Electrical failures are one of the leading causes of unscheduled downtime, equipment loss, and workplace injuries in commercial and industrial environments. Historically, the approach to electrical maintenance was largely discretionary—businesses could choose how and when to maintain their equipment. But that has changed.
In January 2023, the National Fire Protection Association (NFPA) released a major update to NFPA 70B. The 2023 edition of NFPA 70B marks a pivotal shift in electrical maintenance requirements, transitioning from recommended practices to mandatory standards. This change carries significant implications for electrical safety, equipment reliability, and potential regulatory compliance. Understanding these new requirements is essential for preempting equipment failures, preventing workplace accidents, and avoiding costly OSHA citations.
The Fundamental Shift: From Recommendations to Requirements
The National Fire Protection Association’s NFPA 70B has undergone a monumental transformation in 2023, changing from a “Recommended Practice” to a “Standard” containing mandatory language for electrical maintenance programs. This change replaces suggestive “should” language with definitive “shall” directives, creating clear obligations for businesses that maintain electrical equipment.
While NFPA 70B is not a code directly mandated by law (unlike the National Electrical Code), its significance shouldn’t be underestimated. Similar to NFPA 70E, this standard represents consensus requirements for safe electrical work practices, and OSHA can reference it when issuing citations. In practical terms, this means that following NFPA 70B is no longer optional for businesses serious about electrical safety and regulatory compliance.
| While OSHA does not directly enforce NFPA Standards, it can now use them as evidence of a failed practice for electrical equipment maintenance. So, if an incident occurs, OSHA would then cite the employer for violating the General Duty Clause and use NFPA 70B as evidence of what should have been done since this is now a “Standard” instead of a “Recommendation.” |
~Michael Gebauer, Director of Services for IBT
What This Means for Your Business
The 2023 standard now contains enforceable language for the development, implementation, and operation of electrical maintenance programs (EMPs). This closely aligns with NFPA 70E Standard for Electrical Safety in the Workplace, which indicates that properly installed equipment may still be unsafe to work on unless it’s “properly maintained” according to manufacturer instructions or industry consensus standards.
These changes apply to electrical infrastructure in various settings:
- Industrial Plants: Manufacturing facilities, refineries, and processing plants.
- Commercial Buildings: Office buildings, shopping centers, and data centers.
- Institutional Facilities: Hospitals, schools, and government buildings.
- Large Multifamily Residential Complexes: Apartment buildings and senior living communities with centralized electrical systems.
- Utilities and Infrastructure Sites: Substations, switchgears, and distribution equipment.
Key Differences Between 2019 and 2023 NFPA Requirements
The 2023 update introduces several significant changes that businesses must understand to maintain compliance:
1. Mandatory Maintenance Intervals
Chapter 9 of NFPA 70B now provides mandatory scopes of work and maintenance intervals broken out by product type based on equipment condition assessment. Unlike the 2019 version, which merely suggested maintenance timeframes, the 2023 standard clearly defines required intervals with detailed maintenance tables for different types of electrical equipment.
For example, equipment classified under “Condition 1” might require inspection every 60 months, while the same equipment under “Condition 3” would require inspection every 12 months. These requirements don’t supersede manufacturer guidelines but provide clear direction in their absence.
2. Equipment Condition Assessment Framework
The 2023 standard introduces a formal equipment condition assessment system based on three key factors:
- Physical condition of the equipment
- Criticality of the equipment
- Operating environment
Equipment is classified into three conditions, with the most stringent condition driving the maintenance schedule. For example, if equipment is designated “Condition 1” for physical condition and criticality but “Condition 3” for operating environment, then it must follow the more frequent “Condition 3” maintenance intervals.
3. Clearly Defined Electrical Maintenance Programs
NFPA 70B 4.2 now clearly defines what elements must be included in electrical maintenance programs:
- An electrical safety program addressing maintenance conditions
- Identification of personnel in charge of implementing each part of the EMP.
- Survey and analysis of electrical systems to determine priorities
- Documented maintenance procedures
- Inspection and testing plans
- Maintenance, equipment, and personnel documentation and records-retention policy
- Processes for corrective measures based on collected data
- Design for maintainability in new installations
- Program review and continuous improvement
4. Comprehensive Field Testing Requirements
The 2023 NFPA 70B standard introduces a more structured approach to field testing, with clearly defined testing methods outlined in Chapter 8. These methods help ensure that electrical equipment is maintained safely and effectively.
Section 8.3 categorizes tests into four types:
- Type 1 – Online Standard Test: Performed while the equipment is energized and connected to its power source.
- Type 1A – Online Enhanced Test: Conducted while energized, but more in-depth and diagnostic in nature. These are not typically part of routine maintenance.
- Type 2 – Offline Standard Test: Performed when equipment is de-energized or connected to an external test power source.
- Type 2A – Offline Enhanced Test: More advanced and typically optional, used when diagnosing specific issues or verifying performance under special conditions.
While NFPA 70B provides a baseline for what testing should be done, manufacturer guidelines always take precedence. For example, testing of circuit breaker trip functions may not be required for breakers rated at 250 amps or below. Instead, electronic trip units often only need a calibration check using the manufacturer’s test equipment.
5. Mandated System Study Intervals
System studies, including short-circuit studies, coordination studies, and incident energy analyses, must now be performed at intervals not exceeding 5 years. This aligns with NEC and NFPA 70E requirements and ensures that safety calculations remain accurate as electrical systems evolve.
Infrared Thermography: From Recommended to Required
One of the most significant changes in the 2023 standard involves infrared thermography, which has transitioned from recommended to mandatory practice. This shift represents a recognition of thermography’s essential role in preventing electrical failures.
New Mandatory Requirements for Infrared Inspections
Under the 2023 NFPA 70B standard:
- All electrical equipment must undergo infrared inspection at least every 12 months. This is a significant change from the 2019 edition’s recommendation of annual inspections.
- Equipment in Condition 3 requires thermographic inspection at least every six months. This enhanced frequency for certain equipment underscores the critical safety role of infrared inspections.
- Specific procedural requirements have been established:
- Temperature differences between areas of concern and reference areas must be documented
- Inspections must be performed under normal circuit loading when possible
- Circuit loading characteristics must be documented and retained
- All accessible covers must be removed before inspection unless appropriate IR windows are installed
- Inspector qualifications are now mandated:
- Inspectors must be properly trained for specific test procedures and the equipment they use
- Documentation of qualifications is required
Why This Matters for Safety and Compliance
Infrared thermography detects abnormal heating in electrical components to identify potential problems before they cause failures. The technology can locate issues such as loose connections, overloaded circuits, or imbalanced loads, which, if left unaddressed, could lead to system failures, fires, or electrical accidents.
Standardizing infrared inspection requirements helps ensure consistent application of this critical preventive measure across all facilities. By mandating these inspections, NFPA 70B 2023 creates a more robust framework for electrical safety.
Practical 2023 NFPA 70B Implementation for Your Facility
Implementing the new NFPA 70B requirements involves several strategic steps:
1. Conduct an Equipment Inventory and Condition Assessment
Begin by documenting all applicable electrical equipment and assessing its condition according to the NFPA 70B framework. This baseline assessment will determine the appropriate maintenance intervals for each piece of equipment.
2. Develop a Comprehensive Maintenance Schedule
Based on equipment conditions and the mandatory intervals specified in NFPA 70B, create a detailed maintenance schedule that covers:
- Visual inspections
- Cleaning and lubrication
- Mechanical servicing
- Electrical testing
- Infrared thermography
3. Ensure Proper Documentation
The 2023 standard places significant emphasis on documentation. Establish systems to record:
- Maintenance procedures performed
- Test results
- Equipment condition assessments
- Personnel qualifications
- Any corrective actions taken
4. Train and Qualify Personnel
Ensure that staff performing electrical maintenance and testing are properly qualified. The standard now requires that personnel be explicitly trained in the tasks they perform and the tools they use.
5. Implement Safer Testing Methods
Consider implementing IR windows for safer infrared inspections. While section 7.4.2 requires removing accessible covers for clearer infrared images, section 6.8 mandates that dangerous tasks be evaluated and designed to be safer, which is where IR windows become valuable.
Meeting OSHA Requirements Through NFPA 70B Compliance
While NFPA 70B is not directly mandated by law, OSHA can use non-compliance with industry consensus standards as a basis for citations under the General Duty Clause. By implementing the 2023 NFPA 70B requirements, businesses can demonstrate due diligence in electrical safety and potentially avoid costly citations.
Furthermore, proper maintenance reduces the risk of equipment failures that could lead to workplace injuries–incidents that might trigger OSHA investigations and penalties regardless of whether specific standards were cited.
Infrared Electrical Inspection Services
Implementing comprehensive electrical maintenance programs that meet the new NFPA 70B requirements can be challenging, particularly for organizations without specialized in-house expertise. This is where partnerships with qualified service providers become invaluable.
IBT has partnered with Monroe Infrared to offer professional infrared electrical inspection services that comply with the new NFPA 70B requirements. Their certified thermographers provide expert infrared inspections that can identify potential issues before they lead to equipment failure, production downtime, or safety incidents. These services help ensure your facility meets the new mandatory requirements while protecting your valuable electrical assets and personnel.
Learn more about electrical infrared inspection services with this PDF flyer.
By proactively addressing the updated NFPA 70B requirements through professional partnerships, businesses can mitigate risks, avoid potential OSHA fines, and create safer, more reliable electrical systems.
Schedule Your Infrared Electrical Inspection Today
IBT and Monroe Infrared offer NFPA 70B-compliant infrared inspection services everywhere within the continental United States.
Contact your IBT representative to book an assessment or to learn how Monroe Infrared’s expertise can support your maintenance and compliance goals.
