Is There a Specific Standard and Section that States an EEWP is NOT Required When Applying Grounds for High Voltage?

red background with burning question

Q:  Is there a specific standard and section that states an Energized Electrical Work Permit is NOT required when applying grounds for high voltage?

A: (Two of our instructors gave similar answers; both are posted here.)

Expert #1: It is generally understood that establishment of an ‘electrically safe work condition’ is part of listed exemption for Testing, troubleshooting, and voltage measuring  since that is one of the necessary steps to establish ‘a safe working condition’ for low voltage.

The installation of grounds is the final step to achieving ‘the electrically safe working condition’ for high voltage equipment, and I would consider it part of the listed exemption for Testing, troubleshooting, and voltage measuring.

Expert #2: You will not find a chapter and verse in OSHA, NESC or NFPA 70E that comes right out and says no EEWP is required for applying protective grounds.

Here is the logic:

Applying protective grounds is mandated by OSHA 1910.269(n). It states that grounding needs to be applied to consider the HV lines and equipment de-energized.  So now let’s jump to a 70E definition for “Electrically safe work condition”:

“A state in which an electrical conductor or circuit part has been disconnected from energized parts, locked/tagged in accordance with established standards, tested to ensure the absence of nominal voltage and grounded if determined necessary.”  (As stated above, grounding is mandatory.)

The addition of nominal by me in the above definition comes from 1910.269(n)(5).

As the NESC and OSHA 1910.269 documents do not have the concept of an EEWP, we must fall back on 70E for that concept.  It is common practice to not require an EEWP for the establishment of an Electrically Safe Work Condition; therefore, applying protective grounding after the verification of absence of nominal voltage would fit under that.  As testing and voltage measuring is exempt from an EEWP, so would grounding as part of creating an Electrical Safe Work Condition for HV.

Don’t get hung up on the wording in NFPA 130.2(B)(3) as being absolute.  Like activities can also be exempt from an EEWP.  For example, tuning rolling mill drives by adjusting the potentiometers is not listed as no-EEWP-required even though the potentiometers are located within the Restricted Approach Boundary, but it falls under the same concept as testing because the power has to be on to do the tuning.

Hugh Hoagland

Hugh Hoagland

Hugh Hoagland is the foremost tester of clothing and PPE exposed to electrical arcs and is an arc flash expert. Read more about Hugh.

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2 Responses

  1. We could take a step back and ask what is the intent of the EEWP? 1. Prevent unwarranted energized work. 2. Ensure that warranted energized work is formally documented, all safety concerns addressed / risk assessed / controlled, and approved by senior management.

    If industry or the utility has formal procedures that addresses frequent tasks (such as switching and energy control), then the intent of the EEWP is met if the procedure was written by a qualified person and approved by senior management. Obviously, such procedures would be useless if the worker wasn’t trained (training being current) on the procedure or it lacked the annual supervisory work inspection (audit) rules.

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