NFPA 70B Conditions
As it pertains to Condition 2, the following are noted from 9.3.1.2 and I quote:
- Maintenance results deviate from past results or have indicated more frequent maintenance in accordance with manufacturer’s published data.
- The previous maintenance cycle has revealed issues requiring the repair or replacement of major equipment components,
- There have been notifications form the continuous monitoring system since the prior assessment, and
- There are active recommendations from predictive techniques.
Condition 2 has a focus on the testing results (or results from mechanical or visual inspections) that deviate from accepted norms. In other words, if the handle on a switch is exercised and it’s “a little rough and clicks oddly when moved”, in contract to the last time, this would be an example. Additionally, if the oil sample pulled from a transformer shows contents that are beyond the tolerances, this would be an additional example. There is no reference to a missed testing/inspection interval; that is, if a visual inspection was missed, or your doing it late, this does not move the device into Condition 2, if it was at Condition 1. Frankly, most advisors place devices into Condition 1 or 2, as Condition 3 points towards failure and who is going to allow a critical device to sit in an “unmaintained condition for two successive maintenance cycles” condition? Lastly, the points 3 and 4 again refer to predictive techniques or continuous monitoring systems, leading someone to wonder if one of the contributors to NFPA 70B sits on the board of a predictive maintenance integration company. However, the use of an EEOS that would give access to manufacturers’ recommendations and the management of all these aspects mentioned, is the clear path to having active data; a necessity, frankly.
With respect to Condition 3, the following are noted in NFPA 70B 9.3.1.3 and I quote:
- The equipment has missed the last two successive maintenance cycles in accordance with the EMP,
- The previous two maintenance cycles have revealed issues requiring the repair or replacement of major equipment components,
- There is an active or unaddressed notification from the continuous monitoring system, and
- There are urgent actions identified from predictive techniques.
Condition 3 is meant to be an alert for the facility manager and other supervisory roles. Ignoring the “unaddressed notification from the continuous monitoring system” and “urgent actions identified form predictive techniques”, it is a “call to action” for the maintenance department. Point 4 is especially vague, due to the fact that “predictive techniques” also includes advisors, whom, due to incentives, may recommend urgently replacement, repair, reconditioning, etc of equipment that may or may not have to do with imminent failure or personal safety. However, this does mean, for example, if visual inspections are identified as a monthly interval by the internal EMP and three months go by without the visual inspection taking place, this device should be placed into Condition 3. Therefore, I cannot stress enough the importance of a well-crafted EMP, as well as the considerations of labor that it implies, especially when third-party vendors are a part of the equation. Lastly, having an EEOS like Neptune or Gimba Technology will allow the party to avoid redundant activities, as one can include other regulations, such as OSHA-mandated operational checks on eye wash stations, etc to be included in the visual inspections.
Non-Serviceable Equipment – Chapter 9.3.1.4
Referring back to NFPA 70B 8.7.1.3 Non-Serviceable, NFPA 70B 9.3.1.4 discusses equipment that “has a problem that is detrimental to the proper electrical or mechanical operation of the equipment”. This means that if there is a breaker that is stuck or a relay that is not responding, this is non-serviceable. Does this mean that a transformer that is leaking oil is “detrimental”? The section is not clear, but we advise on the side of caution. However, there is most certainly some room to become more specific in this standard, understanding that the variety of issues that the wide-array of electrical equipment would make NFPA 70B rather cumbersome.
NFPA 70B notes that said equipment, exhibiting these “detrimental” characteristics be corrected before returning to use and that no person who is unqualified should not be allowed access to said equipment. This, of course, is entirely reasonable and understandable.