Why do so many of us get wrapped around the axle? We are all committed to electrical safety. We all know that removing an electrical hazard is a good thing. But is removing the hazard the same as eliminating the hazard? Can a hazard only be permanently eliminated? If so, does this mean a hazard can only be temporarily removed but not temporarily eliminated? I might be an instigator of this confusion because I never expected it to be an issue. I do believe that a hazard that never exists should be the goal. I have often stated that “full elimination of the hazard is often not an option for installed equipment. Although elimination also can be achieved by applying other controls such as through establishing an electrically safe work condition (ESWC), these other controls introduce a potential for human error. Therefore, the initial attempt should be full elimination of the hazard.” I do not believe such a statement alters meaning of the word elimination. I was not aware that elimination has a time component for many of you. I haven’t found a definition of elimination that includes a time base. Here is the problem.
Many in the electrical safety industry consider the hierarchy of risk controls to first eliminate the electrical hazard. This is such that there is no electrical hazard at any time. I agree. NFPA 70E®, Standard for Electrical Safety in the Workplace® states that it includes installation of electrical equipment but such work is typically not conducted while energized. I believe the electrical safety of employees should be addressed at design and installation regardless whether NFPA 70E applies at that time or not. Under this belief, I have stated that full elimination of the hazard should be considered at design of the equipment as well as the design of the electrical system. I hold on to that belief since attempting it will protect future employees by making electrical installations safer. I would then consider the rest of the hierarchy for the installation to further control hazards and risks while the system design, equipment selection and installation are being considered.
For many of users of NFPA 70E, a problem comes with requirement in 105.4 that hazard elimination be the first priority. Another issue is many reference another standard where elimination only means “total elimination.” That fixed idea may not be applicable to elimination within NFPA 70E. It is typically not possible to permanently eliminate the hazard using work the practices required by NFPA 70E. Once equipment has been installed my concept of hazard elimination shifts but my definition of elimination does not. When using the hierarchy of risk controls for work practices on installed equipment, I run down the list again. Full elimination, substitution, and engineering controls are typically not possible. This brings me to the other controls (administrative, awareness, personal protective equipment (PPE). Under NFPA 70E these lead to establishing an ESWC which temporarily removes (or eliminates) electrical hazards in a specific location for a finite period of time. This leads many to believe that they have not met the goal of “elimination” of the hazard as a first priority. Many consider only full removal of the hazard as in the first context (previous paragraph) to be elimination, therefore removal of the hazard in this second context cannot also mean elimination.
I must be missing something. A sports team is eliminated from the playoffs, they are not eliminated from the league. It is a temporary thing. When a hazard is verified as not being present, it has been removed or eliminated regardless of time. There are many intricacies of requirements in a standard that you must handle on your own. NFPA 70E is no different and elimination is one of those. NFPA 70E does not mention permanent or temporary elimination of a hazard, it is simply elimination. To my knowledge I have never stated that the only elimination of a hazard is permanent elimination. I have said that the process of establishing an ESWC is not the elimination control but it results in the elimination of the hazard. There is a difference. But it is just what the standard required by eliminating the hazard through work processes. The employee will not be injured since there is no electrical hazard present where the task is being performed. You will not convince me that permanent elimination should not be considered first. However, if permanent removal of the hazard is not possible then removal of the hazard on a temporary basis is a very effective method of protecting an employee. I also do not believe that an ESWC be a default work practice without further considering ways to mitigate the hazard or risk.
I expect that much of the second draft meeting will be spent addressing the meaning of the word elimination. If full elimination or an attempt to mitigate a hazard is not addressed, many of you will ignore the hierarchy and only establish an ESWC on all equipment. On the other hand, if elimination only means an ESWC, the safety of future electrical employees will continue to be jeopardized by not mitigating the exposed hazard during the process of establishing the ESWC. Since the concern has been raised, we are getting wrapped around the axle on meaning of the word elimination. But I am not sure how many do not understand what it means and how to use it in regards to NFPA 70E. The solution may be worse than the problem it is trying to solve.
For more information on 70E, read my entire 70E blog series on Xchange
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Next time: Equipment that has electrical hazards beyond what safety equipment is designed for.
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