The National Fire Protection Association (NFPA) 70E standard for electrical safety in the workplace has already come a long way regarding personal protective equipment (PPE) for thermographers (people who use infrared cameras).
In the past NFPA 70E cycles, thermographers and their employers have been pushing to change the requirements for spark-arc resistant clothing and PPE for performing an infrared scan. And there are reasons to complain.
In a paper submitted to the 2008 IEEE/IAS/ Electrical Safety Workshop1 , Vladimir Ostrovsky noted that such equipment (especially the hood) restricts the oxygen supply for the wearer, which increases the feeling of claustrophobia and causes breathing difficulties. Although ventilation systems can reduce this discomfort, thermographers still struggle to take good thermal images due to limited light conditions, the hood's limited viewing window and the use of their infrared camera in combination with the heavy gloves.
During the review of NFPA 70E proposals in 2009, 2012 and 2015, several
people and companies proposals for thermal imaging and the 70E committee once again discussed their approach to the problem.
The following questions were addressed:
- What are the real risks of thermography?
- Will the thermographer remove the equipment housing under power or will someone else perform this task?
- Will the thermographer interrupt the field of the enclosure?
- Was there a risk of contact or parts going live in the equipment?
- How close will the thermographer get to the potential source of spark arcs?
- Is the person performing the scan a qualified electrician in accordance with OSHA and NFPA 70E?
In the 2015 NFPA 70E, the committee ruled that if the person removing the enclosure is wearing spark-resistant clothing and PPE, the thermographer need not do so provided:
- The thermographer does not enter the unauthorised area,
- Does not interrupt the housing field; or
- Do not operate or touch the equipment in any way.
One of the main questions the committee had to address was whether or not thermographers qualify. We decided that OSHA and NFPA 70E require anyone exposed to the hazards to be eligible for qualification. Therefore, the 70E committee decided it was acceptable to allow electrically qualified persons the flexibility to perform their duties in a safe manner. Since we cannot be present at every site, that decision must be made by the qualified person doing the work.
Time to decide
It is important to note that NFPA 70E stands for minimum safe practices, not recommended procedures. Any qualified person wishing to perform a task that exposes them to electrical hazards must carry out a full risk assessment, including an assessment of the risk of electric shock and electric arcing. At first glance, this may seem confusing and contradictory. On the one hand, NFPA 70E does not mandate spark arc-resistant PPE and clothing while performing an infrared scan. On the other hand, the technician may find that PPE may be required in his or her specific case even though it is not required by NFPA 70E.
The 70E Committee considers that as long as the equipment is live, the risk of arcing remains. In Table 130.7(C)(15)(A)(a), we note that spark-arc resistant PPE may or may not be required depending on the tasks and conditions. Spark-resistant PPE may be required for personal safety even though it is not required by NFPA 70E. As mentioned earlier, 70E represents the minimum acceptable requirements and there is a possibility that these requirements may need to be exceeded. This is an example of why the user of NFPA 70E should know the entire Chapter 1 if performing tasks on electrical equipment.
There are no exceptions: ignoring the risks associated with a task under NFPA 70E will only result in you ending up in a burn centre sooner. Nobody wants to end up there. This is an area where being lazy can change the thermographer's life forever.
In addition, the person removing the enclosure must wear full spark-resistant clothing and PPE. Once the enclosure has been removed, the area secured and checked for potential hazards, the thermographer can enter and perform the scan with the PPE required for that level of risk.
Summary
Wearing spark-resistant clothing and personal protective equipment (PPE) for thermographers may now become a personal decision in some cases. Remember that OSHA requires employers to provide PPE and employees to wear such PPE if there are hazards. A hazard/risk analysis can indicate whether such PPE is necessary and this analysis should be properly recorded.
Consider the following questions when deciding whether or not to wear personal protective equipment (PPE) for thermographers:
- What would your life be like after a serious spark incident?
- What would follow for your family and friends? How would your life change if you were maimed or disabled?
- How sure are you that there are no defects in the equipment you are about to scan?
The NFPA 70E committee (and I) sincerely hope (hope) that no one ever finds themselves in a situation where they have to answer these questions because of an electrical incident. If it is really inconvenient to wear the required PPE or if there is simply no room, a viewing window can be considered.
