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61 Posts authored by: ccoache Employee

 

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

 

Want to keep track of what is happening with the National Electrical Code® (NEC®)? Subscribe to the NEC Connect newsletter to stay informed of new content. The newsletter also includes NFPA 70E information such as my blogs.

 

Next time: Equipment that has electrical hazards beyond what safety equipment is designed for.

 

Please note: Any comments, suggested text changes, or technical issues related to NFPA Standards posted or raised in this communication are not submissions to the NFPA standards development process and therefore will not be considered by the technical committee(s) responsible for NFPA Standards development. To learn how to participate in the NFPA standards development process and submit proposed text for consideration by the responsible technical committee(s), please go to www.nfpa.org/submitpi for instructions.

As you know, NFPA 70E®Standard for Electrical Safety in the Workplace® does not determine what normal operation of your equipment entails. NFPA 70E details the normal operating conditions necessary before someone can safely operate that equipment. So, in that regard, which of these do you consider to be normal operation of the equipment?

  1. Flipping a light switch in an office.
  2. Placing a light bulb into a socket.
  3. Opening a motor disconnect.
  4. Placing an ammeter into a circuit to measure current.
  5. Operating a circuit breaker in a panelboard after opening the hinged cover.
  6. Placing a fuse into a fuse holder.
  7. Replacing a ballast in a luminaire.
  8. Placing an appliance plug into a receptacle.
  9. Pushing an emergency stop on equipment.
  10. Racking a circuit breaker out of a cabinet.
  11. Plugging a circuit breaker into a panelboard.
  12. Replacing a damaged receptacle.
  13. Pulling conductors through rigid metal conduit.
  14. Programming a variable frequency drive.

Remember that the tasks you consider to be “normal operation” of the equipment should be able to be done while energized and without the need to use personal protective equipment (PPE). If you are required to use PPE it generally means that the equipment is not under normal operating conditions and therefore, the task is not normal operation. Opting not to wear PPE while performing a task does not make the task “normal operation.” Here in the United States of America, it is not believed that equipment meeting the normal operating condition requirements is inherently unsafe to the person properly operating the equipment. No interaction would be permitted with any electrical equipment if it were. Pulling the trigger on a hand tool, using a computer, charging a cell phone, or playing a video game would pose risks and hazards that could cause injury. Such a condition would require PPE for all of those tasks. Only qualified persons could perform those tasks. Luckily, society has agreed that such precautions are not necessary. 

All the tasks listed are necessary for the equipment to function as designed. I am pretty sure you will find manufacturer’s instructions that include the above tasks or the equipment is specifically designed to permit performance of the task. And if it is in the instructions or if the equipment is designed to do it, does that make the task normal operation of that equipment? Your decision to deem something to be “normal operation” plays a big part in protecting employees from injury. I am not going to state which of the above tasks are normal operation. That is not my call. That is not NFPA 70E’s call. It is your call.

For more information on 70E, read my entire 70E blog series on Xchange

Want to keep track of what is happening with the National Electrical Code® (NEC®) Subscribe to the NEC Connect newsletter to stay informed of new content. The newsletter also includes NFPA 70E information such as my blogs.

Next time: Elimination of an electrical hazard.

Please Note: Any comments, suggested text changes, or technical issues related to NFPA Standards posted or raised in this communication are not submissions to the NFPA standards development process and therefore will not be considered by the technical committee(s) responsible for NFPA Standards development.  To learn how to participate in the NFPA standards development process and submit proposed text for consideration by the responsible technical committee(s), please go to www.nfpa.org/submitpi for instructions.

There still seems to be a misunderstanding about the responsibility of the purchaser when is comes to personal protective equipment (PPE). As explained in my blog, Who verifies that personal protective equipment (PPE) meets the correct standards, it is and always has been your responsibility to verify PPE meets all standards. From the purchaser to the manager to the wearer of the PPE, as well as the safety manager, facility manager, supervisor, etc. failure to make this determination places the employee at risk of injury. You have the responsibility of obtaining assurance that the PPE complies with the applicable standard. You are responsible for assuring that PPE that makes false claims or that is knock-off or counterfeit is not issued to the employee. It is your responsibility to provide equipment that is suitable for the installation or in the case of NFPA 70E®Standard for Electrical Safety in the Workplace®, that the PPE has been evaluated to protect an employee.

There are many pieces of equipment, including PPE, in the electrical industry that are not required to be evaluated (listed) by a third party. Just as in previous editions, the 2018 Edition of NFPA 70E requires that PPE conform to the applicable standards without actually requiring the manufacturer submit the PPE to testing. This is because NFPA 70E is a work practice standard that PPE manufacturers do not have to follow. Since evaluation of PPE to any product standard is not a requirement in many codes and standards that address electrical safety, NFPA 70E took steps in the 2018 edition to provide some guidance to assist you in verifying the manufacturer’s claim of compliance to applicable standards. These are self-declaration, self-declaration under a quality management system, and certification (listing) by a third party. Let’s look at what these mean starting from the most understood to possibly the least understood claim.

Certification by a third party is a common way for equipment to be deemed suitable by a purchaser, authority having jurisdiction, or user of the equipment. This is referred to a Listing in NFPA standards. Within the United States of America (USA), OSHA has a process for accrediting organizations for performing evaluations using specific standards. An evaluation of equipment by an independent party to a published standard removes many apprehensions of someone tasked with approving equipment for use or purchase. It allows for a quick determination that equipment is indeed suitable for the use and that it complies with the minimum requirements of the applicable standard. As part of listing, the independent party also audits manufacturing sites to have continued assurance that equipment built over a period of time is identical to what was originally listed. If materials, manufacturing processes, or drawings are different that submitted for the certification, the listing of the equipment may be withdrawn until the “new” version is determined to comply with the standard. Equipment may be listed as complying with many standards. It is also your responsibility to verify that the equipment purchased has met the correct standard.

 

Self-declaration (Declaration of Conformity (DoC)) is possibly the second most understood of the conformity allowances. This is simply a statement by the manufacturer that the equipment meets a standard. You must be competent enough to know if the specified standard is applicable to the final product. Some standards evaluate fabric only, not the final product (i.e., shirt, pants) that is made of the fabric. A separate standard may be necessary to address the testing of the final product. There is no external oversight of the testing, manufacturing or raw material procurement process under this system. The manufacturer may or may not be able to conduct tests or evaluate the final product for compliance with the applicable standard. Neither prohibits them from supplying this DoC. Outside of the USA, a DoC is a legal document declaring that the equipment complies with the specific laws of the governing country. Some of those DoCs may only cover recycling of the equipment. Those DoCs do not typically address USA standards including the National Electrical Code® (NEC)®. There are substantial liabilities, fines and imprisonment for falsifying those DoCs. However, within the USA, the DoC is not tied to a legal system although the USA is a highly litigious country. The DoC is as good as the credible company backing it with their reputation.

 

The least understood of the conformity methods is a DoC under a registered quality management system and product testing by an accredited laboratory. A registered quality management system (typically IS0 9000 series) requires documentation of many company functions. Documentation of an engineering change order system for document revisions, of test and inspection procedures, and of returned equipment are examples of topics addressed. This quality system typically does not address required safety standards for the equipment being manufactured but only that documentation is in place to have a manufacturing process followed. The accredited laboratory portion of this method is not necessarily an independent testing laboratory. Many registered quality management companies have an accredited on-site laboratory to conduct evaluations and testing of their products by company employees. The credibility of the manufacturer is once again an important factor with this type of DoC.

 

Delivery of one of these conformity methods does not absolve you of the responsibility for determining the validity of a claim. You must be competent to understand the standard applicable to the purchased PPE, the correctness of the claim, the validity of the test results, or verification of a listing mark. No matter which conformity assessment you request there will be non-compliant PPE or counterfeit versions of a credible manufacturer’s PPE. False claims may be made. A transient company may market PPE and provide a false listing or DoC to take advantage of a growing market. A company producing counterfeit PPE will provide an apparently valid DoC or listing mark. The “same” arc-flash suit that is substantially less expensive than from a reputable manufacturer or distributor can be purchased from some online party. Caveat emptor (buyer beware) is the rule for anything you purchase but it is even more important when someone’s life is at risk. The approved vendor or distributor, reputable manufacturer, DoC and product listing organization is there for a reason. For the protection of your employee you must do some homework before purchasing the PPE. That requirement has not changed.

 

For more information on 70E, read my entire 70E blog series on Xchange, or sign up for NFPA's electrical newsletter.

 

Next time: A normal operation quiz.

 

Please Note: Any comments, suggested text changes, or technical issues related to NFPA Standards posted or raised in this communication are not submissions to the NFPA standards development process and therefore will not be considered by the technical committee(s) responsible for NFPA Standards development. To learn how to participate in the NFPA standards development process and submit proposed text for consideration by the responsible technical committee(s), please go to www.nfpa.org/submitpi for instructions.

 

NFPA 70E®, Standard for Electrical Safety in the Workplace® has been processed through the First Draft stage and will soon be open for public comment. The first draft will be posted on or before February 27, 2019 allowing you to review what occurred during the First Draft. When the first draft is posted it will be available at https://www.nfpa.org/codes-and-standards/all-codes-and-standards/list-of-codes-and-standards/detail?code=70E&tab=nextedition.

 

The 332 submitted public inputs resulted in 86 revisions being made to the standard. A majority of revisions added informational notes to help explain requirements that many were having trouble understanding or to provide additional guidance on where to find pertinent information.

 

If your submitted input received a reply of Reject But See from the technical committee it means that your idea or concept was included but it was not possible to use the wording as you had submitted. Also, the information from all public inputs on a single requirement are addressed as one revision. This often requires combining the concepts proposed by several inputs to develop a single requirement. This also results in a Reject But See response to all affected public inputs since each may have had different changes. The first revisions created by such inputs should be reviewed to make sure the concept of your input was incorporated in a way to resolve your concern with the standard or the requirement.

 

Remember that the first draft only contains the changes made to the standard. There were 332 proposed changes submitted for consideration. You should review the public inputs, including those from others, to see if there was something submitted that did not result in a change. Sometimes a submitted comment provides necessary information or further clarifies a concern or requirement. It is not unusual for a comment on a rejected public input to lead to a second revision due to this additional information. Note that without a submitted comment on a particular public input, this second draft stage will be your last chance to have that public input reconsidered.

 

As a final note, essentially new information or a new requirement cannot be added during the Second Draft stage. However, this does not mean that changes cannot be made. Anything added in the second draft process must be based on something that occurred during the first draft. Changes may also be made if a first revision made another subsequent change necessary during the second draft.

 

You and your colleagues have ideas on how to better protect yourself or your employees from the electrical hazards faced during a work day. You are the ones who need to understand how to apply the requirements. Everyone wants to make it home safely today. As previously stated in my blogs before - it is your standard. Be a part of it.

 

For more information on 70E, read my entire 70E blog series on Xchange.

 

Next time: Verification of manufacturer’s PPE ratings.

 

Please Note: Any comments, suggested text changes, or technical issues related to NFPA Standards posted or raised in this communication are not submissions to the NFPA standards development process and therefore will not be considered by the technical committee(s) responsible for NFPA Standards development. To learn how to participate in the NFPA standards development process and submit proposed text for consideration by the responsible technical committee(s), please go to www.nfpa.org/submitpi for instructions.

 

What do you think of when you hear the phrase protective equipment? Many of you likely went right to clothing but protective equipment is anything used to protect the employee from injury. Clothing, hard hats, multi-meters, hand tools and insulating blankets are all equipment that provide protection for the employee. For each of these to achieve that goal they must be properly maintained. An employer is responsible for assuring that appropriate protective equipment is provided to the employee. It is relatively easy for the employer to purchase and verify that equipment is compliant and suitably rated. What happens after the equipment is issued for use is more difficult to track. However, all that equipment must be verified to provide the necessary protection whether the equipment was purchased yesterday or ten years ago.


An employer must have a well-documented policy for the handling of each piece of protective equipment. It is equally important to provide proper inspection training for employees using the equipment. How to inspect an arc-rated suit is entirely different from inspecting voltage rated gloves. Transportation, on-site conditions, and rugged use necessitate an inspection immediately prior to use. A general rule is that protective equipment be inspected before each use. Visual inspection often provides the first sign that protective equipment may not perform as necessary. If the equipment is defective or suspect in any way it must be brought back into compliance before use.


Equipment that is used infrequently must be maintained just as equipment that is used daily. Insulation properties can be effected by time, storage method or atmospheric conditions. Annual calibration of a multi-meter typically does not verify proper insulation. Some equipment may be kept in a common area for use by several employees, some may be issued to individual employees, some may be purchased by the employee, and some may be leased. All this equipment requires appropriate scheduling to be properly maintained in order to protect the employee. For the most part, proper maintenance is directed by the equipment manufacturer. Who performs the maintenance is often the choice of the purchaser. The selection is critical since an employee will be at risk of injury if the equipment is not properly maintained.


What about the protective clothing? More expensive gear like an arc-rated suit may be purchased and maintained by the employer. But every day arc-rated shirts and pants may be the employee’s responsibility to purchase as well as maintain. Rips and tears must be properly repaired. Contaminated gear may be prone to catastrophic failure. Laundering must be done in the correct cycle and temperature as well as with appropriate detergent. If anything is done incorrectly, the protection may not be there when needed. An employer is responsible for protecting an employee. This is true regardless of who is maintaining the protective gear. What is your company’s policy and procedure for the maintaining equipment used to protect you?


For more information on 70E, read my entire 70E blog series on Xchange.


Next time: NFPA 70E Second Draft.


Please Note: Any comments, suggested text changes, or technical issues related to NFPA Standards posted or raised in this communication are not submissions to the NFPA standards development process and therefore will not be considered by the technical committee(s) responsible for NFPA Standards development. To learn how to participate in the NFPA standards development process and submit proposed text for consideration by the responsible technical committee(s), please go to www.nfpa.org/submitpi for instructions.

An employer using NFPA 70E®, Standard for Electrical Safety in the Workplace®can be either a host or contract employer. If an employer is using in-house workers it is obvious who has the responsibility for 130.2(A). When a contractor is working for a host employer it may become less obvious for the application of 130.2(A). However, consider that both the host and contract employer have responsibilities set forth in Article 110. Each is responsible for assuring proper protection for their own employees.
In a host/contractor situation, the host may determine that energized work is justified or simply that they don’t want the system to be turned off. However, the contract employer should fully understand the reason behind the energized work and has the responsibility of protecting their employees from electrical hazards. If the contract employer feels their employees are at undue risk, there is no requirement that they perform the proposed task. On the other hand, the contract employer may decide that their employee can handle energized work or may determine that energized work is justified. However, if the host employer feels the contract employer will use unsafe work practices there is no requirement that the contractor be used to perform the work.
From an NFPA 70E viewpoint, both the host employer and contract employer should have a fully developed electrical safety program. For the host employer, the program should address both in-house and contract work. Using contract workers does not absolve the host employer of their obligation to provide a work environment that is federally mandated to be free of recognized hazards. In order to do so, the host employer must notify a contract employer of known hazards. The contract employer’s electrical safety program should not only address common electrical safety issues but also conditions anticipated for the specific tasks conducted at a host employer site. The contract worker must be qualified to perform the assigned task on the specific equipment present at the host employer site.
If electrical work is to be performed there will almost always be known hazards. This is true whether an electrically safe work condition (ESWC) will be established or energized work will be justified. A documented meeting between the host and contract employer is therefore required. The meeting should cover many things. Before any work has begun it is first necessary to determine that the equipment is indeed in a normal operating condition. Anything otherwise can pose risks not anticipated. Inspection, maintenance, and failure logs should be reviewed. A risk assessment is necessary for the assigned task on the specific equipment. This could be a review of the risk assessment provided by the host employer or a previous risk assessment by the contract employer. It could be the first assessment for that task on that equipment. It may require verification of the parameters on the equipment label.  
If an ESWC is to be established, it is possible that each employer has a procedure. One procedure may be more thorough or stringent than the other. The host and contract employers must agree on the procedure to be used. A contract worker may not be familiar with the host’s procedure, and training should be provided to that worker. A detailed record should be developed if a task will be conducted while energized. The host employer is typically responsible for the safety of anyone present in their facility. A contract employer has a responsibility to protect their workers at a contract site. In no case should an employee be subjected to unjustified, exposed, energized electrical hazards.
There are many other things that a host and contract employer must reach agreement on before a contract worker begins a task. Who decides that the equipment is under normal operating conditions? Whose PPE will be used? Who will provide any specialized equipment? Who is responsible for verifying that all PPE is suitable for the assigned task? How will affected host employees be notified of the task? Who will be responsible for establishing and enforcing the approach boundaries? What happens when the procedure will include a complex lockout program? A host employer occasionally feels that they have no obligations or responsibility for safety of a contract worker. A contract employer sometimes feels as if they know better than the host employer. The rules of electrically safety apply regardless of a host or contract employee conducting the task but someone must make sure that the rules are followed. This needs to be determined before any task has begun. 
The host and contract employer relationship is unique. Both employers are responsible for the safety of a contract worker at risk of an injury. There must be open and honest dialog between the two employers for there to be a true safety culture for a contract worker. The host employer may look at things differently if they treat the contract worker as one of their own. The contract employer may benefit by considering employee safety above all else. The welfare of the employee should always be in the forefront of any decision and revenue for either party should not be part of the safety discussion.
For more information on 70E, read my entire 70E blog series on Xchange
Next time: Maintaining protective equipment.
Please Note: Any comments, suggested text changes, or technical issues related to NFPA Standards posted or raised in this communication are not submissions to the NFPA standards development process and therefore will not be considered by the technical committee(s) responsible for NFPA Standards development. To learn how to participate in the NFPA standards development process and submit proposed text for consideration by the responsible technical committee(s), please go to www.nfpa.org/submitfor instructions.
It has been over a year since I summarized the Bureau of Labor Statistics (BLS) fatal electric injury statistics. You can read my blog about it here. To refresh your memory there currently is an annual average of 192 fatal electrical injuries (U.S.A.). This accounts for about 12% of the fatalities in the occupations generally covered by NFPA electrical standards. An American employee is killed by electricity every day and half of work. Luckily, many more of you make it home than do not. However, that does not mean that you returned home unscathed. You made it home but where you uninjured? Here are some non-fatal injury statistics between 2012 and 2016. You can read the summarized NFPA report online.
About 9,760 (2012-2016) of you in the U.S. were injured through direct and indirect exposure to electricity. “Direct exposure to electricity” is contact with a power source, such as touching a live electrical wire. “Indirect exposure to electricity” refers to injuries resulting from contact with material that is unintentionally conducting electricity. This is an average of 1,952 injuries per year which due to a downward trend is lower than the decade average of 2,155 per year (2007-2016). Although you escaped being a fatality, nearly eight of you are injured every work day. This does not mean you returned to work the next day. Nearly one half of your injuries resulted in 6 or more days away from work. Putting it another way, your reported electrical injuries resulted in considerable lost work time (41% of injuries required more than two weeks away from work).
Electrical injuries are experienced by all occupations including those not necessarily associated with exposure to electrical hazards While employees in installation, maintenance, repair, and construction occupations account for the largest number of injuries, a substantial number of injuries involve other occupations, including service, production, transportation and material moving, and sales and related occupations. Electrical parts and materials accounted for 59% of the injuries. Furniture or fixtures (5%), and hand tools (5%) are on the other end of the specified injury source list. 26% (2,540) of exposure injuries involved a voltage of 220 volts or less and 14% (1,400 injuries) involved a voltage of greater than 220 volts. Voltage was unspecified in the remainder of the injuries. An interesting statistic is that 16% of the injured were female whereas that group suffered 1% of the fatal electrical injuries. 
A much higher share of injuries from direct exposure to electricity resulted from contact with parts and materials (67%) than for indirect exposure (41%). This is the primary statistic that NFPA 70E strives to reduce. In the workplace, direct contact to exposed, energized parts is specifically addressed in NFPA 70E. First, it must be justified for you to cross the restricted approach boundary while the circuit is energized rather than in an electrically safe work condition. Second, if you do cross the boundary you must be properly insulated from the energized part by PPE. This requirement, if followed, would have prevented many of your direct contact injuries. Properly maintained equipment under normal operating conditions, as required for general electrical safety, may have had addressed many of your indirect exposure injuries.
Shock and electrocution have been a known electrical hazard since the beginning. Insulation as protection from electrical shock has existed since the start. It is troubling that 120 years later these injuries are still occurring. Yes, some of these injuries were completely unexpected. However, an injury should not be seen as unexpected when you are knowingly exposed to electrical hazards. It is very probable that many of you were injured because you were not provided proper training or an inexpensive, properly insulted tool when performing properly justified energized tasks.
These injuries are only those that are reported. Shocks and near-death experiences are very often not reported. Unreported injuries would be a magnitude or two higher than these reported injuries. Electrical injuries can be reduced through the use of proper safety procedures, training, personal protective equipment, and other methods. It’s important for you to receive appropriate training for the tasks assigned to you. You may have returned home today but were you injured or have a near-death experience?
For more information on 70E, read my entire 70E blog series on Xchange
Next time: Are you a host employer or a contract employer.
Please Note: Any comments, suggested text changes, or technical issues related to NFPA Standards posted or raised in this communication are not submissions to the NFPA standards development process and therefore will not be considered by the technical committee(s) responsible for NFPA Standards development. To learn how to participate in the NFPA standards development process and submit proposed text for consideration by the responsible technical committee(s), please go to www.nfpa.org/submitpi for instructions.
If the National Electrical Code® (NEC®)covers the installation of electrical equipment and provides for the practical safeguarding of persons and property from hazards arising from the use of electricity and NFPA 70E®, Standard for Electrical Safety in the Workplace®addresses electrical safety-related work practices for employee workplaces then how does someone span the gap between the two? That statement may surprise many of you. There’s a gap between the two standards? How can that be? From the questions I receive regarding both standards, there is a difference between what could be done and what is required to be done. 
The NEC covers the installation of electrical equipment. When electrical equipment is installed in compliance with the NEC, properly designed electrical equipment does not normally pose a risk to a person interacting with the equipment under normal operating conditions. NFPA 70E also covers a person interacting with the equipment under normal operating conditions but not from the installation aspect. NFPA 70E approaches safety from the procedural aspect of interacting with the equipment. NFPA 70E furthermore covers electrical safety when an employee is exposed to electrical hazards or the equipment is not under normal operating conditions. Neither of these conditions are addressed by the NEC. Again from NFPA 70E this is from a procedural viewpoint. So where is the gap between the two? It is in how many people approach electrical safety. Often the safe installation is completed then an electrical safety procedure is developed to address situations when an employee is exposed to electrical hazards.
Should it be that installation is installation and employee electrical safety is employee electrical safety and never the twain shall meet? Since the NEC and NFPA 70E are not always utilized by the same person and since the use of the NEC is often legislated, many consider electrical installations and electrical safety programs to be separate and distinct from one another. Something not required for a NEC compliant installation is historically not done. The NEC provides installation requirements for equipment operating at kilovolts, kiloamps and kilojoules. Correctly installed there are no exposed electrical hazards. Installation is not presumed to be energized work therefore the NEC does not address safe work practices. NFPA 70E addresses how to protect an employee when those electrical hazards are exposed. So if everyone is protected where is that gap?
I receive many questions regarding electrical safety. When descriptions of some designs and installations are given, if the question is regarding NFPA 70E, I often ask why is it being done that way. The answer usually is because the installation is permitted. I often mention that since employees will be exposed to electrical hazards when performing justified energized work, there are ways the exposure might possibly be eliminated or reduced. The reply is often that such an installation is not required. That is the gap I am talking about. There are those who install equipment in a safe manner and those who must work in a safe manner while exposed to electrical hazards. Safe work practices are not part of a de-energized installation and installation is not a work practice for exposed electrical hazards. 
For electrical safety to progress for anyone interacting with electrical equipment, electrical safety should to take a holistic approach. There are thousands of ways to install a piece of equipment while complying with the NEC requirements. One method is selected but all would result in a safe installation. The equipment will be operated safely. However, the decision to install in a particular manner can have a great effect on someone responsible for maintaining that equipment. That installation decision has a lasting impact on electrical safety for the life of that equipment. These decisions need to be made prior to installation in order to be effective. Touch safe terminals, fast-acting overcurrent devices, or some other engineering controls are installation decisions that can have a significant impact on the safety for future employees. 
Both installation and work practices impact electrical safety but they are separate and distinct electrical industries. There is no limit to the amount of energy that a safe installation can contain. However, once an employee is exposed to those hazards hindsight regarding the installation decision is too late. Electrical safety procedures are written to address the resultant electrical hazards when the safe installation is moved into a maintenance situation. In a holistic approach to electrical safety, the installation considers justified employee exposure to hazards and methods of controlling them. Under that condition, the future employee exposed to the hazards is not only protected by the installation but by the work practices. Do your electrical installations consider the future?
For more information on 70E, read my entire 70E blog series on Xchange
Next time: Non-fatal injury statistics.
Please Note: Any comments, suggested text changes, or technical issues related to NFPA Standards posted or raised in this communication are not submissions to the NFPA standards development process and therefore will not be considered by the technical committee(s) responsible for NFPA Standards development. To learn how to participate in the NFPA standards development process and submit proposed text for consideration by the responsible technical committee(s), please go to www.nfpa.org/submitpifor instructions.
New equipment is added to a facility. Knowledge gained while working through an issue drives change in safety standards. Employees with different backgrounds and from different generations have dissimilar learning styles. Electrical safety is not a static field, it is more dynamic than often believed. How do you evaluate your electrical safety program? Training, procedures and practices involving electrical safety need to be periodically reviewed to not only stay current but to be effective. NFPA 70E®, Standard for Electrical Safety in the Workplace® contains many requirements which should be your starting point for auditing an electrical safety program (ESP).
The first place NFPA 70E requires an evaluation of an ESP is in 110.1(F). Controls are the company’s electrical safety metrics for determining if the ESP is effective and efficient. In order to evaluate a system, you need to know where you started and how far you have come. Metrics are measurable points to determine performance. They also can be used to determine if improvements to the safety program are required and, if so, what needs to be changed. There are two common metrics used to determine the effectiveness of something: lagging metrics and leading metrics. Lagging metrics provide a reactive view of a safety program. Leading metrics are used to identify and correct contributing factors before an incident occurs. A combination of these metrics can enhance a safe work program.
Next in NFPA 70E, 110.1(K) covers necessary audits. Auditing and enforcement is a critical part of any electrical safety program. It is vital that the electrical safety program — as well as the auditing and enforcement actions — be documented for the benefit of the employees and of the company. The process control points and actions (i.e., the items capable of being measured) need to be determined for there to be effective auditing. An audit of the overall ESP (110.1(K)(1)) is necessary to ensure that program principles and procedures are kept current with changing situations.
Section 110.1(K)(2) addresses field audits. This involves going into the field — wherever employees are performing their required tasks and there is the potential of exposure to electrical hazards — to gather information. It is important to watch employees perform their electrical safety related tasks and ensure that they are using PPE appropriate for the task to be performed. When it has been confirmed that the ESP principles or procedures are not being followed, corrective action must be taken. The field audit should be used to confirm that all electrical hazards are addressed, and to evaluate any program and physical conditions that have changed. 
Lockout/tagout programs and procedures require auditing in 110.1(K)(3). The objective of the audit is to make sure that all requirements of the procedure are properly detailed and that employees are familiar with their responsibilities. The audit should determine whether the requirements contained in the procedure are sufficient to ensure that the electrical energy is satisfactorily controlled. The audit must ensure that the lockout/tagout procedure is effective and is being properly implemented.
There are several other requirements for audits and supervision in NFPA 70E. Any audit should identify and correct deficiencies in the procedure, employee training, or enforcement. Corrective actions could consist of either modification of the training program or a revision to the procedures, such as increasing the frequency of training. Audits and metrics should measure program effectiveness as well as be used for developing program improvement. Audits should evaluate incidents to determine any necessary change to the ESP. An ESP should not be developed then placed on the shelf as a job well done. Electrical safety in the workplace is not the same as it was 10 years ago. How are you protecting employees with the best ESP possible?
For more information on 70E, read my entire 70E blog series on Xchange
Next time: Is there a way to increase electrical safety for workers in the future.
Please Note: Any comments, suggested text changes, or technical issues related to NFPA Standards posted or raised in this communication are not submissions to the NFPA standards development process and therefore will not be considered by the technical committee(s) responsible for NFPA Standards development. To learn how to participate in the NFPA standards development process and submit proposed text for consideration by the responsible technical committee(s), please go to www.nfpa.org/submitpi for instructions.
You would think that the concept of properly installed electrical equipment would be easily understood. However, there are some areas in United States that do not adopt the most recent National Electrical Code® (NEC®) and therefore may not have installation requirements for new technologies or alternate methods. Also, there are counties that do not follow the state’s adoption of the NEC. Some areas are more concerned with residential installations than commercial or vice versa. In many areas, the service and initial electrical distribution system are inspected by a local authority at the time of building construction. However, commercial, industrial, and residential electrical installations have additions to the electrical system and additional installed electrical equipment that have been done in-house. Many times an outside contractor performs that work. Installations could have been done by someone who may or may not know the correct NEC installation requirements.
Often the installation is in accordance with NEC requirements. Occasionally, installations deviate from those requirements. The conductor or cable that is on the truck or available in-house is used rather than what is specified. A different fuse or circuit breaker is used because it was less expensive. Conduits or tubing are installed in locations not appropriate for compliance with the NEC. Grounding and bonding may not be completely accomplished. Some of the time this occurs due to an error. Other times this occurs by choice. Either way an inspection of the installation will help correct these before someone is harmed.
Whether we want to admit it or not, at some point in our career, we have all done something that we felt was “good enough.” We may have done this under the assumption that we would be the one responsible for dealing with that piece of equipment. If we were lucky enough, someone inspected the installation and pointed out areas that were lacking. When an installation is done in a neat and workmanlike manner and compliance with the requirements, almost everyone would welcome an inspection by someone else. Most of us take pride in our work and having it validated is rewarding. 
Regardless of who did the installation, inspections are not for the purpose of assigning blame. Electrical inspections are conducted to verify that installations are in compliance with requirements set in place for safety. NFPA 70E®, Standard for Electrical Safety in the Workplace® requires proper installation as a basis for minimizing electrical injuries. A safe installation is necessary for not only for any person operating the equipment but also for those maintaining the equipment. Although the NEC and NFPA 70E address electrical safety, safe operation of equipment is not limited to complying with electrical standards since things like improperly installed pressure systems may affect the safety of that equipment. If an outside authority having jurisdiction (AHJ) does not perform inspections of these installations, you are by default the AHJ. It is your responsibility to have installations verified as being are in compliance with the NEC and manufacturer’s requirements before permitting an employee to interact with the equipment in any manner. This is true whether the work is done in-house or by an outside contractor. How are you doing this?
For more information on 70E, read my entire 70E blog series on Xchange
Next time: NFPA 70E audits.
Please Note: Any comments, suggested text changes, or technical issues related to NFPA Standards posted or raised in this communication are not submissions to the NFPA standards development process and therefore will not be considered by the technical committee(s) responsible for NFPA Standards development. To learn how to participate in the NFPA standards development process and submit proposed text for consideration by the responsible technical committee(s), please go to www.nfpa.org/submitpi for instructions.
There must be an increase in the need to perform justified, energized work on equipment with high incident energy levels. Questions have come in regarding the restriction for incident energies above 40 cal/cm2. Many believed that NFPA 70E®, Standard for Electrical Safety in the Workplace® requirements “really” only applied above 40 cal/cm2. Others believed the standard did not cover incident energies above 40 cal/cm2. It took some time to realize what everyone was considering to be a restriction. Prior editions of NFPA 70E contained an informational note that stated when incident energy exceeded 40 cal/cm2 at the working distance, greater emphasis may be necessary with respect to de-energizing when exposed to electrical hazards. The purpose of this note was to re-emphasize the requirements of the standard. Establishing an electrically safe work condition (ESWC) was and still is required regardless of the incident energy.
One problem with the informational note was that many where incorrectly interpreting it to mean that it wasn’t necessary to worry about incident energies below 40 cal/cm2. These people felt that this note meant that an ESWC was not “really” necessary or required until 40 cal/cm2. Below this level it was just a suggestion to establish an ESWC. This may be why I receive so many questions about using PPE when working on energized equipment rather than establishing an ESWC. Those who thought that way have put many employees at a greater risk of injury. 
Another group was interpreting the informational note to mean that NFPA 70E placed a limit on the permissible incident energy. The PPE category tables are limited to address equipment that is permitted to be worked on while wearing at least 40 cal/cm2 gear. If you have equipment that is listed on the PPE category tables but the specified parameters are not met then the equipment must be evaluated under the incident energy analysis method. There is no limit to the incident energy that can be calculated. However, finding PPE rated to protect at high energy levels may be difficult. 
Misuse of the standard and specifically of the 40 cal/cm2 informational note is one reason for the removal of that informational note. Once you have a system that exceeds the threshold limits in NFPA 70E, you must minimize the hazard and risk that hazard presents to your employees. An electrically safe work condition must be established if an employee is to enter the limited approach boundary. NFPA 70E is about protecting the worker from injury but there may not be equipment available to protect from all levels of a hazard. That is one area where the hierarchy of risk controls comes into play. Although there is no limit to the amount of incident energy that may present, if energized work is justified, you are responsible for protecting your employees from whatever level of hazard exists. 
For more information on 70E, read my entire 70E blog series on Xchange
Next time: Properly installed equipment.
Please Note: Any comments, suggested text changes, or technical issues related to NFPA Standards posted or raised in this communication are not submissions to the NFPA standards development process and therefore will not be considered by the technical committee(s) responsible for NFPA Standards development. To learn how to participate in the NFPA standards development process and submit proposed text for consideration by the responsible technical committee(s), please go to www.nfpa.org/submitpi for instructions.
The First Draft meeting for the 2021 edition of NFPA 70E®, Standard for Electrical Safety in the Workplace® will be taking place in St. Louis, Missouri next week (August 13th-17th) at the Hyatt Regency at the Arch. NFPA technical meetings are open to the public. If you want to witness the process first hand please come see what happens at this stage of the standard development process. 
There have been 332 inputs submitted for the next edition. They cover everything from basic editorial issues to substantial changes in the safety requirements. The Technical Committee will discuss the inputs and develop a draft standard during the meeting. After the meeting, the Technical Committee will be formally balloted on the changes made. Only changes that pass the formal ballot will be shown as a First Draft for viewing by the public. However, all the submitted inputs (whether they led to change or not) will also be viewable after the vote. If you cannot make the meeting you can see all the public inputs submitted and the first revisions made to the standard. These are available on NFPA's 70E "next edition" webpage. This link will also allow viewing the First Draft once it has been balloted by the TC and posted on the page.
It is up to you to review what has happened during the First Draft process. The First Draft allows you to see what the standard would require if it were to be issued at this stage (which could conceivably happen if no public comments are submitted). When the draft is posted, remember to read through it and the submitted public inputs. Doing so will allow you to comment on this draft when the Second Draft process starts. NFPA 70E is a consensus standard. That means that your involvement has a direct effect on addressing electrical safety. It is your standard, be part of it.
For more information on 70E, read my entire 70E blog series on Xchange
Next time: The 40 cal/cm2 limit.
Please Note: Any comments, suggested text changes, or technical issues related to NFPA Standards posted or raised in this communication are not submissions to the NFPA standards development process and therefore will not be considered by the technical committee(s) responsible for NFPA Standards development. To learn how to participate in the NFPA standards development process and submit proposed text for consideration by the responsible technical committee(s), please go to www.nfpa.org/submitpi for instructions.

 

It is good to hear that this blog is getting those involved with electrical safety to think and talk about what they are doing to protect employees from electrical injury. I have been asked to explain what it means to use the hierarchy of risk controls regardless of a policy requiring the establishment of an electrically safe work condition (ESWC) or permitting justified energized work. How to use the hierarchy is obvious when it comes to justified energized work. However, using the hierarchy when establishing an ESWC is less obvious to many. It should be used the same way regardless of your policy. This comes down to considering the act of establishing an ESWC to be an administrative control to achieve elimination of the hazard. Bear with me and hopefully this will again shed some light on the process. Remember that the act of establishing an ESWC is considered to be energized work.


Consider an electrical installation with a step-up transformer (480/2400 volts) being used for a motor installation. An interrupting switch for a motor load is on the secondary. The primary disconnect and overcurrent device is located back at the switchgear. The incident energy at the transformer input terminal is 22 cal/cm2 with an arc-flash boundary out at 12 feet. Your employee will don 25 cal/cm2 PPE. This will require a full hood and arc-rated gloves. She will complete the eight steps in 120.5. She interrupts the motor circuit then opens the breaker in the switchgear. She goes into the transformer enclosure to verify the absence of voltage. The limited approach boundary is at 5 feet because the secondary is exposed. She is within the restricted approach boundary (2 feet, 2 inches) of the secondary terminals  which requires the use of insulated tools and shock PPE rated for 2,400 volts. She will have established an ESWC while being potentially subjected to 2,400 volts and 22 cal/cm2.


If the hierarchy of risk controls was used, here is what the scenario might have been when establishing this EWSC. The overcurrent device is replaced with a current-limiting device with a faster clearing time to lower the incident energy to 8 cal/cm2. The arc-flash boundary has been lowered to 5 feet. There is a viewing window in the motor disconnect to permit visual verification that the load has been isolated. (Yes, this not the disconnect device but it is still used here.) The switchgear is arc-rated so that if an incident occurs when opening the breaker the arc-flash will be directed away from the employee. The input terminals of the transformer are in a separate enclosure allowing the use of shock PPE rated for 480 volts. The limited approach boundary is now at 3 feet 6 inches and the restricted approach boundary is 1 foot. The employee dons 10 cal/cm2 PPE with leather glove protectors and a face shield. She will complete the eight steps of 120.5. She verifies that the contacts isolating the motor load are clear. She opens the breaker in the switchgear then opens the transformer terminal box to verify the absence of voltage. She has also established an ESWC while potentially being subjected to 480 volts and 8 cal/cm2. Other methods might have been used to mitigate the hazard. The point is the hierarchy of risk controls was used to increase safety for the employee rather than solely establishing an ESWC.


Your employee can be injured at 480 volts and 8 cal/cm2 just as she can be injured at 2,400 volts and 22 cal/cm2. However, there is less risk and lower hazard levels in the second scenario. This is why you must consider the hierarchy even when your policy is to establish an ESWC. You may decide not to use some or all other controls but your risk assessment should consider them. There should never be energy present and the voltage measured should always be zero when an ESWC is being properly established. Your employee should truly never be exposed to an electrical hazard.


So why go through these additional steps? I am aware of situations where equipment is labeled with an incident energy higher than what currently available PPE is rated to provide protection from. The apparent “theory” is that since the policy is to eliminate the hazard through an ESWC that the hierarchy need not be used to lower the risk or hazard. Using and wearing inadequately rated PPE might be considered by many to be as irresponsible as not using any PPE. The personal protection your employee is required to use is for no other reason than something unexpected might happen that could injure them. When that does happen isn’t it important to provide, if not at least consider, a higher level of protection for that employee?


Please Note: Any comments, suggested text changes, or technical issues related to NFPA standards posted or raised in this communication are not submissions to the NFPA standards development process and therefore will not be considered by the technical committee(s) responsible for NFPA standards development. To learn how to participate in the NFPA standards development process and submit proposed text for consideration by the responsible technical committee(s), please go to www.nfpa.org/submitpi for instructions.


For more information on NFPA 70E, Standard for Electrical Safety in the Workplace, read my entire NFPA 70E blog series on Xchange


Next time: NFPA 70E First Draft Meeting

When it comes to having you work on electrical equipment there are essentially four choices your employer could make. The first is to design or substitute out electrical hazards so that you are not exposed to voltages above 50 volts or incident energies above 1.2 cal/cm2. The second is to follow NFPA 70E®, Standard for Electrical Safety in the Workplace® and establish an electrically safe work condition (ESWC). The third is to properly justify the need for the work to be conducted while energized then follow the requirements of NFPA 70E. The fourth is to conduct unjustified energized work. Here are some of the outcomes I have been made aware of when an employee was working under each situation.  
The first option. Unfortunately, this is not something that can occur with a majority of electrical equipment. I have never heard of an employee being injured by electricity when there were no electrical hazards present for the given situation. However, with the shock hazard being above 50 volts there are circumstances that a shock hazard could exist in other circuits that I have not had to deal with. I am aware of situations where energy levels below the arc-flash hazard of 1.2 cal/cm2 have caused minor burn injuries to employees who were not wearing a long sleeve shirt or gloves. With the use of correct equipment and clothing there should be no injuries under this option regardless of low voltage or incident energy levels. A secondary method of eliminating electrical hazards is through an ESWC. I have never heard of an employee suffering an electrical injury when working on equipment placed into an ESWC.
The second option. The best outcome is that no employee was subjected to a shock or arc-flash incident while establishing an ESWC. The procedure went smoothly and the equipment was put into an ESWC. On the other end of this is that something went wrong while establishing the ESWC. However, with everything else being in accordance with NFPA 70E, the employee suffered no injury and in other cases a minor injury. Once an ESWC was established, no employee has been injured.
The third option. In many cases, a qualified worker was not injured while performing justified energized work. Things begin to go downhill from here. There is potential for an incident even when all the protections required by NFPA 70E have been done correctly. One outcome involves an incident occurring during the task but the equipment and protective devices provided protection for the employee. After this, the best outcome of an incident was that the PPE fully protected the employee from physical injury. The next best outcome was that the PPE performed as designed and limited the injury to one of lesser severity.
The fourth option. This one is wide open since it does not follow NFPA 70E or OSHA regulations. At extreme end of this option is there is absolutely no attempt at safety. Employees have worked bare handed on energized electrical equipment without an injury while other employees have been killed. Sometimes under this option there is a perceived safety culture. When you don’t follow industry standards while suggesting that safety is a concern many things can go wrong. Even when an employee wears PPE in accordance with the equipment label, severe injuries and fatalities have occurred when everyone has assumed that everything is being done correctly. Equipment has been improperly labeled or inappropriate PPE has been specified. Cutbacks on maintenance or components have made even normal operation a risk. Deaths and injuries have occurred when the safe practices have slowly eroded such as when short cuts are taken because nothing happened to the employee the last time. Employers have supplied the worker with sub-standard, counterfeit, or inappropriate PPE. These pseudo safety cultures are arguably the worst of all since there was an assumption that safety was a concern when it actually was not. 
Unjustified energized work, poor work practices, improper or lack of training, etc. generate the highest employee injury and fatality rates. Wouldn’t you rather do everything possible to increase the odds that you will be returning home at the end of the day? Other than eliminating the hazards or after an ESWC has been properly established, there is a risk of injury to you, the employee. When you are conducting justified energized electrical work you are finding ways to minimize that possibility. What you and your employer do, and how you and why you do it does matter when you are at risk. Choose the safe way to do something. If you work in a facility as in the fourth option, it is only a matter of time before you or someone you know will be added to the injury or fatality statistics.
For more information on 70E, read my entire 70E blog series on Xchange
Next time: Using the hierarchy of risk controls when establishing an electrically safe work condition.
70e
Just like statistics can be presented in ways to prove different points, sometimes including completely opposite conclusions, the arc-flash risk assessment process can be skewed to one’s advantage. NFPA 70E®, Standard for Electrical Safety in the Workplace® is not pushing the industry to the incident energy analysis method over the PPE category method. You may benefit by reading my blog, A preference between the PPE Category Method and the Incident Energy Analysis Method.
Not too long ago I was an observer listening to a consultant who performs risk assessments and applies the labels required by NFPA 70E. The sales pitch went into the fact that either the PPE category or the incident energy (IE) analysis method could be used. The “facts” became fuzzy after that. It was pointed out that although both methods could be used, it is better to only use one within a facility. Since a single method is better, and not all equipment meets the PPE category method, the IE analysis method was the preferred choice. I sat there thinking there are many ways to successfully mingle both methods within a facility with no confusion by the employee. I also thought most of the equipment within the facility could be evaluated quickly under the PPE category method.
To illustrate the point that the PPE category method would be a problem, it was portrayed that employees need to use the PPE category tables each time they worked on equipment. It was pointed out that the tables rely on the clearing time of the overcurrent device and the available fault current. Not only would the employee have no way of knowing this information, they may not be able to find where to get it. How would the employee know if the equipment complied with the table parameters without this information? I am not sure why the labels would be incorrect. The sales pitch led one to believe that the employee would not have this problem with the IE analysis method. I waited to hear the reason why this was true but it did not come.
The fact that equipment maintenance plays a big part of electrical safety was presented. How it affects the arc flash hazard was illustrated. At no point was it mentioned that this is required for both risk assessment methods. It was alluded that this is only a benefit for the IE analysis method and not the PPE category tables. Based on the presentation I would have concluded that the IE analysis method was the “safer” choice because PPE category equipment might not be maintained or would no longer comply with the table parameters. After this point the PPE category method was no longer mentioned. Everything else presented was based on using the IE analysis method. I almost forgot there was another method as the presentation went on.
What the consultant failed to point out was that the risk assessment and label are necessary before the employee performs any task on the equipment regardless of the method used. The method used and details necessary to get to the information necessary for the label are often not the employee’s concern. The employee needs to be qualified for their task on that equipment and must know how to protect themselves from the hazards indicated. The affixed label, work permit and work procedure for the task provide the necessary information. 
One method may have an advantage over the other for a piece of equipment or portion of the distribution network. The category method was developed to aid in PPE selection for common equipment without the need for an extensive calculation. The IE analysis method covers many more pieces of equipment. Before you make a decision remember these facts. 
  • There is no preference for a risk assessment method. 
  • Either method can be used within a facility but not on the same piece of equipment. 
  • Some of the same information is necessary to use either method. 
  • Whoever you consider should be knowledgeable in both methods and offer the use of either as applicable. 
  • Either method results in the correct label information and the necessary protection of the employee. 
  • If the IE analysis method is used be aware that one equation may not be applicable for all of your equipment. If a computer program is used, know what equation is used, were it came from and that it is the correct equation. Ask the right questions when making your selection of a consultant. 
  • Determining the incident energy or PPE category for a piece of equipment is only a portion of conducting a risk assessment. Make sure you know what needs to be addressed in a risk assessments. 
  • Risk assessments and equipment labeling have become a business of their own. After an employee injury or fatality is not the time to find out that the applied risk assessment or labelling method was flawed. 
You are responsible for providing a safe work environment for your employees. Your employees trust that you are doing what is necessary for that safe environment to exist. This includes having competent and qualified people, whether your own employees or an outside organization, perform the required risk assessments. 
For more information on 70E, read my entire 70E blog series on Xchange
Next time: Four different ways to work on electrical equipment.

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