The Evolution of NFPA 70B: From Recommended Practice to Enforceable Standard

For 50 years, NFPA 70B, Standard for Electrical Equipment Maintenance, was a recommended practice. However, it existed with limited enforceability. While many people still found the document useful and incorporated it into their businesses, it really left the accountability side of electrical equipment maintenance, well, unmaintained. With the 2023 edition of NFPA 70B, the document became a standard, which added the aspect of enforceability. The discussion about it has really started to take off — especially around considerations for putting it into practice and who might enforce it.

Who enforces it?

Some think the Occupational Safety and Health Administration (OSHA) will enforce it through CFR 29-1926, Safety and Health Regulations for Construction or CFR29-1910, Occupational Safety and Health Standards under electrical safety. That certainly could become a possibility. As is well known in the United States, OSHA requires an employer to create a work environment that is free from known risks or hazards. So, OSHA would not directly enforce NFPA 70B but could enforce a requirement not being met because when electrical equipment hasn’t been maintained, it is not as safe as the equipment that has been. So, companies may put NFPA 70B into practice to comply with safety regulations. Others often think that facility managers or business owners will be the enforcers to keep production moving. Often, we get wrapped up in “how” we are going to implement a process when we should ask a bigger question: Why do we need to put NFPA 70B into practice? Figure that question out, and the “how to” will follow.

Why enforce NFPA 70B?

While there are likely a lot of unique reasons for each facility’s “why,” it makes sense to incorporate NFPA 70B. I think a common answer for all facilities is that from the moment electrical equipment is first energized, it begins a process of deterioration that could take months or years, depending on several factors.

Each facility should be aware that there is an opportunity to be proactive or reactive in electrical maintenance. The latter often proves to be a much more difficult route, as it often entails an unplanned loss of production and the possibility of extended lead times to obtain the proper parts for repair.

It needs to be understood that electrical equipment requires maintenance to work properly, because when it is not maintained, the equipment will decide when it wants to schedule the maintenance for you. Again, this often occurs at the most inconvenient time for the facility, resulting in a prolonged disruption of production and a significant loss of revenue.

Planned maintenance allows the facility to obtain necessary materials or equipment ahead of time and to schedule a shutdown to occur during a slower, or at least manageable, period of time. This results in shorter downtimes and helps keep production on track and aligned with customer commitment dates.

Also, equipment that is not maintained according to the manufacturer’s installation instructions and NFPA 70B may not be safe. This is why NFPA 70B is one of three key parts to the Electrical Cycle of Safety™ (ECoS™). The ECoS is a holistic approach to electrical safety that considers codes and standards for electrical installations (NFPA 70), electrical maintenance (NFPA 70B), and electrical safety (NFPA 70E). When used collectively, these codes complete the ECoS. Where just one is missing, it could result in preventable incidents that put people, property, and critical processes at risk.

Creating an electrical maintenance program (EMP)

To help prevent an unintended disruption in production, loss of revenue, or potential safety hazards from arising, facilities should create an electrical maintenance program (EMP). This is a key part of NFPA 70B that helps direct activity appropriate to the safety and operational risks, as well as taking into consideration the manufacturer’s installation instructions. In areas where the manufacturer’s instructions may lack guidance, such as maintenance intervals, NFPA 70B could step in and fill those gaps.

Some key components of an EMP are:

• Equipment inspection — An EMP must include elements that verify electrical equipment, or electrical systems, have been inspected and installed according to applicable codes. This is where NFPA 70, National Electrical Code (NEC), comes in because it covers the installation of electrical equipment, wiring, and inspections of the installations. It is difficult to maintain electrical equipment if it wasn’t properly installed and inspected initially, which is why the NEC is another key part of the ECoS.
• Condition of maintenance — An EMP shall include elements that consider the current condition of maintenance of the electrical equipment and systems, as well as safety and risks to maintenance and operation personnel. To properly maintain electrical equipment, you must also have an electrical safety program (ESP) that is derived from NFPA 70E, Standard for Electrical Safety in the Workplace. The ESP helps guide how to safely complete tasks when working on maintaining electrical equipment.
• EMP principles — An EMP must be designed to work in conjunction with an applicable ESP. This is where the third key part of the ECoS steps in: NFPA 70E. This standard requires you to create an ESP to help employees manage their risk while working on electrical equipment.
• EMP controls — An EMP must have controls by which it is measured and monitored. This helps to verify that the EMP is working as designed and highlights areas where it can be improved upon.
• Incident investigations — An EMP must include a method to use all associated reports for feedback and ways to further refine and improve the EMP.
• EMP audit — An EMP must be audited at intervals that do not exceed five years to ensure all components of the EMP still comply with the standard.

Who is the EMP coordinator?

The facility’s EMP must have a designated EMP coordinator, who may be the safety or facility manager, or anyone else that the facility deems as qualified, including a 3rd-party affiliate. The EMP coordinator must assign personnel to EMP duties who are qualified for those tasks. A qualified person is defined in NFPA 70B and 70E as “one who has demonstrated skills and knowledge related to the construction and operation of electrical equipment and installations and has received safety training to identify the hazards and reduce the associated risk.”

The qualified person requires training specific to maintenance tasks, testing methods, test equipment, personal protective equipment (PPE) usage as required, and any hazards associated with maintaining the equipment. The training may not just be classroom training, but on-the-job training as well.

On-the-job training allows the trainee to demonstrate to the qualified person in charge of their training that they possess the skills and knowledge to maintain the equipment in the facility where they will be working. Training should be specific to each building, facility, or piece of equipment — even if everything is owned by a big corporation.

For example, someone working in maintenance at a company that has milling machines would likely not be qualified to work on forge equipment. Also, additional training would be required if job duties changed or new equipment was brought on site. All training records provided for employees assigned to conduct maintenance tasks should be kept, since they may be needed in the event of an incident. For additional information on training and retraining, see NFPA 70B, Sec. 4.3.3.

Prioritizing a maintenance schedule & keeping records

The EMP coordinator is also in charge of determining the scope of work to be performed and creating a prioritized maintenance plan for the electrical equipment or system. Electrical equipment should be inspected to determine the appropriate scope and frequency of maintenance. Consideration should be given to the environmental, physical, or operating conditions of the specific installation when evaluating a maintenance schedule. A good example of equipment that may require more frequent cleaning and maintenance would be equipment located in a textile facility because the processes in the facility can lead to fiber build-up on equipment, which could increase the risk of a fire.

Maintenance records are important to have on file so that a facility can provide proof of maintenance being done on the equipment. This is important because the ESP for the facility must show a condition maintenance for electrical equipment according to NFPA 70E. Part of the ESP is a requirement to have an electrically safe work condition (ESWC) policy.

The conditions in which the ESWC is required are found in Sec. 110.2(B), which addresses when an ESWC is required and when it is not. An exception to the requirement of an ESWC is found in Exception No. 2, which explains that: “Normal operation of electric equipment shall be permitted where a normal operating condition exists.” Two of the items required to have normal operating conditions are:

• The equipment is properly installed (NEC).
• The equipment is properly maintained (NFPA 70B).

As you can see from the two bullet points, we can’t have normal operating conditions without the NEC and NFPA 70B being properly implemented; otherwise, workers would need to establish an ESWC just to turn off a breaker or a switch to perform maintenance on a piece of equipment. According to Table 130.5(C) in NFPA 70E, the operation of a circuit breaker, switch, or starter that is not in a normal condition has a likelihood of an arc flash incident. This is a big reason why facilities need NFPA 70B.

Conclusion

Implementing the principles and controls of NFPA 70B is only one part of the ECoS. A facility focused on a culture of safety has all three parts working holistically together. This is accomplished by having any new or relocated equipment installed and inspected according to the NEC, and any tasks being performed on the electrical equipment would be under the direction of an ESP derived from NFPA 70E.

Remember: Having an effective EMP is likely the equivalent of putting money in the bank by saving you repair time/lost revenue and increasing worker safety. Electrical equipment that is not being properly maintained is likely to require the maintenance time for you. Wouldn’t you rather be in control?

NFPA has numerous resources for facility employees who will be working with electrical equipment — from training to certifications. If one part of the ECoS is missing, it will have a negative impact on the safety of the employees and facilities.

Important Notice: Any opinion expressed in this article is the personal opinion of the author and does not necessarily represent the official position of NFPA or its Technical Committees. In addition, this piece is neither intended nor should it be relied upon to provide professional consultation or services.