Attendee Announcements - ISE EXPO€¦ · Ernie Gallo [email protected] 732-754-3474 2018 -...

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Service Deployment Requires Understanding of Enforced

Codes –NEC NESC and 70E

Ernie Gallo

[email protected]

732-754-3474

2018 - Network Infrastructure Solutions (NIS)

mailto:[email protected]

› Understanding enforced codes such as the NEC and NESC are critical

to keep network deployment schedules on track. Lack of understanding

of these codes can cause significant delays or grind a deployment to a

halt. This seminar will discuss the latest updates and changes so

participants will better understand their application in their deployments

› The National Electrical Code and National Electrical Safety Code

standards are adopted by municipalities and states and have the force

of law behind them. So all service providers, contractors and installers

must comply with them. It is important that people understand the

newest versions and how to apply them.

› Wireline versus WIreless

Why is Understanding codes important

› NEC - Adopted by municipalities, legislative bodies, utility commissions and other Authorities Having Jurisdiction (AHJ)

› Unlike voluntary standards, NEC® carries the force of law

› Used by inspectors to approve electrical and communications installations

› Impacts daily activities of communications utilities in providing services as well as manufacturers providing communications products.

› NESC - Adopted by most States and municipalities through legislative and/or regulatory (PUC) process after a review

› Automatic use of latest edition or adoption of specific date

› Some do piecemeal adoption – Part 4 (Work Rules)

› Some States have separate independent codes – e.g., GO95 (California).

› Contractual basis of Joint-Use and Pole Agreements & Inter-Company Contracts.

Purpose

› NFPA 70, National Electrical Code, or the NEC as it is

more commonly known, is the most widely used technical

document in the world. Since it was first published in 1897,

it has been helping to protect both people and property

from hazards associated with electrical energy by providing

safe installation practices for electrical equipment and

systems. The NEC is revised every 3 years

NFPA 70, National Electrical Code

› NESC - National Electric Safety Code- Produced

exclusively by IEEE, the NESC specifies best practices for

the safety of electric supply and communication utility

systems at both public and private utilities. The NESC sets

the ground rules for practical safeguarding of persons

during the installation, operation, or maintenance of power,

telephone, cable TV, and railroad signal systems. The

NESC is revised every 5 years to keep the code up to date

and viable.

NESC - National Electric Safety Code

▪NFPA 70E addresses employee workplace electrical safety

requirements. The standard focuses on practical

safeguards that also allow workers to be productive within

their job functions. While the various OSHA, ASTM, IEEE

and other standard provide guidelines for performance,

NFPA 70E addresses practices and is widely considered

as the de-facto standard for Electrical Safety in the

Workplace. NFPA 70E is revised every 3 years. Electrical

Shocks, Arc Flash and Harmonizes with OSHA 1910 Part-

S & OSHA 1926 Part-K

NFPA 70E Electrical safety in the workplace

Communications Equipment clarified…..› NEC Definition of Communications Equipment

The electronic equipment that performs the telecommunications operations for the

transmission of audio, video, and data, and includes power equipment (e.g., dc converters,

inverters, and batteries), technical support equipment (e.g., computers), and conductors

dedicated solely to the operation of the equipment.

Informational Note: As the telecommunications network transitions to a more data-

centric network, computers, routers, servers are becoming essential to the

transmission of audio, video, and data and are finding increasing applications in

communications equipment installations

▪ NESC Definition of Communications Equipment.

Communication Equipment. Equipment that produces, modifies, regulates, or controls

communication signals. This equipment may also produce, modify or safeguard a supply of

electric energy for the exclusive use of communication devices as long as the equipment

and communications devices being served are owned and operated by the same party .

See electric supply equipment.

Note to NESC Definition of Electric Supply Equipment.

…..NOTE: Electric supply equipment does not include equipment whose purpose is to

provide power to support locally mounted communication systems. For example,

power supplies supporting CATV or communication amplifiers or repeaters are not

considered to be supply equipment.

Definitions

Purposes/ScopesNEC

Purpose = The practical safeguarding

of persons and property from hazards

arising from the use of electricity

› NFPA = Fire and Shock Protection

Scope – covers installation of electrical

and communications (electrical and fiber

optic) conductors, equipment and

raceways, for

› Public & private premises (homes,

residences, buildings, similar

properties) … inside

› Load side of the demarcation point

› Out of Scope (Exemption) = Exclusive

control of Utility (Communications,

Power….)

Not a Design Manual (*)

NESC

Purpose = The practical safeguarding of

persons, utility facilities, and affected property

during the installation, operation, and maintenance

of electric supply and communication facilities.

▪ IEEE = Electrical Safety of Public and Workers

Scope - covers supply and communication

facilities and associated work practices employed

by a electric supply, communications, or railway in

the exercise of its functions as a utility.

▪ Facilities = lines, equipment, and specified

infrastructure (e.g., poles, distribution plant

sub-stations, vaults…)

▪ The NESC covers similar systems under the

exclusive control of the utility and being worked

by qualified persons, such as those associated

with an industrial complex or utility interactive

system.

Not a Design Guide or Instruction

Manual (*)

Example Areas of Coverage

NEC = NFPA 70

› CMP 1 – Purpose and Scope (Arts.

90, 100 and 110),

› CMP 5 – Grounding (Arts. 200,

250, 280 and 285),

› CMP 16 – Communications

Systems (Arts. 770, 800, 810, 820,

830 and 840),

› NEC CC - Oversight responsibility

for the entire Code-making

process, i.e., ensuring due process

and correlating the actions

› Monitor other Panel/Actions –

Panel 12 (Article 645)

› Related work on other NFPA

Standards 70E, 72, 75 and 76

NESC = IEEE C2(not on substations SC 3)

▪ SC1 – Purpose, Scope definitions

▪ SC 2 – Grounding (Rules 09….)

▪ SC 4 – Aerial Clearances (Rules 20-23)

▪ SC 5 – Strength/Loading (Rules 24-26)

▪ SC 7 – Underground/Buried (Rules 30-34)

▪ SC 8 – Work Rules (Part 4 - Rules 40-44)

▪ Main and Executive Committees

▪ C2 Standards Committee - Oversight

responsibility for the entire Code-making

process, i.e., ensuring due process and

correlating the actions

ANSI review Interpretation Requests

▪ IEEE – NESC

▪NFPA – NEC. 70E

▪GO-95….GO128….GO165

▪ OSHA 1910.268/269

▪ Internal M&Ps

▪ GRs and UL Listings

▪ Joint Use Agreements (JUA)

▪ GRs/SRs

▪ UL

▪ ATIS

▪ etc……

Codes in Context

https://www.nfpa.org/index.asp

http://www.ieee.org/index.html?WT.mc_id=hpf_logo

http://www.cpuc.ca.gov/

https://www.google.com/url?sa=i&rct=j&q=&esrc=s&frm=1&source=images&cd=&cad=rja&uact=8&ved=0CAcQjRw&url=https://www.codale.com/index.jsp?path%3Dproduct%26part%3D458586%26ds%3Ddept%26process%3Dsearch%26qdx%3D0%26ID%3D,Tools,Electrical.Tools,Reference.Guides...Books&ei=mEoMVZLeIcy7ggTOsISgCQ&bvm=bv.88528373,d.eXY&psig=AFQjCNHHqZNAffl1jBKrOD8v_roy8n2ifw&ust=1426955280054506

Revision ProcessNEC = NFPA 70

› 3-year revision schedule

› National Fire Protection

Association

› Code-Making Panels (CMPs)

› Correlating Committee (CC),

NFPA Standards Council

› Public Inputs (PIs) = change

proposals

› Public Comments (PCs) on

CMP actions

› Applies on adoption by PUC,

State legislative or local AHJ

bodies – varies

NESC = IEEE C2

▪ 5-year revision schedule

▪ IEEE - Institute Electrical & Electronics

Engineers

▪ Technical Subcommittee (SCs)

▪ Correlation and Coordination – SC1,

Main & Exec Committees and

Standards Committee

▪ Public change proposals (CPs)

▪ Public comments (CMs) on SC actions

on CPs

▪ Applies on adoption by PUC, State

legislative or local AHJ bodies - varies

NEC Adoption - June 2017

NESC Adoption

> 85% use in some form

> 70% use current or near current version

Automatically

adopts latest

NESC

Adopts

current

NESC after

review

Currently use

old Edition or

part of NESC

Uses NESC

to develop

internal

code

Does not

use

NESC

Status

Unclear

Demarcation Points

Central OfficesData Centers

Power Generation

Power SubstationsPoles and Manholes

Huts and CEVS

Cabinets/Handholes

Distributed Power

Generation

(Wind, solar…)

Power Supply

Grid

Public

Telecom

Network

(PTSN)

Customer = House, Apartment Block, Commercial/Industry …..

NID/NIU/ONT/Gateway Telecom Closet

Roof Top PV

WeatherheadService Panel

Code Demarcation

› Code Arrangement (cont’d.)

› Section 90.2(B)(4) - facilities under exclusive communications utility

control are not covered (i.e., out of scope of NEC)

The ‘exemption’ precludes electrical inspection being required for

central office, telephone closets, and similar facilities; the safety &

reliability of which has been fully covered by industry best practices

and internal specifications (e.g., GRs) for many decades.

› Section 90.3 - Chapter 8, Communications Systems, is not subject to

the requirements of Chapters 1–7 unless explicitly referenced (e.g.,

800.3 points to 770) precludes application of inappropriate electrical

power requirements to the low voltages communications facilities.

› If a member of the public can walk up and touch equipment, the AHJ

may not consider as under the exclusive control of the utility. NRTL

Listing may be required

NEC structure

https://www.google.com/url?sa=i&rct=j&q=&esrc=s&frm=1&source=images&cd=&cad=rja&uact=8&ved=0CAcQjRw&url=https://play.google.com/store/apps/details?id%3Dcom.lftechnology.flashcard&ei=FksMVf32H4jlgwS3rIOIAw&bvm=bv.88528373,d.eXY&psig=AFQjCNHHqZNAffl1jBKrOD8v_roy8n2ifw&ust=1426955280054506

› Introduction and nine chapters

– Article 90, Introduction

› Purpose, Scope and Code Arrangement

- Section 90.2(B)(4) and 90.2(B)5), ‘Exemption’

- Section 90.3, ‘Independence’ of Chapter 8

– Chapters 1 through 4 apply generally

› Electrical installations, wiring and protection, grounding

- Article 100 – Definitions,

- Article 110 – General Installations (Arc Flash Warning– 110.16)

- Article 250, Grounding and Bonding (250.94 Intersystem Bonding)

– Chapters 5 through 7 apply to special occupancies, equipment

› Elevators, IT equipment, fire alarm systems, data centers

› Article 645 - Information Technology Equipment (645.10(B) –EPO)

› Article 690 & 691 - PV systems… 692 Fuel cells … 694 - Wind..

› Article 725 - Class 1-3, Remote, Signaling and Power-limited Circuits

› Article 770 (Fiber Optic)

NEC structure

› Code Arrangement (cont’d.)

› Chapter 8, Communications Systems

- Article 800, Communications Circuits (General)

- Article 810, Radio and Television Equipment

- Article 820, CATV and Radio Distribution Systems

- Article 830, Network-Powered Broadband Communications

Systems

- Article 840, Premises-Powered Broadband Communications

Systems (Broadened for 2017 code release)

- Independent of Chapters 1 -7, except where requirements are

specifically referenced within Chapter 8 ……. Article 770 →

reference as a whole in Section 800.3

- Parallelism and cross references between Sections/Articles

› Chapter 9 consists of tables that are applicable as referenced

- Conduit fill, conductor properties, power source limitations

NEC structure

› The NEC recognizes that certain battery units may be

considered to be rated at nominal 48 volts dc, but may

have a charging float voltage up to 58 volts. In dc

applications, 60 volts is used to cover the entire range of

float voltages. This is also being proposed for NFPA 70E

Nominal voltage

NESC Purpose & Scope

Purpose = The practical safeguarding of persons, utility facilities, and affected property

during the installation, operation, and maintenance of electric supply and

communications facilities.

Scope - covers supply and communication facilities and associated work practices

employed by a electric supply, communications, or railway in the exercise of its functions

as a utility.

▪ Facilities = lines, equipment, and specified infrastructure (e.g., poles, vaults…)

▪ The NESC covers similar systems under the exclusive control of the utility and being

worked by qualified persons, such as those associated with an industrial complex or

utility interactive system.

“NESC is Not a Design Guide or Instruction Manual “

21

However, the code is used as defacto minimum baseline to build off for design/engineering

calculations. Extra safety factors and clearances are added to provide the highly reliable and

resilient networks desired. A network designed to just or only meet minimum safety, clearance and

strength rules is not wise planning or design for service reliability or network facility resiliency.

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Applicable and Relevant NESC and NEC Rules for Communications Cables that Contain Powering Circuits For Communications Equipment

22

Code and Cable Distinctions

› If the power circuits are exclusively for providing power to communications equipment,

then

– They are defined as “communications lines” for purposes of NESC

– Defined as “communications equipment” for purposes of NEC and therefore fall

primarily under Chapter 8 unless other chapters/sections are specially referenced

from Chapter 8.

› Outside Plant Cables = located on supply side of service point and/or on network side

of demarcation point are covered under NESC. Such OSP cables are typically under

the exclusive control of communications utility, therefore they are outside of scope of

NEC as per NEC 90.2(B)(4).

› Premises Cables = located on load side or on the premises side of the demarcation

point are covered under NEC Chapter 8.

› Service Drop Cables = may be covered by both NESC and NEC depending on the

approach and knowledge of AHJ inspectors – these two codes are basically in harmony

at present.

NESC Applicable Rules

› The cables are treated as “communications lines” for general purposes of

meeting applicable NESC clearance/separation, grounding, protection,

and other relevant NESC rules.

› Some specific NESC rules that apply to these cables carrying powering

circuits exclusively used for communications equipment are –

– Rule 224B - aerial cables

– Rule 344 – buried/underground cables

Resiliency

Safety Versus Reliability versus “Resiliency” › Safety codes – Defacto Minimum Criteria

› Plus Business and Design/Engineering factors & choices for the

desired

– Functional Performance Objectives

– Quality & Reliable level of Networks

– Resiliency Level for Services

– Criticality of Services

› – E911, hospitals, smart grid,

military, police…..

NESC Storm Loading

Requirements

1) Distributed Generation Power (DGP) – Solar (PV), Energy Storage

(Batteries), etc…

▪ Work Rules- In and around power generation and storage sites

▪ Communications companies need to serve these sites – monitor, alarm,

control

2) 5G – Wireless facilities and associated Joint Use Issues

▪ Congestion - Management of multiple users

▪ Working Space….Clearances….Wireless antennas … FTTX Build-Outs

3) Powering the Internet of Things (IoT) /Wired Ethernet

▪ NESC/NEC – Demarcation & Conflicts

4) Pole Loading Calculations

▪ 60ft exemption… k factor….wind/ice loadings

5) Code process - Need to make NESC more flexible and responsive – FAST-

TRAC

2018 Active Areas of Discussions

26

› Rule 420G – Liquid cell Batteries – (Section Distributed Generation Power 14)

– Keeping up with new battery technologies → Liquid ?

– Lead-Acid, Lead-Calcium VRLA type systems Lead-Selenium

– Ni-Cd (Nickel-Cadmium) … Ni-MH = Nickel Metal Hydride

– Na-Ni-Cl = Sodium Metal Hydride, sodium-sulfur

– Zn-Br, Zn-air, Li-ion – lithium ion technologies – variety of chemistries

› Related Issues for Part 1 (Substations) & Part 4 (Work Rules)

– Distributed power and alternate energy sources

– Solar and Wind Farms, Microgrids, fuel cells, etc…

Distributed Generation Power – Energy Storage Batteries

Growing

varieties

Larger

Facilities 27

A. Congestion

B.Management of Multiple

Users – Joint Use

C.Clearances - from Power,

Guys, other Communications

Lines and Equipment

D.Working and Access Space

E.Wireless Antennas - RF

Levels

5G – Wireless Facilities & FTTx

28

CONGESTION

Space Definitions

Safety

through

Separation

Safety for

workers

(both)

Ground

clearance

Safety for

Public

29

› Space Definitions (previous discussions)

› Clearances between communications lines Rule 235H

– 12 inch minimum separation at support

– 4 inch minimum anywhere in span (spacers?)

– Under all ambient conditions (all expected conditions)

– Wording of final rule may need revision during next cycle period

› Wireless (Antenna) Attachment – Rule 235I clarified

– All other clearances need to be met as facilities are attached to congested

poles with multiple communications and power facilities

– Engineering designs and configurations → Blue Book + other design and

engineering guidance documents.

› Clearance between communications and supply facilities – Rule 238

– Encourages grounding of supply equipment by having larger (40 inch)

separation for ungrounded supply equipment

NESC Aerial Plant

30

Clearance & Separation

31

Guys Insulators

▪ Rule 215 - Guys and Guy insulators

Effectively grounded……..Connections through hardware

Objective is that if guys are slack or broken, the guys do not create hazard

to public…….Reference height is 8+ ft

Protect both Public on ground and workers in aerial plant

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http://www.google.com/url?sa=i&rct=j&q=&esrc=s&frm=1&source=images&cd=&cad=rja&uact=8&ved=0CAcQjRw&url=http://en.wikipedia.org/wiki/Trams_in_Melbourne&ei=K1AMVZ2KNYingwTp24GICA&psig=AFQjCNFgRBLOQIkJyIitVMjZiund_YscrA&ust=1426956694357605

A. NESC Rule 224B for aerial plant

B. NESC Rule 344 for underground/buried plant

C. Section 2 – Definition of “Communication Lines” – provides considerable flexibility

a. located in the communication space. The conductors and their supporting or containing

structures, equipment, and apparatus that are used for public or private signal or

communications service, and which operate at potentials not exceeding 400 V to ground or

750 V between any two points of the circuit, and the transmitted power of which does not

exceed 150 W. When operating at not more than 90 V ac or 150 V dc, no limit is placed on the

transmitted power of the system. Under specified conditions, communication cables may

include communication circuits exceeding the preceding limitation where such circuits are

also used to supply power solely to communications equipment. Fiber-optic cables are

considered as communication lines, regardless of whether they are installed in the

communication space or supply space in accordance with applicable rules,

b. located in the supply space. Communication lines located in the supply space and meeting

Rule 224A may (a) operate at any voltage, (b) include supply circuits of any voltage, or (c) be

included within a supply conductor or cable operating at any voltage.

Powering the Internet

33

Within the context of the NESC, Telecommunications Circuits are inherently safe based on the

voltage/current limitations and descriptions found in GR-1089 and ATIS 0600315 industry.

Powering Circuits for Communications

Modern communications cables can include power supply circuits for Power-over-

Ethernet (PoE), span/line powering applications and to provide for other

communications devices (e.g., antenna). Requiring each conductor of a supply circuit

used exclusively to power communications devices to be “individually enclosed with

an effective shield” is not necessary. Having additional shields around each individual

conductor does not add significantly to the safety of the circuit or cable configuration.

› 2017 changes to Rule 224B2(a) – Aerial cables

› 2017 changes to Rule 344A1– Underground/Buried Cables

34

Powering Circuits for Communications

This is an older hybrid cable design that is a power

cable which had 480 V power on the 1/0 AWG

conductors as well as some communications

conductors in the center portion.

The safety concerns on the use of this type of

hybrid power cable was the reason that this 224B

and 344 rule was first created.

This hybrid construction does require the individual

shield/ground for each 1/0 AWG conductor for

safety reasons.

The objective for the NESC change was to

permit the safe shielding variation shown below for span

powering or line powering applications over small gauge

twisted-pair (19-24 AWG) conductors. These are much

lower voltage and power level circuits then the 480 V power

cable shown to the left.

The configuration to the

right has individual

shields and complies

with 2012 NESC.

35

NESC Rule 097 has 7 interlocking subsections with implicit/explicit links to

other Rules (e.g., 096, 224, 344, 354, 384) applicable to intersystem bonds

(between grounding circuits of power and communications)

› Rule 097A -- separate grounding conductors

› Rule 097B – permits a bond to the power ground where a MGN system is

being used and providing Rule 097C (i.e., 4 grounds/mile) is met.

› Rule 097C - 4 grounds/mile criteria helps define an effective ground

› Rule 097G requires a single grounding conductor on structures except as

required by Rule 097A

Intersystem Bonding & Grounding

36

• Sets expectation that bond to vertical ground should be made

unless explicit technical or safety reason exists not to bond

• Clarifies the relationship between 097G and other subsections of

Rule 097 by placing the criteria in explicit Exceptions.

NESC Sections 24, 25 and 26

1)Pole Strength

2)Loading and Safety Factors

• 60 Foot Pole Exemption

• k Factor

• Appropriate & “Realistic” Wind/Ice

Loadings

• Non-linear Factors

Pole Loading Calculations

37

› Construction Grades – Reorganized & Clarified (Table 242-1) in 2017 code

– More clearly define where and when each Grade is applicable

– Grade N used for temporary emergency work, private rights of way and drops

– Grade B = highest grades – for joint use & railroad crossings

– Grade C = most often for communications poles

› Open Issues with active discussions for Next Cycle

– “K additive constant” - Retained for present but …..

– Appropriate & “realistic” Wind/Ice Loadings… ASCE

– 60 foot exemption – Retained in 2017…but

– Non-Linear Design Factors – still in wings for future introduction

› Communications Consequences - May become more of an issue for communications companies as design/engineering negotiations with other joint users and pole owners for placement locations for 5G wireless and FTTX build outs in congested aerial spaces

Pole Loading Construction Grades

38

• Distributed Generation Facilities → Scope, Part 1 (Substations), Part 4 (Work Rules)

• Utility scale PV, wind and other facilities

• Work rules in facilities

• Battery and energy storage

• Wired Ethernet Evolution and Powering the Internet of Things (IoT)- Parts 2& 3

• Consequences (if any) of clearance, separation and work rules for actual and proposed powering options for communications networks including span powering and pulsed (interrupted) DC

• Evolution to 5G – Part 2 – Mostly Sections 20-23

• Wireless facilities – necessary clearances for pole and strand mount options

• A National Approach to Joint Use – Code Process, Adoption & Regulatory Actions

• Pole Strength & Loadings - Scope and Section 24 through 27

• Resiliency -- Reliability -- Storm Performance

Most Active Discussion Areas

39

The National Fire Protection Association Code (NFPA) Standard

70E, titled Standard for Electrical Safety in the Workplace, is the

consensus standard recognized by OSHA. This standard is a

compilation of technical provisions designed to protect employees

from exposure to electrical hazards, such as arc flash and shock

hazards. Telecommunication facilities are considered a workplace.

Ericsson

NFPA 70 E

It is important to note that NFPA 70E, is a series of guidelines

rather than laws. The Occupational Health and Safety

Administration (OSHA), on the other hand, is a regulatory body.

OSHA’s regulations for worker health and safety are written in Title

29 of the Code of Federal Regulations (29 CFR). OSHA does not

enforce NFPA 70E, and NFPA 70E is not incorporated in 29 CFR,

yet employers can be cited for not following the standard. It is

important to note that as with the NEC, NFPA 70E would also

come under the NEC Exception of Article 90 that it would not

apply in areas under the exclusive control of the utility. However,

OSHA would have enforcement authority.

Typical telecom workers should not be working on electrical

panels, but should understand what to do when work is being

conducted on electrical panels and in power station locations.

Ericsson

Why It’s Important

OSHA 29 CFR 1910.5(a) States

Except as provided in paragraph (b) of this section, the standards

contained in this part shall apply with respect to employments

performed in a workplace in a State, the District of Columbia, the

Commonwealth of Puerto Rico, the Virgin Islands, American

Samoa, Guam, Trust Territory of the Pacific Islands, Wake Island,

Outer Continental Shelf lands defined in the Outer Continental

Shelf Lands Act, Johnston Island, and the Canal Zone.

Ericsson


OSHA 29 CFR 1910.5(b)

None of the standards in this part shall apply to working conditions

of employees with respect to which Federal agencies other than

the Department of Labor, or State agencies acting under section

274 of the Atomic Energy Act of 1954, as amended (42 U.S.C.

2021), exercise statutory authority to prescribe or enforce

standards or regulations affecting occupational safety or health.

Ericsson


The NEC primarily deals with the design and construction of

electrical installations. However, OSHA’s responsibilities include

the employers and employees in the workplace, and the NEC

does not address the requirements for electrical safety-related

work practices associated with the operation and maintenance of

electrical systems.

Realizing this disconnect, the National Fire Protection Association

(NFPA) offered its assistance in preparing a document “to assist

OSHA in preparing electrical safety standards that would serve

OSHA’s needs and that could be expeditiously promulgated

through the provisions of Section 6(b) of the Occupational Safety

and Health Act.” The resulting Standard for Electrical Safety

Requirements for Employee Workplaces, NFPA 70E, was first

issued in 1979 with the specific purpose of being a companion

document to the NEC.

EricssonDoes OSHA Require compliance to NFPA 70E?

Section 5(a)(1) of the Occupational Health and Safety Act states

that employers "shall furnish to each of his employees

employment and a place of employment which are free from

recognized hazards that are causing or are likely to cause death

or serious physical harm to his employees". The key phrase there

is “recognized hazards”; NFPA 70E, as an industry consensus

standard that addresses shock and arc-flash hazard, can be used

as evidence that a hazard is “recognized”. There is effort to revise

“recognized” to “identified” but the end requirements would be the

same.

EricssonSo employers could be cited for not following 70E based on the following

NFPA 70E Standard for Electrical Safety in the Workplace is related to

the National Electrical Code (NFPA 70) as follows:

The National Electrical Code (NEC) describes how to design and install

electrical systems but not how to actually perform the work.

Section 110.16 in the NEC is intended to warn qualified persons of the

hazard of arc flash and is a major step toward increasing the awareness

of this potential for injury and death. Additionally, the fine print note (FPN)

to Section 110.16 references NFPA 70E and is a crucial link between the

NEC and NFPA 70E.

NFPA 70E describes safe work practices for electrical construction and

maintenance but not how to design or install electrical systems.

The two documents (NEC and NFPA 70E) have identical scopes and

many of the same definition. They both cover “inside” wiring in buildings

and similar structures. Neither of them covers utility (line) construction

which would be covered by the National Electric Safety Code (NESC).

Ericsson

70 E - What’s Covered

NFPA 70E Covers Electrical Hazards Only

NFPA 70E describes how to protect workers from three kinds of

electrical hazards:

• Electric shock and electrocution

• Arc-flash (electrical fireball)

• Arc-blast (electrical explosion at high energy levels)

The NFPA 70E standard covers electrical hazards and doesn’t

cover other construction hazards such as fall protection, safe use

of ladders and scaffolds, hazardous substances, and respirators.

These other subjects are covered by OSHA construction safety

regulations.

OSHA = “Shall” & NFPA 70E = “How”

Ericsson

What’s Covered

70E requires that, when working on or near exposed energized circuits,

safety-related work practices shall be used to safeguard employees from injury

while they are working on or near exposed electric conductors or circuit parts

that are or can become energized.

The specific safety-related work practice shall be consistent with the nature

and extent of the associated electric hazards. These work practices shall

include wearing protective clothing and other personal protective equipment

(PPE) when working with the flash protection boundary.

An arc-flash hazard analysis shall be done in order to protect personnel from

the possibility of being injured by an arc flash. The flash hazard analysis shall

determine the Flash Protection Boundary and the personal protective

equipment that people within the Flash Protection Boundary shall use.

[In the NESC, the equivalent rule is the hazard risk assessment of NESC Rule

410A3]

70E Coverage48

OSHA can also use NFPA 70E as a reference in general duty

clause citations, in determining if there was a feasible method of

correcting a hazard. OSHA 29 CFR 1910 Subpart S Appendix A -

Reference Documents specifically states that NFPA 70E is a

national consensus standard, and can be helpful in understanding

and complying with the requirements of Subpart S – Electrical.

OSHA’s 29 CFR contains many requirements for electrical safe

work practices that parallel NFPA standards, but without specific

directives on how to apply the requirements. “Relevant industry

standards such as NFPA 70E are considered "how-to" guides for

complying with the more general OSHA rules.

Ericsson

So employers could be cited for not following 70E based on the following

OSHA 1910.303 requires employers to mark electrical equipment

with descriptive markings, including the equipment's voltage,

current, wattage, or other ratings as necessary. Employers are

also required to use techniques such as safety signs and tags,

barricades, and attendants to warn and protect employees from

hazards that could cause injury due to electric shock, burns or

failure of electric equipment parts.

Ericsson


OSHA's regulations do not include a specific requirement for the

use of fire resistant clothing, but paragraph (a)(2)(ii) of §1910.335

requires the use of protective shields, barriers, or insulating

equipment "to protect each employee from shocks, burns, or other

electrically related injuries while that employee is working . . .

where dangerous electric heating or arcing might occur", and that

the “shield, barrier, or insulating material — must fully protect

employees from electric shock, the blast, and arc- flash burn

hazards associated with the incident energy exposure for the

specific task to be performed.”

Ericsson


In both these areas, NFPA 70E is the industry consensus standard

that gives more specific guidance on compliance.

Another Industry standard, ANSI/IEEE C2 – National Electric

Safety Code (NESC), further amplifies these requirements. The

NESC requires and/or recommends that facilities provide:

• A safety program with defined responsibilities.

• Electrical hazards analyses.

• Personal protective equipment (PPE) for workers.

• Training for workers.

• Tools for safe work.

Ericsson


The NESC also requires that the employer shall ensure that an

assessment is performed to determine potential exposure to an

electric arc for employees who work on or near energized parts or

equipment. If the assessment determines a potential employee

exposure greater than 2cal/cm2 exists the employer shall require

employees to wear clothing or a clothing system that has an

effective arc rating not less than the anticipated level of arc

energy.

Ericsson


It is evident that OSHA is using NFPA 70E as an industrial

consensus standard. Further, OSHA expects employers and

employees to comply with the provisions of NFPA 70E regardless

of whether or not it has been “adopted” as an OSHA requirement.

In summary, following NFPA 70E can be key to ensuring

compliance with OSHA regulations and industry standards on

electrical safety. Again, it is important to note that as with the

NEC, NFPA 70E would also come under the NEC Exception of

Article 90 that it would not apply in areas under the exclusive

control of the utility.

Ericsson


Ericsson


Article 100 provides definitions for terms used in one or more of

the chapters of this document. I.e Arc Flash Hazards , boundary,

qualified person, voltage, etc

• Article 105 provides for application of safety‐related work

practices and procedures. I.e Employer and employee

responsibility, contractor, etc

• Article 110 provides general requirements for electrical safety related

work practices and procedures. I.e inspections, risk

assessment, human error, job briefing, audit

Ericsson70 E Coverage Electrical Safety Program

Article 120 provides requirements for establishing an electrically

safe work condition. I.e LOTO & Program, Testing, ESWC

• Article 130 provides requirements for work involving electrical

hazards. I.e energy electrical work permit, shock risk assessment,

AFRA, & tables, PPE and PPE Labels

• Informative ANNEX A to Q (E through Q for sure)

Ericsson70 E Coverage Electrical Safety Program

While all of the material in 70E is important, the following would be

of interest to telecommunication service providers, special

attention should be focused on the information in 70E about the

effects of arc flash, arc blast, and direct current (dc) hazards, and

recent developments in electrical design and Personal Protective

Equipment (PPE).

Ericsson

70 E Coverage

70E requires that, when working on or near exposed energized

circuits, safety-related work practices shall be used to safeguard

employees from injury while they are working on or near exposed

electric conductors or circuit parts that are or can become

energized. The specific safety-related work practice shall be

consistent with the nature and extent of the associated electric

hazards. These work practices shall include wearing protective

clothing and other personal protective equipment (PPE) when

working with the flash protection boundary.

With regard to arc flash hazards, a flash hazard analysis shall be

done in order to protect personnel from the possibility of being

injured by an arc flash.

Ericsson

70 E Coverage

Training Requirements

› Art. 100 definition of Qualified Person – “One who has

demonstrated skills and knowledge…”

– “Demonstrated” is added – for consistency with OSHA language

– How to demonstrate?

› New requirements for training documentation

– 110.2(C)(3) – “Employers shall verify at least annually that the

employee training required by this section is current.”

– 110.2(C)(4) – “The employer shall document that the training

required by this section has occurred.”

› Retraining requirement added – required at least every 3

years

Training Requirements

› Similar requirements in Article 120 for LOTO, but some

specifics are added:

– 120.2(B)(4)(b) – “The documentation shall be made when the

employee demonstrates proficiency in the work practices involved.”

– 120.2(B)(4)(c) – “The documentation shall contain the content of

the training, each employee’s name, and the dates of the training.”

› 110.2(C) – Emergency Response Training

– Annual training on “contact release” is required

– “Responding Employees” shall have annual training in first aid /

CPR / AED

– Verification and documentation requirements also apply here

Host / Contractor Relationship

› 2012 edition contained some requirements for Host &

Contract employers

– Generally, host informs contactor of known hazards

– Generally, contract employer makes sure employees are following

proper procedures & informs host of other hazards identified

› 130.3(C) Documentation

– “Where the host employer has knowledge of hazards covered by

this standard that are related to the contract employer’s work, there

shall be a documented meeting between the host employer and

the contract employer.”

Maintenance› 110.1(B) Maintenance

– “The electrical safety program shall include elements that consider

condition of maintenance of electrical equipment and systems.”

– Recognizes that maintenance (or lack thereof) does have an impact

on safety

› 205.3 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.”

› 205.7 – “…Covers and doors shall be in place with all

associated fasteners and latches secured.”

130.1 General › New text:

– 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

› Good reminder – that establishing an Electrically Safe

Work Condition is the baseline. It is what is expected.

› Just because we do a study, and put labels on the

equipment, and even mitigate hazard levels – none of this

means that we can overlook that basic requirement. It’s

not a free pass to work on equipment while it’s energized.

Risk Assessment Terminology Changes

› “Electrical Hazard Analysis” -> “Electrical Hazard Risk

Assessment”

› “Shock Hazard Analysis” -> “Shock Risk Assessment”

› “Arc Flash Hazard Analysis” -> “Arc Flash Risk

Assessment”

› Noticing a trend?

Risk Assessment Terminology Changes – Eliminate the hazard don’t relay on ppe

Definition - Hazard

› Hazard – a source of possible injury or damage to health

› Does not imply high energy or low energy, high risk or low

risk. It simply states there is a potential hazard.

› Analysis & assessment can determine:

– The severity of the hazard

– Whether the worker is exposed to the hazard

– The likelihood of occurrences, etc.

› Related: hazardous = involving exposure to at least one

hazard

Boundaries

Definition - Risk› 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

› Not necessarily related to the degree of hazard, though

common sense tells you that would be a factor in the

potential “severity” of injury that could result from an

incident

› Safety is not a “0” or a “1” – there is a relationship

between likelihood of incident, severity of hazard, and

potential severity of injury

› In the next section, we will see later at least one way that

NFPA 70E is going to use Hazard and Risk as separate

concepts to determine the required level of PPE for a

given task

So What does a Risk Assessment Do for Me?

› Article 100 Definition of 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.”

› 1. Determine whether or not a hazard exists

› 2. Estimate the potential severity of the exposure

› 3. Determine proper work practices or other protective

measures to be used

› If done right, it makes us think about what we’re doing and

ultimately promotes higher levels of safety

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.

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.

Risk Assessment. Informational Note: As used in this

standard, arc flash risk assessment and shock risk assessment

are types of risk assessments.

If the risk is high and ignored and something happens, it is not

an accident it is an incident.

70 E Risk Assessment

› Likelihood (Probability): Looks proximity to task, frequency of

task, etc.

› Consequences (Severity): Looks at injury severity potential

(first aid, disabling injury, fatality).

› Acceptable Risk: level of human and property loss that can be

tolerated by an organization. Note there is no zero risk unless

a hazard is eliminated, but we can mitigate risk through

observation and control measures.


High Consequence

Low Probability

Low Probability High Probability

High Probability

Risk Assessment

RISK

Frequency

High Consequence

Low ConsequenceLow Consequence

High Consequence

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.


› 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 when the incident

energy is 1.2 cal/cm2 and above.


› 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.


› 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/cm2 and above.

› Arc flash PPE protection and prudent avoidance should be used to mitigate the risk.

Low Probability

Low Probability High Probability

High Probability

Risk Assessment

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!

High Consequence

Low ConsequenceLow Consequence

High Consequence

Justified Energized work

Qualified Person”Only “person” permitted to work on

conductors or circuits that are not in an “electrically safe

working condition”.

› Qualified persons must be determined by employer

› Directly applies to those assigned to perform energized

work

› •Types of Assessments

› Shock Risk Assessment

› Arc Flash Risk Assessment

Energized Electrical Work Permit

› Description of work

› Justification for working energized

› Description of safe work practices

› Results of shock risk assessment

› Results of arc flash risk assessment

› Means to restrict access of unqualified

› Evidence of Job Briefing

› Energized work approval

› Supervisor and company and owner or owner’s

representative

Energized Electrical Work Permit

› When is it required?

› Reinforces the idea that there is a potential arc flash

hazard even when doors are closed and covers are in

place, if you’re interacting with the equipment in some

way.

› Risk Assessment should address this possibility…

› When management has to sign the work permit, it

seems the need to work energized (live) goes away

Best to be in an electrically safe work condition.

Energized Work› Defines four conditions when Energized Work is allowed:

– (1) Covers when de-energizing would produce a “greater hazard” – (was

there in 70E-12)

– (2) Covers “infeasibility” of de-energized work – (was there in 70E-12)

– (3) Covers equipment operating at less than 50V – (was there in 70E-12)

– Item (4) is new.

› (4) Normal Operation. Permitted if equipment is:

– Properly installed

– Properly maintained

– Doors are closed and secured

– Covers are in place and secured

– There is no evidence of impending failure

› This is an “AND” gate – all five conditions must be true!

What is Normal Operation?

› Operating voltmeter / ammeter selector switch

› Pushing buttons on a PowerLogic meter or similar device

› Opening / closing a circuit breaker

› What is NOT normal operation?

– Opening a door / removing a cover, or doing anything that involves

having to do these

– Insertion or removal of withdrawable parts (racking breaker /

bucket / etc.; changing fuses)

Be Careful about the Conditions

› Properly Installed – how can you tell just by looking at it?

› Properly maintained – eliminates this provision for the

majority of the facilities I have ever been in

› Doors / Covers closed & secured

– Are all bolts & screws in place? Quite often, they’re not!

– If they’re not, is it properly secured?

› No evidence of impending failure

– Why are you looking at this piece of equipment?

– “It’s [getting hot, humming, not working right, etc.]” – may be an

automatic disqualification

› How much equipment is left??

130.5 – Arc Flash Risk Assessment› Intended to:

– 1. Determine if an AF Hazard exists

– 2. If so, then:

› Select appropriate work practices

› Determine the AF Boundary

› Determine the proper PPE to be used inside the AFB

› Allows use of one but not both analysis methods:

– 1. Incident Energy Analysis (an “Arc Flash Study”)

– 2. PPE Selection Tables from NFPA 70E

› Results are to be documented, per 130.5(A)

Sample Format: Label Showing Incident Energy

Sample “Site Specific” Label

Labels Change…or do they?

› So…NFPA 70E specifically prohibits showing PPE

Category and Incident Energy on the same label

› But…workers are used to PPE Categories. Everybody

knows what they mean.

› The good news – NFPA 70E gives you enough flexibility

to do more or less what you want/need to do

› You do have to think about things a bit, and make sure

that your labeling practices are consistent with the way

you equip workers with PPE, your training practices, etc.

› This is a good thing…

NEW Table 130.7(C)(15)(A)(a)

NOTE: this does not apply to calculations. This is to be

used when the PPE is being selected with the Tables.

When doing calculations, refer back to 130.2(A)(4)

regarding “Normal Operation”.

NEW Table 130.7(C)(15)(A)(b)

No task-specific hazard levels. One PPE level for each

equipment class.

Notice what’s missing? There is no such thing as

Category 0 PPE any more.

PPE Selection

› Incident Energy Analysis Method (See NFPA 70E

Annex D)Based on working distance from employee’s

face and chest

– Basic Equations for calculating must include:Amperage

– Voltage

– Impedance

– Distance

– Maximum MVA during bolted fault

– MVA rating of the transformer

– Time of arc exposure

PPE Selection

Table 130.7(C)(15)(c) Personal Protective Equipment

(PPE)

› PPE Category 1 –Minimum Arc Rating of 4 cal/cm2




Examples of RF warnings

Safety CodesAre Not Enough

› Safety Codes…….Regulatory and Legal Mandates– NESC…NEC..OSHA…GO 95…. Local and Regional Building and Fire Codes

› Internal Practices – Best Industry Practices– Telcordia Construction Blue Book – Issue 5 (2011).., new issue in 2016

– Service Providers - ATT..Verizon… Centurylink … RUS..

– Manufacturer/Supplier provided instructions and guidance documents

– CSRIC Best Practices - Communications, Security, Reliability, and Interoperability Council (old NRIC Best practices) - links to FCC

› Product Specifications and Functional Performance Criteria – Wireless Facilities – Family of GRs GR-3171,GR-3031, 3032, 3033, 3178

– Poles & Hardware - GR-60 Wood, GR-3159 Non-Wood, GR-3174 Hardware

– Equipment - Physical Protection -- GR-3108… GR-1089 EMC…..GR-63

– Enclosures and Closures - GR-43 (Huts), GR-487 (Electronic Equipment Cabinets), GR-950 (ONUs), GR-902 (Handholes), GR-3121/3123/3125 (FDHs)

– Cables - GR-421, GR-3163, GR-3164, GR-137, GR-492, GR-20, etc..….

› Design Engineering for Network – Reliability and Long Lifetimes --- 20…..40 years

– Quality and Availability of Services (99.999+%)

– Resilient Designs – Backup Services, Duplicate Routes, Sharing Agreements

www.atis.org/peg

Ernie Gallo

Director– Ericsson …..- Network Infrastructure Solutions (NIS)

[email protected]

THE

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