With the issuance of the 2018 edition of NFPA 70E®, Standard for Electrical Safety in the Workplace, a risk assessment must consider the outcome of human error during the performance of a task. The three most effective controls are less affected by human interaction. Awareness and administrative controls are two controls which rely more heavily on a human for proper implementation. The hierarchy of risk controls is:
(3) Engineering controls
(5) Administrative controls
(6) Personal protective equipment (PPE)
Awareness methods often have no impact on the severity of injury and have no impact on the hazard. Each system can require unique awareness devices in order to have the desired impact on risk. This risk control is often the most obvious to employees through the use of warning labels and signs. Placards indicating DANGER or RISK OF SEVERE INJURY rely on the comprehension and training of the employee to limit their exposure to the hazard. The control method could fail due to desensitization from too many warning signs, lack of understanding of provided information and disregard of the provided warning. Fortunately, human nature generally guides people away from things that may harm them.
Administrative controls are typically employed when hazards are not controlled. Much of NFPA 70E Chapter 1 discusses the use of effective administrative controls when energized work is justified. These controls include procedures, employee training, risk assessment, job briefing, auditing, and the use of an energized electrical work permit. Employee commitment is heavily relied upon under this control method. Procedures have a great impact on avoiding injury but have a minimal impact on severity of injury. Training has an impact on avoiding injury with regard to the proper interaction and foreseeable inappropriate interaction with the electrical system. It is the correct actions of a human that determine the success of this risk control.
Administrative controls include one of the most common forms of achieving removal of a hazard. You may have noticed that establishing an electrically safe work condition (ESWC) was not included under the highest level of control – elimination. Establishing an ESWC does not rely on the risk control of elimination; it achieves elimination through the use of administrative controls. Not all administrative controls achieve removal of the hazard or risk.
The act of establishing the EWSC places an employee at risk of injury from the hazard. Establishing an ESWC through a lockout procedure removes the hazard only if correctly applied. The hazard exists prior to this occurring and after the procedure is reversed so it is not full “elimination” of the hazard. The hazard is only removed for a defined period of time and often at a very specific location. By creating an ESWC, the risks associated with potential electrical hazards have been temporarily reduced to an acceptable level and the electrical hazards have temporarily been effectively removed. Proper training is critical to the implementation of this administrative control. (Refer to my earlier blog on elimination for an understanding of that risk control method.)
Notice that administrative controls are fifth on the hierarchy of controls list. If establishing an ESWC is the only control method employed without attempting to use the higher control methods, employees may be put at a greater risk of injury than necessary. Even when the policy is to establish an ESWC, it is necessary to use the other controls to minimize the risk or hazard present for that task.
Human error has a great impact on the effectiveness of this control method. Not considering all hazards and situations, training not being understood, procedures not kept current, and training not consistent with procedures can defeat this control method. However, when all other control methods have been exhausted, the use of an administrative control (electrically safe work condition) provides the last option to remove electrical hazards and increase the safety for an employee working on the electrical equipment.
Next time: The least effective risk control.