I would like to know what other firms are doing with regard to requiring an Energized Electrical Work Permit. Are you obtaining an EEWP when working ON energized electrical conductors, exactly as stated in NFPA 70E 130.1(B)(1)? I take working on to mean making contact with energized electrical conductors with the exception of the troubleshooting clause. Or, are you obtaining an EEWP when working within the Limited Approach Boundry as implied in NFPA 70E 130.1(A)? If we take the latter approach it would seem that even if one was tightening hinges on an MCC door within the Limited Approach Boundry the EEWP would be required. I appreciate your input.

We have implemented a two level live work permit system, one is where actual work is performed live, the other (limited) permit covers work where exposed live parts may accidentally encountered, but not purposely contacted. 1000 volt tools required, along with PPE rated for the voltage and available incident energy. Testing and troubleshooting is exempted from the permit process, as the majority of our work is testing and troubleshooting.

The Electrical Energized Work Permit is intended to ensure that the increased risk associated with exposure to exposed energized electrical conductors and components receives adequate consideration and that no safer alternatives to energized work are reasonably possible.

Tightening the hinges on an MCC door is not diagnostic in nature so you can't apply the troubleshooting exception and it certainly doesn't fall under the 50V exception either. Obtaining an EEWP requires that the live work be justified which means it must meet the requirements of either greater hazard or infeasibility. If performing the work live cannot be justified then you must lockout, in which case an EEWP is not required.

For example, a common one at our shop might be drilling a hole and adding another conduit to a panel. While neither the conduit nor the metal enclosure are energized components, an EEWP is required to perform this task without lockout since you are not troubleshooting and you are exposed to the energized components inside the panel which are operating at >50V. If this task doesn’t meet the requirements for justification, a shutdown would be planned to enable lockout. Often for tasks of short duration such as this we'd lockout and do the work during the operator's lunch, break, meeting or shift change.

So short answer, yes; an EEWP is required for work performed within the Limited Approach Boundary.