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86 Posts authored by: ccoache Employee

70E

If you haven’t been keeping up with the NFPA 70E, Standard for Electrical Safety in the Workplace revision cycle, the 2021 edition was issued June 1, 2020 with an effective date of June 21, 2020. Independent standards development organizations, such as NFPA, and the standards they publish play a major role in protecting the public from injury or death. For those of you who took part in the process whether by submitting inputs and comments, attending the draft meetings, or by being a member of the technical committee, NFPA thanks you for your participation.

For the 2021 edition, Article 110 was revised to incorporate the general requirements for electrical safety-related work programs, practices and procedures from other articles. References to arc-resistant switchgear has been changed to arc-resistant equipment to address the use of other types of arc-resistant equipment. Article 360, Safety-Related Requirements for Capacitors and Annex R, Working with Capacitors were added to address specific electrical safety requirements unique to capacitors. Annex D, Incident Energy and Arc Flash Boundary Calculation Methods was revised to reference IEEE-1584-2018 as a method of calculation. Throughout the standard there are other changes so be sure to check for those that might affect your electrical safety program.

Information regarding not only this new edition but earlier editions, providing input to the next edition and asking a technical question is available on the NFPA 70E web page at www.nfpa.org/70E.

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

Next time: Why NFPA 70E, Standard for Electrical Safety in the Workplace does not include incident energy calculations.

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

electrical safety

 

I receive many questions from companies in the process of implementing an electrical safety work program. Can their own employees conduct risk assessments? Who should they hire? How do they know if an organization is qualified to do the work? While I am unable to answer those questions, my recent blog about knowing what is involved with risk assessments can help provide some guidance. Equipment is required to be labeled with the highest voltage and incident energy or PPE category. This worst-case condition can be used for 100 percent of tasks associated with the equipment. However, another of my Electrical Safety Month blogs discusses how a risk assessment could address tasks performed within that equipment. There is a difference between providing a label to attach to equipment and performing a risk assessment. Which was the contractor hired to perform?

 

Since most contract organizations use the more detailed incident energy analysis method rather than the PPE category method, there are two quick checks you can use to determine which one the contractor delivered. One check comes from 130.5(B). If equipment condition and maintenance is not questioned, the contractor is simply providing a label. Be aware that information on that label might create an unsafe condition for the employee. Another quick check is in 130.5(G). If the contractor did not address tasks conducted closer than the typical working distance, they are likely only providing a label. If they ask about the tasks to be performed on the specific equipment then provide the incident energy at the hand position, for example, they might be providing more than a label. Neither of these checks verify that a proper risk assessment has been performed but you are being provided with additional information necessary to conduct an assessment and develop safe work practices.

 

These quick checks may help determine if the contractor performed the work that they were hired to perform. Determining the maximum voltage or incident energy is identification of electrical hazards. Risk assessments are much more involved and assessments for specific tasks are typically not conducted by a contract company. Providing labels or calculating incident energy at the hand position is not a confirmation that a contractor is qualified, or that a proper assessment was performed. There are many other things you must verify when hiring a contractor to conduct such work. Make sure that you do your homework before hiring someone to be responsible for your employee’s safety.

 

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

 

Next time: The 2021 edition of NFPA 70E, Standard for Electrical Safety in the Workplace.

 

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

electrical safety

 

What are the primary NFPA 70E, Standard for Electrical Safety in the Workplace requirements for an employee? Section 105.3(B) lists one. An employee must comply with the safety-related work practices and procedures provided by the employer. Public Law 91-596, “Occupational Safety and Health Act of 1970” SEC. 5.(b) requires that each employee comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to the Act which are applicable to his own actions and conduct. Most employees do not know the law but expect that their employer ensures that they are following it. One way for them to comply with respect to electrical hazards is to follow NFPA 70E. However, the employee’s compliance with the law is typically dependent on the quality of the employer’s electrical safety program.

 

An employee has a great responsibility after being trained to use and follow the safety-related work practices and procedures for the tasks assigned. Once out in the workplace conducting daily assigned tasks, employees make decisions to apply that training and the steps detailed in the provided procedures. Following documented procedures is the easiest part of the employee’s responsibility. However, the employee’s safety is not solely addressed by following procedures. Safety training, safe work practices, and safety policies also include things often not part of the detailed work procedure for the assigned task.

 

The employee’s training should teach them to recognize that new technology, new types of equipment, or changes in procedures affect their safety. They must recognize that their skills may not be sharp if they have not performed the task regularly. They must recognize that safety-related work practices not normally used during regular job duties may necessitate additional training. Although the employer must document employee training, the employee should question their training if job duties change.

 

Employees must be instilled with an awareness of potential electrical hazards and the self-discipline to control their own safety when working around electrical hazards. Awareness is entirely dependent on the employee. An employee must always be alert where electrical hazards might exist. An employee must recognize that they are impaired due to illness, fatigue, or other reason. Even a supervisor may request that the employee perform a task not originally assigned and the employee must recognize that that changes during the work that might affect their safety. The employee must be alert that reaching blindly into areas affects their safety.

 

The employee’s training must also address illumination. The employee must realize that they should not enter a space unless the lighting enables them to perform the work safely. They must also use their training to recognize that a task should not be performed if insufficient lighting or an obstruction prevents them from seeing the location where the task is be performed.

 

The employee is responsible for applying the training that conductive articles of jewelry and clothing should not be worn within the restricted approach boundary or where they present an electrical contact hazard. Only the employee can handle conductive materials, tools, and equipment in a manner that prevents unintentional contact with energized electrical conductors or circuit parts. The employee must apply the training to secure doors and hinged panels to prevent their swinging into them. The employee’s training directs them to keep the working space clear to permit safe operation and maintenance of electrical equipment. Qualified and unqualified employees must use their training to anticipate equipment failure and that they should be protected from those hazards by suitable barricades and other alerting techniques.

 

The training provided to an employee must address these issues and more. Following detailed procedures is relatively easy. Following electrical safety principles and practices that were provided during training is a little more difficult for employees. The safe work practice that conductive jewelry not be worn should be discussed during training but it is typically not addressed in a detailed procedure. However, the employee is responsible for applying that safe work practice daily. Safety training must be provided by the employer. It is the employee’s consistent use of this training that will dictate if they will be returning home uninjured at the end of the day. Remember, it is the law.

 

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

 

Next time: Is the contractor printing labels or are they doing risk assessments.

 

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

70E

What are the primary NFPA 70E, Standard for Electrical Safety in the Workplace requirements for an employer? Section 105.3(A) narrows it to basically two. The first is that the employer establish, document, and implement safety-related work practices and procedures. The second is that the employer provide safety-related work practices and procedures training to employees. From the federal side, 1910.332(b)(1) states that employees must be trained in and familiar with the safety-related work practices that pertain to their respective job assignments. Before any of this starts the employer must be committed to improving electrical safety within their facility.

 

Overriding principles to protect employees must be established. Management must commit to protecting the employee by providing guidelines. Establishing an electrically safe work condition will be the primary safe work procedure. All electrical equipment will be inspected and maintained. All work tasks will be planned. Proper tools and equipment will be provided. Employee qualifications will be ensured. Electrical installations will comply with the National Electrical Code (NEC). All employee safety concerns will be addressed. These principles should be documented in order to form the basis for the safe work procedures.

 

In order to establish safety-related practices and procedures, the employer must understand the electrical hazards and risks that employees face as part of their daily tasks. Do employees use portable tools? Does a security guard turn the production floor lights on at a panelboard? What voltages are present in the facility? Are contractors hired to work on electrical equipment? Do contractors engage in energized work? Do electricians install equipment, or do they also maintain it? Do employees open electrical equipment enclosures? Once it has been determined that employees are at risk, it is necessary to determine steps to protect them.

 

With an understanding of the tasks performed and risks faced, and by overlaying the safety principles, the employer can establish safe work procedures. Employee involvement in developing procedures typically increases the likelihood of the procedure being used. What are the steps necessary to safely operate Circuit Breaker #23 in Subpanel #8 to turn on the production floor lights? How does a cord-and-plug connected drill get inspected before use? What is the proper method of establishing an electrically safe work condition for Acme Company, Model 123 motor starter as it has been installed on Production Line #5? What about the starter on Production Line #1? What is the correct lockout procedure for a hydraulic press? What is the applicable testing protocol for insulated gloves? The procedures will be used as part of the required field audits. They should be detailed and controlled so that continued improvement can be implemented.

 

Once all this is documented, the practices and procedures must be implemented. Placing the documents into a file cabinet without this stage is a job poorly done. How will all this safety information be distributed? Who is responsible for making sure the proper information is given to those in need? How will training be implemented? Who oversees implementation of the safety program? How will revisions be incorporated?

 

Lastly, employees must be trained to follow the procedures. How will they be trained? Is there necessary prequalification? Who is qualified to train an employee for a specific task? Who verifies that they are qualified to perform the task? Does the ability to follow the procedure qualify an employee for the task? How will general safety training occur when a detailed procedure may not be necessary, such as how to properly unplug equipment from a receptacle? How does an employee recognize that it is safe to operate electrical equipment? How will a qualified person demonstrate the skills necessary for a task? How will the training be documented? How will the field audits address training or procedure deficiencies?

 

Safe work practices, policies, and procedures will be part of the larger electrical safety program. Electrical safety is not a static thing. Lessons learned through field audits and employee feedback should be evaluated to improve safety. Procedures should be reviewed for relevance and new ones developed when necessary. The goal is to minimize risk and work towards elimination of employee injuries.

 

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

 

Next time: An Employee’s Responsibility.

 

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

 

As all of us continue to navigate the evolving situation with COVID-19, NFPA remains committed to supporting you with the resources you need to minimize risk and help prevent loss, injuries, and death from fire, electrical, and other hazards. For information on NFPA’s response to the coronavirus, please visit our webpage.

70E

 

Rather than a blog on manufacturer’s responsibility, this blog is about risk assessment. Once again it is May and National Electrical Safety Month, sponsored by Electrical Safety Foundation International (ESFI) to raise awareness of electrical hazards both on the job and at home, and this week I'm focusing on risk assessments.

 

Once a hazard is identified, it is necessary to determine if there is risk of injury. This process is called a risk assessment in NFPA 70E, Standard for Electrical Safety in the Workplace. Shock and arc-flash risk assessment procedures are required to be part of the documented electrical safety program. There are hundreds of valid methods of performing risk assessments for the thousands of tasks that could be conducted on the millions of pieces of equipment available. NFPA 70E is not a how-to manual for detailing a risk assessment procedure. However, what is necessary as part of an assessment is addressed. A risk assessment identifies hazards, estimates the likelihood of occurrence of injury, estimates the potential severity of injury, and determines if protective measures are required. This is the basis for any applied method of risk assessment.

 

Sections 110.1(H), 130.4 and 130.5 require that risk assessments be conducted before an employee begins a task. The person conducting the assessments is presented with many dilemmas. That person must identify the hazards and risks presented by different equipment, understand the training of employees, be knowledgeable of tasks to be performed, determine the operating condition of the equipment and protective devices, assess potential for human error, and verify proper equipment installation. There are many more issues, and each requires a decision. Equipment is required to be labeled with the highest voltage and incident energy or PPE category determined by the risk assessments. This protects the employee with the highest level of protection without regard for the task assigned. Without any additional criteria these are the hazards that any employee opening the enclosure must be protected from. However, a risk assessment could address other tasks performed within the equipment.

 

First, identify the the hazards associated with the task. A shock hazard typically exists if there is 50 volts or more. This voltage itself does not mean there is a shock hazard if the equipment is under normal operating conditions and there are no exposed energized parts. If the enclosure is opened for either justified energized work or to establish an electrically safe work condition, there might be exposure to shock hazards. There might be two separate sections within the enclosure; one with a power supply and another with control circuitry. If both sections are uncovered, the employee is exposed to the highest voltage and might be within a restricted approach boundary. But what if the power supply section is surrounded by grounded metal? Does the assessment method allow for this? Perhaps only the supply input terminals are finger-safe with a plastic cover and there are exposed 240-volt portions of the power supply. A 24-volt switching power supply might present a different hazard than a transformer supply. The task might only require access to the 24-volt control section. Capacitors and inductors in the control circuit could alter where a shock hazard exists.

 

Next determine the risks associated with the shock hazard. Parts operating above 50 volts may be exposed when the enclosure is opened. A cover over the supply may need to be removed to verify the absence of voltage. The interior covers may not require a tool for removal. The finger-safe plastic on the terminal may have an insulating value, or it may only be a guard. A guard should be properly spaced from energized parts and rigid enough to prevent deflection. Tools required for the assigned task might defeat the finger safe protection. The required tool might extend the shock boundary. Both the risk and hazards may be very different if the equipment is not properly maintained. The documented risk assessment procedure may not accept any less risk regardless of the task.

 

The arc-flash hazard and risk also need to be determined. Using the PPE category method, a piece of equipment will be marked with a minimum PPE Category 1. Using the incident energy analysis method an arc-flash hazard does not exist below 1.2 cal/cm2. Is the risk of a second-degree burn acceptable? The low incident energy might be based on a working distance of 18 inches. The hands could be nearer to the arc-flash source during performance of the task. Does an incident energy equate to an arc-flash hazard and what are the risks associated with an arc-flash capable incident energy? The control section could present a different arc-flash hazard than the supply section. Using the same equipment examples as in the previous paragraph, does an enclosure or cover remove the arc-flash hazard? Does the arc-flash hazard in the grounded metal covered supply section apply if a task is only performed within the control section? Does the arc-flash hazard exist if two specific supply points must be under a bolted fault and those two points are in separate, inaccessible sections?

 

Determining the maximum shock and arc-flash hazard present within an enclosure is relatively easy. These worst-case conditions are required to be on the label. The next part is why the qualification and knowledge of the person conducting a task specific risk assessment matter. The worst case can be used for 100 percent of tasks associated with the equipment. Although providing the maximum level of protection is always permitted, what about tasks in Table 130.5(C)? For example, working on 24-volt control circuits is not likely to create an arc flash when no parts above 125 volts are exposed. If the assigned task only involves the second cabinet section does the maximum arc-flash hazard present in the unopened, high-power first cabinet section apply? The employer’s risk tolerance could be zero. If the risk assessment procedure is predicated on poor equipment maintenance, untrained employees, inadequate procedures, and human error, a worst-case scenario may be required for all tasks. Some risk may be tolerated. An employer’s risk assessment procedure might allow a situation where access to hazards within the equipment is controlled. Interior protective covers might only be removed by a special tool that is not available to employees. However, the person conducting the assessment might consider hazards behind those covers if willful negligence is considered.

 

When a risk assessment determines that electrical hazards exist and there is risk to the employee, the next step is to determine the necessary protective measures. To many this means specifying personal protective equipment (PPE) but that is incorrect. The hierarchy of risk controls must be applied to further mitigate the hazard or risk. If the assessment is being conducted before equipment selection or installation, elimination, substitution, and engineering controls might be possible. Awareness requires knowledge of and possible revision of employee qualifications and training for the specific task being assessed. A detailed procedure for the task and specific equipment needs to be developed under administrative controls to address remaining hazards and risks. Implementing any of these controls may necessitate another run through the assessment to determine their effectiveness. After this, it is possible to specify required PPE. Even this requires some decision by the person conducting the risk assessment. Does the employer accept the risk of using 6.3 cal/cm2 PPE for a calculated incident energy of 6.3 cal/cm2?

 

NFPA 70E does not detail any of this. An entire encyclopedia might not cover it all. For an employer following NFPA 70E and OSHA regulations, the task being assessed most often should be establishing an electrically safe work condition. Remember, the purpose of these assessments is to prevent injury or death of an employee. The employer develops the risk assessment procedures to use. Those procedures must identify hazards, estimate the likelihood of occurrence of injury, estimate the potential severity of injury, and determine the required protective measures. To do so, the person conducting the risk assessment must be competent.

 

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

 

Next time: An Employer’s Responsibility.

 

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

 

As all of us continue to navigate the evolving situation with COVID-19, NFPA remains committed to supporting you with the resources you need to minimize risk and help prevent loss, injuries, and death from fire, electrical, and other hazards. For information on NFPA’s response to the coronavirus, please visit our webpage.

I have written several blogs regarding employees at risk of an electrical injury. Many of those blogs point out that electrical injuries and fatalities are not limited to those solely in an electrical occupation. It has been a while since I looked through 29 CFR 1910. Standard 1910.332 applies to training employees who face a risk of electric shock that is not reduced to a safe level. A table associated with 1910.332(a) (summarized below) indicates occupational categories considered to be a greater risk of electrical injury than other occupations.

electrical safety

Notice that more non-electrical occupations are listed than electrical ones. An included note further states that employees in the listed occupations are required to be trained. You may want to remedy the situation if your occupation is on this list and no documented electrical safety program exists at your company.

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 NFPA Network to stay informed of new content. The newsletter also includes NFPA 70E information such as my blogs.

 

Next time: An Employer’s Responsibility.

As all of us continue to navigate the evolving situation with COVID-19, NFPA remains committed to supporting you with the resources you need to minimize risk and help prevent loss, injuries, and death from fire, electrical, and other hazards. For information on NFPA’s response to the coronavirus, please visit our website.

70e

Many people miss the point of providing a workplace that is free of electrical hazards for an employee. The main point of the federal law as well as NFPA 70E, Standard for Electrical Safety in the Workplace is to not put an employee’s life at risk when it is not absolutely necessary to do so. Electrocution was a known electrical hazard prior to 1900. In 1970, it was federally mandated that employers protect employees from known workplace hazards. Still, over 600 employees were electrocuted in the workplace annually before the first edition of NFPA 70E was issued in 1979. Employers thought they knew how to protect them. In 2018, 160 employees were electrocuted in the workplace according to the Bureau of Labor Statistics (BLS). Forty years after the first NFPA 70E, these employers also thought they knew how to protect an employee from electrical hazards.

 

I have written many articles, blogs, and handbooks which attempt to drive the point home that unless justified, an employee should not be put at risk of becoming a fatality. However, it seems just as many believe it should not be a requirement to shut equipment off before working on or near the electrical hazards present in that equipment. Rather than providing this highest level of protection, the decision to perform unjustified energized work typically (whether consciously considered or not) weighs the cost of an employee injury against the cost of shutting off equipment. Protect the worker by a less effect means, just hope that everything will be fine. Read my blog regarding three employers who felt they had it covered. It may also be beneficial to read my blog about what employers think they know.

 

All of the fatalities involving electricity that I am aware of did not involve one task that was either infeasible or created a greater hazard if power had been removed. Fluorescent light ballasts were replaced. Motor starters repaired. Circuits were extended. Electrical enclosures were vacuumed out. Blown fuses were replaced. Conductors were stripped. Maintenance was performed on circuit-breakers. Residential HVAC units were repaired. Damaged receptacles were replaced. BLS data since 2011 shows 21% of electrical contact fatalities occur at or below 220 volts. Also, with each of these fatalities at least a portion of the electrical system was down for a period of time that was not decided by the employer.

 

These tasks had no justification to be conducted while energized. Not that it should be a criterion, but almost all did not have a significant financial impact to the employer until the fatality occurred. None of the tasks involved more than a localized shut-down. Many of the tasks involved equipment or circuits that were already without electrical power. Other than some emergency lights, no other electrical equipment was on an electrical power back-up system because sudden loss of power to the equipment was not a concern. Almost all the tasks could be conducted in a matter of minutes not hours. Why were these employees fatally injured while at work when their employer knew that they would be exposed to known hazards? A major problem with unjustified energized electrical work is that it typically means that only select requirements (if any) are implemented for protecting an employee from injury or death. The employer decided which electrical safety requirements to follow and which ones to ignore. Incorrectly chosen and ignored requirements can cause fatalities.

 

In the over 30 years of being involved with electrical safety, I have no knowledge of any employee being fatally injured by electricity when electrical hazards were not present. There are two ways to reach that state. The first is not to have electrical hazards present in the electrical system from the start. The second way is to establish an electrically safe work condition (ESWC). Properly protecting an employee from electrical hazards while establishing an ESWC greatly minimizes their risk and exposure to the hazards. Establishing an ESWC also qualifies as justification for performing that portion of energized electrical work. Using a lesser level of protection as reasoning for permitting unjustified energized electrical work is willfully exposing the employee to undue electrical hazards. In those same 30 years of electrical safety, I am aware of many fatalities, injuries and damaged equipment under that condition.

 

For more information on 70E, read my entire 70E blog series on Xchange. Additional information to help guide you through the understanding of safe work practices can be found in our latest "Safe Electrical Work Practices Online Training" series.

 

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

Next time: Employees at greater risk of an electrical injury.

 

As all of us continue to navigate the evolving situation with COVID-19, NFPA remains committed to supporting you with the resources you need to minimize risk and help prevent loss, injuries, and death from fire, electrical, and other hazards. For information on NFPA’s response to the coronavirus, please visit our webpage.

I have written a few blogs about host and contractor employer responsibilities. Over the past year, I have pointed out many times that  NFPA 70E, Standard for Electrical Safety in the Workplace has minimum issues that need to be addressed between the two employers. NFPA 70E requires a documented meeting but does not detail exactly what should be documented. NFPA 70E refers to known electrical hazards but it really is how the contract employee will be protected from those hazards that should be addressed.

 

A host employer is responsible for safety in their facility regardless of purpose of a visit. No one should violate the host’s established safety procedures regardless of their employment status. A host employer is not given carte blanche to allow contract employees to willfully expose themselves to the risk of an injury or fatality. Host employers have been cited by OSHA for incidents involving contract employees. At the very least the host and contract employers should review each other’s applicable safety procedures. They should then document how the contract employee will conduct the task. A host employer may find it hard to justify hiring a contract employer who has no safety policy, procedures or training for the task to be performed in their facility. It is also possible that the contract employer must educate, train and document what is to occur due to lack of a host employer safety policy. A consensus should be reached on how to educate and train contract employees. This must occur before an employer begins the task. If it is not documented, it did not happen.

 

I pulled up the BLS database for fatal occupational injuries incurred by contracted workers (2011-2017) to provide some data to illustrate the need for a host and contract employer to be in the same ball park. During this time there were 1,049 fatalities, including 440 contract employees, from exposure to electricity in all occupations. I expect that an employee is either working for a host (employer) or a contract employer. A simplistic view with all things being equal would be a 50/50 split if there was an equal number of employees. Contract employees account for 42% of all contact fatalities. Contract workers in the database are not limited to those in the electrical industry. Employees from cleaning services, HVAC, plumbing, groundskeeping, and other non-electrical trades are included. The following charts show the percentage of contact fatalities attributed to contracted workers compared to all other workers. Note that fatalities due to >220 volts may be included within the other three sub-categories.

 

70e

From this data, it seems as if the contract employee is not fully aware of the distribution system or equipment at the host’s site when performing an assigned task. This unfamiliarity results in contract employees accounting for a higher percentage of building wiring and switchboard, switch and fuse fatalities than for all contact fatalities. It could also be the reason behind the slightly higher percentage of contract electrician fatalities. The minor rise in >220 volt contact fatalities may be due to contract employees being exposed to higher voltages than seen while performing typical tasks. Contract employee fatalities due to contact with powerlines is consistent with the overall contact fatalities.

 

Host employers may be taking a hands-off attitude with electrical safety when using a contact employer. Host employers may be hiring contract employers without implementing a safety program with them. Host employers may not be verifying that a qualified or a properly trained unqualified contract employee is assigned the task. The contract employer may not be enforcing their own safety protocols while at a host employer facility. The contact employer may not be ensuring that an employee is qualified or trained for the specific task to be conducted and to recognize the electrical hazards associated with the host’s specific equipment.

 

A contract employer must address the safety of their own employees regardless of the work location and assigned task whether it is electrical or not. A host employer is not only responsible for the safety of their own employees but also contract employees from any trade. A host may assume that a contract employer has a well-developed and documented electrical safety program (ESP) and that only qualified or trained contract employees will be assigned work. The host may assume that the contract employer’s ESP addresses issues within the host’s facility. We all know about assumptions. When it comes to electrical safety and keeping an employee alive or uninjured, an assumption does not provide the correct answer. A host and contract employer must be sure and it should be documented.

 

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 newsletterto stay informed of new content. The newsletter also includes NFPA 70E information such as my blogs.

Next time: Putting an Employee’s Life at Risk for No Reason

A well-developed safety program, in this case an electrical safety program (ESP), is crucial for protecting the most important part of any corporation; employees. The ESP must involve all levels of employees in order to identify and correct issues. The goal of the ESP should be to proactively address workplace hazards which is a more effective approach than reacting to injuries and fatalities caused by those hazards. An employer is required by NFPA 70E, Standard for Electrical Safety in the Workplace to implement and document an overall ESP that directs activity appropriate to the risk associated with electrical hazards.

For those who need to start an ESP, the Occupational Safety and Health Administration identifies 10 steps to help get the ball rolling:

  1. Always set safety and health as the top priority – assure employees that getting them home safely is a priority.
  2. Lead by example – make safety part of your interaction with employees and practice safety yourself.
  3. Implement a reporting system – encourage reporting of any safety issue without fear of reprisal.
  4. Provide training - train employees on how to identify and control hazards.
  5. Conduct inspections - Inspect the workplace with employees and ask for about their concerns.
  6. Collect hazard control ideas - Ask employees for improvement ideas and follow up on their ideas.
  7. Implement hazard controls – Task employees with choosing, implementing, and evaluating their solutions.
  8. Address emergencies - Identify foreseeable emergency scenarios and develop what to do in each case.
  9. Seek input on workplace changes - Before making significant changes, consult with employees to identify potential issues.
  10. Make improvements - Set a regular time to discuss safety and health and identify ways of improving the program.

 

An ESP must also be documented. Once you’ve started down the path with the above 10 steps, NFPA 70E lists specific items that must be part of an ESP. Remember that a standard is a minimum set of requirements and much more can be included. An ESP may be more effective when it is implemented as part of an overall occupational health and safety management system. NFPA 70E requires that the following items be addressed by an ESP:

 

  1. Inspection – Safety relies on verifying that that newly installed or modified electrical equipment or systems complies with applicable installation codes and standards prior to being placed into service.
  2. Condition of Maintenance – Electrical safety is greatly impacted by the condition of maintenance of electrical equipment and systems.
  3. Awareness and Self-Discipline – Employees must be instilled with an awareness of the potential electrical hazards and the self-discipline to control their own safety when working around electrical hazards.
  4. Principles – The EPS must identify the principles upon which it is based.
  5. Controls – The EPS must identify the controls by which it is measured and monitored.
  6. Procedures – Procedures detail the tasks to be conducted. Documented procedures must be in place before work is started by employees exposed to an electrical hazard.
  7. Risk Assessment Procedure – Procedures for shock and arc flash risk assessments procedures must documented.
  8. Job Safety Planning and Job Briefing - Before starting each job that involves exposure to electrical hazards, a job safety plan and a job must be conducted.
  9. Incident Investigations – Elements for electrical incident investigation must be included and should address incidents that do not result in injury.
  10. Auditing – A method for auditing the ESP, as well as field audits of employee performance of tasks must be included.

 

It is always a good idea to begin with a basic program then let it grow. Continuous improvement is important. By achieving modest goals, monitoring performance, evaluating outcomes, and implementing improvements, higher levels of safety can be achieved.

 

By using NFPA 70E and visiting the OSHA web page at www.osha. gov/shpguidelines, you should be able to develop a well-thought out electrical safety program. The main goal of a safety program is to prevent workplace injuries and fatalities. Remember, electrical safety doesn’t only affect the employer and the employee, but the employee’s family burdened with the suffering and financial hardship cause by injuries and fatalities.

 

For additional information and resources related to NFPA 70E, check out our blog series on NFPA Xchange.

Section 130.5(H) has specific requirements for equipment labels when there are electrical hazards present. For some reason, users of NFPA 70E, Standard for Electrical Safety in the Workplace have trouble applying Exception No. 1 (compliance with a previous edition) and the requirement that the data be reviewed for accuracy within 5 years. Looking at these as two separate issues may help those who are confused on applying the rules.

The exception applies to the information on an existing label. The intent is not to require replacement of labels when electrical safety is not affected. The exception assumes that the applied label complied with a previous edition of the standard. For example, a previous edition of the standard required only an incident energy or HRC on the label. A subsequent edition required the arc-flash boundary. The current edition uses PPE categories. If nothing else has changed in the electrical system, these labels would not need to be replaced. Depending on how your facility handles electrical safety there may be reasons to change the label to the current labeling method for consistency or due to your written safety procedures. A qualified person has been trained to understand how to apply the appropriate safety procedures for any affixed, compliant label. Notice that the exception is applicable upon adoption of the current standard. It is not based on a 5-year review.

The 5-year review applies to all evaluated equipment. A review is not required to occur once every five years. It is required that a review not exceed five years. You are responsible for being aware of changes in the electrical system at your facility. It is your responsibility to conduct a review whenever a modification may change or increase the electrical hazards that an employee might be exposed to. If distribution equipment is modified the day after the labels were applied, it would be necessary to conduct a review that next day. The review may be conducted within 5 years of the last review when no known changes to the electrical system have occurred. This of course, assumes that you have conducted proper equipment maintenance, purchased the exact replacement fuse or circuit breaker for the system, and did not install auxiliary power equipment for power outages.

Another point of confusion is what is required as part of this review. The word review was chosen to be exactly that. It does not require that an entire risk analysis or re-calculation be performed within five years. You must review the systems to which the risk assessment was based on. If proper maintenance has been performed, no overcurrent devices were replaced, no new risks are present based on new equipment tasks, etc., then a note could be added in the file that the review revealed no changes in the electrical system have affected electrical safety. If equipment was not maintained, if the replacement circuit breaker specifications are different, or if the utility swapped out the facility transformer, there may be concern. A new risk assessment should be conducted to verify or change the label information.

As usual, all this is necessary to protect the employee from injury. Anything that effects their safety must be addressed in a timely manner. Hopefully, the label and risk assessment reviews are just another area where you go beyond the minimum requirements of the standard.

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: A host employer is responsible for the safety of contract employees.

People tend to get hung up on whether or not it is safe to work on a specific piece of electrical equipment. Often the hang up is caused by an attempt to classify a task as electrical work or non-electrical work. Working on electrical equipment or performing non-electrical work are really just terms. When it comes to electrical safety the task being performed does play a role in the steps to be taken in protecting the employee. However, the electrical hazard is really the issue. What doesn’t change, regardless of what the assigned task is considered, is whether or not the employee is exposed to an electrical hazard. 

Consider the exposure to electrical hazards without classifying a set of tasks as electrical or non-electrical. An equipment label indicates that the restricted approach boundary is 2 feet, 2 inches, the limited approach boundary is 5 feet and the arc-flash boundary is 14 feet. An employee is removing the bolts to open the enclosure although the equipment is not yet placed into an electrical safe work condition. Another employee who will do a thermography scan and a maintenance worker assigned to vacuum out the equipment are standing 4 feet away. Another worker is standing 2 feet away ready to establish an electrically safe work condition after the thermography scan is completed. Another worker is painting the ceiling 10 feet away. There will be exposed electrical hazards when the enclosure is opened. What does 130.2 require? It requires that an electrical equipment be placed in an electrically safe work condition whenever the exposed voltage will be above 50 volts or when someone is interacting with equipment that increases the likelihood of an arc-flash unless the exposure is justified. Section 130.3 requires that employees be protected when working while exposed to electrical hazards. What exposed hazards will put each of these employees at risk?

Start with the employee unbolting the enclosure’s cover. This employee will be within the restricted approach boundary during the removal of the cover. Not only will the employee be inside the arc-flash boundary at that time but will be interacting with the equipment in such a way to increase the likelihood of an arc-flash. The employee who is responsible for establishing the electrically safe work condition is also within all three boundaries. The thermography and maintenance employees are within the limited approach boundary as well as the arc-flash boundary. What of the worker whose back is to the equipment while painting the ceiling? That worker is within the arc-flash boundary and may not know what is occurring behind her. 

There are so many things that I would do differently, but this blog is to illustrate a point. NFPA 70E, Standard for Electrical Safety in the Workplace does not deem a task as electrical or non-electrical work. It requires that all employees be protected from electrical hazards. There are specific requirements on how to do so based on the boundary being crossed. Who is permitted to cross a specific boundary and what should occur upon doing so is also addressed. It does not matter if an employee’s title is mechanic, electrician, maintenance worker, technician, contractor, or painter. NFPA 70E uses the terms qualified and unqualified person. All five employees are at risk of being injured by an arc-flash. Two of the employees are at increased risk of being shocked (electrocuted) and two more are exposed to a shock hazard. 

How you classify a task at your facility is semantics when it comes to electrical safety. What will be your justification for the painter’s injury following an arc-flash incident? That she was not working on the electrical equipment will not be acceptable. It will not matter that the thermographer was doing something deemed non-electrical when the arc-flash occurred. Is the injury different because the employee removing the cover is a technician when he is electrocuted due to a loose, energized wire? If you want to get hung up on an electrical term, make it hazards. Adequately protect all employees performing any task around any electrical hazard. Even better, don’t expose an employee to an electrical hazard.

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: Arc-flash label replacement and risk assessment reviews.

This blog was going to cover protecting employees from electrical hazards, but the subject has been changed to reflect the latest news about NFPA 70E.

The Second Draft of NFPA 70E, Standard for Electrical Safety in the Workplace has been posted on the NFPA 70E Doc Info Page under the Next Edition tab. Please review the document since it is what will to be voted on at the 2020 Conference and Expo in Orlando. You have until February 19, 2020 to submit a Notice of Intent to Make A Motion (NITMAM) if you feel the Second Draft requires further revision. You should review the Regulations and Policies and the standards development process if you intend to submit a NITMAM. 

It is important that you play a role in the development of the standard. Safety in the workplace can only be improved through the benefit of your knowledge. What you see online is what will become the 2021 Edition if no Certified Amending Motions (CAM) are presented on the floor in Orlando. You will be complying with the requirements for the next 3 years. It is your standard, be part of it.

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: When to protect an employee from electrical hazards.

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 110 is going through its first substantial change in decades and the change will affect those who typically were not subject to NFPA 110's requirements. The different uses of fuel cells have increased as the cells became a viable power source option. One such use is as an emergency power source. The National Electrical Code(NEC) has permitted fuel cells as an emergency source since 2005.  NFPA 99, Health Care Facility Code added fuel cells as an acceptable emergency source in 2012. The scope of NFPA 110 is the performance of emergency and standby power systems providing an alternate source of emergency electrical power to loads in buildings and facilities in the event that the primary power source fails.

Currently, there are no NFPA 110 requirements addressing fuel cells for that application.

The performance of an emergency power system is critical for life safety. With the increased interest is utilizing fuel cells, general installation requirements for fuel cells are inadequate just as general requirements for a generator were inadequate. There needs to be specific requirements to address issues to help ensure proper fuel cell function during an emergency.  To that end, the NFPA 110 Technical Committee is seeking public and industry comments for the next edition of the standard. The intent is to provide performance requirements similar to those for generators.

Much work is being conducted to have the requirements fleshed out for the Second Draft meeting. The Technical Committee has drafted Committee Input No. 9 (CI-9) to solicit comments on the performance requirements specific to a fuel cell used as an emergency system. Please review CI-9 through the online portal.

Comments can be made until May 6, 2020 by clicking the link to Public Comment.

70e

With the number of electrical contact fatalities in the workplace being relatively flat since 2012 (average 146 fatalities with a range of 134 to 156), I decided to look into what the Bureau of Labor Statistics (BLS) database provides for the electrical parts contributing to these fatalities. Perhaps if more of us have knowledge of who and what are involved in electrocutions we can further reduce the number of fatalities. 

The 1980-1992 data from the National Institute for Occupational Safety and Health (NIOSH) National Traumatic Occupational Fatalities Report (May 1998) shows a high of 582 electrical contact fatalities in 1981. An average of 411 fatalities occurred over those dozen years with the construction industry accounting for a majority of the fatalities. The most frequent victims were linesmen, laborers, electricians and painters. Thirty-three percent of the electrocutions occurred at less than 600 volts. Of these low-voltage electrocutions, 54% occurred at household voltage levels (120-240 volts). Fatalities at all voltages were caused by: direct worker contact with an energized powerline (28%); direct worker contact with energized equipment (21%); boomed vehicle contact with an energized powerline (18%); improperly installed or damaged equipment (17%); conductive equipment contact with an energized powerline (16%). Over 60% of the electrical contact fatalities occurred by contact with overhead power lines.

The BLS database shows an annual average of 269 electrical contact fatalities between 1992-2010 with a high of 348 in 1994. Although listed differently, the construction industry still suffered the most fatalities over this period. The three leading causes of electrical contact fatalities were: contact with overhead power lines (43%), contact with wiring, transformers, or other electrical components (16%) and contact with electric current of machine, tool, appliance, or light fixture (10%). 

The BLS lists an annual average of 152 fatalities between 2011-2017 with a high of 174 fatalities in 2011. Once more the construction industry suffered the most fatalities. Recording of the fatalities and the equipment involved changed in 2011. Now power lines, transformers, and convertors are included in one category which accounted for 59% of the fatalities, followed by building electrical wiring (15%) and power cords, electrical cords, extension cords (10%) and switchboards, switches, fuses (8%). 

An encouraging note from this data is that there has been an annual decrease of 76% in electrical contact fatalities since 1982. Which not surprisingly began to decrease after the issuance and increased use of the first edition (1979) of NFPA 70E, Standard for Electrical Safety in the WorkplaceA discouraging statistic is that nearly 60% of the annual fatalities over 40 years have consistently been through contact with overhead wires. I looked through available NIOSH case studies to find out who the victims were. Electricians, linesmen, painters, grounds keepers, roofers, and tree trimmers are common victims. A majority of their fatalities involved the use of a ladder. Other victims include well drillers, dump and cement truck drivers, and boom truck operators. Most of these involved parking near or beneath overhead power lines then raising a portion of the truck. It is disturbing that awareness of the work area could be a simple way to cut electrocutions in the workplace nearly in half.

NFPA 70E, Standard for Electrical Safety in the Workplace as its title suggests, is for all employees who might be exposed to electrical hazards while performing their assigned tasks. However, many employers and employees tend to believe that it is written only for those in the electrical industry. This may be one reason for so many overhead power line fatalities occurring even though NFPA 70E has requirements specifically covering this scenario. Fatalities are occurring in trades that may be mistaken in the belief that an electrical safety program does not apply to them. It is foreseeable that employees from these other trades will be exposed to electrical hazards. A field, yard, roadway or rooftop is their work environment. Federal law mandates that an employer furnish to each of his employees’ employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees. If you are not in an “electrical trade” what does your employer do to ensure your electrical safety at your workplace?

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: Where are the employees who are exposed to electrical hazards?

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.

Reply to this statement if you are capable of being truthful to yourself. I have always followed my electrical safety training. Unfortunately, for majority of us, the honest answer is no, I have not always followed my safety training. For some of us it may have been when working on a 120-volt circuit. For others it may have been a 13.8 kV system. It really doesn’t matter what the voltage, current or incident energy was. Nearly 25% of the electrical contact fatalities occur at or below 220 volts. Most of us work on electrical systems that have the capacity to kill. A fatality has probably been recorded for the type of electrical system you work on. It would be surprising to meet someone who did not know that contact with electricity can be fatal. Yet, according to the Bureau of Labor Statistics, since 2003 there has been an annual average of 186 electrocutions in the workplace.

The first question is why do we put ourselves at risk of becoming a fatality? We have been trained to recognize and avoid electrical hazards but still we put ourselves at risk. We know that our death is a potential outcome of performing the task the way we intend to do the work. We know that the circuit should be deenergized regardless of voltage or incident energy. If energized work is justified, we know we should get the appropriate tools and use the correct personal protective equipment. However, at some point in our career we do not shut off the system or take the trip out to the truck to get the proper gear. The next question is why do we decide to risk our life?

Over my career, the most common answer is that we can’t be bothered: we can’t be bothered to shut the system down; we can’t be bothered to walk downstairs to the panelboard; we can’t be bothered to take the time necessary to correctly don the protective gear; we can’t be bothered to come back tomorrow to finish up the work; we can’t be bothered to take time to explain to our employer that being at risk is wrong; we can’t be bothered to forego accepting a job that puts us at risk, and/or we can’t be bothered to protect ourselves when a task will only take a few moments. 

So, we justify risking our lives to ourselves: the disconnect is too far away; I know what I am doing; they will not let me shut the production line down; the protective gear makes it difficult to work; I have never been injured doing it this way; I shut it off so it must be off; my shift is done in a few minutes; I won’t make a mistake; I’ve been shocked before; it’s only 277 volts, and/or if I don’t do it someone else will. Unfortunately for many of us, we justify putting a paycheck ahead of our life.

Sometime during our career, many of us have put ourselves at risk of becoming a fatality regardless of our safety training. We may have done so with no adverse consequence. In that case no one is the wiser. No harm, no foul? We may have taken a risk and ended up with a temporary injury or some time away from work. Were we rewarded for being a hero who took an undue risk or were we tagged as an employee who violated the rules? Worse yet, some have risked their life and lost. Was the consequence of becoming a fatality and its impact on their family considered when they justified ignoring their safety training?  No one alive can know the answer to that question.

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: What is causing electrical contact fatalities?

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.

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