With all the time and effort it takes to keep employees safe from electrical hazards in the workplace, what people concern themselves about is confusing. A controversial topic has moved to the top of NFPA 70E®, Standard for Electrical Safety in the Workplace® employee safety issues. Comments have been made so often that a blog must be dedicated to it to clear up the issue. You may be thinking that you must be out of the loop since you are unaware of any pressing electrical safety issue. What could be so controversial? The answer may surprise you. The topic is the cover art on the cover of new editions of the NFPA 70E standard and handbook. I put the image on the cover for the purpose of drawing attention to the need to use the hierarchy during your risk assessments. To be clear, the hierarchy of risk controls is a hierarchy (defined as any system of things ranked one above another). No matter how this hierarchy is depicted in any media, the requirements on how it is to be applied is specifically addressed by the standard. This does not change.
I chose the peaked triangle as a pictorial for the hierarchy based on the pinnacle being where you want to be. The best place is at the top. Some have an issue with the base being personal protective equipment (PPE) but a hierarchy is typically not listed from the bottom up. If the triangle was inverted and PPE was at the bottom, it might make sense to me if I went for a scuba diving analogy. I would not want to be at the tip of that inverted pyramid because things get less safe when you get deeper in the water. Your frame of reference may cause you to look at it another way.
What the triangle or the hierarchy do not represent are steps or a process. You do not build off of PPE on the first step nor do you build off elimination. You do not don PPE then work on making the situation more “safe” and moving off of elimination increases the hazards or risks to the employee. In an ideal, electrically safe environment, all hazards and risks are eliminated. A descending staircase could represent moving from a preferred action to less desirable action but who would get the analogy? The steps may not depict a hierarchy and could be interpreted as an attempt to illustrate the process of using it. No matter how the hierarchy is drawn someone will take issue with it based on their point of reference. If you want it to be a process then a triangle will not make sense no matter which orientation is used. If you want it to be an indication of a desired order, should the base be the highest control or the lowest one or to use it should you start at the top or bottom? If you simply look at the triangle as a hierarchy it probably will make sense to you. The figure is serving its purpose and many have finally been made aware of the hierarchy. Your frame of reference will determine if you agree with the figure or any rendering for that matter. However, no matter how you see it, it is a hierarchy and you must use it as required by 110.1(H)(3).
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