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Risk and NFPA 70E in Healthcare


The fabric of codes and regulations monitoring healthcare systems is vast and intricate. As one thread in a garment supports and impacts the others, so one standard established (or changed) in healthcare in one area will undoubtedly have ramifications on other areas. Take, for example, an excerpt from the Department of Health requirements for hospitals established by the District of Columbia:

”Surgical areas shall have heating and cooling systems that are capable of producing room temperatures at a range between sixty-eight (68°F) and seventy-three degrees Fahrenheit (73°F) and humidity at a range between thirty (30) and sixty percent (60%) relative humidity.”

As you can see, these parameters will drive a load on a power system that will have to be designed and regularly maintained so that it can deliver the requisite energy. And, those that maintain the system will want to be kept as safe as possible while they are performing their duties. In light of the complexity and interconnectedness of safety regulations, here is a summary review of a handful of key updates in the 2015 revision of NFPA 70E.

  1. Hazard Labels must now contain:
    • At least one of the following:
      • Available Incident Energy or required PPE category, but not both
      • Minimum arc rating of clothing
      • Site specific level of PPE
    • Nominal system voltage
    • Arc flash boundary
    • **the calculation method and data to support the information for the label shall be documentedIndustrial automation arc flash

This leaves the facility director to determine the best path forward for him or her. Several options are as follows:

  • Simplified labeling based on “minimum arc rating” levels
    • Level 1: < 8cal/cm2 OR
    • Level 2: >8cal/cm2 and < 40 cal/cm2
  • Actual Incident Energy (IE) level labels that include precise IE and arc flash boundary
    • This requires workers to interpret IE values for PPE selection
    • A single power system may have multiple arc flash boundaries within it, depending on the included equipment
  • Site specific labels that group equipment within a given IE range
    • This is to align with the Electrical Safe Work Practices policy and site-specific PPE outlined therein
  1. The 2015 update requires that a Risk Assessment be performed. Previously, shock hazard and arc flash analysis were required, but article 100 of the 2015 update (quoted below) includes these previous analyses as part of a larger Risk Assessment strategy:

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.

The Risk Assessment should help answer three general questions:

  • Is the worker exposed to a hazard?
  • If so, what is the severity of the hazard?
  • What actions can be taken to reduce the severity of or exposure to the hazard?

Question 1 requires evaluation of the particular work task vs. equipment construction & condition, possibly including evaluation of equipment to criteria such as:

  • Properly installed
  • Properly maintained
  • Doors closed and secured
  • Covers in place and secured
  • There is no evidence of impending failure

Determination of the severity of the hazard requires analysis via calculations or the NFPA 70E tables, while reducing the hazard may involve Engineering Controls for arc flash mitigation, employing proper safe work practices, and use of properly-rated PPE.

  1. In keeping with the Risk Assessment theme, the arc flash tables in the 2015 update now provide one table to inform the worker if PPE is required; see binary decision matrix in table 130.7(C)(15)(A)(a) that combines tasks, equipment condition, and PPE requirement. The next table, 130.7(C)(15)(A)(b), is then utilized to identify the proper PPE Category. As you will see, this table ties the PPE Category to the equipment, not the task. You’ll also notice that there is no longer a PPE Category 0.

As your employees maintain the electrical power system that is so important to the health and well-being of your patients, we hope that the points mentioned above help your facility workers maintain an equally high level of health, well-being, and safety.

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