An important issue has arisen with NFPA 70E®, Standard for Electrical Safety in the Workplace® and what it takes to establish an electrically safe work condition (ESWC). There have been some misinterpretations of the content. The issue revolves around the hierarchy of risk controls, the act of establishing an ESWC and a properly established EWSC. The words are carefully chosen and it is troubling that they are being misunderstood. If I have made an error in my presentations, in NFPA 70E®, Handbook for Electrical Safety in the Workplace® or in this blog that a properly established ESWC has not removed the hazard, I apologize for that. However, I am not aware of any instance where this has occurred and would gladly welcome any feedback. The following statements from those forums agree with industry’s view that a properly established ESWC has removed the hazard:
- After this strategy (EWSC) is executed, all electrical energy has been removed from all conductors and circuit parts to which the employee could be exposed.
- Where an ESWC exists, there is no electrical energy in proximity of the work task(s). The danger of injury from electrical hazards has been removed, and neither protective equipment nor special safety training is required.
- By creating an ESWC, the risks associated with potential electrical hazards have been temporarily reduced to an acceptable level and electrical hazards have temporarily been effectively removed.
- There is no electrical hazard when equipment is in an ESWC. You will not be harmed by electrical energy.
- If trainers are stating that establishing an ESWC is an administrative control they are correct. However, they should be stating that it (an ESWC) achieves elimination of the hazard through the use of several of the controls.
How you look at the hierarchy is a safety issue. If you believe the act of establishing an ESWC is an elimination control there would be no need to exhaust time or money in an attempt to use substitution, engineering, awareness, administrative or PPE as a control function since the hazard has been eliminated. Step 1: ESWC. Done. However, I don’t see it that way since the act of establishing an ESWC and a properly established ESWC are two separate concepts. The act of establishing an ESWC relies on awareness, administrative, and PPE controls to achieve elimination. The hazard is not suddenly eliminated. An ESWC does not exist until all eight steps of 120.5 have been completed. With electrical safety do not treat this as a trivial matter. What seems to be misunderstood is the applicability of the required hierarchy of risk controls. The following statements help clarify the issue:
- Regardless of the intent to require the establishment of an electrically safe work condition or to justify energized work, the hierarchy of risk controls must be implemented to minimize the hazard or risk of injury.
- In this first context, elimination is the removal of the electrical hazard so that it does not exist at any time. If there is no hazard there is no risk of injury.
- Temporary removal of a hazard may be achieved through the administrative control of creating an electrically safe work condition (ESWC) discussed in item 5 (administrative controls).
- Elimination can be also be achieved by applying other controls, such as through the establishment of an electrically safe work condition.
- Establishing an ESWC is possibly the most recognized administrative control addressed in NFPA 70E. 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.
There is a safety concern which clearly indicates that the hazard is not eliminated during the act of establishing an ESWC. Additional statements regarding this follow:
- There is no way to establish an ESWC without some risk of exposure to a potential hazard.
- Until the task (ESWC) is completed, a worker is exposed to hazards and potential injury since there is no assurance that the equipment is properly de-energized.
- 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.
- Until the ESWC is established, an unacceptable risk of injury exists and employees must continue to wear protective equipment.
The chosen words convey the fact that the act of establishing an ESWC is not elimination of the hazard. The act of establishing an ESWC relies on awareness, administrative, and PPE controls not on elimination. These are numbers four (4), five (5) and six (6) on the hierarchy. Once the EWSC has been properly established, elimination of the hazard has been achieved. Equipment in an ESWC has had the hazards removed. The chosen words consistently convey this fact.
The fact is that the primary work procedure must be to establish an EWSC. Consider what the employee must do before they are permitted to remove their PPE (time when the hazard has been eliminated). If the act of establishing an ESWC was elimination of the hazard, there would be no need for an energized work permit, training, safe work procedures, or the donning of PPE. It is often difficult to see things differently than what is currently considered. In my mind, the act of establishing an ESWC was an elimination control until this specific hierarchy of risk controls became a requirement. The hierarchy has helped clarify the difference between the act of establishing and a properly established EWSC.
This should help clarify the difference between the risk control of elimination and the risk controls of awareness, administrative, and PPE necessary to establish an ESWC. It is equally important for safety to make a distinction between the act of establishing an ESWC and the result of a properly established ESWC. When you think of them as the separate issues that they are, it allows the hierarchy to be implemented to increase electrical safety. This should clarify my position on the issue of an electrically safe work condition. I am not aware that any of my statements are incorrect based on the requirements in NFPA 70E. Please quote me correctly. This is not semantics. This is employee safety.
For more information on 70E, read my entire 70E blog series on Xchange.
Next time: Outsourcing your risk assessments.