WHAT DOES “WORKING ON” MEAN IN THE ELECTRICAL ENVIRONMENT AND WHEN DO YOU NEED TO WEAR ARC FLASH PPE?

Question: When do I need to wear arc flash PPE?

Answer: Anytime you are working on live electrical equipment.
Pretty simple, right?

Well, that was the shortest article I’ve ever written. I guess I can take the rest of the day off! Actually, it’s not quite that simple. As ESPN football analyst Lee Corso famously says, “Not so fast my friend!” Technically, my answer above is correct. You need arc flash PPE whenever you are working on live electrical equipment. However, that just leads to another, more important question. What does “working on” mean in the electrical environment?

NFPA 70E defines “Working On” as
“Intentionally coming in contact with energized electrical conductors or circuit parts with the hands, feet, or other body parts, with tools, probes, or with test equipment, regardless of the personal protective equipment (PPE) a person is wearing.”

Does it then follow that if the doors are closed and the panel covers are on, arc flash PPE is not required?
Not necessarily. Before you make that assumption, you need to make sure that the equipment is under normal operating conditions. Normal operating conditions means the following:

• The equipment is properly installed.
• The equipment is properly maintained.
• The equipment is used in accordance with manufacturer’s recommendations.
• The equipment doors are closed and secured.
• The equipment covers are in place.
• No evidence exists of impending failure.

Equipment covers are only one part of the requirements. If the worker has any reason to believe the equipment is not properly installed, maintained, or showing signs of failure, the worker must wear PPE. In reality, the worker shouldn’t engage in electrical work on this type of equipment with or without PPE. It should be de-energized, taken out of service, and repaired.

Are any of these panels safe to work on without flash PPE?
Are they safe to work on with arc flash PPE?

“Working on” can fall into two categories: diagnostic and repair.
Diagnostic means troubleshooting or testing that does not involve physical alteration of the equipment. Repair involves physically altering the electrical equipment such as tightening connections, removing or replacing breakers, or any other type of modification. Both diagnostic and repair work require PPE and are considered live electrical work when the circuit is energized.
To answer the question in the title of this article, arc flash PPE is required whenever the worker is “working on” live electrical equipment and is within the arc flash boundary.

Please reach out to me with any questions or comments on this article or any of the other educational resources we have at www.mitchellandlindsey.com/resources

Thank you for your time. Be safe, and please reach out to me with any questions you may have.

Bobby Lindsey – CESCP
Mitchell & Lindsey – President
M: (502) 836-4217
email: blindsey@mitchellandlindsey.com