NFPA 70E® 2024 defines the following:
Exposed (as applied to energized electrical conductors or circuit parts). Capable of being inadvertently touched or approached nearer than a safe distance by a person. It is applied to electrical conductors or circuit parts that are not suitably guarded, isolated, or insulated.
Additionally NFPA 70E® 2024 requires that boundaries be applicable when personnel are approaching exposed energized electrical conductors, including:
130.4 (G) Restricted Approach Boundary. No qualified person shall approach or take any conductive object closer to exposed energized electrical conductors or circuit parts than the restricted approach boundary set forth in Table 130.4(E) (a) and Table 130.4(E) (b), unless one of the following conditions applies:
- (1) The qualified person is insulated or guarded from energized electrical conductors or circuit parts operating at 50 volts or more. Insulating gloves and sleeves are considered insulation only with regard to the energized parts upon which work is performed.
- (2) The energized electrical conductors or circuit parts are insulated from the qualified person and from any other conductive object at a different potential.
NFPA 70E® 2024 Table 130.4(E)(a) does not have a required distance listed for the restricted approach boundary below 150V, it just says "AVOID CONTACT". This doesn't mean try to avoid, it means if you can avoid without trying, then the boundary doesn't exist. However for all voltages above 150V we have to either respect the boundary or make the conductors not be "exposed". One great option is to de-energize equipment by utilizing proper LOTO techniques including the verification of absence of voltage (see NFPA 70E® 2024 120.6), then there is no energized conductor to be exposed to. What about working inside of a panel that has a main breaker LOTO with the top side still energized, can you make that "not exposed"?
A guard on the top side of a breaker can do the trick as long as it properly covers energized conductors, this would reduce the need for worrying about shock protection. Here is an explanation that came from: https://forums.mikeholt.com/showthread.php?t=142789 per Steve Merrick, his response is from 2012 which means some of his quotes are a few standards behind but this should give you a very good starting point:
If the inside of the panel meets IP20 "finger-safe" requirements in accordance with IEC 60529, then there are no "exposed" live parts as defined by NFPA 70E® and shock PPE requirements may be reduced accordingly. As long as all components are "suitably guarded, isolated or insulated," then under NFPA 70E® Article 100 they are not considered to be "Exposed (as applied to energized electrical conductors or circuit parts)." Since with 100 percent fingersafe panels there and no live parts to which a worker might be exposed, the approach limitations and PPE requirements under Article 130 do not apply. If you are opening the panel for inspection purposes only and you are not using tools or otherwise making contact with potentially live parts, then no additional PPE is required - again, so long as no tools are involved in the work activity.
Remember, Article 130 is all about working on or around exposed live parts. If the parts are all suitably guarded, isolated or insulated they are not "exposed."
Consider a standard 120 volt receptacle. A receptacle with its cover plate installed is considered IP22 compliant (finger safe, drip proof). It has live parts, but they are suitably guarded, isolated and/or insulated, and therefore we are not required to wear PPE to plug in an appliance.
With that said, sometimes hidden hazards do exist (uncovered power terminals, etc.). it is up to the electrical workers to be qualified to know and recognize the potential work hazards involved and to wear the appropriate level of PPE accordingly, and if work activities evolve from inspection only to troubleshooting and beyond to where they may indeed become exposed to potentially live parts, then they must be willing to immediately stop work and regroup and take appropriate precautions for the expanded work (lockout/tagout, live work permits, PPE, approach limits, barricades, etc.)
NFPA 70E® is clear that it applies to work on or around exposed live parts. NFPA 70E® Article 100 provides a clear definition of what it means by the term "exposed" as follows:
"Exposed (as applied to energized electrical conductors or circuit parts). Capable of being inadvertently touched or approached nearer than a safe distance by a person. It is
applied to electrical conductors or circuit parts that are not suitably guarded, isolated, or insulated."
Wires in a conduit are guarded by the rigid steel and insulated by their jackets, hence you can put your bare hand on a conduit carrying energized conductors without wearing PPE. Live contacts in a receptacle are isolated by the narrow finger-safe slots that can be contacted by a tool, but not inadvertently by a person and are again not covered by 70E requirements.
As there is no US definition of finger safe, manufacturers and AHJs have been using IEC-60529, the international Ingress Protection standard, or IP Code, as a basis for determining if a part is suitably guarded, isolated, or insulated for the purposes of NFPA 70E®. This standard holds that an assembly is considered finger-safe (IP-2X compliant) if a 12.5 mm (1/2 inch) metal sphere probe 80 mm in length (the size of an average little finger) is unable to make contact with any potentially energized circuit component within the assembly.
Again, if a worker is not "exposed" to hazardous energy as defined, NPFA 70E protection requirements do not apply. This is not simply my opinion - I have been an insider on this from the beginning. If you think otherwise, consider how you could justify allowing unqualified, unprotected people to change a light bulb or plug in a tool or appliance. They are certainly approaching live parts carrying greater than 50 volts. How is it different because it is in a panel?
The following options exist as terminal covers for an AB breaker
https://literature.rockwellautomation.com/idc/groups/literature/documents/td/140g-td101_-en-p.pdf (pg 93)
The AB "High Covers" offer IP40 protection which protects objects from as small as 1mm from ingress.
Rubber insulating blankets are also available to cover exposed conductors and can be purchased through electrical safety providers, here is a link to one sold by Grainger.
Flash protection may still apply if the label indicates a hazard exists and the type of work that is being performed may increase the risk of being exposed to the flash, this includes during verification of absence of voltage.
We discuss this topic under a similar context in the following post: https://www.70econsultants.com/is-electrical-equipment-considered-de-energized-with-a-voltage-present-on-the-line-side-of-the-disconnect/