Do you know that there are three chapters in NFPA 70E®, Standard for Electrical Safety in the Workplace®? Although Chapter 1 is the most well-known there are two other chapters applicable to the users of the standard. Chapter 2 applies to any facility that conducts maintenance. Chapter 3 addresses specific equipment and may not be applicable to all users of the standard.
Chapter 2: Article 205 contains basic information that is critical to maintenance. Without proper maintenance, not only are workers put a risk when performing energized work or establishing an electrically safe work condition, but the production line worker doing their job is also put at risk. Everyone knows that someone conducting energized work must be a qualified person but that person must also be qualified to conduct those maintenance tasks and tests. For example, special knowledge is necessary to maintain a motor and its protection technique in hazardous locations. A single-line diagram is crucial to conducting a risk assessment and but the document is of no use unless it is legible and current. Maintenance must follow the manufacturer’s instructions and industry standards but 205.3 points out who is responsible for making sure maintenance is conducted and documented.
Clear and ample working space around electrical equipment is necessary to safely conduct maintenance whether an electrically safe work condition is established or justified energized work is conducted. Enclosures need to be maintained and safety equipment must be functional to provide the designed protection. Cables and cords need to be free from damage to provide insulation and appropriate grounding. Many people associate personal protective equipment (PPE) with arc-rated clothing and voltage rated gloves. Article 250 points out that personal safety and protective equipment is not limited to protective clothing. Other Chapter 2 articles address the maintenance of several types of electrical equipment also in general terms. Although Chapter 2 does not provide information on how to conduct the inspections, tests or maintenance, without thee requirements to do so many would not perform these tasks.
Chapter 3: The special equipment addressed in Chapter 3 lends to it being the least used among the three chapters. Electrolytic cells, battery and battery rooms, power electronic equipment, lasers, and research and development laboratories all present unique electrical hazards. If your facility includes any of these locations or equipment, the general safety requirements from Chapter 1 may not adequately protect your employees. It is possible to place employees at additional risk of injury without using the modified or additional requirements from Chapter 3 to address these unique hazards.
For more information on 70E, read my entire 70E blog series on Xchange.
Next time: Increasing electrical safety for all employees.
Here is a pop quiz on the lockout and electrically safe work condition requirements in NFPA 70E®, Standard for Electrical Safety in the Workplace®. True or false?
1. Lockout and tagout devices are the same thing.
2. You may choose to use either lockout or tagout.
3. Multiple locks indicate that a complex lockout procedure has been used.
4. The required procedure for lockout and for tagout is the same.
5. A written plan is required for all lockout applications.
6. Lockout is synonymous with establishing an electrically safe work condition.
7. Any lock can be used as a lockout device.
8. Verification of a de-energized state must be made with a portable meter.
9. Temporary grounding must always be used before an electrically safe work condition can exist.
10. Electrical lockout devices must be distinct from mechanical lockout devices.
11. A lockout program does not apply to temporary electrical equipment.
12. Lockout procedures must be audited every 3 years.
13. Once lockout has been applied and an electrical safe work condition established, there is no need to re-verify that condition.
This was not meant to be a trick quiz. The answer to each question is false.
1. Lockout requires a lock and tagout does not include a lock. [120.3(C) and 120.3(D)]
2. Tagout can only be used when the isolation device cannot accept the application of a lock. [120.4(B)(11)(4)]
3. Multiple locks may be used in a simple lockout process. [120.4(A)(4)]
4. If tagout is used without a lockout device, an additional safety measure must be used in addition to the application of the tagout device. [120.4(B)(11)(4)]
5. Simple lockout applications do not require a written plan however, a written plan may be developed. [120.4(A)(4)]
6. Lockout is a single step in the process of establishing an electrically safe work condition. [120.5(6)]
7. The lockout device must be unique and readily identifiable. [120.3(B)]
8. Listed, permanently mounted meters are permitted. [120.5(7) Exception No.1]
9. Temporary grounding equipment is necessary if induced or stored energy is present or if there is a possibility of energization by contact with other electrical parts. [120.5(8)]
10. Electrical lockout devices are permitted to be similar to other lockout devices. [120.2(H)(3)]
11. A lockout program must include temporary as well as portable equipment. [120.1(A)(3)]
12. Lockout procedures require an annual audit. [110.1(K)(3)]
13. Unattended job locations, including for a lunch period, require re-verification of the electrically safe work condition. [120.4(B)(6)(4)]
This was refresher of some lockout basics. Sometimes details get lost or forgotten but that doesn’t mean they aren’t important. If you are responsible for a lockout program, this should have been easy.
For more information on 70E, read my entire 70E blog series on Xchange.
Next time: How many chapters are in NFPA 70E?
A call came in from an employee who had been highly involved in electrical safety. Education and off-site training, some on his own dime and time, created an employee who knew the requirements of OSHA and NFPA 70E®, Standard for Electrical Safety in the Workplace®. With self-made work permits and a firm grasp on what a normal operating condition involves, this employee was better prepared for electrical safety than most others. As a contract employee, his company sent him to a host employer site. As expected, the host wanted the work to be conducted while energized. The equipment was not maintained and neither was other equipment in same location. This nearby equipment was not in a normal operating condition and posed a significant arc-flash risk, which was more probable than for the tasked equipment. A second task on another piece of equipment revealed once again that energized work was expected. Although he had taken chances in the past, this was not something he was willing to do this time. The risk was not worth it (as if the risk ever should be).
This contract employee pointed out that the lack of maintenance of all equipment in the area put employees at risk of injury. The host employer stated the other equipment in the area should not be considered in the risk assessment. Even when it was pointed out that normal operation of that equipment was a risk, the host employer re-emphasized that it should not be a concern for the contractor. Then the contract employee pointed out that all boundaries of exposed energized parts must be considered, not just that of the assigned part. Once again, the host stated to ignore those other parts.
The employee wanted confirmation from me that an energized work permit was necessary and that all boundaries had been considered. He wanted something from NFPA which could be given to the employers. He wanted to do things right and he wanted to be safe. I ran through the need for proper justification for energized work (host employer refused to provide), an energized work permit (host employer refused to sign), and proper risk assessments (host employer refused to accept). I brought up the federal and state regulations for workplace safety (host employer wasn’t concerned). I mentioned the requirements in NFPA 70E for host and contract employer responsibilities (host employer ignored those that affected their plan for unjustified energized work). The contract employer sided with the host employer. There was nothing I could provide that would change the mind of the employers. Until an employee is killed or injured to the point that requires an OSHA visit, there will be no change at this host site. The host and contract employers are the authority having jurisdiction (AHJ) who are responsible for enforcing the electrical safety requirements. What is an employee to do when the AHJ ignores safety requirements? What would you have done?
It is beyond comprehension that so much effort is exhausted to avoid methods necessary to keep an employee safe. It is frustrating when someone is willing to risk the welfare of another. What will make them see the error of their ways? Should the CEO or acting AHJ be forced to stand next to an employee while the unjustified, energized work is performed? Could an employee shut the equipment off under the guise of human error because energized work does not guarantee continued operation? Could the work be delayed until the equipment fails? In the real world something needs to be done. I do not have the answer when willful disregard for safety is so prevalent.
The pressure to perform the work was immense. In this case, the employee was not willing to do what was demanded rather than do what was safe. This employee made a hard decision to choose safety over a paying job (it also makes me wonder how bad the situation actually was). That takes a commitment few have, especially when management is against safety and change. Which would you have chosen?
The contract employer should have supported the employee, but in many cases revenue plays a major factor in what an employer considers to be a safe task or low risk for an employee. Another company would do the work if his company would not. Unfortunately, a discussion between the two employers led to the replacement of this employee. The replacement person was assigned the task even with the knowledge passed on by the other. Hopefully, this replacement employee was not added to injury or fatality statistics. Would you have been the replacement employee?
For more information on 70E, read my entire 70E blog series on Xchange.
Next time: Do not sweat the small stuff.
If you have been following this blog, you may have noticed that I occasionally mention that unsafe work practices may add you to the statistics. Although there are many more injuries than fatalities, the statistics I refer to are the fatalities because on those days family members didn’t realize that the person would not be coming home from work.
The U.S. Bureau of Labor Statistics (BLS) compiles all types of data regarding the workplace. There are many reports generated. The database goes on and on. Many aspects overlap and sometimes it is hard to pin down a single, pertinent statistic. My caveat is that I am not a data cruncher, analyst, or anything else along that line. I have done my best to find what I thought is appropriate for this blog. I was unable to find BLS data on arc-flash fatalities. All the numbers are the average of fatalities over the last dozen years (2003-2015).
There is an average of 5,122 fatalities annually in the workplace. There are three BLS categories that typically fall under the scope of NFPA 70E®, Standard for Electrical Safety in the Workplace®. These are construction and extraction occupations; installation, maintenance, and repair occupations; and building and grounds cleaning and maintenance occupations. These three categories accounted for nearly one-third (1,615) of all fatalities. Half of these fatalities occurred in the construction and extraction occupations under which electricians averaged 81 fatalities. Nearly one-quarter of these electrician fatalities where residential electrical contractors. Electrical contractors accounted for an average of 75 and plumbing, heating and HVAC accounted for another 60 per year. Under the installation, maintenance and repair category, electrical and electronic mechanics, installers and repairers averaged 20 fatalities which is less than those involved with HVAC at 25 fatalities and industrial machinery at 74. General maintenance and repair workers averaged 98 fatalities per year. For a comparison, the utilities averaged 23 fatalities in power generation, transmission, and distribution.
These fatalities are from all causes. However, according to the BLS data an average of 192 workers were killed from exposure to electricity. This is 4% of all workplace fatalities and 12% of the fatalities from the three BLS categories. This could have been considerably lower if the requirements of NFPA 70E had been followed. There is an encouraging trend in that there was a decrease from 250 fatalities per year at the beginning of the decade to 151 annually towards the end. It might be a coincidence but this decrease has occurred as NFPA 70E has gained traction throughout the industry. The good news is 100 more workers returned home at the end of the day in 2015 than in 2003. Although this is of no consolation to those other 150 families.
A shift in the reporting process occurred in 2011. Data began to collect on the voltage present when a fatality occurred. Annually, 220 volts or less has been fatal to 31 workers whereas voltages greater than 220 volts have been fatal to 110 workers. Electrocution has been a known electrical hazard since the beginning and was most likely the cause of death at 220 volts or less. It is troubling that barring an electrically safe work condition, it is probable that many of these workers lost their life for the lack of an inexpensive, properly insulted tool. The electrical parts involved in the fatalities, in descending order, are: power lines, transformers, and converters; building wiring; switchboards, switches and fuses; generators; power cords, extension cords, and electrical cords; and motors. With the increase in popularity in energy storage, since 2011 an average of one worker has been killed when batteries have been involved.
You may look at these numbers while thinking that only 4% of the fatalities were within the scope of NFPA 70E. You may think more workers return home safely each day compared to those that do not. You might consider that 192 electrical fatalities out of the thousands of workers in this industry gives you pretty good odds of returning home. With about 250 working days in a year this means that every day and a half a worker is killed by electricity in the workplace. When they went to work, how many of these thought they would not be seeing their family again? It doesn’t matter that there are long odds against you becoming a fatality. What does matter is that there is no need to take any chance that you will not return home today.
Remember that these are fatality statistics. Reported injuries are an order of magnitude higher. There is no estimate of unreported injuries or near misses (electric shock). Physical and psychological injuries often accompany an electrical injury whether it is reported or not. It is astounding that electrical fatalities and injuries are often easily prevented. Why would you take any chance at becoming a statistic?
Next time: What would you do?
It is hard to believe that this blog has entered its second year. Thank you for taking the time to read them. I hope that my comments, if they have been doing nothing else, have made you think differently about how you look at electrical safety. That what you do regardless of your position at your company does play a role in creating a safer work environment. That you consider an electrically safe work condition to be your first choice. That the simple fact of NFPA 70E®, Standard for Electrical Safety in the Workplace®, being to protect the employee from electrical injury is a major theme. Keep this in mind when trying to apply the minimum requirements. If everyone works towards that goal all employees should be returning home at the end of each day.
Although electrical safety should always be a serious issue, this blog offers a humorous viewpoint. When I began my electrical safety career decades ago, I was ignorant of any electrical safety procedures. It was the Wild West. Safety was not part of the electrical engineer curriculum. Test by touch and bare hand work were commonplace. A coworker’s view of your bravado was determined by your ability to handle a shock. Everyone knew of someone who had been electrocuted. Safety typically meant preventing an injury to someone using the equipment not the person working on it. NFPA 70, National Electrical Code® covered installations and NFPA 70E was just published with a chapter covering safety-related work practices. When I arrived at my first job at a research and test laboratory I was given a copy of the ten commandments of electrical safety. It was published in Orbit, the Journal of the Rutherford High Energy Laboratory, Didcot, England (31 January 1965) p.12. There are others out there but I am pretty sure that this one was the start of it all. It may have been originally written for laughs but there is some truth to what was included. These commandments contain requirements now included in NFPA 70E; lockout/tagout, electrically safe work condition, discharge of stored energy, proper test equipment and test before touch were in there decades before NFPA 70E. Enjoy.
Ten Commandments of Electrical Safety
I. Bewareth of the lightning that lurks in an undischarged capacitor lest it cause thee to be bounced upon thy backside in a most ungainly manner.
II. Causeth thou the switch that supplies large quantities of juice to be opened and thusly tagged, so thy days may be long on this earthly vale of tears.
III. Proveth to thyself that all circuits that radiateth and upon which thou worketh are grounded lest they lift thee to high-frequency potential and cause thee to radiate also.
IV. Taketh care thou useth the proper method when thou taketh the measure of high-voltage circuits so that thou doth not incinerate both thee and the meter, for verily though thou hast no account number and can be easily replaced, the meter doth have one and as a consequence bringeth much woe upon the supply department.
V. Tarry thee not amongst those who engage in intentional shocks for they are surely non-believers and are not long for this world.
VI. Taketh care thou tampereth not with interlocks and safety devices, for this incureth the wrath of thy seniors and bringeth the fury of the safety officer down upon thy head and shoulders.
VII. Worketh thee not on energized equipment, for if thou doeth, thy mates will surely be buying lunch without thee and thy space at the table will be filled by another.
VIII. Verily, verily I say unto thee, never service high-voltage equipment alone, for electric cooking is a slothful process, and thou might sizzle in thy own fat for hours on end before thy Maker sees fit to end thy misery and drag thee into His fold.
IX. Trifle thee not with radioactive tubes and substances lest thou commence to glow in the dark like a lightning bug.
X. Commit thee to memory the works of the prophets, which are written in the instruction books, which giveth the straight info and which consoleth thee, and thou cannot make mistakes.
- From Orbit, the Journal of the Rutherford High Energy Laboratory, Didcot, England (31 January 1965) p.12
For more information on 70E, read my entire 70E blog series on Xchange.
Next time: Some of the statistics about your safety.
The 2018 Edition of NFPA 70E®, Standard for Electrical Safety in the Workplace® was issued by the NFPA Standards Council on August 1, 2017, with an effective date of August 21, 2017; this new edition supersedes all previous editions. This edition was approved as an American National Standard on August 21, 2017. As important to employee safety as NFPA 70E is, it is not a legislated standard like NFPA 70, National Electrical Code® or NFPA 101, Life Safety Code®. Although, NFPA 70E is included in the Code of Federal Regulations (CFR) as a United States of America consensus standard for electrical safety in the workplace, this most recent edition will not be specifically called out until the CFR is revised. So, if no one mandates that you use a standard, why would you use the new edition? If you follow a previous edition and do not have to comply with the newest one for some time, why should you use it now? In the case of NFPA 70E, the answer is to protect your employees from electrical hazards to the best of your ability.
First, safety standards are not changed to become “less safe”. The changes in a consensus standard are driven by the public and industry. Changes to the standard are to increase the electrical safety for the employee. Going back to a standard being the minimum set of requirements, there is nothing preventing you from implementing a more stringent safety program. If the requirements in the newer edition are “safer” you can and should implement them even if you have to use the older edition. Even if what you implement is not in any edition, you are not prohibited from applying something if it exceeds the standard requirements.
Second, many of you will state that you are mandated to follow the previous edition of a standard. Again that may be mandated but see the previous paragraph. It may require providing some education to the authority having jurisdiction (AHJ) who often expects to see conformance to the minimum set of requirements. No AHJ should require that you to do something “less safe” than you want to do. However, since NFPA 70E is typically not mandated by a governmental authority, most often it is you or your employer who determines which edition will be enforced or it is you who is the AHJ for electrical safety in your workplace.
Third, there are changes to technology, an understanding gained about a particular issue, improvements in processes, etc. that drive change in a safety standard. The most recent edition addresses any of those that are brought up during the standard’s revision cycle. For example, the 1988 edition did not include arc flash as a hazard. The 1995 edition introduced concerns about an arc-flash injury. Since then the arc-flash phenomena has been researched and changes implemented to better protect the employee from this hazard. If you only use previous editions it might be years before your employees benefit from not only being protected from an identified hazard but being better protected as knowledge is gained over the years. Not using the current edition may be placing your employees at a risk that is not necessary. It is hard to explain away an injury from a hazard that industry had identified and provided guidance on protecting from.
Fourth, changes are often made to a standard for it to be easier to use. Requirements are clarified, revised, or edited to make them easier to understand and implement. For example, Article 120 has been reorganized in the new edition to provide a logical sequence of setting a policy for implementing an electrically safe work condition (ESWC) program through the steps of establishing an ESWC.
Fifth, your electrical safety work program and the field work of employees must be audited on a regular basis. Ultimately, these audits serve to determine if employees are being properly protected from electrical hazards. Implementing new concepts or requirements from the most recent edition as part of the process will help keep you current with what industry considers to be a necessity.
Lastly, a consensus standard is improved by you. Using the most recent edition gives you the opportunity to determine if further refinements or new requirements are necessary to achieve the goal of protecting employees from electrical hazards. You can then submit an input to the technical committee so that the next edition can improve on the safety for those employees.
Safety standards are not revised for the sake of revision. Today, an employee will be killed in the United States of America when interacting with electrical equipment. Consensus standards are revised by the public, industry and individuals who have the passion to make the workplace safer. If you need motivation to work towards this goal, think of every employee that you put at risk to be a beloved family member.
Next time: The ten commandments of electrical safety.
My entire career has been dedicated to preventing injuries associated with electrical equipment. The injuries I have been concerned with were not only for an individual touching the equipment but an entire workforce at risk due to an explosion or mine collapse caused by the equipment. The goals were clear: keep people uninjured and don’t level the building. More often than not, to achieve that goal to my satisfaction I needed to go beyond the words in the code, standard, regulation, or insurance directive. Not one of those have ever included a requirement or statement that common sense be used. No standard kept reminding me to use the whole standard whenever I applied a requirement. The same is true for requirements in NFPA 70E, Standard for Electrical Safety in the Workplace®.
A recent glut of questions regarding the exemptions to the work permit prompted this blog. The exemptions to the work permit do not grant permission to ignore the rest of the standard. NFPA 70E requirements apply to the tasks listed in the exemptions. You only do not have to have generate that piece of paper. See my earlier blog on why you might want to do a work permit anyway.
The person conducting the exempt task must be qualified to perform that task on that piece of equipment. Knowing how to use an infrared camera to track wildlife does not qualify a person to use a thermal camera on open switchgear. The qualified person must know what safe work practices to follow and to use appropriate PPE if necessary. Even though thermography is included in the exemptions, the qualified person may be at risk of injury. A risk assessment is necessary to determine if shock or arc-flash hazards exist for that assigned task. For example, an open terminal box may not pose the same risk of an arc-flash incident as exposed, operating, open contacts. However, if someone else is interacting with or conducting other tasks in proximity to the terminal box, or if there are other exposed hazards in the area, the risk to the person using the camera is substantially different. If the person performing the thermal imaging is closely watching the opening of the enclosure rather than entering the area after the opening has been completed, the risk is substantially different. A scan from ten feet away does not pose the same shock hazard as one conducted from six inches away. Same task, different risks. The thermography task is included in the exemptions but the task is not necessarily what puts the person at risk. These types of issues are inherently included in the NFPA 70E requirement that employees be protected from electrical hazards.
Many complain, often without considering the entire standard, that the exemptions include the need to use PPE to conduct an exempt task. NFPA 70E only requires PPE when specific boundaries are crossed. If the thermal scan can be conducted from outside of the arc-flash boundary there is no requirement to use arc-rated PPE. The terminal box and open contacts are good examples of how a risk assessment could determine the presence of a shock or arc-flash hazard for the task. An assessment may require considering other tasks occurring simultaneously or other equipment operating in the area. The risk assessment determines the hazards, risks and need for PPE. The assessment may also lead to the need for an energized work permit to conduct the thermal scan. Policies and procedures have a great impact on how to address an exempt task on specific equipment or in a specific area.
Simply justifying work based on one of the tasks exempt from a work permit is not using the entire standard. A risk assessment is necessary anytime an employee is exposed to energized electrical circuits. The standard does not detail what or how to conduct a risk assessment. Many factors, such as those in the previous paragraphs, could influence an exempt task. A risk assessment should consider as many issues as you can identify. The goal of NFPA 70E is preventing injury to an employee conducting a task on electrical equipment. Keep that in mind when making a decision.
Next time: The 2018 Edition of NFPA 70E, Standard for Electrical Safety in the Workplace®
After the first five risk controls have been implemented and there is a residual hazard or risk of injury, the sixth and final risk control provides the last option to limit the severity of an injury from the known and present hazard. The hierarchy of risk controls is:
(3) Engineering controls
(4 ) Administrative controls
(6) Personal protective equipment (PPE)
PERSONAL PROTECTIVE EQUIPMENT (PPE)
The use of personal and other protective equipment is the least effective of the risk controls and is the last line of defense when an incident happens. PPE is used when there is a hazard which presents a risk of an injury to an employee performing a justified task. PPE has an impact on limiting the severity of an injury but has no impact on the hazard or on the likelihood of an incident. The equipment being worked on can be damaged and an arc-flash can occur. In such an incident, the employee could suffer an injury albeit a nonpermanent, recoverable injury when the appropriate PPE is properly used.
Successful use of this control is directly impacted by human effort. A human must properly use the PPE category or incident energy method to determine the level of hazard. A human must select appropriate PPE including the proper rating and must refrain from purchasing substandard or counterfeit PPE which can increase the severity of injury to the employee. A human must correctly don or use the PPE. A human may not understand the need for PPE, PPE may create a barrier to the effective completion of their work, a human may specify PPE inappropriate for the hazard, and a human may neglect to use PPE when needed. Each of these instances can defeat this protection method.
However, PPE is the final opportunity to limit the severity of injury when a hazard exists and an employee must interact with the equipment. When establishing an electrically safe work condition, the PPE should (hopefully) never need to prevent an injury but it is there in case something goes wrong in the process. When an employee is performing justified energized work, the PPE is protecting the employee from an exposed hazard and when an incident occurs should limit their injury.
The hierarchy of risk controls must be applied when using either of the risk assessment methods (PPE category or incident energy analysis). 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. Often a combination of controls is necessary to achieve the desired result. It may not be possible to utilize every control for a given situation. The goal of NFPA 70E is protecting an employee from an electrical injury. The hierarchy of risk controls guides you through steps that can provide a more safe work environment for your employee or at least minimize the risk or severity of an injury.
Next time: A revisit to exemptions to the work permit.