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80 Posts authored by: ccoache Employee

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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.

 

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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.

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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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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.

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