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

 

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


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


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


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


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


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


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


Next time: NFPA 70E First Draft Meeting

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

 

An important issue has arisen with NFPA 70E®, Standard for Electrical Safety in the Workplace® and what it takes to establish an electrically safe work condition (ESWC). There have been some misinterpretations of the content. The issue revolves around the hierarchy of risk controls, the act of establishing an ESWC and a properly established EWSC. The words are carefully chosen and it is troubling that they are being misunderstood. If I have made an error in my presentations, in NFPA 70E®, Handbook for Electrical Safety in the Workplace® or in this blog that a properly established ESWC has not removed the hazard, I apologize for that. However, I am not aware of any instance where this has occurred and would gladly welcome any feedback. The following statements from those forums agree with industry’s view that a properly established ESWC has removed the hazard:

 

  • After this strategy (EWSC) is executed, all electrical energy has been removed from all conductors and circuit parts to which the employee could be exposed.
  • Where an ESWC exists, there is no electrical energy in proximity of the work task(s). The danger of injury from electrical hazards has been removed, and neither protective equipment nor special safety training is required.
  • By creating an ESWC, the risks associated with potential electrical hazards have been temporarily reduced to an acceptable level and electrical hazards have temporarily been effectively removed.
  • There is no electrical hazard when equipment is in an ESWC. You will not be harmed by electrical energy.
  • If trainers are stating that establishing an ESWC is an administrative control they are correct. However, they should be stating that it (an ESWC) achieves elimination of the hazard through the use of several of the controls.

 

How you look at the hierarchy is a safety issue. If you believe the act of establishing an ESWC is an elimination control there would be no need to exhaust time or money in an attempt to use substitution, engineering, awareness, administrative or PPE as a control function since the hazard has been eliminated. Step 1: ESWC. Done. However, I don’t see it that way since the act of establishing an ESWC and a properly established ESWC are two separate concepts. The act of establishing an ESWC relies on awareness, administrative, and PPE controls to achieve elimination. The hazard is not suddenly eliminated. An ESWC does not exist until all eight steps of 120.5 have been completed. With electrical safety do not treat this as a trivial matter. What seems to be misunderstood is the applicability of the required hierarchy of risk controls. The following statements help clarify the issue:

 

  • Regardless of the intent to require the establishment of an electrically safe work condition or to justify energized work, the hierarchy of risk controls must be implemented to minimize the hazard or risk of injury.
  • In this first context, elimination is the removal of the electrical hazard so that it does not exist at any time. If there is no hazard there is no risk of injury.
  • Temporary removal of a hazard may be achieved through the administrative control of creating an electrically safe work condition (ESWC) discussed in item 5 (administrative controls).
  • Elimination can be also be achieved by applying other controls, such as through the establishment of an electrically safe work condition.
  • Establishing an ESWC is possibly the most recognized administrative control addressed in NFPA 70E. However, when all other control methods have been exhausted, the use of an administrative control (electrically safe work condition) provides the last option to remove electrical hazards and increase the safety for an employee working on the electrical equipment.

 

There is a safety concern which clearly indicates that the hazard is not eliminated during the act of establishing an ESWC. Additional statements regarding this follow:

 

  • There is no way to establish an ESWC without some risk of exposure to a potential hazard.
  • Until the task (ESWC) is completed, a worker is exposed to hazards and potential injury since there is no assurance that the equipment is properly de-energized.
  • Establishing an ESWC through a lockout procedure removes the hazard only if correctly applied. The hazard exists prior to this occurring and after the procedure is reversed so it is not full “elimination” of the hazard.
  • Until the ESWC is established, an unacceptable risk of injury exists and employees must continue to wear protective equipment.

 

The chosen words convey the fact that the act of establishing an ESWC is not elimination of the hazard. The act of establishing an ESWC relies on awareness, administrative, and PPE controls not on elimination. These are numbers four (4), five (5) and six (6) on the hierarchy. Once the EWSC has been properly established, elimination of the hazard has been achieved. Equipment in an ESWC has had the hazards removed. The chosen words consistently convey this fact.


The fact is that the primary work procedure must be to establish an EWSC. Consider what the employee must do before they are permitted to remove their PPE (time when the hazard has been eliminated). If the act of establishing an ESWC was elimination of the hazard, there would be no need for an energized work permit, training, safe work procedures, or the donning of PPE. It is often difficult to see things differently than what is currently considered. In my mind, the act of establishing an ESWC was an elimination control until this specific hierarchy of risk controls became a requirement. The hierarchy has helped clarify the difference between the act of establishing and a properly established EWSC.

 

This should help clarify the difference between the risk control of elimination and the risk controls of awareness, administrative, and PPE necessary to establish an ESWC. It is equally important for safety to make a distinction between the act of establishing an ESWC and the result of a properly established ESWC. When you think of them as the separate issues that they are, it allows the hierarchy to be implemented to increase electrical safety. This should clarify my position on the issue of an electrically safe work condition. I am not aware that any of my statements are incorrect based on the requirements in NFPA 70E. Please quote me correctly. This is not semantics. This is employee safety.

 

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

 

Next time: Outsourcing your risk assessments.

Just when I think people are beginning to understand what is involved with electrical safety, I get a series of calls that convince me otherwise. Other than for the determination of PPE category or incident energy, the requirements in NFPA 70E®, Standard for Electrical Safety in the Workplace® do not really include a time constraint for the conditions of conducting energized work. However, it seems that many want to include time in their safety consideration. How long can someone leave a site unattended before they have to verify an electrically safe work condition (ESWC)? How long can an employee work on electrical equipment before they have to establish an ESWC? How long does someone have to be inside the arc-flash boundary before they have to don PPE? How long do energized electrical parts have to be exposed before they must considered to be an electrical hazard?
Those are just some of the actual questions that I have been asked. I am not aware of a method to determine that sticking a screwdriver into energized electrical equipment for only few seconds is considered safe. I am not sure that leaving an area for a ten minute smoke break is insufficient time for someone else to enter the area and do something unanticipated. I am not convinced that quickly walking through the arc-flash boundary removes the possibility of an arc flash occurring. I do not know the length of time necessary to avert an incident when “only” operating an internal switch after opening an enclosure. 
How suddenly does a screwdriver slip from a terminal to initiate an arc flash or electrocution? How swiftly can an employee run when an arc flash occurs near them? How quickly can an employee react to prevent an injury after dropping a screw into switchgear? How long must electrical current pass through an employee’s body before a shock becomes an electrocution? 
There are many electrical safety aspects that rely on common sense. Use yourself as a litmus test. If you think you could be injured so does your employee. If you wouldn’t feel comfortable doing what is being proposed neither will your employee. If you think something could go wrong it possibly will. Do you really believe that putting your employee at risk only for a short time, removes the chance of an incident occurring? If you are asking these types of questions to get around providing protection for your employee, choose safety.  
For more information on 70E, read my entire 70E blog series on Xchange.  
Next time: The act of establishing an electrically safe work condition (ESWC) or a properly established ESWC.

 

With so much emphasis on the need for a qualified person in NFPA 70E®, Standard for Electrical Safety in the Workplace® many wonder why 110.2(A)(2) is a requirement. The title of NFPA 70E provides the answer. There is a potential for injury anytime an employee is interacting with electrical equipment, not just when they are working on electrical equipment. Examples of a person interacting with electrical equipment include a janitor opening a panel to turn on lights in the facility at the start of the day or a machine operator starting the equipment and performing his/her duties. Both must be trained in safety-related practices related to these tasks. Equipment must be under normal operating conditions before operating this equipment is considered to be “safe”. All employees should be trained to understand the normal operating conditions for the equipment they are interacting with. Without that understanding they could be put a risk of an electrical injury. Beyond that there are many general electrical safety topics that any employee should know.


Employees not required to be a qualified person by NFPA 70E must have the knowledge and skills necessary for their safety when interacting with electrical equipment. After understanding normal operating conditions for the equipment, the additional training is often common sense with regard to electrical safety. You may have employees using extension cords and portable equipment for example and they should trained in the use of such equipment. The following is a sampling of some basic, commonsense rules for avoiding electrical accidents and injuries that unqualified employees need to understand:

 

  • How to properly remove an attachment plug from a receptacle.
  • Never use damaged electrical equipment; damaged cables, cords, or connectors; or damaged receptacles.
  • Never reset a circuit breaker after an automatic trip but rather always notify a qualified person to determine the cause.
  • Be aware of the proper approach distance from overhead power lines.
  • Be aware of alerting techniques such as safety signs and tags, barricades, and warning attendants.
  • Never cross the arc-flash boundary.
  • Never cross the limited approach shock boundary unless advised and continuously escorted by a qualified person.
  • Never overload circuits, such as by running multiple appliances from a single outlet.
  • Never use electrical equipment if it is sparking, smoking, or otherwise appears to be malfunctioning.

 

You must determine the subject matter that your unqualified employees must know. In order to do so you must understand the duties they perform in the course of their day. Not all unqualified employees will need the same training and some employees may require a focused training program. Training will vary to deal with the specific equipment they interact with. There is nothing prohibiting comprehensive training for all employees. None of this training will make the employee qualified under NFPA 70E requirements but this training will affect electrical safety in your workplace.


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

A very troubling trend is being used by some in the electric industry. That trend is performing energized work without justification. They believe that performing energized work is defensible since they know how to protect their employee from death (notice that I did not say injury) when an incident happens. These are not NFPA 70E®, Standard for Electrical Safety in the Workplace® risk assessments. If conducted at all, some risk assessment has determined that there is a significant risk of injury from a known hazard. They just don’t want to establish an electrically safe work condition to protect the employee. The greater hazard, greater risk and infeasible criteria are ignored. They think they can guarantee that their employee will be able to return home at the end of the day. This fallacy will only serve to increase electrical injuries and fatalities. 
Currently, there are only two electrical hazards, shock and arc flash, for which protection is addressed. Assume that the employer did an NFPA 70E risk assessment but decided to ignore the standard. Personal protective equipment (PPE) will be used to protect from electrical hazards. First, shock protection requires separation of the employee from exposed, energized electrical components. Insulation is the most understood of the protection techniques whether it be through air or some other insulating material. You know everything about the type of insulation and how to maintain it. You know there are several steps where human error can render this protection technique ineffective. You know the shock PPE is adequate. 
The second recognized hazard is arc flash but assuming that it is a fully understood hazard can be dangerous. The only aspect of an arc flash that protection is provided for is the thermal injury. Protection from other hazards is serendipitous but you know that. You know that the real world incident energy is not absolutely known for any scheduled task. You know where the arc flash PPE came from, that it is compliant with applicable standards, what the ratings mean, that it has been properly laundered, and everything else about it. You know every step where human error with the PPE could lead to a fatality during an incident. Read my blogs regarding some of these issues; a best practice, PPE verification, and PPE as a control method. You know that the arc flash rating of the PPE is adequate for the labeled incident energy. 
You know that your employee is protected from the two hazards addressed. There are additional known hazards that you must protect them from but these are not currently covered by a standard. But you know that. An arc blast is one hazard that the industry has not come to agreement on. You have seen videos of an arc flash and the blast that accompanies it. Some say there is a great increase in pressure while others dispute this. A blast in a closed enclosure generates a different pressure than that from same enclosure when it is open. The chutes, channels and shape of an enclosure can alter the pressure imparted upon the employee during an incident. Employees have been knocked down or blown back yet there is debate on what had really occurred. Covers, bolts, and other electrical parts have been found several feet away. Employees have been hit by shrapnel. And yet there is no agreement on how to determine how bad a blast will be or if it will even occur. If blunt force trauma is a potential blast injury there are no protection techniques. You know this then make an assumption that an arc blast will not happen since you are not providing protection anyway. 
You don’t want to shut the equipment off even for the few minutes that many properly planned repairs take. You have not justified the need for energized work. With your employee suited up, you will make many assumptions before they begin. One is that they will follow your infallible electrical safety work program, practices and procedures to the letter because you have trained them so well that they would never deviate from it. Another is that they will properly select and use or don any PPE. Your assumption that nothing will go wrong is what causes a problem. Allow me to make an assumption of my own; you know that your employee is being put at risk solely for a monetary reason with a perceived value greater than that of the employee. 
Your employee on a step ladder leans in a few extra inches to get a better view of what they are doing. There is an incident. It could be human error or finally the equipment fails. The sound level hits 160 dB. Caustic fumes are emitted. Carcinogens are present in the smoke. A trough cover is ejected from the top of the equipment. The incident lasts part of a cycle longer than used for the calculation although the circuit breaker was maintained. Once again you knew all of this would happen. 
Such things have happened. But you knew that the hearing protection would prevent damage at the decibel level. You knew that the ejected cover hitting their face shield would not knock them off the ladder causing secondary injuries. You knew that their head was protected from the increased energy. You knew that your employee would close their eyes to avoid retina damage from the intense light. You knew that the fumes would not cause long term health issues because you knew that they would not gasp or inhale when the incident occurred. You knew that they would not breathe in the smoke and molten metal vapor that filled the room. You knew that they were not wearing underwear that would melt under PPE. Since you knew the exact incident energy you knew not to apply a safety factor to the PPE rating. You also knew that the PPE had a 100% success rate at that incident energy. You knew that an arc blast would not be part of this incident. You knew that the employee's constitution was high enough that this incident would not affect their ability to continue to function at their job. Never mind that the electrical equipment is severely damaged thereby defeating your reason for unjustified energized work in the first place. The outage was not unexpected because you knew it would occur. So, you knew to have high cost, one-off, spare equipment onsite that very quickly replaced the damaged equipment with no disruption that took longer than a planned repair after establishing an electrically safe work condition. 
What do you know now? You know that you may have been prevented a fatality but your employee’s family knows that they did not return home today. Also, OSHA knows that your employee was injured regardless of what you thought you knew.  
For more information on 70E, read my entire 70E blog series on Xchange.  
Next time: Why you need to train an unqualified employee.
When I was assigned as the staff liaison for NFPA 70E®, Standard for Electrical Safety in the Workplace®, I was also assigned the daunting task of developing a handbook. The NFPA 70E handbook had been out for several editions with each previous editor adding their own style and addressing what they felt needed clarification. I was now able to add my own viewpoint but I could only address concerns that I had. I also used information received from you as part of being an NFPA member which gave you the ability to ask me questions. What I think was needed may not be what you really wanted. I did not want to go off on a tangent but felt that the employee who was risking their life while performing electrical work was not adequately addressed. That became the theme for the 2018 edition commentary.
It is always a loaded prospect to solicit information for the public but the readers of this blog are kindred spirits. We all want to save lives and prevent injuries.  
So, if you have seen a 2018 handbook, please help make the 2021 edition better. Of the things I tried were they helpful? Here are some features and my reason for including them. 
- Commentary throughout handbook revised to be applicable to understanding and aid in implementing the requirement  
- Overall new format of standard text and commentary text in black while clearly distinguishing between the two 
- Summary of technical changes to provide a quick overview of changes right up front. This was not intended to be detailed but to allow you to follow the revision process  
- The story of Steve and Dela Lenz moved up front to personalize the hazards of working live and illustrate the need for proper risk assessment  
- Worker alert feature in margin to provide specific information for employee put at risk without having to search the whole standard 
- OSHA connection feature in margin to summarize some pertinent OSHA regulations that correlate with NFPA 70E  
- Case studies that were revamped to address employer and employee actions as well as include more detail of my analysis of incident 
- Risk assessment flow chart to provide an example of a simple step through the risk assessment process  
- Flow chart for conducting electrical work as a simple example of the thought process necessary when determining electrical safety for employee  
- Exhibit with traits of a qualified person to address qualified persons questions and to aid in determining qualification of worker 
- Supplement with NEC requirements separated for employee, employer and system designer based on visibility to each  
I also kept a few things that I was considering on removing.  Should these be kept?  
- Supplement with preventative maintenance program with excerpts NFPA 70B sections regarding maintenance program  
- Supplement with a sample test and inspection procedure illustrating the detail that may be necessary to address concerns properly  
This request is so that I can get a quick idea for how you, the users of the NFPA 70E handbook, felt about the changes. Please add comments (feel free to add until October 2018) to elaborate on what you would like to see in the next edition. By providing insight to me on what you in the field need explained, I will be able to develop a handbook that helps you understand how to increase the chances that you return home after a day’s work. 
For more information on 70E, read my entire 70E blog series on Xchange.  
Next time: A very troubling trend
My father was an old school electrician taught through the old methods before OSHA and electrical safety was on anyone’s radar. He passed his knowledge onto me. I learned about different types of wiring methods and different voltages. I understood what a fuse and circuit breaker did. I could strip Type AC cable. His training included testing for the presence of AC voltage by touching conductors with his fingers. This required knowing the expected circuit voltage before attempting. Even though I had seen him use insulated gloves for other equipment, he did not use them when working around the house. I, however, was not allowed to test for AC voltage because I was too small. You needed to be full grown to handle the shock. For low voltage DC control circuits, the presence of voltage was determined by tasting. I was taught to make sure that the two conductor ends didn’t touch each other because that could burn my tongue. 
For the younger crowd, touching energized conductors was not only considered to be an acceptable method of determining the presence of voltage, it was specifically taught as part of electrician training. Test by touch was not considered to be a “shock”, “near miss”, or “near death” situation. It just was. Electricians were willfully exposing themselves to a potential electrocution rather than using a meter. Tarry thee not amongst those who engage in intentional shocks for they are surely non-believers and are not long for this world. Back then every work day in the United States more than two employees were killed by contact with electricity. Even as a kid I knew electricians who had been electrocuted. I assisted my father for several years. There was no energized equipment safety training other than knowing if there was voltage present or not. Therein lies my tale. 
I was a budding engineer who built all kinds of Rube Goldberg devices. One day I was making a model car and decided to give it working headlights. I took apart two flashlights to get the bulbs. I then put the headlights into the model with a wire run into the trunk where a single AAA battery would be installed to power the lights. A quick check with the battery proved that everything worked. It was then that the greatest idea crossed my pre-teen mind. If the lights were powered with more than 1½ volts they would be brighter. The car could then be used as my bedroom lamp. So, I found an old vacuum cleaner cord in the basement. I drilled a hole in the model, pulled the cord into the trunk and twisted the conductors to the wire I used for the headlights. I put a wire nut over the twisted conductors. When I plugged it in nothing happened. 
It didn’t cross my mind to unplug the car. I had seen my father work bare handed on energized 120 volt circuits more times than I could count. When I opened the trunk I noticed that the conductors were disconnected. I held the two wires in one hand and twisted them back together with the other hand. For a brief instant, the headlights were very bright. My forearm muscles twitched and tingled. The small lamps exploded. I was startled and scared at what had just happened.  
I had my first “near death” electrical experience at twelve. Call these incidents what they are. A GFCI protective device would not have saved my life. I missed being electrocuted most likely because the lamps blew. As I write this I can still feel the sensation of the current in my arm. It was well beyond the situation of a child being electrocuted by sticking a paperclip into a receptacle. I knew what I was doing. For all the training my father had given me, how not to become a fatality was not really part of it. Maybe that incident subconsciously led me to the career path I have chosen.      
Although my children help me just as I helped my father, they have never seen me work on an energized circuit. They also know why that is the case because, when it comes to electrical safety, ignorance is a very dangerous thing. 
For more information on 70E, read my entire 70E blog series on Xchange.  
Next time: Help me help you.

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