The following are typical fault clearing times of overcurrent protective devices: (a) 0.5 cycle fault clearing time is typical for current limiting fuses. (b) 1.5 cycle fault clearing time is typical for molded case circuit breakers rated less than 1000 volts with an instantaneous integral trip. (c) 3.0 cycle fault clearing time is typical for insulated case circuit breakers rated less than 1000 volts with an instantaneous integral trip or relay operated trip. (d) 5.0 cycle fault clearing time is typical for relay operated circuit breakers rated 1 kv to 35 kv. (e) 20 cycle fault clearing time is typical for low-voltage power and insulated case circuit breakers with a short time fault clearing delay for motor inrush. (f) 30 cycle fault clearing time is typical for low-voltage power and insulated case circuit breakers with a short time fault clearing delay without instantaneous trip. (See IEEE Table 1 for further information regarding Notes b through d.) Table 130.7(C)(15)(b) Arc-Flash PPE Categories for Direct Current (dc) Systems Equipment Storage batteries, dc switchboards, and other dc supply sources Parameters: Greater than or equal to 100 V and less than or equal to 250 V Arc Flash PPE Category Arc-Flash Boundary

311 79 of 403 9/2/2016 9:49 AM Equipment Arc Flash PPE Category Arc-Flash Boundary Maximum arc duration and minimum working distance: mm (18 in.) Short-circuit current less than 4 ka 1 Short-circuit current greater than or equal to 4 ka and less than 7 ka Short-circuit current greater than or equal to 7 ka and less than 15 ka Storage batteries, dc switchboards, and other dc supply sources Parameters: Greater than or equal to 250 V and less than or equal to 600 V Maximum arc duration and minimum working distance: mm (18 in.) Short-circuit current less than 1.5 ka 1 Short-circuit current greater than or equal to 1.5 ka and less than 3 ka Short-circuit current greater than or equal to 3 ka and less than 7 ka Short-circuit current greater than or equal to 7 ka and less than 10 ka mm (3 ft) 1.2 m (4 ft) 1.8 m (6 ft) 900 mm (3 ft) 1.2 m (4 ft) 1.8 m (6 ft.) 2.5 m (8 ft) Note 1: Apparel that can be expected to be exposed to electrolyte must meet both of the following conditions: (1) Be evaluated for electrolyte protection in accordance with ASTM F1296, Standard Guide for Evaluating Chemical Protective Clothing (2) Be arc-rated in accordance with ASTM F1891, Standard Specification for Arc Rated and Flame Resistant Rainwear, or equivalent Note 2: A two-second arc duration is assumed if there is no OCPD or if the fault clearing time is not known. If the fault clearing time is known and is less than two seconds, an incident energy analysis could provide a more representative result. Table 130.7(C)(15)(c) Personal Protective Equipment (PPE) Arc Flash PPE Category PPE Arc-Rated Clothing, Minimum Arc Rating of 4 cal/cm 2 (16.75 J/cm 2 ) a Arc-rated long-sleeve shirt and pants or arc-rated coverall Arc-rated face shield b (see Note 2) or arc flash suit hood 1 Arc-rated jacket, parka, rainwear, or hard hat liner (AN) Protective Equipment Hard hat Safety glasses or safety goggles (SR) Hearing protection

312 80 of 403 9/2/2016 9:49 AM Heavy-duty leather gloves c Leather footwear (AN) Arc-Rated Clothing, Minimum Arc Rating of 8 cal/cm 2 (33.5 J/cm 2 ) a Arc-rated long-sleeve shirt and pants or arc-rated coverall Arc-rated flash suit hood or arc-rated face shield b and arc-rated balaclava Arc-rated jacket, parka, rainwear, or hard hat liner (AN) 2 Protective Equipment Hard hat Safety glasses or safety goggles (SR) Hearing protection Heavy-duty leather gloves c Leather footwear Arc-Rated Clothing Selected so That the System Arc Rating Meets the Required Minimum Arc Rating of 25 cal/cm 2 (104.7 J/cm 2 ) a Arc-rated long-sleeve shirt (AR) Arc-rated pants (AR) Arc-rated coverall (AR) Arc-rated arc flash suit jacket (AR) Arc-rated arc flash suit pants (AR) 3 Arc-rated arc flash suit hood Arc-rated gloves c Arc-rated jacket, parka, rainwear, or hard hat liner (AN) Protective Equipment Hard hat Safety glasses or safety goggles (SR) Hearing protection Leather footwear Arc-Rated Clothing Selected so That the System Arc Rating Meets the Required Minimum Arc Rating of 40 cal/cm 2 (167.5 J/cm 2 ) a Arc-rated long-sleeve shirt (AR) Arc-rated pants (AR) Arc-rated coverall (AR) Arc-rated arc flash suit jacket (AR) 4 Arc-rated arc flash suit pants (AR) Arc-rated arc flash suit hood Arc-rated gloves c Arc-rated jacket, parka, rainwear, or hard hat liner (AN) Protective Equipment Hard hat Safety glasses or safety goggles (SR)

313 81 of 403 9/2/2016 9:49 AM Hearing protection Leather footwear Notes: AN: as needed (optional). AR: as required. SR: selection required. a Arc rating is defined in Article 100. b Face 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. c If 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. Statement of Problem and Substantiation for Public Comment Changed maximum available "short circuit" current to maximum available "fault" current in 130.7(C)(15)(a)(2) per actions taken by global FR-82. No other changes are made by this comment. Related Item First Revision No. 82-NFPA 70E-2015 [Global Input] First Revision No. 48-NFPA 70E-2015 [Sections 130.7(C)(15), 130.7(C)(16)] Submitter Information Verification Submitter Full Name: Louis Barrios Organization: Shell Global Solutions Affilliation: American Petroleum Institute Street Address: City: State: Zip: Submittal Date: Sun May 15 18:34:23 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-35-NFPA 70E-2016 Statement: 1. List items 130.7(C)(15)(A)(1) and (B)(1) are deleted as Tables 130.7(C)(15(a) and 130.7(C)(15)(b) are no longer task based, rather, they are equipment based (C)(15(A)(2): The phrase short circuit current is revised to available fault current for correlation in the standard in AC systems. 3. List items 130.7(C)(15)(A)(4) and (B)(4) are editorially revised for clarity. 4. List item 130.7(C)(15)(B)(2) and Table 130.7(C)(15)(b): short circuit current is revised to available fault current for consistent use of terminology and to correlate with the definition of available fault current in Article (C)(15) Informational Notes 3 and 4 are relocated to below Table 130.7(C)(15)(b) as they only apply to that table. 6. Table 130.7(C)(15)(a) Note 2 is changed to an Informational Note in accordance to correlate with

314 82 of 403 9/2/2016 9:49 AM the action taken by the Committee in the first draft. 7. Table 130.7(C)(15)(a): Informational Note list items (a) and (d) are modified for clarity. 8. Table 130.7(C)(15)(b): The phrase or equal to is deleted from parameter Greater than or equal to 250 V and less than or equal to 600 V in the second section to correlate with the parameter Greater than or equal to 100 V and less than or equal to 250 V in the first section of the table. Both sections of the Table cannot apply to 250 V. 9. Table 130.7(C)(15)(b): Both references to Arc Flash PPE Category 1 are revised to Arc Flash PPE Category 2 because the arc flash boundaries are at 900 mm (36-inches). This action is necessary for correlation as the existing requirement is in direct conflict with 130.7(C)(10)(b)(1). 10. Table 130.7(C)(15)(c): The requirement for ear canal inserts is restored in the Second Revision. Specifically identifying ear canal inserts rather than a generic reference to hearing protection simplifies use of the table for the electrical worker. Ear canal inserts provide a similar if not greater Noise Reduction Rating (NRR) when compared to ear muffs, but without a large amount of meltable material in the ear and face area. Table Note (d) informs the user of the standard that other types of hearing protection are permitted to be used in lieu of or in addition to ear canal inserts provided it is worn under arc-rated arc flash suit hood. In order for hearing protection to achieve a reliable NRR it must form a seal within the ear canal or over the ear, and so cannot be worn over top of PPE. 11. The reference to Type 1 and Type 2 is deleted from the arc resistant portion of Table 130.7(C) (15)(a) as it is no longer necessary because it is only available in Type 1 and Type 2 as available and tested in accordance with IEEE C The voltage reference in this portion of the table was relocated for clarity.

315 83 of 403 9/2/2016 9:49 AM Public Comment No. 195-NFPA 70E-2016 [ Section No (C)(15) ]

316 84 of 403 9/2/2016 9:49 AM (15) Arc Flash PPE Category Method.

317 85 of 403 9/2/2016 9:49 AM The requirements of 130.7(C)(15) shall apply when the arc flash PPE category method is used for the selection of arc flash PPE. (a) Alternating Current (ac) Equipment. When the arc flash risk assessment performed in accordance with indicates that arc flash PPE is required and the arc flash PPE category method is used for the selection of PPE for ac systems in lieu of the incident energy analysis of 130.5(B)(1), Table 130.7(C)(15)(a) shall be used to determine the arc flash PPE category. The estimated maximum available fault current, maximum fault-clearing times, and minimum working distances for various ac equipment types or classifications are listed in Table 130.7(C)(15)(a). An incident energy analysis shall be required in accordance with for the following: (2) Tasks not included in Table (3) Power systems with greater than the estimated maximum available short-circuit current (4) Power systems with longer than the maximum fault clearing times (5) Tasks with less than the minimum working distance for the specific task to be performed from the employee s face and chest areas to an arc source (f) Direct Current (dc) Equipment.When the arc flash risk assessment performed in accordance with indicates that arc flash PPE is required and the arc flash PPE category method is used for the selection of PPE for dc systems in lieu of the incident energy analysis of 130.5(B)(1), Table 130.7(C)(15)(b) shall be used to determine the arc flash PPE category. The estimated maximum available fault current, maximum arc duration, and working distances for dc equipment are listed in 130.7(C)(15)(b). An incident energy analysis shall be required in accordance with for the following: (7) Tasks not included in Table (8) Power systems with greater than the estimated maximum available short-circuit current (9) Power systems with longer than the maximum fault clearing times (10) Tasks with less than the minimum working distance for the specific task to be performed from the employee s face and chest areas to an arc source Informational Note No.1: The arc flash PPE category of the protective clothing and equipment is generally based on determination of the estimated exposure level. Informational Note No.2: In most cases, closed doors do not provide enough protection to eliminate the need for PPE in situations in which the state of the equipment is known to readily change (e.g., doors open or closed, rack in or rack out). Informational Note No.3: Short-circuit current, as used in this table, is determined from the dc power system maximum available short-circuit, including the effects of cables and any other impedances in the circuit. Power system modeling is the best method to determine the available short-circuit current at the point of the arc. Battery cell short-circuit current can be obtained from the battery manufacturer. See Informative Annex D.5 for the basis for table values and alternative methods to determine dc incident energy. Methods should be used with good engineering judgment. Informational Note No.4: The methods for estimating the dc arc-flash incident energy that were used to determine the categories for this table are based on open-air incident energy calculations. Open-air calculations were used because many battery systems and other dc process systems are in open areas or rooms. If the specific task is within in an enclosure, it would be prudent to consider additional PPE protection beyond the value shown in this table. Engineering judgment is necessary when reviewing the specific conditions of the equipment and task to be performed, including the dimensions of the enclosure and the working distance involved. (k) Protective Clothing and Personal Protective Equipment (PPE). Once the arc flash PPE category has been identified from Table 130.7(C)(15)(a) or Table 130.7(C)(15)(b), Table 130.7(C)(15)(c) shall be used to determine the required PPE for the task. Table 130.7(C)(15)(c) lists the requirements for PPE based on arc flash PPE categories 1 through 4. This clothing and equipment shall be used when working within the

318 86 of 403 9/2/2016 9:49 AM arc flash boundary. Informational Note No. 1: See Informative Annex H for a suggested simplified approach to ensure adequate PPE for electrical workers within facilities with large and diverse electrical systems. Informational Note No. 2: The PPE requirements of this section are intended to protect a person from arc flash hazards. While some situations could result in burns to the skin, even with the protection described in Table 130.7(C)(15)(c), burn injury should be reduced and survivable. Due to the explosive effect of some arc events, physical trauma injuries could occur. The PPE requirements of this section do not address protection against physical trauma other than exposure to the thermal effects of an arc flash. Informational Note No. 3: The arc rating for a particular clothing system can be obtained from the arc-rated clothing manufacturer. Table 130.7(C)(15)(a) Arc-Flash PPE Categories for Alternating Current (ac) Systems Equipment Panelboards or other equipment rated 240 volts and below Parameters: Maximum of 25 ka available fault current; maximum of 0.03 s (2 cycles) fault clearing time; minimum working distance 455 mm (18 in.) Panelboards or other equipment rated greater than 240 volts and up to 600 volts Parameters: Maximum of 25 ka available fault current; maximum of 0.03 s (2 cycles) fault clearing time; minimum working distance 455 mm (18 in.) 600-volt class motor control centers (MCCs) Parameters: Maximum of 65 ka available fault current; maximum of 0.03 s (2 cycles) fault clearing time; minimum working distance 455 mm (18 in.) 600-volt class motor control centers (MCCs) Parameters: Maximum of 42 ka available fault current; maximum of 0.33 s (20 cycles) fault clearing time; minimum working distance 455 mm (18 in.) 600-volt class switchgear (with power circuit breakers or fused switches) and 600-volt class switchboards Parameters: Maximum of 35 ka available fault current; maximum of up to 0.5 s (30 cycles) fault clearing time; minimum working distance 455 mm (18 in.) Other 600-volt class (277 volts through 600 volts, nominal) equipment Parameters: Maximum of 65 ka available fault current; maximum of 0.03 s (2 cycles) fault clearing time; minimum working distance 455 mm (18 in.) NEMA E2 (fused contactor) motor starters, 2.3 kv through 7.2 kv Parameters: Maximum of 35 ka available fault current; maximum of up to 0.24 s (15 cycles) fault clearing time; minimum working distance Arc Flash PPE Category Arc-Flash Boundary 485 mm (19 in.) 900 mm (3 ft) 1.5 m (5 ft) 4.3 m (14 ft) 6 m (20 ft) 1.5 m (5 ft) 12 m (40 ft)

319 87 of 403 9/2/2016 9:49 AM Equipment 910 mm (36 in.) Metal-clad switchgear, 1 kv through 15 kv Parameters: Maximum of 35 ka available fault current; maximum of up to 0.24 s (15 cycles) fault clearing time; minimum working distance 910 mm (36 in.) Arc-resistant switchgear Type 1 or 2 [for clearing times of less than 0.5 s (30 cycles) with a perspective fault current not to exceed the arc-resistant rating of the equipment], and metalenclosed interrupter switchgear, fused or unfused of arc-resistant-type construction, tested in accordance with IEEE C , 1 kv through 15 kv Parameters: Maximum of 35 ka available fault current; maximum of up to 0.24 s (15 cycles) fault clearing time; minimum working distance 910 mm (36 in.) Other equipment 1 kv through 15 kv Parameters: Maximum of 35 ka available fault current; maximum of up to 0.24 s (15 cycles) fault clearing time; minimum working distance 910 mm (36 in.) Notes: Arc Flash PPE Category 4 N/A (doors closed) 4 (doors open) 4 Arc-Flash Boundary 12 m (40 ft) N/A (doors closed) 12 m (40 ft) 12 m (40 ft) (1) For equipment rated 600 volts and below and protected by upstream current-limiting fuses or currentlimiting circuit breakers sized at 200 amperes or less, the arc flash PPE category can be reduced by one number but not below arc flash PPE category 1. (2) The following are typical fault clearing times of overcurrent protective devices: (a) 0.5 cycle fault clearing time is typical for current limiting fuses. (b) 1.5 cycle fault clearing time is typical for molded case circuit breakers rated less than 1000 volts with an instantaneous integral trip. (c) 3.0 cycle fault clearing time is typical for insulated case circuit breakers rated less than 1000 volts with an instantaneous integral trip or relay operated trip. (d) 5.0 cycle fault clearing time is typical for relay operated circuit breakers rated 1 kv to 35 kv. (e) 20 cycle fault clearing time is typical for low-voltage power and insulated case circuit breakers with a short time fault clearing delay for motor inrush. (f) 30 cycle fault clearing time is typical for low-voltage power and insulated case circuit breakers with a short time fault clearing delay without instantaneous trip. (See IEEE Table 1 for further information regarding Notes b through d.) Table 130.7(C)(15)(b) Arc-Flash PPE Categories for Direct Current (dc) Systems Equipment Storage batteries, dc switchboards, and other dc supply sources Parameters: Greater than or equal to 100 V and less than or equal to 250 V Maximum arc duration and minimum working distance: mm (18 in.) Arc Flash PPE Category Arc-Flash Boundary

320 88 of 403 9/2/2016 9:49 AM Equipment Arc Flash PPE Category Short Available -circuit fault current less than 4 ka 1 Short Available -circuit fault current greater than or equal to 4 ka and less than 7 ka Short Available -circuit fault current greater than or equal to 7 ka and less than 15 ka Storage batteries, dc switchboards, and other dc supply sources Parameters: Greater than or equal to 250 V and less than or equal to 600 V Maximum arc duration and minimum working distance: mm (18 in.) Short Available -circuit fault current less than 1.5 ka 1 Short Available -circuit fault current greater than or equal to 1.5 ka and less than 3 ka Short Available -circuit fault current greater than or equal to 3 ka and less than 7 ka Short Available -circuit fault current greater than or equal to 7 ka and less than 10 ka Arc-Flash Boundary 900 mm (3 ft) 1.2 m (4 ft) 1.8 m (6 ft) 900 mm (3 ft) 1.2 m (4 ft) 1.8 m (6 ft.) 2.5 m (8 ft) Note 1: Apparel that can be expected to be exposed to electrolyte must meet both of the following conditions: (1) Be evaluated for electrolyte protection in accordance with ASTM F1296, Standard Guide for Evaluating Chemical Protective Clothing (2) Be arc-rated in accordance with ASTM F1891, Standard Specification for Arc Rated and Flame Resistant Rainwear, or equivalent Note 2: A two-second arc duration is assumed if there is no OCPD or if the fault clearing time is not known. If the fault clearing time is known and is less than two seconds, an incident energy analysis could provide a more representative result. Note 3 Some Battery Manufacturers use the term Prospective Short-Circuit Current to describe available fault current. Table 130.7(C)(15)(c) Personal Protective Equipment (PPE) Arc Flash PPE Category PPE Arc-Rated Clothing, Minimum Arc Rating of 4 cal/cm 2 (16.75 J/cm 2 ) a Arc-rated long-sleeve shirt and pants or arc-rated coverall Arc-rated face shield b (see Note 2) or arc flash suit hood 1 Arc-rated jacket, parka, rainwear, or hard hat liner (AN) Protective Equipment Hard hat Safety glasses or safety goggles (SR) Hearing protection

321 89 of 403 9/2/2016 9:49 AM Heavy-duty leather gloves c Leather footwear (AN) Arc-Rated Clothing, Minimum Arc Rating of 8 cal/cm 2 (33.5 J/cm 2 ) a Arc-rated long-sleeve shirt and pants or arc-rated coverall Arc-rated flash suit hood or arc-rated face shield b and arc-rated balaclava Arc-rated jacket, parka, rainwear, or hard hat liner (AN) 2 Protective Equipment Hard hat Safety glasses or safety goggles (SR) Hearing protection Heavy-duty leather gloves c Leather footwear Arc-Rated Clothing Selected so That the System Arc Rating Meets the Required Minimum Arc Rating of 25 cal/cm 2 (104.7 J/cm 2 ) a Arc-rated long-sleeve shirt (AR) Arc-rated pants (AR) Arc-rated coverall (AR) Arc-rated arc flash suit jacket (AR) Arc-rated arc flash suit pants (AR) 3 Arc-rated arc flash suit hood Arc-rated gloves c Arc-rated jacket, parka, rainwear, or hard hat liner (AN) Protective Equipment Hard hat Safety glasses or safety goggles (SR) Hearing protection Leather footwear Arc-Rated Clothing Selected so That the System Arc Rating Meets the Required Minimum Arc Rating of 40 cal/cm 2 (167.5 J/cm 2 ) a Arc-rated long-sleeve shirt (AR) Arc-rated pants (AR) Arc-rated coverall (AR) Arc-rated arc flash suit jacket (AR) 4 Arc-rated arc flash suit pants (AR) Arc-rated arc flash suit hood Arc-rated gloves c Arc-rated jacket, parka, rainwear, or hard hat liner (AN) Protective Equipment Hard hat Safety glasses or safety goggles (SR)

322 90 of 403 9/2/2016 9:49 AM Hearing protection Leather footwear Notes: AN: as needed (optional). AR: as required. SR: selection required. a Arc rating is defined in Article 100. b Face 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. c If 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. Statement of Problem and Substantiation for Public Comment The term available fault current is being used throughout the remainder of NFPA 70E, other than for extracted material, to improve consistency. Not all dc systems are supplied from batteries and these other systems sometimes use the term" maximum circuit current". Not all battery manufacturers provide "prospective-short circuit current values on labels or data sheets based on Informational Note No. 1 to 320.3(A)(5) Related Item First Revision No. 82-NFPA 70E-2015 [Global Input] Submitter Information Verification Submitter Full Name: Paul Dobrowsky Organization: Innovative Technology Services Street Address: City: State: Zip: Submittal Date: Mon May 16 09:33:45 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-35-NFPA 70E-2016 Statement: 1. List items 130.7(C)(15)(A)(1) and (B)(1) are deleted as Tables 130.7(C)(15(a) and 130.7(C)(15)(b) are no longer task based, rather, they are equipment based (C)(15(A)(2): The phrase short circuit current is revised to available fault current for correlation in the standard in AC systems. 3. List items 130.7(C)(15)(A)(4) and (B)(4) are editorially revised for clarity. 4. List item 130.7(C)(15)(B)(2) and Table 130.7(C)(15)(b): short circuit current is revised to available fault current for consistent use of terminology and to correlate with the definition of available fault current in Article (C)(15) Informational Notes 3 and 4 are relocated to below Table 130.7(C)(15)(b) as they only apply to that table. 6. Table 130.7(C)(15)(a) Note 2 is changed to an Informational Note in accordance to correlate with the action taken by the Committee in the first draft.

323 91 of 403 9/2/2016 9:49 AM 7. Table 130.7(C)(15)(a): Informational Note list items (a) and (d) are modified for clarity. 8. Table 130.7(C)(15)(b): The phrase or equal to is deleted from parameter Greater than or equal to 250 V and less than or equal to 600 V in the second section to correlate with the parameter Greater than or equal to 100 V and less than or equal to 250 V in the first section of the table. Both sections of the Table cannot apply to 250 V. 9. Table 130.7(C)(15)(b): Both references to Arc Flash PPE Category 1 are revised to Arc Flash PPE Category 2 because the arc flash boundaries are at 900 mm (36-inches). This action is necessary for correlation as the existing requirement is in direct conflict with 130.7(C)(10)(b)(1). 10. Table 130.7(C)(15)(c): The requirement for ear canal inserts is restored in the Second Revision. Specifically identifying ear canal inserts rather than a generic reference to hearing protection simplifies use of the table for the electrical worker. Ear canal inserts provide a similar if not greater Noise Reduction Rating (NRR) when compared to ear muffs, but without a large amount of meltable material in the ear and face area. Table Note (d) informs the user of the standard that other types of hearing protection are permitted to be used in lieu of or in addition to ear canal inserts provided it is worn under arc-rated arc flash suit hood. In order for hearing protection to achieve a reliable NRR it must form a seal within the ear canal or over the ear, and so cannot be worn over top of PPE. 11. The reference to Type 1 and Type 2 is deleted from the arc resistant portion of Table 130.7(C) (15)(a) as it is no longer necessary because it is only available in Type 1 and Type 2 as available and tested in accordance with IEEE C The voltage reference in this portion of the table was relocated for clarity.

324 92 of 403 9/2/2016 9:49 AM Public Comment No. 201-NFPA 70E-2016 [ Section No (C)(15) ]

325 93 of 403 9/2/2016 9:49 AM (15) Arc Flash PPE Category Method.

326 94 of 403 9/2/2016 9:49 AM The requirements of 130.7(C)(15) shall apply when the arc flash PPE category method is used for the selection of arc flash PPE. (a) Alternating Current (ac) Equipment. When the arc flash risk assessment performed in accordance with indicates that arc flash PPE is required and the arc flash PPE category method is used for the selection of PPE for ac systems in lieu of the incident energy analysis of 130.5(B)(1), Table 130.7(C)(15)(a) shall be used to determine the arc flash PPE category. The estimated maximum available fault current, maximum fault-clearing times, and minimum working distances for various ac equipment types or classifications are listed in Table 130.7(C)(15)(a). An incident energy analysis shall be required in accordance with for the following: (2) Tasks not included in Table (3) Power systems with greater than the estimated maximum available short-circuit current (4) Power systems with longer than the maximum fault clearing times (5) Tasks with less than the minimum working distance for the specific task to be performed from the employee s face and chest areas to an arc source (f) Direct Current (dc) Equipment.When the arc flash risk assessment performed in accordance with indicates that arc flash PPE is required and the arc flash PPE category method is used for the selection of PPE for dc systems in lieu of the incident energy analysis of 130.5(B)(1), Table 130.7(C)(15)(b) shall be used to determine the arc flash PPE category. The estimated maximum available fault current, maximum arc duration, and working distances for dc equipment are listed in 130.7(C)(15)(b). An incident energy analysis shall be required in accordance with for the following: (7) Tasks not included in Table (8) Power systems with greater than the estimated maximum available short-circuit current (9) Power systems with longer than the maximum fault clearing times (10) Tasks with less than the minimum working distance for the specific task to be performed from the employee s face and chest areas to an arc source Informational Note No.1: The arc flash PPE category of the protective clothing and equipment is generally based on determination of the estimated exposure level. Informational Note No.2: In most cases, closed doors do not provide enough protection to eliminate the need for PPE in situations in which the state of the equipment is known to readily change (e.g., doors open or closed, rack in or rack out). Informational Note No.3: Short-circuit current, as used in this table, is determined from the dc power system maximum available short-circuit, including the effects of cables and any other impedances in the circuit. Power system modeling is the best method to determine the available short-circuit current at the point of the arc. Battery cell short-circuit current can be obtained from the battery manufacturer. See Informative Annex D.5 for the basis for table values and alternative methods to determine dc incident energy. Methods should be used with good engineering judgment. Informational Note No.4: The methods for estimating the dc arc-flash incident energy that were used to determine the categories for this table are based on open-air incident energy calculations. Open-air calculations were used because many battery systems and other dc process systems are in open areas or rooms. If the specific task is within in an enclosure, it would be prudent to consider additional PPE protection beyond the value shown in this table. Engineering judgment is necessary when reviewing the specific conditions of the equipment and task to be performed, including the dimensions of the enclosure and the working distance involved. (k) Protective Clothing and Personal Protective Equipment (PPE). Once the arc flash PPE category has been identified from Table 130.7(C)(15)(a) or Table 130.7(C)(15)(b), Table 130.7(C)(15)(c) shall be used to determine the required PPE for the task. Table 130.7(C)(15)(c) lists the requirements for PPE based on arc flash PPE categories 1 through 4. This clothing and equipment shall be used when working within the

327 95 of 403 9/2/2016 9:49 AM arc flash boundary. Informational Note No. 1: See Informative Annex H for a suggested simplified approach to ensure adequate PPE for electrical workers within facilities with large and diverse electrical systems. Informational Note No. 2: The PPE requirements of this section are intended to protect a person from arc flash hazards. While some situations could result in burns to the skin, even with the protection described in Table 130.7(C)(15)(c), burn injury should be reduced and survivable. Due to the explosive effect of some arc events, physical trauma injuries could occur. The PPE requirements of this section do not address protection against physical trauma other than exposure to the thermal effects of an arc flash. Informational Note No. 3: The arc rating for a particular clothing system can be obtained from the arc-rated clothing manufacturer. Table 130.7(C)(15)(a) Arc-Flash PPE Categories for Alternating Current (ac) Systems Equipment Panelboards or other equipment rated 240 volts and below Parameters: Maximum of 25 ka available fault current; maximum of 0.03 s (2 cycles) fault clearing time; minimum working distance 455 mm (18 in.) Panelboards or other equipment rated greater than 240 volts and up to 600 volts Parameters: Maximum of 25 ka available fault current; maximum of 0.03 s (2 cycles) fault clearing time; minimum working distance 455 mm (18 in.) 600-volt class motor control centers (MCCs) Parameters: Maximum of 65 ka available fault current; maximum of 0.03 s (2 cycles) fault clearing time; minimum working distance 455 mm (18 in.) 600-volt class motor control centers (MCCs) Parameters: Maximum of 42 ka available fault current; maximum of 0.33 s (20 cycles) fault clearing time; minimum working distance 455 mm (18 in.) 600-volt class switchgear (with power circuit breakers or fused switches) and 600-volt class switchboards Parameters: Maximum of 35 ka available fault current; maximum of up to 0.5 s (30 cycles) fault clearing time; minimum working distance 455 mm (18 in.) Other 600-volt class (277 volts through 600 volts, nominal) equipment Parameters: Maximum of 65 ka available fault current; maximum of 0.03 s (2 cycles) fault clearing time; minimum working distance 455 mm (18 in.) NEMA E2 (fused contactor) motor starters, 2.3 kv through 7.2 kv Parameters: Maximum of 35 ka available fault current; maximum of up to 0.24 s (15 cycles) fault clearing time; minimum working distance Arc Flash PPE Category Arc-Flash Boundary 485 mm (19 in.) 900 mm (3 ft) 1.5 m (5 ft) 4.3 m (14 ft) 6 m (20 ft) 1.5 m (5 ft) 12 m (40 ft)

328 96 of 403 9/2/2016 9:49 AM Equipment 910 mm (36 in.) Metal-clad switchgear, 1 kv through 15 kv Parameters: Maximum of 35 ka available fault current; maximum of up to 0.24 s (15 cycles) fault clearing time; minimum working distance 910 mm (36 in.) Arc-resistant switchgear Type 1 or 2 [for clearing times of less than 0.5 s (30 cycles) with a perspective fault current not to exceed the arc-resistant rating of the equipment], and metalenclosed interrupter switchgear, fused or unfused of arc-resistant-type construction, tested in accordance with IEEE C , 1 kv through 15 kv Parameters: Maximum of 35 ka available fault current; maximum of up to 0.24 s (15 cycles) fault clearing time; minimum working distance 910 mm (36 in.) Other equipment 1 kv through 15 kv Parameters: Maximum of 35 ka available fault current; maximum of up to 0.24 s (15 cycles) fault clearing time; minimum working distance 910 mm (36 in.) Notes: Arc Flash PPE Category 4 N/A (doors closed) 4 (doors open) 4 Arc-Flash Boundary 12 m (40 ft) N/A (doors closed) 12 m (40 ft) 12 m (40 ft) (1) For equipment rated 600 volts and below and protected by upstream current-limiting fuses or currentlimiting circuit breakers sized at 200 amperes or less and labeled current limiting, the arc flash PPE category can be reduced by one number but not below arc flash PPE category 1. (2) The following are typical fault clearing times of overcurrent protective devices: (a) 0.5 cycle fault clearing time is typical for current limiting fuses. (b) 1.5 cycle fault clearing time is typical for molded case circuit breakers rated less than 1000 volts with an instantaneous integral trip. (c) 3.0 cycle fault clearing time is typical for insulated case circuit breakers rated less than 1000 volts with an instantaneous integral trip or relay operated trip. (d) 5.0 cycle fault clearing time is typical for relay operated circuit breakers rated 1 kv to 35 kv. (e) 20 cycle fault clearing time is typical for low-voltage power and insulated case circuit breakers with a short time fault clearing delay for motor inrush. (f) 30 cycle fault clearing time is typical for low-voltage power and insulated case circuit breakers with a short time fault clearing delay without instantaneous trip. (See IEEE Table 1 for further information regarding Notes b through d.) Table 130.7(C)(15)(b) Arc-Flash PPE Categories for Direct Current (dc) Systems Equipment Storage batteries, dc switchboards, and other dc supply sources Parameters: Greater than or equal to 100 V and less than or equal to 250 V Maximum arc duration and minimum working distance: mm (18 in.) Arc Flash PPE Category Arc-Flash Boundary

329 97 of 403 9/2/2016 9:49 AM Equipment Arc Flash PPE Category Short-circuit current less than 4 ka 1 Short-circuit current greater than or equal to 4 ka and less than 7 ka Short-circuit current greater than or equal to 7 ka and less than 15 ka Storage batteries, dc switchboards, and other dc supply sources Parameters: Greater than or equal to 250 V and less than or equal to 600 V Maximum arc duration and minimum working distance: mm (18 in.) Short-circuit current less than 1.5 ka 1 Short-circuit current greater than or equal to 1.5 ka and less than 3 ka Short-circuit current greater than or equal to 3 ka and less than 7 ka Short-circuit current greater than or equal to 7 ka and less than 10 ka Arc-Flash Boundary 900 mm (3 ft) 1.2 m (4 ft) 1.8 m (6 ft) 900 mm (3 ft) 1.2 m (4 ft) 1.8 m (6 ft.) 2.5 m (8 ft) Note 1: Apparel that can be expected to be exposed to electrolyte must meet both of the following conditions: (1) Be evaluated for electrolyte protection in accordance with ASTM F1296, Standard Guide for Evaluating Chemical Protective Clothing (2) Be arc-rated in accordance with ASTM F1891, Standard Specification for Arc Rated and Flame Resistant Rainwear, or equivalent Note 2: A two-second arc duration is assumed if there is no OCPD or if the fault clearing time is not known. If the fault clearing time is known and is less than two seconds, an incident energy analysis could provide a more representative result. Table 130.7(C)(15)(c) Personal Protective Equipment (PPE) Arc Flash PPE Category PPE Arc-Rated Clothing, Minimum Arc Rating of 4 cal/cm 2 (16.75 J/cm 2 ) a Arc-rated long-sleeve shirt and pants or arc-rated coverall Arc-rated face shield b (see Note 2) or arc flash suit hood Arc-rated jacket, parka, rainwear, or hard hat liner (AN) 1 Protective Equipment Hard hat Safety glasses or safety goggles (SR) Hearing protection Heavy-duty leather gloves c Leather footwear (AN)

330 98 of 403 9/2/2016 9:49 AM Arc-Rated Clothing, Minimum Arc Rating of 8 cal/cm 2 (33.5 J/cm 2 ) a Arc-rated long-sleeve shirt and pants or arc-rated coverall Arc-rated flash suit hood or arc-rated face shield b and arc-rated balaclava Arc-rated jacket, parka, rainwear, or hard hat liner (AN) 2 Protective Equipment Hard hat Safety glasses or safety goggles (SR) Hearing protection Heavy-duty leather gloves c Leather footwear Arc-Rated Clothing Selected so That the System Arc Rating Meets the Required Minimum Arc Rating of 25 cal/cm 2 (104.7 J/cm 2 ) a Arc-rated long-sleeve shirt (AR) Arc-rated pants (AR) Arc-rated coverall (AR) Arc-rated arc flash suit jacket (AR) Arc-rated arc flash suit pants (AR) 3 Arc-rated arc flash suit hood Arc-rated gloves c Arc-rated jacket, parka, rainwear, or hard hat liner (AN) Protective Equipment Hard hat Safety glasses or safety goggles (SR) Hearing protection Leather footwear Arc-Rated Clothing Selected so That the System Arc Rating Meets the Required Minimum Arc Rating of 40 cal/cm 2 (167.5 J/cm 2 ) a Arc-rated long-sleeve shirt (AR) Arc-rated pants (AR) Arc-rated coverall (AR) Arc-rated arc flash suit jacket (AR) Arc-rated arc flash suit pants (AR) 4 Arc-rated arc flash suit hood Arc-rated gloves c Arc-rated jacket, parka, rainwear, or hard hat liner (AN) Protective Equipment Hard hat Safety glasses or safety goggles (SR) Hearing protection Leather footwear

331 99 of 403 9/2/2016 9:49 AM Notes: AN: as needed (optional). AR: as required. SR: selection required. a Arc rating is defined in Article 100. b Face 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. c If 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. Statement of Problem and Substantiation for Public Comment Many people think that all fuses and circuit breaker are current limiting. Even they they refer to the definition of current limiting, it does not help in determining the characteristics of a fuse or circuit breaker. UL standards call for testing of fuses and circuit breakers and labeling if the device is current limiting. The qualified person should look for the labeling instead of just assuming current limitation. Related Item Public Input No. 397-NFPA 70E-2015 [Section No (C)(15)(A)] Public Input No. 346-NFPA 70E-2015 [Sections 130.7(C)(15), 130.7(C)(16)] Public Input No. 42-NFPA 70E-2015 [Section No (C)(15)(A)] Public Input No. 3-NFPA 70E-2015 [Section No (C)(15)] Public Input No. 53-NFPA 70E-2015 [Section No (C)(15)(A)] Public Input No. 495-NFPA 70E-2015 [Section No (C)(15)(A)] Submitter Information Verification Submitter Full Name: Peter Walsh Organization: Mersen Street Address: City: State: Zip: Submittal Date: Mon May 16 15:05:17 EDT 2016 Committee Statement Committee Action: Rejected Resolution: The proposed revision does not add clarity.

332 00 of 403 9/2/2016 9:49 AM Public Comment No. 50-NFPA 70E-2016 [ Section No (C)(15) ]

333 01 of 403 9/2/2016 9:49 AM See statement for CC Note (15) Arc Flash PPE Category Method.

334 02 of 403 9/2/2016 9:49 AM The requirements of 130.7(C)(15) shall apply when the arc flash PPE category method is used for the selection of arc flash PPE. (a) Alternating Current (ac) Equipment. When the arc flash risk assessment performed in accordance with indicates that arc flash PPE is required and the arc flash PPE category method is used for the selection of PPE for ac systems in lieu of the incident energy analysis of 130.5(B)(1), Table 130.7(C)(15)(a) shall be used to determine the arc flash PPE category. The estimated maximum available fault current, maximum fault-clearing times, and minimum working distances for various ac equipment types or classifications are listed in Table 130.7(C)(15)(a). An incident energy analysis shall be required in accordance with for the following: (2) Tasks not included in Table (3) Power systems with greater than the estimated maximum available short-circuit current (4) Power systems with longer than the maximum fault clearing times (5) Tasks with less than the minimum working distance for the specific task to be performed from the employee s face and chest areas to an arc source (f) Direct Current (dc) Equipment.When the arc flash risk assessment performed in accordance with indicates that arc flash PPE is required and the arc flash PPE category method is used for the selection of PPE for dc systems in lieu of the incident energy analysis of 130.5(B)(1), Table 130.7(C)(15)(b) shall be used to determine the arc flash PPE category. The estimated maximum available fault current, maximum arc duration, and working distances for dc equipment are listed in 130.7(C)(15)(b). An incident energy analysis shall be required in accordance with for the following: (7) Tasks not included in Table (8) Power systems with greater than the estimated maximum available short-circuit current (9) Power systems with longer than the maximum fault clearing times (10) Tasks with less than the minimum working distance for the specific task to be performed from the employee s face and chest areas to an arc source Informational Note No.1: The arc flash PPE category of the protective clothing and equipment is generally based on determination of the estimated exposure level. Informational Note No.2: In most cases, closed doors do not provide enough protection to eliminate the need for PPE in situations in which the state of the equipment is known to readily change (e.g., doors open or closed, rack in or rack out). Informational Note No.3: Short-circuit current, as used in this table, is determined from the dc power system maximum available short-circuit, including the effects of cables and any other impedances in the circuit. Power system modeling is the best method to determine the available short-circuit current at the point of the arc. Battery cell short-circuit current can be obtained from the battery manufacturer. See Informative Annex D.5 for the basis for table values and alternative methods to determine dc incident energy. Methods should be used with good engineering judgment. Informational Note No.4: The methods for estimating the dc arc-flash incident energy that were used to determine the categories for this table are based on open-air incident energy calculations. Open-air calculations were used because many battery systems and other dc process systems are in open areas or rooms. If the specific task is within in an enclosure, it would be prudent to consider additional PPE protection beyond the value shown in this table. Engineering judgment is necessary when reviewing the specific conditions of the equipment and task to be performed, including the dimensions of the enclosure and the working distance involved. (k) Protective Clothing and Personal Protective Equipment (PPE). Once the arc flash PPE category has been identified from Table 130.7(C)(15)(a) or Table 130.7(C)(15)(b), Table 130.7(C)(15)(c) shall be used to determine the required PPE for the task. Table 130.7(C)(15)(c) lists the requirements for PPE based on arc flash PPE categories 1 through 4. This clothing and equipment shall be used when working within the

335 03 of 403 9/2/2016 9:49 AM arc flash boundary. Informational Note No. 1: See Informative Annex H for a suggested simplified approach to ensure adequate PPE for electrical workers within facilities with large and diverse electrical systems. Informational Note No. 2: The PPE requirements of this section are intended to protect a person from arc flash hazards. While some situations could result in burns to the skin, even with the protection described in Table 130.7(C)(15)(c), burn injury should be reduced and survivable. Due to the explosive effect of some arc events, physical trauma injuries could occur. The PPE requirements of this section do not address protection against physical trauma other than exposure to the thermal effects of an arc flash. Informational Note No. 3: The arc rating for a particular clothing system can be obtained from the arc-rated clothing manufacturer. Table 130.7(C)(15)(a) Arc-Flash PPE Categories for Alternating Current (ac) Systems Equipment Panelboards or other equipment rated 240 volts and below Parameters: Maximum of 25 ka available fault current; maximum of 0.03 s (2 cycles) fault clearing time; minimum working distance 455 mm (18 in.) Panelboards or other equipment rated greater than 240 volts and up to 600 volts Parameters: Maximum of 25 ka available fault current; maximum of 0.03 s (2 cycles) fault clearing time; minimum working distance 455 mm (18 in.) 600-volt class motor control centers (MCCs) Parameters: Maximum of 65 ka available fault current; maximum of 0.03 s (2 cycles) fault clearing time; minimum working distance 455 mm (18 in.) 600-volt class motor control centers (MCCs) Parameters: Maximum of 42 ka available fault current; maximum of 0.33 s (20 cycles) fault clearing time; minimum working distance 455 mm (18 in.) 600-volt class switchgear (with power circuit breakers or fused switches) and 600-volt class switchboards Parameters: Maximum of 35 ka available fault current; maximum of up to 0.5 s (30 cycles) fault clearing time; minimum working distance 455 mm (18 in.) Other 600-volt class (277 volts through 600 volts, nominal) equipment Parameters: Maximum of 65 ka available fault current; maximum of 0.03 s (2 cycles) fault clearing time; minimum working distance 455 mm (18 in.) NEMA E2 (fused contactor) motor starters, 2.3 kv through 7.2 kv Parameters: Maximum of 35 ka available fault current; maximum of up to 0.24 s (15 cycles) fault clearing time; minimum working distance Arc Flash PPE Category Arc-Flash Boundary 485 mm (19 in.) 900 mm (3 ft) 1.5 m (5 ft) 4.3 m (14 ft) 6 m (20 ft) 1.5 m (5 ft) 12 m (40 ft)

336 04 of 403 9/2/2016 9:49 AM Equipment 910 mm (36 in.) Metal-clad switchgear, 1 kv through 15 kv Parameters: Maximum of 35 ka available fault current; maximum of up to 0.24 s (15 cycles) fault clearing time; minimum working distance 910 mm (36 in.) Arc-resistant switchgear Type 1 or 2 [for clearing times of less than 0.5 s (30 cycles) with a perspective fault current not to exceed the arc-resistant rating of the equipment], and metalenclosed interrupter switchgear, fused or unfused of arc-resistant-type construction, tested in accordance with IEEE C , 1 kv through 15 kv Parameters: Maximum of 35 ka available fault current; maximum of up to 0.24 s (15 cycles) fault clearing time; minimum working distance 910 mm (36 in.) Other equipment 1 kv through 15 kv Parameters: Maximum of 35 ka available fault current; maximum of up to 0.24 s (15 cycles) fault clearing time; minimum working distance 910 mm (36 in.) Notes: Arc Flash PPE Category 4 N/A (doors closed) 4 (doors open) 4 Arc-Flash Boundary 12 m (40 ft) N/A (doors closed) 12 m (40 ft) 12 m (40 ft) (1) For equipment rated 600 volts and below and protected by upstream current-limiting fuses or currentlimiting circuit breakers sized at 200 amperes or less, the arc flash PPE category can be reduced by one number but not below arc flash PPE category 1. (2) The following are typical fault clearing times of overcurrent protective devices: (a) 0.5 cycle fault clearing time is typical for current limiting fuses. (b) 1.5 cycle fault clearing time is typical for molded case circuit breakers rated less than 1000 volts with an instantaneous integral trip. (c) 3.0 cycle fault clearing time is typical for insulated case circuit breakers rated less than 1000 volts with an instantaneous integral trip or relay operated trip. (d) 5.0 cycle fault clearing time is typical for relay operated circuit breakers rated 1 kv to 35 kv. (e) 20 cycle fault clearing time is typical for low-voltage power and insulated case circuit breakers with a short time fault clearing delay for motor inrush. (f) 30 cycle fault clearing time is typical for low-voltage power and insulated case circuit breakers with a short time fault clearing delay without instantaneous trip. (See IEEE Table 1 for further information regarding Notes b through d.) Table 130.7(C)(15)(b) Arc-Flash PPE Categories for Direct Current (dc) Systems Equipment Storage batteries, dc switchboards, and other dc supply sources Parameters: Greater than or equal to 100 V and less than or equal to 250 V Maximum arc duration and minimum working distance: mm (18 in.) Arc Flash PPE Category Arc-Flash Boundary

337 05 of 403 9/2/2016 9:49 AM Equipment Arc Flash PPE Category Short-circuit current less than 4 ka 1 Short-circuit current greater than or equal to 4 ka and less than 7 ka Short-circuit current greater than or equal to 7 ka and less than 15 ka Storage batteries, dc switchboards, and other dc supply sources Parameters: Greater than or equal to 250 V and less than or equal to 600 V Maximum arc duration and minimum working distance: mm (18 in.) Short-circuit current less than 1.5 ka 1 Short-circuit current greater than or equal to 1.5 ka and less than 3 ka Short-circuit current greater than or equal to 3 ka and less than 7 ka Short-circuit current greater than or equal to 7 ka and less than 10 ka Arc-Flash Boundary 900 mm (3 ft) 1.2 m (4 ft) 1.8 m (6 ft) 900 mm (3 ft) 1.2 m (4 ft) 1.8 m (6 ft.) 2.5 m (8 ft) Note 1: Apparel that can be expected to be exposed to electrolyte must meet both of the following conditions: (1) Be evaluated for electrolyte protection in accordance with ASTM F1296, Standard Guide for Evaluating Chemical Protective Clothing (2) Be arc-rated in accordance with ASTM F1891, Standard Specification for Arc Rated and Flame Resistant Rainwear, or equivalent Note 2: A two-second arc duration is assumed if there is no OCPD or if the fault clearing time is not known. If the fault clearing time is known and is less than two seconds, an incident energy analysis could provide a more representative result. Table 130.7(C)(15)(c) Personal Protective Equipment (PPE) Arc Flash PPE Category PPE Arc-Rated Clothing, Minimum Arc Rating of 4 cal/cm 2 (16.75 J/cm 2 ) a Arc-rated long-sleeve shirt and pants or arc-rated coverall Arc-rated face shield b (see Note 2) or arc flash suit hood Arc-rated jacket, parka, rainwear, or hard hat liner (AN) 1 Protective Equipment Hard hat Safety glasses or safety goggles (SR) Hearing protection Heavy-duty leather gloves c Leather footwear (AN)

338 06 of 403 9/2/2016 9:49 AM Arc-Rated Clothing, Minimum Arc Rating of 8 cal/cm 2 (33.5 J/cm 2 ) a Arc-rated long-sleeve shirt and pants or arc-rated coverall Arc-rated flash suit hood or arc-rated face shield b and arc-rated balaclava Arc-rated jacket, parka, rainwear, or hard hat liner (AN) 2 Protective Equipment Hard hat Safety glasses or safety goggles (SR) Hearing protection Heavy-duty leather gloves c Leather footwear Arc-Rated Clothing Selected so That the System Arc Rating Meets the Required Minimum Arc Rating of 25 cal/cm 2 (104.7 J/cm 2 ) a Arc-rated long-sleeve shirt (AR) Arc-rated pants (AR) Arc-rated coverall (AR) Arc-rated arc flash suit jacket (AR) Arc-rated arc flash suit pants (AR) 3 Arc-rated arc flash suit hood Arc-rated gloves c Arc-rated jacket, parka, rainwear, or hard hat liner (AN) Protective Equipment Hard hat Safety glasses or safety goggles (SR) Hearing protection Leather footwear Arc-Rated Clothing Selected so That the System Arc Rating Meets the Required Minimum Arc Rating of 40 cal/cm 2 (167.5 J/cm 2 ) a Arc-rated long-sleeve shirt (AR) Arc-rated pants (AR) Arc-rated coverall (AR) Arc-rated arc flash suit jacket (AR) Arc-rated arc flash suit pants (AR) 4 Arc-rated arc flash suit hood Arc-rated gloves c Arc-rated jacket, parka, rainwear, or hard hat liner (AN) Protective Equipment Hard hat Safety glasses or safety goggles (SR) Hearing protection Leather footwear

339 07 of 403 9/2/2016 9:49 AM Notes: AN: as needed (optional). AR: as required. SR: selection required. a Arc rating is defined in Article 100. b Face 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. c If 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. Statement of Problem and Substantiation for Public Comment The Correlating Committee directs that the committee review 130.7(C)(15)(b) and compare the use of the term maximum arc duration and maximum fault clearing times for consistency. Related Item First Revision No. 48-NFPA 70E-2015 [Sections 130.7(C)(15), 130.7(C)(16)] Submitter Information Verification Submitter Full Name: CC on NEC-AAC Organization: NFPA Street Address: City: State: Zip: Submittal Date: Mon Mar 14 16:28:18 EDT 2016 Committee Statement Committee Action: Resolution: Rejected The phrase arc duration is more appropriate and accurate than fault clearing time when referring to a dc arcing fault.

340 08 of 403 9/2/2016 9:49 AM Public Comment No. 88-NFPA 70E-2016 [ Section No (C)(15) ]

341 09 of 403 9/2/2016 9:49 AM (15) Arc Flash PPE Category Method.

342 10 of 403 9/2/2016 9:49 AM The requirements of 130.7(C)(15) shall apply when the arc flash PPE category method is used for the selection of arc flash PPE. (a) Alternating Current (ac) Equipment. When the arc flash risk assessment performed in accordance with indicates that arc flash PPE is required and the arc flash PPE category method is used for the selection of PPE for ac systems in lieu of the incident energy analysis of 130.5(B)(1), Table 130.7(C)(15)(a) shall be used to determine the arc flash PPE category. The estimated maximum available fault current, maximum fault-clearing times, and minimum working distances for various ac equipment types or classifications are listed in Table 130.7(C)(15)(a). An incident energy analysis shall be required in accordance with for the following: (2) Tasks not included in Table (3) Power systems with greater than the estimated maximum available short-circuit current (4) Power systems with longer than the maximum fault clearing times (5) Tasks with less than the minimum working distance for the specific task to be performed from the employee s face and chest areas to an arc source (f) Direct Current (dc) Equipment.When the arc flash risk assessment performed in accordance with indicates that arc flash PPE is required and the arc flash PPE category method is used for the selection of PPE for dc systems in lieu of the incident energy analysis of 130.5(B)(1), Table 130.7(C)(15)(b) shall be used to determine the arc flash PPE category. The estimated maximum available fault current, maximum arc duration, and working distances for dc equipment are listed in 130.7(C)(15)(b). An incident energy analysis shall be required in accordance with for the following: (7) Tasks not included in Table (8) Power systems with greater than the estimated maximum available short-circuit current (9) Power systems with longer than the maximum fault clearing times (10) Tasks with less than the minimum working distance for the specific task to be performed from the employee s face and chest areas to an arc source Informational Note No.1: The arc flash PPE category of the protective clothing and equipment is generally based on determination of the estimated exposure level. Informational Note No.2: In most cases, closed doors do not provide enough protection to eliminate the need for PPE in situations in which the state of the equipment is known to readily change (e.g., doors open or closed, rack in or rack out). Informational Note No.3: Short-circuit current, as used in this table, is determined from the dc power system maximum available short-circuit, including the effects of cables and any other impedances in the circuit. Power system modeling is the best method to determine the available short-circuit current at the point of the arc. Battery cell short-circuit current can be obtained from the battery manufacturer. See Informative Annex D.5 for the basis for table values and alternative methods to determine dc incident energy. Methods should be used with good engineering judgment. Informational Note No.4: The methods for estimating the dc arc-flash incident energy that were used to determine the categories for this table are based on open-air incident energy calculations. Open-air calculations were used because many battery systems and other dc process systems are in open areas or rooms. If the specific task is within in an enclosure, it would be prudent to consider additional PPE protection beyond the value shown in this table. Engineering judgment is necessary when reviewing the specific conditions of the equipment and task to be performed, including the dimensions of the enclosure and the working distance involved. (k) Protective Clothing and Personal Protective Equipment (PPE). Once the arc flash PPE category has been identified from Table 130.7(C)(15)(a) or Table 130.7(C)(15)(b), Table 130.7(C)(15)(c) shall be used to determine the required PPE for the task. Table 130.7(C)(15)(c) lists the requirements for PPE based on arc flash PPE categories 1 through 4. This clothing and equipment shall be used when working within the

343 11 of 403 9/2/2016 9:49 AM arc flash boundary. Informational Note No. 1: See Informative Annex H for a suggested simplified approach to ensure adequate PPE for electrical workers within facilities with large and diverse electrical systems. Informational Note No. 2: The PPE requirements of this section are intended to protect a person from arc flash hazards. While some situations could result in burns to the skin, even with the protection described in Table 130.7(C)(15)(c), burn injury should be reduced and survivable. Due to the explosive effect of some arc events, physical trauma injuries could occur. The PPE requirements of this section do not address protection against physical trauma other than exposure to the thermal effects of an arc flash. Informational Note No. 3: The arc rating for a particular clothing system can be obtained from the arc-rated clothing manufacturer. Table 130.7(C)(15)(a) Arc-Flash PPE Categories for Alternating Current (ac) Systems Equipment Panelboards or other equipment rated 240 volts and below Parameters: Maximum of 25 ka available fault current; maximum of 0.03 s (2 cycles) fault clearing time; minimum working distance 455 mm (18 in.) Panelboards or other equipment rated greater than 240 volts and up to 600 volts Parameters: Maximum of 25 ka available fault current; maximum of 0.03 s (2 cycles) fault clearing time; minimum working distance 455 mm (18 in.) 600-volt class motor control centers (MCCs) Parameters: Maximum of 65 ka available fault current; maximum of 0.03 s (2 cycles) fault clearing time; minimum working distance 455 mm (18 in.) 600-volt class motor control centers (MCCs) Parameters: Maximum of 42 ka available fault current; maximum of 0.33 s (20 cycles) fault clearing time; minimum working distance 455 mm (18 in.) 600-volt class switchgear (with power circuit breakers or fused switches) and 600-volt class switchboards Parameters: Maximum of 35 ka available fault current; maximum of up to 0.5 s (30 cycles) fault clearing time; minimum working distance 455 mm (18 in.) Other 600-volt class (277 volts through 600 volts, nominal) equipment Parameters: Maximum of 65 ka available fault current; maximum of 0.03 s (2 cycles) fault clearing time; minimum working distance 455 mm (18 in.) NEMA E2 (fused contactor) motor starters, 2.3 kv through 7.2 kv Parameters: Maximum of 35 ka available fault current; maximum of up to 0.24 s (15 cycles) fault clearing time; minimum working distance Arc Flash PPE Category Arc-Flash Boundary 485 mm (19 in.) 900 mm (3 ft) 1.5 m (5 ft) 4.3 m (14 ft) 6 m (20 ft) 1.5 m (5 ft) 12 m (40 ft)

344 12 of 403 9/2/2016 9:49 AM Equipment 910 mm (36 in.) Metal-clad switchgear, 1 kv through 15 kv Parameters: Maximum of 35 ka available fault current; maximum of up to 0.24 s (15 cycles) fault clearing time; minimum working distance 910 mm (36 in.) Arc-resistant switchgear Type 1 or 2 [for clearing times of less than 0.5 s (30 cycles) with a perspective fault current not to exceed the arc-resistant rating of the equipment], and metalenclosed interrupter switchgear, fused or unfused of arc-resistant-type construction, tested in accordance with IEEE C , 1 kv through 15 kv Parameters: Maximum of 35 ka available fault current; maximum of up to 0.24 s (15 cycles) fault clearing time; minimum working distance 910 mm (36 in.) Other equipment 1 kv through 15 kv Parameters: Maximum of 35 ka available fault current; maximum of up to 0.24 s (15 cycles) fault clearing time; minimum working distance 910 mm (36 in.) Notes: Arc Flash PPE Category 4 N/A (doors closed) 4 (doors open) 4 Arc-Flash Boundary 12 m (40 ft) N/A (doors closed) 12 m (40 ft) 12 m (40 ft) (1) For equipment rated 600 volts and below and protected by upstream current-limiting fuses or currentlimiting circuit breakers sized at 200 amperes or less, the arc flash PPE category can be reduced by one number but not below arc flash PPE category 1. (2) The following are typical fault clearing times of overcurrent protective devices: (a) 0.5 cycle fault clearing time is typical for current limiting fuses. (b) 1.5 cycle fault clearing time is typical for molded case circuit breakers rated less than 1000 volts with an instantaneous integral trip. (c) 3.0 cycle fault clearing time is typical for insulated case circuit breakers rated less than 1000 volts with an instantaneous integral trip or relay operated trip. (d) 5.0 cycle fault clearing time is typical for relay operated circuit breakers rated 1 kv to 35 kv. (e) 20 cycle fault clearing time is typical for low-voltage power and insulated case circuit breakers with a short time fault clearing delay for motor inrush. (f) 30 cycle fault clearing time is typical for low-voltage power and insulated case circuit breakers with a short time fault clearing delay without instantaneous trip. (See IEEE Table 1 for further information regarding Notes b through d.) Table 130.7(C)(15)(b) Arc-Flash PPE Categories for Direct Current (dc) Systems Equipment Storage batteries, dc switchboards, and other dc supply sources Parameters: Greater than or equal to 100 V and less than or equal to 250 V Maximum arc duration and minimum working distance: mm (18 in.) Arc Flash PPE Category Arc-Flash Boundary

345 13 of 403 9/2/2016 9:49 AM Equipment Arc Flash PPE Category Short-circuit current less than 4 ka 1 Short-circuit current greater than or equal to 4 ka and less than 7 ka Short-circuit current greater than or equal to 7 ka and less than 15 ka Storage batteries, dc switchboards, and other dc supply sources Parameters: Greater than or equal to 250 V and less than or equal to 600 V Maximum arc duration and minimum working distance: mm (18 in.) Short-circuit current less than 1.5 ka 1 Short-circuit current greater than or equal to 1.5 ka and less than 3 ka Short-circuit current greater than or equal to 3 ka and less than 7 ka Short-circuit current greater than or equal to 7 ka and less than 10 ka Arc-Flash Boundary 900 mm (3 ft) 1.2 m (4 ft) 1.8 m (6 ft) 900 mm (3 ft) 1.2 m (4 ft) 1.8 m (6 ft.) 2.5 m (8 ft) Note 1: Apparel that can be expected to be exposed to electrolyte must meet both of the following conditions: (1) Be evaluated for electrolyte protection in accordance with ASTM F1296, Standard Guide for Evaluating Chemical Protective Clothing (2) Be arc-rated in accordance with ASTM F1891, Standard Specification for Arc Rated and Flame Resistant Rainwear, or equivalent Note 2: A two-second arc duration is assumed if there is no OCPD or if the fault clearing time is not known. If the fault clearing time is known and is less than two seconds, an incident energy analysis could provide a more representative result. Table 130.7(C)(15)(c) Personal Protective Equipment (PPE) Arc Flash PPE Category PPE Arc-Rated Clothing, Minimum Arc Rating of 4 cal/cm 2 (16.75 J/cm 2 ) a Arc-rated long-sleeve shirt and pants or arc-rated coverall Arc-rated face shield b (see Note 2) or arc flash suit hood Arc-rated jacket, parka, rainwear, or hard hat liner (AN) 1 Protective Equipment Hard hat Safety glasses or safety goggles (SR) Hearing protection (ear canal inserts) d Heavy-duty leather gloves c Leather footwear (AN)

346 14 of 403 9/2/2016 9:49 AM Notes: AN: as needed (optional). AR: as required. SR: selection required. a Arc rating is defined in Article 100. b Face 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. c If 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. d Other types of arc rated hearing protection are permitted to be used in addition to ear canal inserts. Statement of Problem and Substantiation for Public Comment The action in FR 48 to delete the requirement for ear canal inserts as hearing protection is by design going to create significant exposure and serious burns when twenty plus square inches of meltable plastic burns the face and ears of the worker. Only plastic surgeons will benefit from this revision. The technical substantiation for this revision was simply taken from the associated PI as follows: "The requirement for ear canal inserts is deleted as other types of hearing protection may be necessary or preferred." Where will ear canal inserts not work? Other types of hearing protection, if arc rated, can be worn over ear canal inserts, significantly increasing protection and are not prohibited where they are necessary or preferred. Ear canal inserts are the most inexpensive article of PPE referenced in this standard. It is prudent and feasible to require they be worn at all times and where other types of arc rated hearing protection are available, they may be worn over the ear canal inserts, thereby significantly increasing protection. What did we gain with this revision? We gave permission to use whatever you have on the job and we all know they are MELTABLE. The vast majority of justified energized work performed using the Arc Flash PPE categories will be in PPE categories 1 and 2. This revision endorses the use of whatever hearing protection is on the job and they are all meltable. This comment reinstates the requirement for ear canal inserts and adds a note for clarity and usability as follows: "dother types of arc rated hearing protection is permitted to be used in addition to ear canal inserts." This comment achieves the intent of the committee without creating additional exposure. Related Item First Revision No. 48-NFPA 70E-2015 [Sections 130.7(C)(15), 130.7(C)(16)] Submitter Information Verification Submitter Full Name: James Dollard Organization: IBEW Local Union 98 Street Address: City: State: Zip: Submittal Date: Wed Apr 13 10:21:38 EDT 2016

347 15 of 403 9/2/2016 9:49 AM Committee Statement Committee Rejected but see related SR Action: Resolution: SR-35-NFPA 70E-2016 Statement: 1. List items 130.7(C)(15)(A)(1) and (B)(1) are deleted as Tables 130.7(C)(15(a) and 130.7(C)(15)(b) are no longer task based, rather, they are equipment based (C)(15(A)(2): The phrase short circuit current is revised to available fault current for correlation in the standard in AC systems. 3. List items 130.7(C)(15)(A)(4) and (B)(4) are editorially revised for clarity. 4. List item 130.7(C)(15)(B)(2) and Table 130.7(C)(15)(b): short circuit current is revised to available fault current for consistent use of terminology and to correlate with the definition of available fault current in Article (C)(15) Informational Notes 3 and 4 are relocated to below Table 130.7(C)(15)(b) as they only apply to that table. 6. Table 130.7(C)(15)(a) Note 2 is changed to an Informational Note in accordance to correlate with the action taken by the Committee in the first draft. 7. Table 130.7(C)(15)(a): Informational Note list items (a) and (d) are modified for clarity. 8. Table 130.7(C)(15)(b): The phrase or equal to is deleted from parameter Greater than or equal to 250 V and less than or equal to 600 V in the second section to correlate with the parameter Greater than or equal to 100 V and less than or equal to 250 V in the first section of the table. Both sections of the Table cannot apply to 250 V. 9. Table 130.7(C)(15)(b): Both references to Arc Flash PPE Category 1 are revised to Arc Flash PPE Category 2 because the arc flash boundaries are at 900 mm (36-inches). This action is necessary for correlation as the existing requirement is in direct conflict with 130.7(C)(10)(b)(1). 10. Table 130.7(C)(15)(c): The requirement for ear canal inserts is restored in the Second Revision. Specifically identifying ear canal inserts rather than a generic reference to hearing protection simplifies use of the table for the electrical worker. Ear canal inserts provide a similar if not greater Noise Reduction Rating (NRR) when compared to ear muffs, but without a large amount of meltable material in the ear and face area. Table Note (d) informs the user of the standard that other types of hearing protection are permitted to be used in lieu of or in addition to ear canal inserts provided it is worn under arc-rated arc flash suit hood. In order for hearing protection to achieve a reliable NRR it must form a seal within the ear canal or over the ear, and so cannot be worn over top of PPE. 11. The reference to Type 1 and Type 2 is deleted from the arc resistant portion of Table 130.7(C) (15)(a) as it is no longer necessary because it is only available in Type 1 and Type 2 as available and tested in accordance with IEEE C The voltage reference in this portion of the table was relocated for clarity.

348 16 of 403 9/2/2016 9:49 AM Public Comment No. 115-NFPA 70E-2016 [ Section No (C)(16) ] (16) Personal Protective Equipment Conformity Assessment. (a) All personal protective equipment referenced in Table 130.7(C)(14) shall comply with the associated referenced standard. (b) Effective January 1, 2018, all personal protective equipment shall comply with ANSI/ISEA 125, American National Standard for Conformity Assessment of Safety and Personal Protective Equipment, conformity assessment Level 1, 2, or 3 in its entirety, and shall be marked in accordance with Section 9 of ANSI/ISEA 125. Statement of Problem and Substantiation for Public Comment This Public Comment is submitted by Daniel Roberts in behalf of the Canadian Standards Association (CSA) Z462 Workplace Electrical Safety Technical Committee. Revise and relocate 130.7(C)(16) Conformity Assessment as Informational Note No. 2 in Section 130.7(C)(14) Standards for Personal Protective Equipment (PPE). The information regarding conformity assessment is better suited as an informational note. See Public Comment # 116 for additional rational Related Item First Revision No. 70-NFPA 70E-2015 [New Section after 130.7(C)(16)] Submitter Information Verification Submitter Full Name: Daniel Roberts Organization: Schneider Electric Affilliation: CSA Z462 Technical Committee Street Address: City: State: Zip: Submittal Date: Mon Apr 25 12:38:37 EDT 2016 Committee Statement Committee Action: Resolution: Rejected Because mandatory references have become informational in nature, the document lacked any guidance for manufacturers of PPE with regard to product performance. Conformity assessment should not be deleted since it provides a standard format for a manufacture to describe the performance and assure the quality of their products.

349 17 of 403 9/2/2016 9:49 AM Public Comment No. 174-NFPA 70E-2016 [ Section No (C)(16) ] (16) Personal Protective Equipment Conformity Assessment. (a) All personal protective equipment referenced in Table 130.7(C)(14) shall comply with the associated referenced standard. (2) Effective January 1, 2018, all personal protective equipment shall comply with ANSI/ISEA 125, American National Standard for Conformity Assessment of Safety and Personal Protective Equipment, conformity assessment Level 1, 2, or 3 in its entirety, and shall be marked in accordance with Section 9 of ANSI/ISEA 125. (3) Statement of Problem and Substantiation for Public Comment The requirements of the proposed conformity assessment are already being met by product manufacturers who must verify their product performance by undertaking specific testing and maintaining product quality to ensure that their claims are consistent in demonstrating that products meet the requirements of the referenced standards. Further, the additional costs associated with compliance to Levels 2 & 3 of ANSI 125 that may be passed on to the end user do nothing to improve worker safety. For example, the specific requirement for ISO 9001 registration of the manufacturer quality control process does not guarantee that manufactured product will be of higher quality. Instead, ISO 9001 is an extensive and onerous requirement for documenting the manufacturer s quality system. Even with ISO 9001 registration, a manufacturer can have inadequate inspection levels and poor control of their manufacturing processes. ISO 9001 only ensures that activity surrounding a company s quality system is thoroughly documented but provides no provision for actually improving the quality of the finished product. Related Item First Revision No. 70-NFPA 70E-2015 [New Section after 130.7(C)(16)] Submitter Information Verification Submitter Full Name: Denise Statham Organization: Bulwark Protective Apparel Street Address: City: State: Zip: Submittal Date: Fri May 13 15:24:57 EDT 2016 Committee Statement Committee Action: Resolution: Rejected Because mandatory references have become informational in nature, the document lacked any guidance for manufacturers of PPE with regard to product performance. Conformity assessment should not be deleted since it provides a standard format for a manufacture to describe the performance and assure the quality of their products.

350 18 of 403 9/2/2016 9:49 AM Public Comment No. 175-NFPA 70E-2016 [ Section No (C)(16) ] (16) Personal Protective Equipment Conformity Assessment. (a) All personal protective equipment referenced in Table 130.7(C)(14) shall comply with the associated referenced standard. (b) Effective January 1, 2018, all personal protective equipment shall comply with ANSI/ISEA 125, American National Standard for Conformity Assessment of Safety and Personal Protective Equipment, conformity assessment Level 1, 2, or 3 in its entirety, with the exception permitted as provided in (c) of this section, and shall be marked in accordance with Section 9 of ANSI/ISEA 125. (c) In lieu of having ISO 9001 registration, manufacturers of personal protective equipment shall be permitted to maintain a quality assurance program that includes the following minimum elements: 1. The quality assurance program shall include a documented inspection and product recall system. 2. The manufacturer shall have an inspection system to substantiate conformance to the referenced standard. 3. The manufacturer shall maintain written inspection and testing instructions. (i) The instructions shall prescribe inspection and test of materials, work in process, and completed articles. (ii) Criteria for acceptance and rejection of materials, processes, and final product shall be part of the instructions. 4. The manufacturer shall maintain records of all "pass" and "fail" tests. 5. Manufacturer records shall indicate the the disposition of the failed materials or products. 6. The manufacturer's inspection system shall provide for procedures that assure the latest applicable drawings, specifications, and instructions are used for fabrication, inspection, and testing. 7. The manufacturer shall maintain, as part of the quality assurance program, a calibration program of all instruments used to ensure proper control of testing. 8. The manufacturer's calibration program shall be documented as to the date of calibration and performance verification. 9. The manufacturer shall maintain a system for identifying the inspection status of component materials, work in process, and finished goods. 10. The manufacturer shall establish and maintain a system for controlling non-conforming material, including procedures for the identification, segregation, and disposition of rejected material. 11. The manufacturer shall identify all non-conforming materials or products to prevent use, shipment, and intermingling with conforming materials or products. 12. The manufacturer's quality assurance program shall be audited at least annually by an outside third-party organization to determine that the program ensures continued product compliance with these requirements. Statement of Problem and Substantiation for Public Comment While ANSI 125 permits choices by offering levels of conformity to demonstrate compliance with the referenced PPE standards, ANSI 125 is inconsistent with existing industry practices which are exercised for many arc-rated garments that are jointly represented for compliance with both ASTM F1506 and NFPA 2112 (Standard on Flame- Resistant Garments for Protection of Industrial Personnel Against Flash Fire). NFPA 2112 requires third-party certification with testing performed at an accredited ISO laboratory but does not require ISO 9001 registration of the manufacturer facilities. Instead, NFPA 2112 sets specific requirements for a manufacturer's quality assurance program as presented in the proposed additional language to this section. The inclusion of the proposed additional language would create consistent certification practices for a large majority of garments that comply with both ASTM F1506 and NFPA The current language creates a disparity in the way that conformity assessment practices are applied to the same product and would create an unnecessary burden on

351 19 of 403 9/2/2016 9:49 AM manufacturers with additional costs possibly being passed on to end users. The proposed changes still preserve the intent of the technical committee in addressing a full range of conformity assessment practices to demonstrate compliance with the referenced standards. Related Item First Revision No. 70-NFPA 70E-2015 [New Section after 130.7(C)(16)] Submitter Information Verification Submitter Full Name: Denise Statham Organization: Bulwark Protective Apparel Street Address: City: State: Zip: Submittal Date: Fri May 13 15:27:35 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-36-NFPA 70E-2016 Statement: Because mandatory references have become informational in nature, the document lacked any guidance for manufacturers of PPE with regard to product performance. The new language regarding conformity assessment and marking requirements provides a standard format for a manufacture to describe the performance and assure the quality of their products. The requirements for conformity assessment are more properly located in 130.7(C)(14) where "standards for personal protective equipment" are presently located. The mandatory reference in 130.7(C)(14) is removed and relocated to Informational Note No.1 and the table is retitled as "Informational Note Table 130.7(C)(14).

352 20 of 403 9/2/2016 9:49 AM Public Comment No. 183-NFPA 70E-2016 [ Section No (C)(16) ] (16) Personal Protective Equipment Conformity Assessment. (a) All personal protective equipment referenced in Table 130.7(C)(14) shall comply with the associated referenced standard. (b) Effective January 1, 2018, all personal protective equipment shall comply with ANSI/ISEA 125, American National Standard for Conformity Assessment of Safety and Personal Protective Equipment, conformity assessment Level 1, 2, or 3 in its entirety, and shall be marked in accordance with Section 9 of ANSI/ISEA 125. Statement of Problem and Substantiation for Public Comment Insufficient technical substantiation was provided for this significant change. The Committee Statement provides some background information on ANSI/ISEA 125 but provides no substantiation for the change. The requirement is overly restrictive in that it applies to all equipment referenced in Table 130.7(C)(14) and not just arc flash PPE. The proposed changed does not demonstrate why equipment testing in accordance with the referenced ASTM standards is insufficient to provide worker safety. Related Public Comments for This Document Related Comment Relationship Public Comment No. 187-NFPA 70E-2016 [Section No. H.4] Related Item First Revision No. 70-NFPA 70E-2015 [New Section after 130.7(C)(16)] Submitter Information Verification Submitter Full Name: Louis Barrios Organization: Shell Global Solutions Affilliation: American Petroleum Institute Street Address: City: State: Zip: Submittal Date: Sun May 15 18:20:03 EDT 2016 Committee Statement Committee Action: Resolution: Rejected Because mandatory references have become informational in nature, the document lacked any guidance for manufacturers of PPE with regard to product performance. Conformity assessment should not be deleted since it provides a standard format for a manufacture to describe the performance and assure the quality of their products.

353 21 of 403 9/2/2016 9:49 AM Public Comment No. 72-NFPA 70E-2016 [ Section No (C)(16) ] (16) Personal Protective Equipment Conformity Assessment. (a) All personal protective equipment referenced in Table 130.7(C)(14) shall comply with the associated referenced standard. (b) Effective January 1, 2018, all personal protective equipment shall comply with ANSI/ISEA 125, American National Standard for Conformity Assessment of Safety and Personal Protective Equipment, conformity assessment Level 1, 2, or 3 in its entirety, and shall be marked in accordance with Section 9 of ANSI/ISEA 125. Statement of Problem and Substantiation for Public Comment While I agree with the concept of a conformity requirement, this is not the correct way to do this. This would allow self certification, which happens now and will provide no additional level of confidence that the PPE conforms to applicable standards than we have today. If this requirement is to have any merit, it will have to require listing and labeling as is done with many other items. This needs to be deferred to next cycle to allow time to determine what is needed and the best way to get there. Related Item First Revision No. 70-NFPA 70E-2015 [New Section after 130.7(C)(16)] Submitter Information Verification Submitter Full Name: David Pace Organization: Olin Corporation Affilliation: Self Street Address: City: State: Zip: Submittal Date: Thu Mar 17 17:01:02 EDT 2016 Committee Statement Committee Action: Resolution: Rejected Because mandatory references have become informational in nature, the document lacked any guidance for manufacturers of PPE with regard to product performance. Conformity assessment should not be deleted since it provides a standard format for a manufacture to describe the performance and assure the quality of their products.

354 22 of 403 9/2/2016 9:49 AM Public Comment No. 114-NFPA 70E-2016 [ Section No (D)(1) ]

355 23 of 403 9/2/2016 9:49 AM (1) Insulated Tools and Equipment. Employees shall use insulated tools or handling equipment, or both, when working inside the restricted approach boundary of exposed energized electrical conductors or circuit parts where tools or handling equipment might make unintentional contact. Insulated tools shall be protected from damage to the insulating material. Informational Note: See 130.4(C), Shock Protection Boundaries. (a) Requirements for Insulated Tools. The following requirements shall apply to insulated tools: (2) Insulated tools shall be rated for the voltages on which they are used. (3) Insulated tools shall be designed and constructed for the environment to which they are exposed and the manner in which they are used. (4) Insulated tools and equipment shall be inspected prior to each use. The inspection shall look for damage to the insulation or damage that can limit the tool from performing its intended function or could increase the potential for an incident (e.g., damaged tip on a screwdriver). (e) Fuse or Fuseholder Handling Equipment. Fuse or fuseholder handling equipment, insulated for the circuit voltage, shall be used to remove or install a fuse if the fuse terminals are energized. (f) Ropes and Handlines. Ropes and handlines used within the limited approach boundary shall be nonconductive. (g) Fiberglass-Reinforced Plastic Rods. Fiberglass-reinforced plastic rod and tube used for live-line tools shall meet the requirements of applicable portions of electrical codes and standards dealing with electrical installation requirements. Informational Note: For further information concerning electrical codes and standards dealing with installation requirements, refer to ASTM F 711, Standard Specification for Fiberglass- Reinforced Plastic (FRP) Rod and Tube Used in Live Line Tools. (h) Portable Ladders. Portable ladders used within the limited approach boundary shall have nonconductive side rails. (9) Nonconductive ladders shall meet the requirements of ANSI standards for ladders listed in Table 130.7(F). (j) Protective Shields. Protective shields, protective barriers, or insulating materials shall be used to protect each employee from shock, burns, or other electrically related injuries while an employee is working within the limited approach boundary of energized conductors or circuit parts that might be unintentionally contacted or where dangerous electric heating or arcing might occur. When normally enclosed energized conductors or circuit parts are exposed for maintenance or repair, they shall be guarded to protect unqualified persons from contact with the energized conductors or circuit parts. (k) Rubber Insulating Equipment. Rubber insulating equipment used for protection from unintentional contact with energized conductors or circuit parts shall meet the requirements of the ASTM standards listed in Table 130.7(G). (l) Voltage-Rated Plastic Guard Equipment. Plastic guard equipment for protection of employees from unintentional contact with energized conductors or circuit parts, or for protection of employees or energized equipment or material from contact with ground, shall meet the requirements of the ASTM standards listed in Table 130.7(G). (m) Physical or Mechanical Barriers. Physical or mechanical (field-fabricated) barriers shall be installed no closer than the limited approach boundary distance given in Table 130.4(C)(a) and Table 130.4(C)(b). While the barrier is being installed, the limited approach boundary distance specified in Table 130.4(C)(a) and Table 130.4(C)(b) shall be maintained, or the energized conductors or circuit parts shall be placed in an electrically safe work condition. Statement of Problem and Substantiation for Public Comment This Public Comment is submitted by Daniel Roberts in behalf of the Canadian Standards Association (CSA) Z462 Workplace Electrical Safety Technical Committee.

356 24 of 403 9/2/2016 9:49 AM Errata. Restore the second sentence in list item 130.7(D)(1)(e) regarding nonconductive ladders conforming to the applicable ANSI standard. The sentence appears to have been inadvertently deleted. No Public Input requested the deletion; neither was any rationale was provided for the deletion. Additionally, Table 130.7(F) has not been revised to remove the references to the ANSI ladder standards. Related Item First Revision No. 40-NFPA 70E-2015 [Section No (D)(1)] Submitter Information Verification Submitter Full Name: Daniel Roberts Organization: Schneider Electric Affilliation: CSA Z462 Technical Committee Street Address: City: State: Zip: Submittal Date: Mon Apr 25 12:26:27 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-40-NFPA 70E-2016 Statement: The second sentence was added as it was inadvertently removed in the First Draft. The additional language in the first sentence recognizes inadvertent movement of the employee or a portable ladder. The mandatory references were relocated into an informational note.

357 25 of 403 9/2/2016 9:49 AM Public Comment No. 169-NFPA 70E-2016 [ Section No (D)(1) ] (1) Insulated Tools and Equipment. Employees shall use insulated tools or handling equipment, or both, when working inside the restricted approach boundary of exposed energized electrical conductors or circuit parts where tools or handling equipment might make unintentional contact. Insulated tools shall be protected from damage to the insulating material. Informational Note: See 130.4(C), Shock Protection Boundaries. (a) Requirements for Insulated Tools. The following requirements shall apply to insulated tools: (2) Insulated tools shall be rated for the voltages on which they are used. (3) Insulated tools shall be designed and constructed for the environment to which they are exposed and the manner in which they are used. (4) Insulated tools and equipment shall be inspected prior to each use. The inspection shall look for damage to the insulation or damage that can limit the tool from performing its intended function or could increase the potential for an incident (e.g., damaged tip on a screwdriver). (e) Fuse or Fuseholder Handling Equipment. Fuse or fuseholder handling equipment, insulated for the circuit voltage, shall be used to remove or install a fuse if the fuse terminals are energized. (f) Ropes and Handlines. Ropes and handlines used within the limited approach boundary shall be nonconductive. (g) Fiberglass-Reinforced Plastic Rods. Fiberglass-reinforced plastic rod and tube used for live-line tools shall meet the requirements of applicable portions of electrical codes and standards dealing with electrical installation requirements. Informational Note: For further information concerning electrical codes and standards dealing with installation requirements, refer to ASTM F 711, Standard Specification for Fiberglass- Reinforced Plastic (FRP) Rod and Tube Used in Live Line Tools. (h) Portable Ladders. Portable ladders shall have nonconductive side rails when used within the limited approach boundary shall have nonconductive side rails, or where the employee or ladder could contact exposed energized electrical conductors or circuit parts. (i) Protective Shields. Protective shields, protective barriers, or insulating materials shall be used to protect each employee from shock, burns, or other electrically related injuries while an employee is working within the limited approach boundary of energized conductors or circuit parts that might be unintentionally contacted or where dangerous electric heating or arcing might occur. When normally enclosed energized conductors or circuit parts are exposed for maintenance or repair, they shall be guarded to protect unqualified persons from contact with the energized conductors or circuit parts. (j) Rubber Insulating Equipment. Rubber insulating equipment used for protection from unintentional contact with energized conductors or circuit parts shall meet the requirements of the ASTM standards listed in Table 130.7(G). (k) Voltage-Rated Plastic Guard Equipment. Plastic guard equipment for protection of employees from unintentional contact with energized conductors or circuit parts, or for protection of employees or energized equipment or material from contact with ground, shall meet the requirements of the ASTM standards listed in Table 130.7(G). (l) Physical or Mechanical Barriers. Physical or mechanical (field-fabricated) barriers shall be installed no closer than the limited approach boundary distance given in Table 130.4(C)(a) and Table 130.4(C)(b). While the barrier is being installed, the limited approach boundary distance specified in Table 130.4(C)(a) and Table 130.4(C)(b) shall be maintained, or the energized conductors or circuit parts shall be placed in an electrically safe work condition.

358 26 of 403 9/2/2016 9:49 AM Statement of Problem and Substantiation for Public Comment By referencing the limited approach boundary as an absolute distance, the level of safety provided in 130.7(D)(e) has been reduced. Most step ladders are taller than the limited approach distance and could fall into the exposed circuit parts. Related Item First Revision No. 40-NFPA 70E-2015 [Section No (D)(1)] Submitter Information Verification Submitter Full Name: Jason Wolf Organization: Esco Group Street Address: City: State: Zip: Submittal Date: Fri May 13 14:52:14 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-40-NFPA 70E-2016 Statement: The second sentence was added as it was inadvertently removed in the First Draft. The additional language in the first sentence recognizes inadvertent movement of the employee or a portable ladder. The mandatory references were relocated into an informational note.

359 27 of 403 9/2/2016 9:49 AM Public Comment No. 73-NFPA 70E-2016 [ Section No (E)(3) ] (3) Attendants. If signs and barricades do not provide sufficient warning and protection from electrical hazards, a qualified person shall serve as an attendant and shall be stationed at the work area to warn and protect employees. The primary duty and responsibility of an attendant providing manual signaling and alerting shall be to keep unqualified employees outside a work area where the unqualified employee might be exposed to electrical hazards. An attendant shall remain in the area as long as there is a potential for employees to be exposed to the electrical hazards. Statement of Problem and Substantiation for Public Comment The existing text indicates the original intent of the wording in that it states that the attendant's primary duty is to keep unqualified people outside of the work area where the unqualified person might be exposed to hazards. The wording clearly differentiates the attendant from an unqualified person. It would be useless to have an unqualified person serve as an attendant. The attendant may not be an electrician, in most cases probably would not be, but they would need enough instruction to perform the attendant duties, this instruction would make them qualified to perform this task but unqualified to perform others outside of this instruction. We cannot allow this person to be an unqualified person. Related Item First Revision No. 79-NFPA 70E-2015 [Global Input] Submitter Information Verification Submitter Full Name: David Pace Organization: Olin Corporation Affilliation: Self Street Address: City: State: Zip: Submittal Date: Thu Mar 17 17:06:41 EDT 2016 Committee Statement Committee Action: Resolution: Rejected The Technical Committee reaffirms that an attendant s responsibility is stated in 130.7(C)(E)(3). The submitter has not adequately substantiated why an Attendant needs to be changed to a Qualified Person.

360 28 of 403 9/2/2016 9:49 AM Public Comment No. 185-NFPA 70E-2016 [ Section No ] General Maintenance Requirements. Electrical equipment shall be maintained in accordance with manufacturers' instructions or industry consensus standards to reduce the risk associated with failure. The equipment owner or the owner s designated representative shall be responsible for maintenance of the electrical equipment and documentation. Informational Note No. 1: Common industry practice is to apply test or calibration decals to equipment to indicate the test or calibration date and overall condition of equipment that has been tested and maintained in the field. These decals provide the employee immediate indication of last maintenance date and if the tested device or system was found acceptable on the date of test. This local information can assist the employee in the assessment of overall electrical equipment maintenance status. Informational Note No. 2: Noncontact diagnostic methods in addition to scheduled maintenance activities of electrical equipment can assist in the identification of electrical anomalies. The installation of listed and labeled inspection windows assists in performing this task without opening equipment. Statement of Problem and Substantiation for Public Comment The proposed Informational Note No. 2 is not necessary. While noncontact diagnostic methods have proven to be successful in identifying electrical anomalies, specifically including inspection windows, while excluding other types of inspection is not necessary and opens the door for a laundry list of inspection examples that is not necessary for the application of the Standard. Related Item First Revision No. 43-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: Louis Barrios Organization: Shell Global Solutions Affilliation: American Petroleum Institute Street Address: City: State: Zip: Submittal Date: Sun May 15 18:51:54 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-46-NFPA 70E-2016 Statement: The second sentence was removed to prevent a misunderstanding that inspection windows are the only noncontact diagnostic method to detect electrical anomalies.

361 29 of 403 9/2/2016 9:49 AM Public Comment No. 181-NFPA 70E-2016 [ Section No ] Ventilation. Ventilation systems, When forced or natural ventilation systems are required by the battery system design and are present, they shall be examined and maintained to prevent buildup of explosive mixtures. This maintenance shall include a functional test of any associated detection and alarm systems. Informational Note No. 1: "Natural ventilation" implies there are no mechanical mechanisms. Maintenance includes activities such as inspection for and removal of any obstructions to natural air flow. Informational Note No. 2: Some battery chemistries, such as (but not limited to) lithium-ion do not vent hazardous gas and therefore do not require special ventilation. Others, such as (but not limited to) lead-acid or nickel-cadmium, do vent flammable gas and therefore require ventilation. Statement of Problem and Substantiation for Public Comment Public Input no. 371 was not accepted by the committee because The addition of the words are required and present does not add clarity or readability. This comment addresses the committee s concern by providing more clear text and informational notes explaining why some battery systems do not need additional ventilation. Without such clarification the existing text implies that ventilation systems are required for ALL battery systems. The words and are present is meant to ensure that ventilation systems are provided when needed because of the battery chemistry. In addition, IN #1 clarifies that the type of maintenance on natural ventilation systems would typically be limited to inspection and removal of any obstructions. The revised text should not be considered new material because it directly responds to the committee s earlier statement. Related Item Public Input No. 371-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: Stephen McCluer Organization: Steve McCluer Llc Street Address: City: State: Zip: Submittal Date: Sat May 14 14:43:56 EDT 2016 Committee Statement Committee Action: Resolution: Statement: Rejected but see related SR SR-47-NFPA 70E-2016 The proposed Informational Note No. 2 was deleted because it contains installation related information. Changes were made to clarify text. The phrase and are present is meant to ensure that ventilation systems are provided when needed because of the battery chemistry. The informational note was added to clarify that the type of maintenance on natural ventilation systems would typically be limited to inspection and removal of any obstructions.

362 30 of 403 9/2/2016 9:49 AM Public Comment No. 165-NFPA 70E-2016 [ Section No ] Eye and Body Wash Apparatus. Eye and body wash apparatus shall be maintained in operable condition when such apparatus are installed as appropriate for the battery chemistry and as required by the applicable building codes. Informational Note: Eye and body wash apparatus is only appropriate when there is risk of exposure to liquid electrolyte. Some battery chemistries with solid electrolyte do not have liquid electrolyte, in which case eye/body wash would be inappropriate and would not be present. Statement of Problem and Substantiation for Public Comment Public Input no. 372 was not accepted by the committee because The addition of the words are required and present does not add clarity or readability. Although not explicitly stated, the existing text implies that eye and body wash apparatus are required for all batteries and battery rooms, which is simply not the case. The addition of an informational note makes it clear that eye and body wash apparatus are only appropriate for battery chemistries involving liquid electrolyte. The new text is meant to ensure that eye and body wash systems are provided when needed because of the battery chemistry. The Fire Code stipulates the use of eye wash stations. The revised text should not be considered new material because it directly responds to the committee s earlier statement on PI #372. Related Item Public Input No. 372-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: Stephen McCluer Organization: Steve McCluer LLC Street Address: City: State: Zip: Submittal Date: Thu May 12 14:01:02 EDT 2016 Committee Statement Committee Action: Resolution: Rejected The proposed revision does not add clarity or readability. If an eye and body wash station is not present it cannot be maintained.

363 31 of 403 9/2/2016 9:49 AM Public Comment No. 74-NFPA 70E-2016 [ Section No (A) ] (A) General. Operation and maintenance of electrolytic cell lines might require contact by employees with exposed energized surfaces such as buses, electrolytic cells, and their attachments. The approach distances referred to in Table 130.4(C)(a) and Table 130.4(C)(b) shall not apply to work performed by qualified persons in the cell line working zone. Safeguards such as safety-related work practices and other safeguards shall be used to protect employees from injury while working in the cell line working zone. These safeguards shall be consistent with the nature and extent of the related electrical hazards. Safeguards might be different for energized cell lines and de-energized cell lines. Hazardous battery effect voltages shall be dissipated to consider a cell line de-energized. Informational Note No. 1: Exposed energized surfaces might not present an electrical hazard. Shock hazards are related to current through the body, causing shock and thermal burns. Shock current is Shock injury severity is a function of many factors, including resistance through the body and the skin, return paths, paths in parallel with the body, and system voltages. Arc flash burns and arc blasts are a function of the arcing current and the duration of arc exposure. Informational Note No. 2: A cell line or group of cell lines operated as a unit for the production of a particular metal, gas, or chemical compound might differ from other cell lines producing the same product because of variations in the particular raw materials used, output capacity, use of proprietary methods or process practices, or other modifying factors. Detailed standard electrical safety-related work practice requirements could become overly restrictive without accomplishing the stated purpose of Chapter 1. Statement of Problem and Substantiation for Public Comment Shock current is not the correct wording here. The wording relates to the injury resulting from a shock event. Related Item First Revision No. 50-NFPA 70E-2015 [Section No (A)] Submitter Information Verification Submitter Full Name: David Pace Organization: Olin Corporation Affilliation: Self Street Address: City: State: Zip: Submittal Date: Thu Mar 17 17:24:36 EDT 2016 Committee Statement Committee Action: Rejected but see related SR Resolution: SR-48-NFPA 70E-2016 Statement: The editorial revision in language clarifies and improves usability of the informational note.

364 32 of 403 9/2/2016 9:49 AM Public Comment No. 118-NFPA 70E-2016 [ Section No (C) ] (C) Electrical Arc Flash Hazard Analysis Arc Flash Risk Assessment. The requirements of 130.5, Arc Flash Risk Assessment, shall not apply to electrolytic cell line work zones. (1) Arc Flash Risk Assessment. Each task performed in the electrolytic cell line working zone shall be analyzed for the likelihood of arc flash injury. If there is a likelihood of personal injury, appropriate measures shall be taken to protect persons exposed to the arc flash hazards, including one or more of the following: (1) Providing appropriate PPE [see 310.5(D)(2)] to prevent injury from the arc flash hazard (2) Altering work procedures to reduce the likelihood of occurrence of an arc flash incident (3) Scheduling the task so that work can be performed when the cell line is de-energized (2) Routine Tasks. Arc flash risk assessment shall be done for all routine tasks performed in the cell line work zone. The results of the arc flash risk assessment shall be used in training employees in job procedures that minimize the possibility of arc flash hazards. The training shall be included in the requirements of (3) Nonroutine Tasks. Before a nonroutine task is performed in the cell line working zone, an arc flash risk assessment shall be done. If an arc flash hazard is a possibility during nonroutine work, appropriate instructions shall be given to employees involved on how to minimize the risk associated with arc flash. (4) Arc Flash Hazards. If the likelihood of occurrence of an arc flash hazard exists for either routine or nonroutine tasks, employees shall use appropriate safeguards. Statement of Problem and Substantiation for Public Comment This Public Comment is submitted by Daniel Roberts in behalf of the Canadian Standards Association (CSA) Z462 Workplace Electrical Safety Technical Committee. The proposed revision correlates with the global revision from "hazard analysis" to "risk assessment" that occurred last cycle. Related Item First Revision No. 50-NFPA 70E-2015 [Section No (A)] Submitter Information Verification Submitter Full Name: Daniel Roberts Organization: Schneider Electric Affilliation: CSA Z462 Technical Committee Street Address: City: State: Zip: Submittal Date: Mon Apr 25 15:10:26 EDT 2016 Committee Statement Committee Rejected but see related SR

365 33 of 403 9/2/2016 9:49 AM Action: Resolution: SR-49-NFPA 70E-2016 Statement: This editorial revision revises the phrase hazard analysis to risk assessment to correlate with the remainder of the standard. Editorial revisions were made in accordance with the NEC Style Manual.

366 34 of 403 9/2/2016 9:49 AM Public Comment No. 196-NFPA 70E-2016 [ Sections 320.3(B)(1), 320.3(B)(2) ]

367 35 of 403 9/2/2016 9:49 AM The following protective equipment shall be available to employees performing any type of service on a battery with liquid electrolyte: Sections A battery risk assessment, which include electrolyte hazards, shall be performed and shall comply with 320.3( B A )(1), 320.3(B)(2) : (1) Battery Activities That Include Handling of Liquid Electrolyte. (1) General. An electrtolyte risk assessment shall be performed as follows: a. To identify electrolyte hazards b. To estimate the likelihood of occurrence of injury or damage to health and the potential severity of injury or damage to health c. To determine if additional protective measures are required, including the use of PPE (2) Estimate of Likelihood and Severity. The estimate of the likelihood of occurrence of injury or damage to health and the potential severity of injury or damage to health shall take into consideration the following: a. The type of battery and electrolyte b. The battery operating condition and condition of maintenance Table 320.x shall be permitted to be used to estimate the likelihood of occurrence of a person coming in contact with electrolyte. Table 320.y shall be permitted to be used for selection of electrolyte PPE if a battery risk assessment has been conducted. Table 320.x Estimate of the Likelihood of Occurrence of a person coming in contact with electrolyte Task Battery Condition Likelihood of Occurance Acid adjustment Any Yes Use of a bulb hydrometer when taking specific gravity readings Any Yes Use of an electronic density meter when taking specific gravity readings Normal No Adding water to the electrolyte through the flame arrestor Normal No Performing normal battery maintenance and testing excluding specific gravity readings Normal No For batteries with solid or immobilized electrolyte All No Table 320.Y Selection of electrolyte rated based on the battery risk assessment For activities that have a likelihood of occurrence (1) Goggles and face shield appropriate for the electrical hazard and the chemical hazard (2) Gloves and aprons appropriate for the chemical hazards Portable (3) For as long as the hazard exists, portable or stationary eye wash facilities and equipment within the work area that are capable of drenching or flushing of the eyes and body for the duration necessary to mitigate injury from the electrolyte hazard

368 36 of 403 9/2/2016 9:49 AM body are required. Informational Note: Guidelines for the use and maintenance of eye wash facilities for vented batteries in nontelecom environments can be found in ANSI/ISEA Z358.1, American National Standard for Emergency Eye Wash and Shower Equipment. (2) Activities That Do Not Include Handling of Electrolyte. Employees performing any activity not involving the handling of electrolyte shall wear safety glasses. Informational Note: Battery maintenance activities usually do not involve handling electrolyte. Batteries with solid electrolyte (such as most lithium batteries) or immobilized electrolyte (such as valve-regulated lead acid batteries) present little or no electrolyte hazard. Most modern density meters expose a worker to a quantity of electrolyte too minute to be considered hazardous, if at all. Such work would not be considered handling electrolyte. However, if specific gravity readings are taken using a bulb hydrometer, the risk of exposure is higher this could be considered to be handling electrolyte, and the requirements of 320.3(B)(1) would apply. For activities that do not have a likelihood of occurrence (1) Safety glasses appropriate for the electrical hazard and the chemical hazard Additional Proposed Changes File Name Description Approved Suggested_changes_to_electrolyte_section.docx This is how the new section should look Statement of Problem and Substantiation for Public Comment These current sections do not provide much if any guidance for what PPE is really required for the user. It mostly provides a list of PPE that should be provided. The proposed change is consistent with PI 375 and the change in philosophy outlined in FR 60. Related Item Public Input No. 375-NFPA 70E-2015 [Sections 320.3(B)(1), 320.3(B)(2)] First Revision No. 60-NFPA 70E-2015 [Section No ] Submitter Information Verification Submitter Full Name: William Cantor Organization: TPI Corporation Street Address: City: State: Zip: Submittal Date: Mon May 16 09:49:22 EDT 2016 Committee Statement Committee Action: Resolution: Rejected but held The proposed change to Section contains information that has not had public review in accordance with Paragraph of the NFPA Regulations Governing Committee Projects.

369 A battery risk assessment, which include electrolyte hazards, shall be performed and shall comply with 320.3(A)(1): (1) General. An electrolyte risk assessment shall be performed as follows: a. To identify electrolyte hazards b. To estimate the likelihood of occurrence of injury or damage to health and the potential severity of injury or damage to health c. To determine if additional protective measures are required, including the use of PPE (2) Estimate of Likelihood and Severity. The estimate of the likelihood of occurrence of injury or damage to health and the potential severity of injury or damage to health shall take into consideration the following: a. The type of battery and electrolyte b. The battery operating condition and condition of maintenance Table 320.x shall be permitted to be used to estimate the likelihood of occurrence of a person coming in contact with electrolyte. Table 320.y shall be permitted to be used for selection of electrolyte PPE if a battery risk assessment has been conducted. Table 320.x Estimate of the Likelihood of Occurrence of a person coming in contact with electrolyte Task Battery Condition Likelihood of Occurance Acid adjustment Any Yes Use of a bulb hydrometer when taking specific gravity readings Any Yes Use of an electronic density meter when taking specific gravity readings Normal No Adding water to the electrolyte through the flame arrestor Normal No Performing normal battery maintenance and testing excluding specific gravity Normal No readings For batteries with solid or immobilized electrolyte All No Table 320.Y Selection of electrolyte rated based on the battery risk assessment For activities that have a likelihood of occurrence (1) Goggles and face shield appropriate for the electrical hazard and the chemical hazard (2) Gloves and aprons appropriate for the chemical hazards (3) For as long as the hazard exists, portable or stationary eye wash facilities within the work area that are capable of drenching or flushing of the eyes and body are required. Informational Note: Guidelines for the use and maintenance of eye wash facilities for vented batteries in nontelecom environments can be found in ANSI/ISEA Z358.1, American National Standard for Emergency Eye Wash and Shower Equipment. For activities that do not have a likelihood of occurrence (1) Safety glasses appropriate for the electrical hazard and the chemical hazard

370 37 of 403 9/2/2016 9:49 AM Public Comment No. 182-NFPA 70E-2016 [ Section No (C)(1) ] (1) Direct-Current Ground-Fault Detection. Ground-fault detection (A) System Determination. Prior to working on a battery system systems with voltages equal to or greater than 100 volts dc, the worker shall determine: (1) the type of dc grounding system being utilized; and (2) if a ground-fault detection system is present. (B) DC Grounding Method. The ground-fault detection system shall be based on the type of dc grounding systems utilized. (C) Required Shock Protection PPE. PPE for shock protection shall be required when: (1) a dc shock hazard could potentially exist; and (2) a type 2 or type 4 solidly grounded fault detection system is installed. (D) Optional Shock Protection PPE. For type 1 ungrounded systems and type 3 resistance grounded systems, shock protective PPE is recommended but shall only be required if: (1) there is no operational ground fault detection system; or (2) the ground fault detection system is indicating an inadvertent ground. (E) Equipment Test. The ground fault detector shall be tested prior to any battery work. Informational Note: Not all battery systems have dc ground-fault detection systems. For personnel safety reasons, it is important to understand the grounding methodology being used and to determine the appropriate manner of detecting ground faults. If an unintended ground develops within the system (e.g., dirt and acid touching the battery rack), it can create a short circuit that could cause a fire. Commonly used dc grounding systems include, but are not limited to, the following: (1) Type 1. An ungrounded dc system, in which neither pole of the battery is connected to ground. If an unintentional ground occurs at any place in the battery, an increased potential would exist, allowing fault current to flow between the opposite end of the battery and the ground. An ungrounded dc system is typically equipped with an alarm to indicate the presence of a ground fault. (2) Type 2. A solidly grounded dc system, in which either the most positive or most negative pole of the battery is connected directly to ground. If an unintentional ground occurs, it introduces a path through which fault current can flow. A ground detection system is not typically used on this type of grounded system. (3) Type 3. A resistance grounded dc system, which is a variation of a Type 1 system, in which the battery is connected to ground through a resistance. Detection of a change in the resistance typically enables activation of a ground-fault alarm. Introducing an unintentional ground at one point of the battery could be detected and alarmed. A second unintentional ground at a different point in the battery would create a path for short-circuit current to flow. (4) Type 4. A solidly grounded dc system, either at the center point or at another point to suit the load system. If an unintentional ground occurs on either polarity, it introduces a path through which short circuit current can flow. A ground detection system is not typically used on this type of grounded system. Statement of Problem and Substantiation for Public Comment

371 38 of 403 9/2/2016 9:49 AM : Public Input No. 516 sought to retain information about dc ground fault protection on battery systems that had been carried over from an earlier edition. It reflects existing best practices in the battery industry. The information needs to be in NFPA 70E because batteries can be grounded in several different ways. Failure to understand which grounding method is or is not - being used on any given battery can result in serious injury. This comment recommends moving the requirement from Chapter 3 to Chapter 2 for safety-related maintenance. The Informational Note should be retained to clarify the types of ground system. This comment should not be considered new material because it is responding directly to the committee comment on PI # 516, which declared that The Committee does not accept that the proposed revision provides an equivalent level of safety. We would argue that failure to include this information will result in a decreased level of safety. Related Item Public Input No. 516-NFPA 70E-2015 [Section No (C)(1)] Submitter Information Verification Submitter Full Name: Stephen McCluer Organization: Steve McCluer LLC Street Address: City: State: Zip: Submittal Date: Sat May 14 16:44:48 EDT 2016 Committee Statement Committee Action: Resolution: Rejected The proposed change applies to safe work practices. The scope of Chapter 2 safety-related maintenance requirements.

372 39 of 403 9/2/2016 9:49 AM Public Comment No. 150-NFPA 70E-2016 [ Article 330 ] Article 330 Safety-Related Work Practices for Use of Lasers Scope. This article applies to the use of lasers with user-accessible persons with access to hazardous voltage, current, or stored energy. Informational Note No. 1: For recommendations on laser safety requirements for laser use, see LIA ANSI Z Informational Note No. 2: For laser product requirements for laser manufacturers, see 21 CFR , Subchapter J, Radiological Health, Part 1040, Performance Standards for Light-Emitting Products, and Section Products Sections , Laser products ; and 21 CFR products, and , Specific purpose laser products Definitions. For the purposes of this article, the following definitions shall apply. Field Evaluated. A thorough evaluation of nonlisted or modified equipment in the field that is performed by persons or parties acceptable to the authority having jurisdiction. The Informational Note: Field evaluation approval ensures that the equipment meets appropriate codes and standards, or is similarly found suitable for a specified purpose. Hazardous Voltage and Current. 50 VAC and 5 ma AC, or 100 VDC and 40 ma DC. Hazardous Stored Capacitor Energy. Greater than 10 Joules. Hazardous Voltage. 50 Vac or 100 Vdc Joules and 400 Volts, or 1 Joule and 100 Volts and 400 Volts Laser. A device that produces radiant energy at wavelengths between 180 nm (nanometer) and 1 mm (millimeter) predominantly by controlled stimulated emission. Laser radiation can be highly coherent temporally, spatially, or both. Informational Note: Laser originated as is an acronym for light amplification by stimulated emission of radiation. Laser Controlled Area. An area where the occupancy and activity of those within is controlled and supervised and potential exposure to laser equipment hazard is possible. Laser Light Amplification by Stimulated Emission of Radiation. Laser Energy Source. Any device intended for use in conjunction with a laser to supply energy for the excitation of electrons, ions, or molecules. General energy sources, such as electrical supply services or batteries, is not considered to constitute a laser energy source.

373 40 of 403 9/2/2016 9:49 AM Laser Radiation. All electromagnetic radiation emitted by a laser or laser system between 180 nm (nanometers) and 1 mm (millimeters) that is produced as a result of a controlled stimulated emission. Laser System. A laser in combination with an appropriate laser energy source with or without additional incorporated components. Master Control Key. Removal disables all user-accessible hazardous voltage, current, and stored energy. Protective Barrier. Prevents user access to a hazardous voltage, current, or stored energy area. User-Accessible. All equipment components that are accessible to touch during operation, maintenance, or service by laser users Electrical Safety Training. (A) Personnel Persons to Be Trained. Employers shall provide training for all personnel who work persons working on or are near with lasers or laser systems with user-accessible if the person has access to hazardous voltage, current, or stored energy (e.g., flashlamp-pumped lasers). (B) Electrical Safety Training for Work on or with Lasers. Training in electrical safe work practices shall include, but is not limited to, the following: (1) Chapter 1 electrical safe work practices (2) Electrical hazards associated with laser equipment : (3) 2a. Voltage hazards (4) 2b. Current hazards (5) 2c. Stored energy hazards, such as capacitor banks (6) Circuit components, such as electron tubes with anode voltages greater than 5 kv (7) X-ray 2d. ionizing radiation hazards from high-voltage equipment (>5 kv) (8) 2e. Capacitor bank explosion potential (9) (3) Assessing the listing status of electrical equipment and the need for field evaluation of nonlisted equipment Safeguarding of Employees for Persons from Electrical Hazards associated with Lasers and Laser Systems. (A) Guarding. Guarding (doors, covers, protective barriers) shall be used to limit exposure to any electrical hazard, including when where laser enclosure covers can be are removed with the electrical circuits energized. (B) Work Requiring an Electrically Safe Work Condition. Work that might expose employees exposes a person to electrical hazards shall be performed with the equipment in an electrically safe work condition in accordance with 120.1, 120.2, and (C) Energized Electrical Testing. Energized In accordance with 130.2(B)(3), energized electrical testing, troubleshooting, and voltage testing shall not require an energized work permit in accordance with (B)(3). (D) Warning Signs and Labels. Electrical safety warning signs and labels shall be posted as applicable at the entrances to laser work areas and on protective barriers for laser equipment.

374 41 of 403 9/2/2016 9:49 AM (E) Master Control Key. Laser equipment with user-accessible hazardous voltage, current, or stored energy shall include a removable key-operated master control that disables all hazardous voltage, current, and stored energy, as applicable. (F on electrical equipment doors, covers and protective barriers. The warning signs and labels shall adequately warn of the hazard using effective words, colors, and symbols. These signs and labels shall be permanently affixed to the equipment and shall be of sufficient durability to withstand the environment involved. (E ) Listing. Laser system electrical equipment shall be listed or field evaluated prior to use Employee Responsibility for Electrical Safety. Employees All persons with access to hazardous voltage, current or stored energy shall be responsible for the following: (1) Obtaining authorization for work with or on hazardous electrical equipment in lasers and laser systems (2) Use of Chapter 1 electrically safe safety-related work practices (3) Reporting laser equipment failures and accidents, accidents, inadequate barriers and inadequate signage to the supervisor or employer Statement of Problem and Substantiation for Public Comment I am providing recommended edits that represent discussions by myself, Lloyd Gordon and Mark Ode in Summer Some aspects for these edits: - want to be applicable to all persons with access to electrical hazards, not just employees. Also want to restrict applicability to only persons who have access to these hazards and not to all persons who have access to potentially hazardous equipment - some definition updates + removing some definitions. Laser Controlled Area removed since not used in article. Master Key removed since recommending to remove Master Key requirement. - Master Key requirement removed. Not aware of other electrical equipment having a master key requirement. Related Item Public Input No. 67-NFPA 70E-2015 [Article 330] Public Input No. 68-NFPA 70E-2015 [Article 330] Submitter Information Verification Submitter Full Name: Michael Woods Organization: SLAC National Accelerator Laboratory Street Address: City: State: Zip: Submittal Date: Thu May 05 16:01:05 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-51-NFPA 70E-2016

375 42 of 403 9/2/2016 9:49 AM Statement: This revision modifies this Article to clarify application and improve usability. The revision to the Article title and scope are necessary to correlate with the revisions made in this SR. The committee understands that Article titles and scope statements are under the purview of the NEC Correlating Committee.

376 43 of 403 9/2/2016 9:49 AM Public Comment No. 51-NFPA 70E-2016 [ Section No ] See Statement for CC note Custom Built, Non-Listed Research Equipment, <1000 V AC or DC. (A) Equipment Marking and Documentation. (1) Marking. Marking of equipment shall be required for, but not limited to, equipment fabricated, designed, or developed for research testing and evaluation of electrical systems. Marking shall sufficiently list all voltages entering and leaving control cabinets, enclosures, and equipment. Caution, Warning, or Danger labels shall be affixed to the exterior describing specific hazards and safety concerns. Informational Note: Refer to ANSI Z535, Series of Standards for Safety Signs and Tags, for more information on precautionary marking of electrical systems or equipment. (2) Documentation. Sufficient documentation shall be provided and readily available to personnel that install, operate, and maintain equipment that describes operation, shutdown, safety concerns, and nonstandard installation anomalies. Schematics, drawings, and bill of materials describing power feeds, voltages, currents, and parts used for construction, maintenance, and operation of the equipment shall be provided. (3) Safety requirements and emergency shutdown procedures of equipment, to include Lock Out Tag Out (LOTO) requirements. If equipment-specific LOTO is required, then documentation outlining this procedure and PPE requirements shall be made readily available. (4) Specific hazards, other than electrical, associated with research equipment shall be documented and readily available. (5) Drawings, standard operational procedures, and equipment shall be approved by the ESA on site before initial start up. (6) Assembly of equipment shall comply with national standards where applicable unless research application requires exceptions. Equipment that does not meet the applicable standards shall be required to be approved by the ESA. Proper safety shutdown procedures and PPE requirements shall be considered in the absence of grounding and/or bonding. (B) Tools, Training, and Maintenance. (1) Documentation shall be provided if special tools, unusual PPE, or other equipment is necessary for proper maintenance and operation of equipment. (2) The ESA shall make the determination of appropriate training and qualifications required to perform specific tasks. Statement of Problem and Substantiation for Public Comment The Correlating Committee directs the Committee to review and add headers as required to comply with the NEC Style Manual.

377 44 of 403 9/2/2016 9:49 AM Related Item First Revision No. 89-NFPA 70E-2015 [Sections 350.4, 350.5] Submitter Information Verification Submitter Full Name: CC on NEC-AAC Organization: NFPA Street Address: City: State: Zip: Submittal Date: Mon Mar 14 16:32:14 EDT 2016 Committee Statement Committee Action: Rejected but see related SR Resolution: SR-52-NFPA 70E-2016 Statement: The section was editorially revised to comply with the NEC Style Manual.

378 45 of 403 9/2/2016 9:49 AM Public Comment No. 186-NFPA 70E-2016 [ Section No ] Establishing an Electrically Safe Work Condition. An electrically safe work condition shall be achieved when performed in accordance with the procedures of Article and verified by following the process identified in Exception: At the discretion of the ESA, alternative methods of ensuring worker safety may be employed for the following conditions: (1) Minor tool changes and adjustments, and other normal production operations that are routine, repetitive, or sequential and integral to the use of the equipment for production (2) Minor changes to the unit under test and other minor servicing activities, to include the activities listed under exception condition (1), that take place during research and development (3) Work on cord-and-plug-connected equipment for which exposure to the hazards of unexpected energization or start up is controlled by (4) Unplugging the equipment from the energy source and (5) The employee performing the work maintains exclusive control of the plug. Statement of Problem and Substantiation for Public Comment Article 120 was re-written during this cycle. The references to and are no longer applicable and are more appropriately referenced by referring to the entire Article 120. Related Item First Revision No. 30-NFPA 70E-2015 [Article 120] First Revision No. 89-NFPA 70E-2015 [Sections 350.4, 350.5] Submitter Information Verification Submitter Full Name: Louis Barrios Organization: Shell Global Solutions Affilliation: American Petroleum Institute Street Address: City: State: Zip: Submittal Date: Sun May 15 19:05:50 EDT 2016 Committee Statement Committee Rejected but see related SR Action: Resolution: SR-53-NFPA 70E-2016 Statement: This requirement is editorially revised to reflect revisions that have been made during this revision cycle in Article 120.

379 46 of 403 9/2/2016 9:49 AM Public Comment No. 24-NFPA 70E-2016 [ Section No. 90.2(A) ] (A) Covered. This standard addresses electrical safety-related work practices, safety-related maintenance requirements, and other administrative controls for employee workplaces that are necessary for the practical safeguarding of employees relative to the hazards associated with electrical energy during activities such as the installation, removal, inspection, operation, maintenance, and demolition of electric conductors, electric equipment, signaling and communications conductors and equipment, and raceways. This standard also includes safe work practices for employees performing other work activities that can expose them to electrical hazards as well as safe work practices for the following: (1) Installation of conductors and equipment that connect to the supply of electricity (2) Installations used by the electric utility, such as office buildings, warehouses, garages, machine shops, and recreational buildings that are not an integral part of a generating plant, substation, or control center Informational Note: This standard addresses safety of workers whose job responsibilities involve interaction with energized electrical equipment and systems with potential exposure to electrical hazards. Concepts in this standard are often adapted to other workers whose exposure to electrical hazards is unintentional or not recognized as part of their job responsibilities. The highest risk for injury from electrical hazards for other workers involve unintentional contact with overhead power lines and electric shock from machines, tools, and appliances. Statement of Problem and Substantiation for Public Comment Adding "removal" correlates to the scope of the 2017 edition of the NEC. Related Item First Revision No. 1-NFPA 70E-2015 [Section No. 90.2(A)] Submitter Information Verification Submitter Full Name: Palmer Hickman Organization: Electrical Training Alliance Street Address: City: State: Zip: Submittal Date: Fri Feb 26 10:01:52 EST 2016 Committee Statement Committee Accepted Action: Resolution: SR-1-NFPA 70E-2016 Statement: The word removal is added to the scope of NFPA 70E to correlate with the newly added word removal in 90.2(A) of the 2017 edition of NFPA 70, the National Electrical Code.

380 47 of 403 9/2/2016 9:49 AM Public Comment No. 192-NFPA 70E-2016 [ Section No. B.1.7 ]

381 48 of 403 9/2/2016 9:49 AM B.1.7 IEEE Publications. Institute of Electrical and Electronic Engineers, IEEE Operations Center, 445 Hoes Lane, P. O. Box 1331, Piscataway, NJ ANSI/IEEE C2, National Electrical Safety Code, ANSI/IEEE C , Standard for 4.76 kv to 38 kv-rated Ground and Test Devices Used in Enclosures, IEEE 4, Standard Techniques for High Voltage Testing,2013. IEEE 450, IEEE Recommended Practice for Maintenance, Testing, and Replacement of Vented Lead-Acid Batteries for Stationary Applications, IEEE 516, Guide for Maintenance Methods on Energized Power Lines, IEEE 937, Recommended Practice for Installation and Maintenance of Lead-Acid Batteries for Photovoltaic Systems, IEEE 946, IEEE Recommended Practice for the Design of DC Auxiliary Power Systems for Generating Systems, IEEE 1106, IEEE Recommended Practice for Installation, Maintenance, Testing, and Replacement of Vented Nickel-Cadmium Batteries for Stationary Applications, 2005 (R 2011). IEEE 1184, IEEE Guide for Batteries for Uninterruptible Power Supply Systems, IEEE 1187, Recommended Practice for Installation Design and Installation of Valve-Regulated Lead-Acid Storage Batteries for Stationary Applications, IEEE 1188, IEEE Recommended Practice for Maintenance, Testing, and Replacement of Valve-Regulated Lead-Acid (VRLA) Batteries for Stationary Applications, 2005 (R 2010). IEEE 1491, IEEE Guide for Selection and Use of Battery Monitoring Equipment in Stationary Applications, IEEE 1584 TM, Guide for Performing Arc Flash Hazard Calculations, IEEE 1584a TM, Guide for Performing Arc Flash Hazard Calculations, Amendment 1, IEEE 1584b TM, Guide for Performing Arc Flash Hazard Calculations Amendment 2: Changes to Clause 4, IEEE 1657, Recommended Practice for Personnel Qualifications for Installation and Maintenance of Stationary Batteries, IEEE , IEEE Recommended Practice for the Operation and Management of Industrial and Commercial Power Systems, IEEE , IEEE Recommended Practice for the Maintenance of Industrial and Commercial Power Systems, IEEE , IEEE Recommended Practice for Electrical Safety in Industrial and Commercial Power Systems, Anderson, W. E., Risk Analysis Methodology Applied to Industrial Machine Development, IEEE Transactions on Industrial Applications, Vol. 41, No. 1, January/February 2005, pp Ammerman, R. F., Gammon, T., Sen, P. K., and Nelson, J. P., DC-Arc Models and Incident-Energy Calculations, IEEE Transactions on Industrial Applications, Vol. 46, No. 5, Doan, D. R, Arc Flash Calculations for Exposures to DC Systems, IEEE Transactions on Industrial Applications, Vol 46, No. 6, Doughty, R. L., T. E. Neal, and H. L. Floyd II, Predicting Incident Energy to Better Manage the Electric Arc Hazard on 600 V Power Distribution Systems, Record of Conference Papers IEEE IAS 45 th Annual Petroleum and Chemical Industry Conference, September 28 30, Lee, R., The Other Electrical Hazard: Electrical Arc Flash Burns, IEEE Trans. Applications, Vol. 1A-18, No. 3, May/June Statement of Problem and Substantiation for Public Comment

382 49 of 403 9/2/2016 9:49 AM Committee response accepted. The IEEE Industrial Applications Society could do a better job getting their safety concepts driven to the NFPA 70-suite. Consider placing these references into Annex A. Related Item Public Input No. 180-NFPA 70E-2015 [Section No. B.1.7] Submitter Information Verification Submitter Full Name: Michael Anthony Organization: University of Michigan Street Address: City: State: Zip: Submittal Date: Mon May 16 09:15:57 EDT 2016 Committee Statement Committee Action: Resolution: Rejected The proposed references are not appropriate to be included in either Annex A or Annex B as they are not referenced within the 70E standard and are not relevant to electrical safety.

383 50 of 403 9/2/2016 9:49 AM Public Comment No. 119-NFPA 70E-2016 [ Section No. F.2 ] F.2 Relationship to Occupational Health and Safety Management System (OHSMS). As discussed in Annex P, the most effective application of the requirements of this standard can be achieved within the framework of an OHSMS. Using a management system provides a businesslike methodical approach to health and safety by means of goal setting, planning, and performance measurement. Risk management shares the six management system process elements of the following: (1) Leadership. If any venture is to succeed it needs to be sponsored at the highest levels of the organization. (2) Policy. The organization should articulate its vision and establish relevant, attainable goals. (3) Plan. A plan is developed in line with the organization s vision and to achieve its goals. The plan must include mechanisms to measure and monitor the success of the plan. (4) Do. The plan is executed. (5) Check (Monitor). The success of the plan in achieving the organization s goals is continuously monitored. (6) Act (Review). The measuring and monitoring results are compared to the organization s goals for the purposes of reviewing and revising goals and plans to improve performance. As noted in F.1, risk management is iterative. The repeating nature of the management system plan-docheck-act (PDCA) cycle is intended to promote continuous improvement in health and safety performance. Risk assessment fits into the plan and do stages of the PDCA cycle, as follows: (1) Planning: Information used during the planning stage comes from sources that can include workplace inspections, incident reports, and risk assessments. (2) Do: Risk assessment is an ongoing activity. Statement of Problem and Substantiation for Public Comment Editorial revision proposed for clarity. Related Item First Revision No. 64-NFPA 70E-2015 [Annex F] Submitter Information Verification Submitter Full Name: Daniel Roberts Organization: Schneider Electric Affilliation: CSA Z462 Technical Committee Street Address: City: State: Zip: Submittal Date: Mon Apr 25 15:33:37 EDT 2016 Committee Statement Committee Action: Accepted

384 51 of 403 9/2/2016 9:49 AM Resolution: SR-54-NFPA 70E-2016 Statement: The term methodical replaces the term businesslike for better clarity within Section F.2.

385 52 of 403 9/2/2016 9:49 AM Public Comment No. 29-NFPA 70E-2016 [ Section No. F.6 ] F.6 Risk Assessment Methods. There are many risk assessment methods. The method or combination of methods should be chosen based on the following: (1) The application (2) The desired result (3) The skill level of the persons performing the assessment Some risk assessment methods include the following: (1) Brainstorming. An open group discussion regarding hazards, the associated risk, and risk control methods can be used as part of pre-job planning and during a job briefing session. (2) Checklists. A list of common hazards and possible control methods is a useful tool for pre-job planning and for job briefing purposes. See Annex I for an example of a job briefing and planning checklist. (3) Risk assessment matrix. A risk assessment matrix is commonly used to quantify levels of risk. The matrix can be in a multilevel or a simple two-by-two format. See Figure F.6 for an example of a risk assessment matrix. Figure F.6 Example of a Qualitative Two-by-Two Risk Assessment Matrix. Informational Note: See ISO 31010, Risk management Risk assessment techniques, and ANSI/AIHA Z , Occupational Health and Safety Management Systems, for further information regarding risk assessment methods. Additional Proposed Changes File Name Description Approved FR_64.pdf Comment FR #64 Statement of Problem and Substantiation for Public Comment In figure F.6, change the word Improbable to Remote. Change the last word in the existing Improbable definition to unlikely. Change the last word in the Possible definition to likely. Document clarity