A Better Understanding of NFPA 70E: Three Different Approaches to Electrical Safety and Their Consequences

Blog Post created by ccoache Employee on Sep 4, 2019

At the 2019 NFPA Conference & Expo in San Antonio, I presented a program that covered NFPA 70E, Standard for Electrical Safety in the Workplace and energized work permits. For that presentation, those attending were to consider work tasks and the justification for energized work. Scenarios presented were taken from National Institute for Occupational Safety and Health (NIOSH) case studies. Three of the scenarios included the task of wiring a 277-volt lighting system. This is a simple task, which should be expected to be pulled off without a hitch. Unfortunately, it was not. While going through the NIOSH system, I was surprised at how many electrocutions occur in the US while wiring a 277-volt lighting system. Such situations may be why the number of electrocutions in the workplace have been relatively consistent since 2012.

All three scenarios involved installing a circuit or extending an existing circuit for a 277-volt emergency lighting system. The task was assigned to a journeyman electrician with several years of experience (Victim #1), a 12-year master electrician (Victim #2), and a journeyman electrician just finished with an apprenticeship (Victim #3). As you can tell by the designation of "Victim" not one of them returned home that day. They all became a fatality for the same reason - making contact with an energized conductor. Many in the electrical industry consider this task to be routine or to be low risk. With this kind of mind-set, the task is often performed as unjustified energized work. It's hard to comprehend a situation where this task must be conducted while energized. Even without establishing a proper electrically safe work condition, you would think that flipping the switch off or opening the breaker would be a minimum step for performing the task. Although I do not condone energized work, it seems as if there wasn't an understanding of the use of properly rated, insulated tools and gloves. Where else did the safety programs of their employer fail these victims?

The employer stated that Victim #1 should have been trained by a previous employer. Apparently, in this case, it did not matter if a previous job has no transferable skills or training to the new employer. There was no written safety program, policy or procedures. Foreman are responsible for job site safety and for holding weekly safety meetings. Both the foremen and manager claimed to be unaware of past safety issues. However, interviews with the foremen and other electricians revealed that making connections while conductors are “hot” was not an unusual practice and was done more often than not. In addition, several prior shock incidents reveal that employees assigned to perform electrical tasks had not been adequately trained. The employer was unaware of this lack of training although they did not provide any safety training. In a nutshell, there was nothing documented to show that Victim #1 was a qualified person. How could there be documentation? No requirements from NFPA 70E were addressed by the employer. 

Victim #2’s fatality is troubling. The employer had a written safety program that included safety rules, safe work procedures for specific settings, and a lockout procedure. The employer used on-the-job training and reinforced it with safety manuals, scheduled safety meetings, and printed materials. Bi-weekly safety meetings were conducted by field foremen to discuss safety and other job-related topics. All employees worked under close supervision of a field foreman and were checked on how well they performed expected tasks before they were permitted to work alone. In addition to the years spent becoming a master electrician, Victim #2 had demonstrated sufficient skills to be designated as a field foreman. Working on energized conductors was not permitted by company policy and no employee had previously been found in violation of that rule. In this case, the employer appears to have done much to prevent an electrocution. However, this master electrician did not return home that day.

Comments by the employer of Victim #3 show how the “facts” become cloudy after a fatality. The employer did not have any electrical safety work program, policies, or procedures. They felt none were necessary since, as a contract employer under a signed contract, their employees were required to follow the host employer’s electrical safety program and lock out procedures. The employer also expected that Victim #3 was previously trained while becoming a journeyman electrician. How could the victim’s general  training possibly address the host employer’s required, specific safety procedure? In addition, the foreman stated that that there was no reason for the circuits to be energized and that every circuit is tested beforehand. How could this verification occur if there was no company safety policy to establish an electrically safe work condition? The foreman appears to have been aware of the contract requiring that his electricians follow the host employer’s policy to establish an electrically safe work condition. However, there was no training provided to the victim. This scenario not only illustrates issues with a host and contract employer’s situation, but that a perceived safety culture is dangerous.

One simple task. Three concepts of electrical safety training. Three perceptions of a qualified person. Three approaches to electrical safety. A decision to work energized. Three mistakes. Three fatalities. Three families devastated.


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