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75 Posts authored by: ccoache Employee

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.

 

70e

 

Electrical safety in the workplace is not as clear cut as many would like. It would be easier if boxes could be checked and safety would be achieved. However, a detailed step-by-step checklist is not possible. Although the basic concept of not being exposed to an electrical hazard is the crux of electrical safety, the organization, management, and employee have a substantial impact on achieving that goal. There are signs throughout the system that may point to problems needing to be addressed to bring things back in line.

 

The organization should review a program or process if personal ownership has taken a back seat to numerous, inefficient, or cumbersome processes. Another problem indicator at the organization level could be that no one is assigned ownership for high risk tasks. It is not uncommon for a risky behavior to become the norm (standard operating procedure) when a bad outcome does not occur for the situation. It is also not a good sign for the organization when a program or procedure is developed then put on the shelf as a job well done. Electrical safety is a continual process.

 

Those in a supervisory role affect the safety culture of a business. A supervisor who is not on-site may not be aware of conditions affecting safety or of the attitude of employees. This can also lead to the supervisor being unaware of how employees perceive the risks associated with assigned tasks and how those risks are managed. Completion of a task without an adverse outcome, when undue risk is taken, tends become the basis for continuing current practices. The supervisor may use this flawed performance indicator as justification for existing risk management strategies. Lastly, another sign of weakness at the supervisory level is when delegation is lacking. Personal ownership goes a long way in maintaining a safety culture.

 

An employee is at risk during the course of a normal workday and as such their performance is critical to an organization’s safety culture. This is also the level where human performance issues are prevalent. Employees start considering their work activities as routine after time on the job. They may self-impose production pressures when no quota is conveyed by the organization. An employee may make risky judgments without taking the time to fully understand the situation in order to meet an unwarranted production goal. Some employees may take pride in their ability to work through or with levels of risk that could have been mitigated or eliminated. Such actions without an adverse outcome become the basis for continuing that practice. Employees may not communicate the risks associated with their assigned task effectively up the company. They may assume that the next level of supervision knows or understands the risk involved. Worse than this, employees may assume that are insufficient resources to manage the risk. Lastly, another indicator of a safety culture weakness is that problem reporting is not transparent. This leads to employees who are not willing to report a high-risk condition.

 

There are many more indicators that an organization’s safety culture is not as solid as perceived. Oversight of the organization’s culture is necessary in order to positively affect safety. All organizational levels must be proactively involved with establishing and maintaining an electrical safety program. Otherwise, indicators such as I have pointed out could be a starting point for an incident investigator. 

 

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: Can you be honest with yourself?

 

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.

 

Wherever there is electrical energy there is a potential for an exposure to an electrical hazard. What makes a work environment safe from electrical hazards? For that matter, who makes sure that you are not exposed to electrical hazards? Is it the equipment manufacturer, your employer, or someone else? Although all of these play a part in electrical safety in the workplace, there is only one who truly has control over it. That person is you and there are steps you can take to keep yourself safe while at work.

Step One: Overcome our own ignorance. It only takes a little bit of knowledge and by reading this blog the hard part is already over. You are now aware that there are electrical hazards out there that can kill you. That was easy. Step One: done. 

Step Two: Recognize when you might be exposed to electrical hazards. NFPA 70E, Standard for Electrical Safety in the Workplace lists conditions of equipment that should permit normal operation of that equipment without exposing you to an electrical hazard. These are properly installed, properly maintained, used in accordance with the instructions, doors closed and secured, covers installed and secured and no sign of impending failure. You should know what the equipment you are working around looks and acts like when it was new. If something has changed or if anything looks out of place (i.e. broken parts, smoke, or funny smell) you may be exposed to an electrical hazard. Step Two: done.

Step Three: Recognize exposed known electrical hazards. The first hazard is a shock hazard. If there is an exposed, conductive, electrical part there is most likely a shock hazard. The exposed part could be a wire, circuit in an open enclosure or broken light bulb. There is a possibility that electrical current will pass over or through your body with fatal consequences if you contact the exposed part. The second hazard is an arc-flash hazard. If electrical equipment is not under normal operating conditions (see Step Two) there might be a possibility of an arc-flash. Unless your employer has done a comprehensive hazard assessment throughout the facility, you should not assume that the absence of an arc-flash label means that there is no arc-flash hazard. Step Three: done.

Step Four: Trust your instincts. A gut feeling often lets you know that something does not seem safe to do. You know when you are out of your comfort zone. You know when equipment appears to be acting funny. You know that is not a normal situation for everything to seem OK, but you still experience near-death experience (receive a shock). Step Four: done.

Step Five: Do not interact with the equipment. If everything is normal (see Step Two) you should be good to go. If it is not normal do not touch, operate or remain around the equipment. Step Five: done.

Step Six: Report the situation. You have recognized a problem. You may have been lucky enough to have just missed becoming a fatality when you received a shock. Without this important step the next person around the equipment could become a fatality. Make sure that you properly report the hazard and you might want to have it documented. Remember, if something is not documented it did not happen. Step Six: done.

Step Seven: Do not assume that someone has fixed the problem. If you have received an electric shock do not let someone tell you not to worry about it. The next shock may be fatal to you. I have many incident reports where the employee reporting more than one shock incident ended up being a fatality due to that same circuit. If the equipment is damaged make sure it has been repaired. Confirm that the hazardous situation has been satisfactorily addressed. Until someone assures you that the problem has been fixed do not interact with the equipment. Step Seven: done.

Step Eight: Enjoy the rest of your workday. Continue to be aware of the electrical hazards around you and how to avoid them. Step Eight: done.

Step Nine: Go home. The most important step for your family. Return home uninjured from your workday. Remember that all of these steps apply to the administrative assistant and the production line worker, as well as the master electrician. Step Nine: done?

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: Smoke on the Horizon (Signs of Weaknesses in a Safety Culture).

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.

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

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

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

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

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

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

 

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: Take responsibility for your own safety.

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.

70e

The Second Draft meeting for NFPA 70E, Standard for Electrical Safety in the Workplace has been completed. There were 45 Second Revisions developed out of the 115 Public Comments submitted. Soon these proposed revisions will be on the way to the Technical Committee for formal ballot. The result of that ballot will determine if the Second Revisions will make it into the standard. The public will be able to view the results once the ballots have been tallied. Here are three of potential major changes.

During the First Draft, Article 360 covering capacitors was added and there are several second revisions proposed for that article. Annex R (also added at First Draft) which provides guidance when working on capacitors was revised to further clarify the associated hazards. For those working with capacitors, you should review the information once the Second Draft Report is available to the public.

Although it is not a change in a requirement, as expected, what an electrically safe work condition (ESWC) is resulted in a proposed change. This dealt with the issue of “eliminating” an electrical hazard. Informational notes are proposed to be modified to clarify that an ESWC is when electrical parts are in a de-energized state for the purpose of temporarily eliminating electrical hazards for the period of time for which an ESWC is maintained.

One proposed change took me some time to comprehend. The change deals with the required arc rating of outwear worn over PPE properly rated for the hazard. Although arc-rated PPE worn over other arc-rated PPE does not directly add together to get a higher arc-rating, it also does not lower the arc-rating of either piece of PPE. So the minimum arc-rating will be the higher of the two. Since all arc-rated PPE is also flame-resistant, the concern of continued exposure to the thermal hazard of the outer layer in flame is unfounded. Therefore, an outer layer with any arc-rating will now be permitted over the appropriately rated PPE.

Only the formal ballot will determine if any of the forty-five revisions will proceed toward the 2021 edition of NFPA 70E.   Some of the changes may alter the things you do during the course of the workday. For others of you, the changes may not have any impact. However, with around three-hundred public inputs being submitted each cycle, at some time, a change will affect your personal safety and the way you perform your tasks. The call for public input on the 2021 edition will be sometime in the first half of 2021. Be ready. 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: Three different approaches to electrical safety with the same result.

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.

How do you know if equipment is ready to fail? What are signs of impending failure? Who should know what the signs of impending failure are for a piece of equipment? NFPA 70E®,Standard for Electrical Safety in the Workplace® requires that before you operate a piece of electrical equipment that you confirm that the normal operating conditions have been met. You are put at risk of injury if any one of those conditions is suspect. I have written several blogs covering the subject and the impending failure condition confuses many people.

Typically the employer/owner is not aware of the daily condition of individual equipment in their facility. This means that the unqualified person operating the electrical equipment must be trained to recognize an impending failure since conditions can change on a daily basis. The electrical safety training provided should include recognizing potential failure modes and identifying signs of impending equipment failure. This is true whether the equipment that the employee operates is portable and cord-and-plug connected or a section of a large assembly line. However, the signs of impending failure vary greatly by the type of electrical equipment.

The smell of ozone, presence of smoke, and sound of arcing are all possible indications of potential equipment failure. Damage or discoloration of the power cord could be a sign for the portable equipment. A tripped circuit breaker or operation of a ground-fault circuit-interrupter could be another sign. For the assembly line equipment there may be warning lights or alarms. A controller may shutdown to prevent damage and should not be routinely reset. Without proper training to understand such things the employee may not recognize the risk of an injury while operating the equipment.

Electrical safety is not just for qualified persons and involves a lot more than donning PPE. Federal law mandates that an employer provide a workplace that is free from known hazards. An employee operating equipment that is exhibiting signs of impending failure is placed at risk of injury due to electrical hazards. It is only proper training that prevents an injury in that circumstance. Does your electrical safety training for unqualified persons include this important aspect? If you are the employee, do you know how to recognize a potential equipment failure that could prevent you from returning home today?

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: On July 16th - 18th, I will be in Indianapolis for the NFPA 70E meeting and the week after for the NFPA 72 meeting so this will be my only blog for the month of July. I will post something about that meeting in my August blog.

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.

Talk about stirring up a hornet nest. A few blogs ago, the most frequently asked question was discussed. That blog concluded by stating: I will only provide one answer in order to ensure protection of your employee. That answer is; yes, PPE is necessary for every task you authorize an employee to perform, including operating a circuit breaker or using a switch to turn a light on in an office. If you want a different answer train your employees and perform risk assessments. Many took offense to the need for PPE to turn on a light. However, if you read the blog, it states that without a risk assessment, I must make the determination that PPE is necessary to operate a light switch. This does not mean that a risk assessment is necessary every time a light switch is operated within your facility. It does not mean that PPE is necessary to turn on any light switch nor does it mean that normal operation of a light switch is not possible. It does not mean that only qualified persons can perform that task. There are many other things that statement does not mean. I have stated several times that something may be presented to prove a point in a blog. So what was the point in that blog? The point was that I have no way of knowing what is happening in your facility.

Look at the normal operating conditions that permit operation of a piece of equipment. Now consider what could be happening on-site. There is no one verifying compliance with National Electrical Code® (NEC®) installation requirements. Installations are done with materials available in-house to quickly get the job done whether the material was specified or not. The 15-ampere switch is used beyond its ratings and is protected by a 30-ampere fuse. The conductors are 14 AWG and are improperly installed to the switch box. The switch is also inappropriately used as a motor controller. The switch is improperly installed so that the yoke is not grounded. The faceplate is damaged thereby exposing energized parts. The metal box for the switch is not grounded. There is visible arcing when the switch is operated. With the misuse of the switch, there is visible discoloration. The employee has not been trained to understand normal operating conditions or to recognize signs of impending failure. An employee is at risk of injury by simply flipping that switch. Although an arc flash is not likely to occur there are several signs that a shock hazard may be present. Even though the restricted approach boundary is avoid contact, the employee is required to make contact with the switch. The yoke, the faceplate screw (or faceplate itself if metal) or the box could be energized. The employee does not know to avoid contact with any metal part and is put at risk of electrocution

My answer is for conditions that I do not personally verify. When pushed to provide an answer to the question; is PPE necessary for a specific task to be conducted on specific equipment, my answer will always be; yes, PPE is required unless YOU determine otherwise. I will always consider that an employee is exposed to a hazard. For me to do otherwise may put that employee at risk of injury. You may determine that the normal operation of light switches or anything else in your facility does not require the use of PPE. It is not typical for such tasks to require PPE. This is true at our facility. Hopefully, it is true at yours as well. 

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®)? Subscribeto the NEC Connect newsletter to stay informed of new content. The newsletter also includes NFPA 70E information such as my blogs.

Next time: Impending equipment failure.

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 are reading this blog so you must be concerned with electrical safety in the workplace. Did you submit a public input to NFPA 70E®, Standard for Electrical Safety in the Workplace® last year? Have you gone to the NFPA 70E website to see what happened to that public input? The public comment closing date has passed. Whether your public input resulted in a first revision or was not included in the standard, has anyone in the world submitted a public comment to re-address your input at the second draft meeting? Soon you will be able to see what the public had to say about the public inputs and the proposed changes that occurred during the first draft stage. 

There are 115 public comments submitted that will be addressed at the second draft meeting. A quick review of the distribution of submitted comments shows that Section 120.5 has received the most comments. Every comment will be addressed at the second draft meeting. NFPA meetings are open to the public which means you are invited whether or not you submitted a public input or public comment. The public is invited to Indianapolis, Indiana on July 16th-19th, 2019 to witness what happens at thesecond draft meeting. I look forward to seeing you in Indy.

For more information on 70E, read my entire 70E blog series on XchangeNext time: Operation of a light switch and the need for personal protective equipment.

 

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.

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.

While I prepare for the second draft meeting of NFPA 70E®, Standard for Electrical Safety in the Workplace®, I also begin to prepare for the next edition of the handbook. I review the questions received over the three year revision cycle to determine what needs to be further explained to help NFPA 70E users increase electrical safety at their company. Questions are varied but there have been three main recurring themes. In honor of National Electrical Safety Month this May, I thought I would go over those with you. The first is; does personal protective equipment (PPE) have to be used to perform this task? Second is; is this employee qualified to do this task? The third is; how is a risk assessment performed? The first two themes are not technical questions. It is expected that I will provide a definitive answer to remove the need for a decision by the questioner. The third theme although more technical is not addressed by NFPA 70E. There are hundreds of valid methods of performing a shock and arc flash risk assessment for the thousands of tasks that could be conducted on the millions of pieces of equipment available. 

So what is the most frequently asked question? It is whether PPE is or is not necessary when operating a circuit breaker. To those reading this; NFPA staff cannot make a determination of conditions that require a visit to the facility. I am not able answer the question if PPE is not necessary for any task that you permit to be conducted as justified energized work. (Which begs the question; is energized work justified?) You are the one who does the required risk assessments for the tasks conducted on your equipment. Your risk assessment determines the need for PPE for any task an employee is scheduled to do. However, my answers to this question attempt to provide some education to those asking the question. This typical covers the broad application of NFPA 70E and refers to sections within Article 130.

The first thing is that circuit breakers are used in many pieces of equipment and the operation of a circuit breaker varies greatly with each application. A blanket statement regarding the need for PPE when operating a circuit breaker is not possible. Also, NFPA staff does not determine that the manual operation of any specific breaker in any specific equipment is acceptable. Which leads to a second point. The permission to operate equipment exists if the equipment is under normal operating conditions. I have addressed this several times. Refer to my blogs: The things needed before normal operation is consider safe (PART 1), the things needed before normal operation is consider safe (PART 2), normal operation and you, and is your equipment properly installed. If the equipment is under a normal operating conditions and is being operated properly, PPE is typically not necessary to perform the task. It is your risk assessment that determines that the equipment meets these requirements. It is not something that NFPA staff is able to do for you.

The next point is the requirement that equipment must be placed into an electrically safe work condition (ESWC) whenever an employee is within the limited approach boundary or is interacting with the equipment in a manner that increases the likelihood of an injury even if energized parts are not exposed. Energized parts must be exposed in order for there to be a limited approach boundary. Your risk assessment determines this. If the qualified employee will be within the restricted approach (or arc-flash) boundary then appropriate PPE is necessary. If the equipment is not under normal operating conditions, there typically will be an increased likelihood of injury. Operation of the equipment in such a state puts an employee at risk of injury. Your risk assessment may also determine that even if the equipment is under normal operating conditions that opening the circuit breaker raises the risk of an incident above a level that is acceptable to you. Your risk assessment would therefore identify the PPE necessary to perform the task.

Many still want an answer to the question; is PPE necessary to operate a circuit breaker? As stated above, I am not at your facility. I must consider the worst case situation where your equipment is not properly installed, is not properly maintained, and is used beyond the manufacturer’s requirements. Equipment covers are missing, equipment doors are open, the listing of the equipment is violated, and the equipment is exhibiting signs of impending failure. I will ponder that your employee is not properly trained even if you consider them to be qualified or to be an unqualified worker with proper training for the task. I will accept that you have no documented electrical safety program or procedures. I will assume that you and your contract employer have not discussed electrical safety issues. I will contemplate that the equipment is not being operated properly. I will not take your word that any of my assumptions are incorrect to provide you a definitive answer. I will only provide one answer in order to ensure protection of your employee. That answer is; yes, PPE is necessary for every task you authorize an employee to perform, including operating a circuit breaker or using a switch to turn a light on in an office. If you want a different answer train your employees and perform risk assessments.

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: Second Draft Meeting for NFPA 70E, Standard for Electrical Safety in the Workplace.

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.

May is National Electrical Safety Month, an annual campaign sponsored by Electrical Safety Foundation International (ESFI), which works to raise awareness of potential home electrical hazards and electrical fire safety on the job. As we consider this month of safety, as an industry professional, what do you think of when you hear the phrase “electrical safety”? 

The first thing that comes to mind may be avoiding a shock or electrocution. Some will jump to the safety of a person interacting with installed electrical equipment. Often this means following the manufacturer’s operating instructions on equipment that is properly installed, properly maintained, closed and secured doors, covers in place and secure, and with no sign of impending failure. Many in the electrical industry may think of personal protective equipment (PPE) and establishing an electrically safe work condition as electrical safety issues. Did anyone think of the design of an electrical system or of the electrical equipment itself? If so, was the equipment operator the only one considered for product liability issues or did you include the person who will maintain the equipment? 

An example of designing for electrical safety for abnormal conditions is a ground-fault circuit-interrupter. For more than a century, people were being electrocuted by accidental contact with energized circuits or parts. A design group developed a device that would limit the potential of an electrocution by opening the circuit before the current level approached an electrocution risk. It is impossible to estimate the lives saved by this device. The design of electrical systems or equipment does play an important role in providing electrical safety. However, many product standards only address safety of the equipment when it is under normal operation conditions. Equipment evaluated under these standards does not typically have a limit to the voltage, current or energy level contained within the enclosure.

The risk of serious injury greatly increases when someone must open the enclosure for any reason. This must be able to be safely performed. As the equipment designer did you consider this highly probable situation? Did you design electrical safety into the equipment to protect maintenance personnel? Even when equipment is going to be placed into an electrically safe work condition (de-energized, locked out), there is a risk in verifying that all energy sources have been successfully removed. You, the equipment or system designer, can save lives by considering electrical safety for tasks conducted over the life of the installation. Sectionalizing equipment, isolating higher voltage, current or energy level circuits, providing disconnect devices in strategic locations, opting for a different circuit design, using insulated terminal blocks or designing-in mitigation systems are examples of means of providing safety for maintenance personnel. When designing an electrical system the same considerations are beneficial. A current-limiting overcurrent device, a separate disconnect box, an arc-flash mitigation device, or an energy-reducing maintenance switch are some methods of protecting the maintenance person.

A designer of electrical equipment or systems needs to consider the electrical hazards inherent in their design for anyone who might be exposed. A person is not only at risk by using the equipment but while maintaining the equipment. There are ways to mitigate the hazards and associated risks in the design. Once the equipment is produced or the system is installed the possibilities for providing protection are greatly decreased. 

During National Electrical Safety Month, let’s take the time to address electrical safety in the design stage; doing so will provide protection for all and will serve to make the workplace a safer electrical environment.

For more information on 70E, check out our 70E blog series here on Xchange. Additional information can be found on NFPA's website or by subscribing to our monthly NEC Connect Newsletter.

Last August I wrote a blog about using the hierarchy of risk controls when the policy is to establish an electrically safe work condition (ESWC). That blog closed out by asking why go through the additional steps of the hierarchy when the hazard will be removed. The example provided was that I am aware of situations where equipment has an incident energy higher than what currently available PPE is rated to provide protection from. Hopefully, this situation will not occur at your facility for any newly installed equipment since you plan to address this hazard early on. But I have been asked what should be done in the cases where equipment is already installed and installation practices cannot be employed to reduce the hazard or risk. In other words elimination, substitution and engineering controls from the hierarchy cannot be employed (at this time.) The work has to be conducted but it is not possible to safely establish an ESWC.

Many simply use the “theory” 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. The equipment is installed and nothing can be done regarding the installation. They will use this “theory” every time the employee is put at risk of injury performing that same task on that installed piece of equipment. Safe installation and normal operation of the equipment does not have a limit on the voltage, current, or energy levels present in that equipment. Those levels are generally a concern once an employee is exposed to them under conditions that are not normal operation. After all these years I do not condone ignoring electrical safety of the employee during design and installation. Every case is different and this blog should in no way be used as a basis for a policy. Some of the examples may seem extreme but remember, this is about not injuring the employee. This will discuss establishing an ESWC when hazards are excessive since very few situations actually qualify as justified energized work. 

If the work can be delayed, a full electrical shutdown by the utility during a facility closure is an option. Even if the facility does not normally close there may be slow times when it is ideal to have the electric supply removed to protect the employee. The utility has policies, practices and procedures that deal with electrical hazards beyond what is typically present on the load side of the service point. Remember this is for the purpose of establishing an ESWC. This typically does not take days or even hours. Once the ESWC is established for that equipment, the remainder of the facility could be brought back online. If this is not an option, the individual equipment may provide guidance on how to perform the task. All loads should be removed. Although non-contact methods are not permitted to verify an ESWC at lower voltages, they may be used to indicate that the voltage has not been properly interrupted thereby avoiding an unexpected outcome. Higher incident energies may also be associated with higher voltages where non-contact methods are acceptable. With arc-flash boundaries at higher incident energies often exceeding 10 feet, it is difficult to remain outside the arc-flash boundary when verifying an ESWC. However, it may be possible to use probes while not standing directly in front of the equipment and away from the arc-flash direction. This could be via remote control or special probes. It may be possible to design a mobile arc-flash barrier to allow closer approach while verifying the ESWC. I would brainstorm solutions with a group. I would exhaust all possible ideas, concepts, and approaches to verifying the ESWC in these cases. I would not condone having an employee don an 80 calorie rated suit while subjected to a possible 200 calorie incident energy. Whatever solution I came up with to deal with this situation, I would probably perform the task myself. If I was not comfortable with the solution I would never put another person at risk.

This goes back to my blog discussing installation and electrical safety of future employees. These should not be independent considerations. I would use this out of the ordinary solution once. Now is the time to use the hierarchy of risk controls to mitigate this dangerous situation in the future. As a safety professional I would feel obligated to better protect the employee the next time this task must be conducted. This may involve modification of the installation. If not now, when? It would be remiss to not correct a known hazard exposure for the employee. At the very least, I would work to have the voltage and incident energy values lowered to ones where appropriate protection is available. At the best, I would strive to have the levels lowered to the least practicably possible. I might also consider installing a permanently mounted test device. 

No matter what you decide to do in these situations consider the outcome. If an employee is injured or killed under the current policy permitting high incident energy levels, how will you justify why you had them do what they did? If an injury happens the third or fourth time that you expose them to these elevated levels, what will be your reason for not addressing it the first time? For that matter, you might want to use this concept anytime an employee is put at risk. What will you say you did to protect that employee from a hazard you had the possibility of mitigating?

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: The NFPA 70E question asked the most often.

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.

 

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.

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