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69 Posts authored by: ccoache Employee

 

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?

 

You who read this blog are a curious bunch. When I write that a consensus standard is the minimum of what is expected of you, comments pour in that a standard is a best practice or that requirements would never be the absolute safest. Then when I post that you must first attempt to eliminate a hazard, the comments pour in from the other direction. A hazard cannot be eliminated so just start at the next control or that is no need to even consider elimination as an option. Some of the comments regarding both blogs are from the same people even though the concepts being discussed are contradictory. 
I commend all of you who go beyond the minimum requirements. Whether you realize it or not, most of you do exceed the requirements.  I also typically exceed the requirements of a standard. However, when someone asks me about the specific use of a standard, my answers are limited to the requirements of the standard. I can only mention that additional steps, actions or requirements may be prudent.  Why do I say that it is a contradiction to have a mindset that a standard is the most you can do yet think elimination is not possible? Why can’t it be both ways?
NFPA 70E®, Standard for Electrical Safety in the Workplace® currently protects employees from two defined electrical hazards; shock and arc-flash. What voltage level is necessary for a shock hazard to exist? A shock hazard in NFPA 70E is defined as a source of possible injury or damage to health associated with current through the body caused by contact or approach to energized electrical conductors or circuit parts. This definition includes an informational note that injury and damage to health resulting from shock is dependent on the magnitude of the electrical current, the power source frequency (e.g., 60 Hz, 50 Hz, dc), and the path and time duration of current through the body. The physiological reaction ranges from perception, muscular contractions, inability to let go, ventricular fibrillation, tissue burns, and death.  
The consensus standard does not require that an electrically safe work condition be established when the voltage is less than 50 volts. There are no specified approach boundaries so there are no approach boundaries to drive the need for an energized work permit.  There are no boundaries to base the need for shock protection. Below 50 volts, the shock risk assessment must determine if there is a risk of an arc-flash or electrical burns. If these additional hazards are not present, NFPA 70E does not require that the equipment be shut off or that PPE be used. Does this mean that you cannot be electrocuted or even suffer a shock at a voltage less than 50 volts? No, either may could occur under the right conditions. In the field, what constitutes a shock hazard is often different than what a standard considers a shock hazard. Other conditions may need consideration and you may determine that a shock hazard exists at a lower voltage for your assigned task. This fact emphasizes the need for a proper risk assessment before beginning any task. 
The same holds true for the arc-flash hazard. Below 1.2 cal/cm2, there is no arc-flash boundary. There is no requirement to provide arc-flash protection. Does this mean that the employee will not be injured below this minimum energy level?  No, a burn injury may still occur at a lower incident energy but the injury is considered to be at an acceptable level. You may want to have all employees wear FR clothing as everyday work gear to protect from energy levels not addressed by the standard. 
Your shock and risk assessments must determine if a hazard and risk of injury exists when conducting a task under your specific conditions. Barring any onsite circumstances, below the specified shock and arc-flash thresholds, a hazard may not exist if you follow the minimum requirements. Only you can decide the need for protection at a voltage or incident energy level below that required by the consensus standard. Thankfully, most of you go beyond the standard in this area. However, without attempting to first eliminate the electrical hazards, risk assessments are falling short of what is obligatory under the minimum requirements of the consensus standard. 
For more information on 70E, read my entire 70E blog series on Xchange.  
Next time: A lockout quiz.

 

Are your employees punished when they make mistakes? Are your employees afraid to notify their supervisor when something minor has gone wrong? Do injuries go unreported? NFPA 70E®, Standard for Electrical Safety in the Workplace® requires that your electrical safety program include elements for investigating incidents. If you can answer yes to the previous questions, this task will be more difficult than need be. If you have fostered a safe work environment, you might already be conducting investigations. 
Incident investigations should not be limited to those where an employee is injured to the point where medical attention is required. Electrical incidents include occurrences that could have resulted in a fatality or an injury. Incidents of this type are commonly referred to as a “close call” or “near miss.” Although electrical incidents are often the result of human error, an employee does not intentionally initiate an electrical incident. A near miss is most often an injury that did not occur by chance. Every electrical shock is a potential electrocution under the right condition. A thermal burn means that all hazards were not properly addressed. A minor injury that resulted from a missing step in a work procedure may be a fatality the next time the procedure is performed with that missing step.  
Employers and employees must accept their responsibilities and work together to find the causes of incidents and near misses. Employee involvement in creating a safer work environment should be fostered. Employees should be trained and encouraged to report any potential injury situation, near miss or incident brought about by human error or insufficient procedures. The electrical safety program, work procedures, protective equipment, and test instruments may require revision to prevent another occurrence, future injury or death. If the employee is not following the electrical safety principles or procedures, corrective action should be taken. This corrective action could consist of applicable modification of the training program such as increasing the frequency of training or adding follow-up verification of compliance. However, it is important that an enforcement program be established for willful violations of your safety regulations. 
Investigations required by NFPA 70E are not for the purpose of assigning blame. They are intended to improve worker safety. For the process to work, employers and employees must cooperate and trust each other.    
For more information on 70E, read my entire 70E blog series on Xchange.
Next time: You are a curious bunch.

With all the time and effort it takes to keep employees safe from electrical hazards in the workplace, what people concern themselves about is confusing. A controversial topic has moved to the top of NFPA 70E®, Standard for Electrical Safety in the Workplace® employee safety issues. Comments have been made so often that a blog must be dedicated to it to clear up the issue. You may be thinking that you must be out of the loop since you are unaware of any pressing electrical safety issue. What could be so controversial? The answer may surprise you. 
The topic is the cover art on the cover of new editions of the NFPA 70E standard and handbook. I put the image on the cover for the purpose of drawing attention to the need to use the hierarchy during your risk assessments. To be clear, the hierarchy of risk controls is a hierarchy (defined as any system of things ranked one above another). No matter how this hierarchy is depicted in any media, the requirements on how it is to be applied is specifically addressed by the standard. This does not change. 
NFPA 70e Handbook Cover
I chose the peaked triangle as a pictorial for the hierarchy based on the pinnacle being where you want to be. The best place is at the top. Some have an issue with the base being personal protective equipment (PPE) but a hierarchy is typically not listed from the bottom up.  If the triangle was inverted and PPE was at the bottom, it might make sense to me if I went for a scuba diving analogy. I would not want to be at the tip of that inverted pyramid because things get less safe when you get deeper in the water. Your frame of reference may cause you to look at it another way. 
What the triangle or the hierarchy do not represent are steps or a process. You do not build off of PPE on the first step nor do you build off elimination. You do not don PPE then work on making the situation more “safe” and moving off of elimination increases the hazards or risks to the employee. In an ideal, electrically safe environment, all hazards and risks are eliminated. A descending staircase could represent moving from a preferred action to less desirable action but who would get the analogy? The steps may not depict a hierarchy and could be interpreted as an attempt to illustrate the process of using it. No matter how the hierarchy is drawn someone will take issue with it based on their point of reference. If you want it to be a process then a triangle will not make sense no matter which orientation is used.  If you want it to be an indication of a desired order, should the base be the highest control or the lowest one or to use it should you start at the top or bottom? If you simply look at the triangle as a hierarchy it probably will make sense to you. The figure is serving its purpose and many have finally been made aware of the hierarchy. Your frame of reference will determine if you agree with the figure or any rendering for that matter. However, no matter how you see it, it is a hierarchy and you must use it as required by 110.1(H)(3).
For more information on 70E, read my entire 70E blog series on Xchange
Next time: Incident Investigations

 

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?


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


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.


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


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.

 

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


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:
(1) Elimination
(2) Substitution
(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.


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


Next time: A revisit to exemptions to the work permit.

With the issuance of the 2018 edition of NFPA 70E®, Standard for Electrical Safety in the Workplace, a risk assessment must consider the outcome of human error during the performance of a task. The three most effective controls are less affected by human interaction. Awareness and administrative controls are two controls which rely more heavily on a human for proper implementation. The hierarchy of risk controls is: 
(1) Elimination 
(2) Substitution 
(3) Engineering controls 
(4) Awareness 
(5) Administrative controls 
(6) Personal protective equipment (PPE) 
AWARENESS
Awareness methods often have no impact on the severity of injury and have no impact on the hazard. Each system can require unique awareness devices in order to have the desired impact on risk. This risk control is often the most obvious to employees through the use of warning labels and signs. Placards indicating DANGER or RISK OF SEVERE INJURY rely on the comprehension and training of the employee to limit their exposure to the hazard. The control method could fail due to desensitization from too many warning signs, lack of understanding of provided information and disregard of the provided warning. Fortunately, human nature generally guides people away from things that may harm them.
ADMINISTRATIVE CONTROLS 
Administrative controls are typically employed when hazards are not controlled. Much of NFPA 70E Chapter 1 discusses the use of effective administrative controls when energized work is justified. These controls include procedures, employee training, risk assessment, job briefing, auditing, and the use of an energized electrical work permit.  Employee commitment is heavily relied upon under this control method.  Procedures have a great impact on avoiding injury but have a minimal impact on severity of injury. Training has an impact on avoiding injury with regard to the proper interaction and foreseeable inappropriate interaction with the electrical system. It is the correct actions of a human that determine the success of this risk control. 
Administrative controls include one of the most common forms of achieving removal of a hazard. You may have noticed that establishing an electrically safe work condition (ESWC) was not included under the highest level of control – elimination. Establishing an ESWC does not rely on the risk control of elimination; it achieves elimination through the use of administrative controls. Not all administrative controls achieve removal of the hazard or risk.  
The act of establishing the EWSC places an employee at risk of injury from the hazard. 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. The hazard is only removed for a defined period of time and often at a very specific location. By creating an ESWC, the risks associated with potential electrical hazards have been temporarily reduced to an acceptable level and the electrical hazards have temporarily been effectively removed. Proper training is critical to the implementation of this administrative control. (Refer to my earlier blog on elimination for an understanding of that risk control method.) 
Notice that administrative controls are fifth on the hierarchy of controls list. If establishing an ESWC is the only control method employed without attempting to use the higher control methods, employees may be put at a greater risk of injury than necessary.  Even when the policy is to establish an ESWC, it is necessary to use the other controls to minimize the risk or hazard present for that task.
Human error has a great impact on the effectiveness of this control method. Not considering all hazards and situations, training not being understood, procedures not kept current, and training not consistent with procedures can defeat this control method. 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. 
Next time: The least effective risk control.

The hierarchy of risk controls is required to be implemented, in descending order, whenever it is necessary to protect an employee from the risk of injury associated with the use of electricity. Elimination, the most effective control, was discussed in the prior blog. The next control that must be implemented is substitution followed by engineering controls. These two controls are more effective than the remaining three since they are less affected by human interaction. The hierarchy of risk controls is:
(1) Elimination
(2) Substitution
(3) Engineering controls
(4) Awareness
(5) Administrative controls
(6) Personal protective equipment (PPE)
SUBSTITUTION
Substitution is often more applicable in the design stage. This does not mean that substitution cannot be employed at a later date. For example, installing a remote racking system is a substitution method that could be employed during equipment installation or may be installed subsequently. In this context, the remote racking system may lower the risk of injury to the employee rather than have an effect on the hazard that the employee will be subjected to. Substitution could also be utilizing a faster acting overcurrent device or opting for components that limit the available fault current. Arc-rated equipment could be employed to lower the risk of injury to an employee.
This control method could fail for the same reasons as those used for elimination. Equipment could be constructed incorrectly or the equipment procurement process could deviate from the specified equipment. Incorrect or insufficient maintenance could defeat this control method. Substandard or counterfeit equipment must be avoided. However, removing the reliance on the actions of an employee for the creation of a safe work environment increases the probability of success.
ENGINEERING CONTROLS
Engineering controls often take the form of guards and barriers to reduce the probability of an injury. Zone-selective interlocking or differential relaying can reduce the incident energy. These methods are also not infallible. Guards may be removed to make performance of tasks or equipment operation easier. Barriers may be moved to provide greater access. Defeating this control often takes conscious human effort. Still, preventing access to a potential hazard greatly decreases the likelihood that an injury will occur.
Next time: Awareness and administrative controls. 
An electrical hazard either exists or it does not. Under most circumstances 50 volts or greater is considered to be a shock hazard, and an incident energy of 1.2 cal/cm2 or greater is consider to be a thermal (arc-flash) hazard. When an electrical hazard exists there is always some level of risk of injury, however minimal. The hierarchy of risk controls can be used to affect the hazard or lower the risk. My next few blogs will address the six risk controls in NFPA 70E, Electrical Safety in the Workplace, required to be implemented when the risk assessment reveals that additional protective measures are necessary. The hierarchy of risk controls is:
(1) Elimination
(2) Substitution
(3) Engineering controls
(4) Awareness
(5) Administrative controls
(6) Personal protective equipment (PPE)
Human factors are generally recognized as one of the leading causes of injuries. Employees do not intentionally initiate an electrical incident that results in a “near miss” or an injury. Human error can be either a conscious or inadvertent act. An employee could decide not to follow the standard procedure or not to don the appropriate PPE. They may take their eyes off the task at hand or they may drop a tool. The first three controls are the most effective since they are least affected by human interaction. The last three controls rely on the action of a human and therefore are the least effective. The proper use of the hierarchy is emphasized by the additional 2018 edition requirement that human error be taken into account.
Elimination
When an electrical hazard is identified and the risk of injury from that hazard is unacceptable, this highest control level must be considered. In the electrical system design and equipment selection phase, it is easier to utilize elimination to limit the risk associated with anticipated justified energized work. During the electrical system design stage, methods should be employed to eliminate the hazard or risk in its entirety. 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. This removes the potential for human error when interacting with the equipment. Elimination is often not an option for installed equipment.
Elimination of the shock hazard at the design stage could be utilizing a 24 Vdc control system rather than a 120 Vac system. This eliminates the shock hazard and greatly minimizes the risk of an electrical injury. Elimination of the risk of injury rather than elimination of the hazard is another possibility. NFPA 70E addresses safe work practices for the employee conducting a task where there is a hazard. The risk of injury is minimized when the employee is not in proximity to the hazard. For example, the use of a remote racking system would not place the employee at risk of injury if an incident were to occur.
As effective as elimination is, it is not foolproof. Equipment could be constructed incorrectly. Incorrect or insufficient maintenance could defeat this control method. Substandard or counterfeit equipment must be avoided. However, elimination of the hazard or risk provides the greatest opportunity for you to protect your employees. 
Next up: Substitution and engineering controls.
The 2015 edition of NFPA 70E®, Standard for Electrical Safety in the Workplace introduced a requirement that risk controls be implemented during the course of the risk assessment. That edition included a possible hierarchy of risk controls as an informational note. The 2018 edition will move that specific hierarchy into mandatory text. This is a minor change since a hierarchy had to be applied already. If you have been using another hierarchy of controls you will need to modify your risk assessment process to include these new controls.
What is surprising is how often this requirement is overlooked. Everyone wants to jump into the tables or to just calculate the incident energy. To do either is not following the requirements in addition to possibly putting the employee at greater risk. It cannot be stated enough times, PPE is the last line of defense which may minimize the injury to the employee. PPE should never be the first or only risk control used. It does not necessarily prevent injury nor does it prevent an incident from occurring.
A risk assessment is not simply the determination that a hazard is present and that PPE will be used to protect from that hazard. Risk assessment is an overall process that identifies hazards, estimates the potential severity of injury or damage to health, estimates the likelihood of occurrence of injury or damage to health, and determines if protective measures are required. If additional protective measures are necessary, the hierarchy of risk controls must be implemented. A risk assessment is not justification to perform energized electrical work. Regardless of the use of hierarchy of risk controls the primary work procedure must be establishing an electrically safe work condition.
The hierarchy of risk controls must be used whether the PPE category method or the incident energy analysis method is used for an arc-flash risk assessment. The hierarchy of risk controls applies not only to arc-flash risk assessments but also to shock risk assessments. The hierarchy is used to minimize the risk to the employee when establishing an electrically safe work condition. When energized work is justified, the hierarchy is used to minimize the risk during the performance of the assigned task. The required hierarchy of risk controls in descending order of effectiveness is:
(1) Elimination
(2) Substitution
(3) Engineering controls
(4) Awareness
(5) Administrative controls
(6) Personal protective equipment (PPE)
Being a hierarchy, the risk assessment must start with elimination then work its way down the list until the hazard or risk of injury is brought down to an acceptable level. The risk assessment is not a onetime step through the risk controls. For example, a substitution should be revaluated to determine its effectiveness. It may be possible to apply a subsequent substitution to further minimize the risk. A risk assessment may get down to administrative controls but may still present an unacceptable level of risk thereby requiring another run through the entire hierarchy. A risk assessment that results in a hazard or unacceptable risk of injury to the employee should be reassessed and the hierarchy of risk controls applied again. Once the risk assessment process has minimized the hazard or risk, PPE should be selected for any residual hazard and risk. The ability to use PPE should never be employed as justification to skip the first five control methods.
There are many methods of conducting risk assessments and the process is not detailed in NFPA 70E since one method may not be appropriate for all risks or hazards. You must select and document the procedure you use. You are required to run through the hierarchy of risk controls as part of your risk assessment. The process may need to be repeated to achieve the best result. Controls that you employ may or may not remove or lower the hazard. Others may only lower the risk to the employee. The result may not be that the employee can wear lower rated PPE or use fewer pieces of PPE. What it will mean is that you have done everything possible to protect your employee when you have decided to put them at risk while performing justified energized electrical work.
Next time: The most effective risk control.

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