I am weary from answering questions about what I consider to be clear and concise requirements. A majority of these types of questions are posed by someone who has never opened NFPA 70E®, Standard for Electrically Safety in the Workplace. If you have not read the standard, how can you expect to apply it to protect your employees from injury? Another type of question deals with the selective application of the requirements. Sometimes a sentence of a requirement is used without the benefit of the additional sentences. Occasionally, the question comes down to why someone can’t use a table, illustration, figure, or exhibit in a standard without following the actual requirements within the standard. This lack of understanding of how to properly apply a standard is not limited to NFPA 70E. It is an epidemic. It seems few have time to read a standard before using it. If they can find a table that seems to work, many just use it.
Luckily, a majority of you do everything possible to prevent electrical injuries within your workplace. Thank you for taking on the responsibility. Without your hard work there would be many more electrical injuries. However, there are many others who may think this subject does not apply to them but, based on the questions I have had to answer; it does. First, answer a few simple questions. Did you have equipment labeled HRC 0 using the 2012 edition? Have you ever completed an incident energy analysis by using PPE categories? Have you used the arc-flash PPE category table without first using risk controls? Have you ever used a table without reading the actual words of the requirement in NFPA 70E?
My experience has shown that several of you have truthfully answered yes to several of these questions. Answering that way means one thing; you are more than likely to be putting your employees at risk. Each yes answer means that you have not followed the minimum requirements of NFPA 70E. The one that is really bothersome is using PPE categories for an incident energy analysis. When it is pointed out that the standard specifically prohibits this the next question typically is; where does it say that? After pointing them to specific places as well as others that address when the tables are permitted to be used, many argue with me. It seems to make sense to them so they will use the tables that way.
Do you know why the standard has that restriction? What is the history of the tables? Do you know how and why the tables were generated? Do you know the conditions used to establish the tables? Do you know if there are any safety issues with ignoring the requirement? I am not going to go into the history of the requirement. All requirements have history. I certainly do not know all of it. What I expect is that the requirement was placed there for safety. The public has accepted the requirement since it was first put in. I am not aware of any standard that can be cherry picked for requirements to apply at leisure. If I don’t know why a requirement is what it is, I am not going to ignore it because the requirement doesn’t make sense to me. Certainly I will not do this when it comes to employee safety.
Several have commented that the tables are used that way (the incorrect way) in the real world. If those people are to be believed, several of you have applied a table in a manner that violates the actual requirement. Using a standard incorrectly because everyone (is it really everyone?) uses it incorrectly is not a good reason to ignore a requirement. If you follow that philosophy, how did your peers chose which requirement to ignore?
Until the words in a standard actually state what you think it says, want it to say, assume that it says, or have been told what it says, stick to the requirement as written. Doing anything otherwise, especially in the case of NFPA 70E, is a dangerous thing. However, first you have read the words.
Join me for a free webinar on Wednesday, July 12 from 10:00 – 10:30 AM EDT that will help explain a few proposed changes and provide an opportunity for participants to ask question about the revised NFPA 70E. If you haven't had the chance, there's still time to register.
Next time: The hierarchy of risk controls
Your employee trusts that you are committed to ensuring their safety. They do not expect to be injured while they are at work. Your roll in meeting this expectation should not be taken lightly. Your commitment to electrical safety will go a long way to getting every one of them home each day. Let’s look at some things that could affect your employees trust based on what NFPA 70E® is trying to accomplish.
Beyond the expectation that you will properly train and qualify employees for any assigned task, NFPA 70E requires a lot of you. Go under the assumption that there is justification for energized work to be conducted. What do you do? Most of the requirements apply if there is shock or arc-flash hazard. Someone must determine this fact. Your own company may do this or it may hire one out of the vast number of companies that claim to be able to do this. You must be competent in being able to determine who is capable of doing a proper risk assessment. You could go with the lowest bidder, most local company, best presentation, longest history, or any other criterion. Your employee will trust that whomever you selected to perform the assessment was competent.
You may have jumped the starting gun by going right into that first step. What happens if your company has never conducted equipment maintenance? Without maintenance even normal operation of the equipment may be putting your employees at risk of an injury. A risk assessment is not done correctly if equipment maintenance has not been addressed. Your employee expects that their interaction with electrical equipment will not harm them. Your employee will trust that the protection techniques that they rely upon to minimize their injury in an incident are not based on the clearing time of a circuit breaker not operated in many years and never maintained.
Your employee will trust that the risk assessment was not a one-time-and-done evaluation but that you have properly used the hierarchy of risk controls to minimize the electrical hazard and the risk of injury as much as possible. Your employee will trust that you have not automatically defaulted to the lowest level of risk control. Personal protective equipment should never be the first or only protection scheme that you utilize. Your employee will trust that you have done everything possible to protect them.
Your employee will trust that you have kept all pertinent information on the equipment label updated. They will expect that the information provided is correct when they are assigned an energized task on that equipment a few years later. They will trust that you made sure that a transformer was not swapped out for a more efficient one or that the upstream breaker was not replaced with something different. Your employee will trust that the label information is correct since they will be the one to suffer a greater injury if it is not.
Your employee will trust that you will provide them with the appropriate protective equipment. They will trust that you have verified that the protective equipment indeed complies with the applicable standard. They will trust that they have not been given knock-off, counterfeit, or sub-standard equipment because it was less expensive than conforming equipment. Your employee will trust that when it comes to their protection that money is no object.
Your employee will trust that you have proper documentation of the risk assessment, complete and current work procedures, and a work permit that defines the hazards, risks and assigned task. Without clear direction, an employee will be improvising their actions in the field. Human error is a major cause of electrical incidents and your employee will trust that you minimize the possibility of an error through a proper electrical safety program and training.
When your employee is schedule for the task, they will trust that you are concerned for their safety. If the task cannot be conducted safely, if the work permit or job briefing are lacking, if the employee feels that they are unqualified or fatigued, or if they express any safety concern, your employee will trust that you will consider these issues above all else. They will trust that they are the most important asset within your company.
When it comes to performing justified energized electrical work your employee needs to trust you. If an employee is injured because they were compelled to work, they were not properly equipped or qualified, or finance took priority over their safety, employee trust will quickly fade. The work environment has taken a bad turn if the next employee goes into a task expecting to be harmed. It is the employee’s life that is at stake when they put their trust in you during justified energized electrical work. You must earn and keep that trust.
Next time: Who needs to read the words that are included in a standard?
My last blog posed the question whether a second-degree burn should be considered an acceptable employee injury. Why 1.2 cal/cm2 was selected as the point when the arc-flash hazard needed to be addressed was also covered. NFPA 70E® still applies where the incident energy is below this level but does not require arc-flash PPE to be worn. When HRC 0 was removed from the standard in 2015 it caused a lot of concern for the standard users. Many of you felt that left no guidelines on what was required to be worn when applying NFPA 70E. You felt your employee could wear whatever they wanted and you could not prevent it. I will attempt to address why this should not have caused as big of a concern as it did.
HRC 0 was not arc-flash PPE. HRC 0 was essentially what an employee should wear for every day work clothes. It required non-melting materials, long sleeve shirts, and long pants. It also required that you make a selection for safety glasses, hearing protection and heavy duty leather gloves. Remember, a second-degree burn is acceptable so no arc-rating was necessary. The specification was that clothes not melt onto the employee during an incident at lower incident energies. What should be done now that HRC 0 is gone?
You should be aware of 130.7 Personal and Other Protective Equipment. If NFPA 70E is being used because there is an electrical hazard then 130.7 applies. Section 130.7 clearly requires that employees working in areas where electrical hazards are present be provided with, and use, protective equipment that is designed and constructed for the specific part of the body to be protected and for the work to be performed. Notice that this statement is not for a specific incident energy or voltage level. You do not have to use the minimum 1.2 cal/cm2 requirement of the standard. You could consider a burn hazard to be anything over the potential of a first-degree burn. You could consider that any work conducted on energized equipment regardless of voltage or incident energy requires nonflammable clothing. If you are protecting you employee from whatever you consider to be a hazard, you have the ability to require that they be protected from that hazard.
Further along in 130.7(C)(12) there is another statement that is not tied to incident energy. It states that clothing and other apparel that do not meet an arc-rating must be made of non-melting or flammability rated material. That alone should cover a major part of the concerns about the removal of HRC 0. Are long sleeve shirts and long pants necessary? That is a decision that you as the employer should be making. It is not truly an electrical safety issue if an employee does not wear eye or hearing protection for these conditions. Steel toed shoes and hard hats are also not electrical safety issues. Does that mean if this protection were necessary for another reason that you as the employer would not require its use? Even if a standard provides no guidance on the issue, you as the employer still need to have some policies in place to address general work apparel. NFPA 70E only covers limited conditions. What protection is necessary for other conditions is something that you always had to determine.
Next time: Have you earned your employee’s trust?
Have you ever had a sunburn? Is a bad sunburn really that bad? The answer to that question will depend on who you ask. If you ask a person not likely to be exposed to the possibility of the burn, they probably will say no. If you ask a person who has been burned, they will probably say yes. The following assumes that you have read each of my posts about the authority having jurisdiction, consensus standards, risks to workers, and workers having some say regarding their safety.
The minimum standard is that should an arc flash occur while you are performing a task on justified energized electrical equipment that you be able to survive without permanent physical damage. Think about this. For anything other than an electrically safe work condition (which your employer has determined not appropriate for the task assigned to you), the standard does not prevent injury to you. While compliant and properly rated PPE increases the possibility that you emerge from an incident unscathed, you are not guaranteed to be uninjured. The severity of the burn injury permitted by the standard is limited by the 1.2 cal/cm2 incident energy. Why is 1.2 cal/cm2 used? Testing determined that this is the level where exposed skin can suffer a second-degree burn.
The Merriam-Webster dictionary defines a second-degree burn as: a burn marked by pain, blistering, and superficial destruction of dermis with edema and hyperemia of the tissues beneath the burn. This type of burn results in red, white, or splotchy skin, swelling, and blisters. A second-degree burn penetrates the second layer of skin. When the first layer is destroyed, it separates from the second layer. The raw nerves in the second skin layer make this burn painful. If a second-degree burn is larger than 3 inches in diameter or is on the hands, feet, face, groin, buttocks, or a major joint, the Mayo Clinic suggests treating it as a major burn and getting immediate medical help.
Those of you who think that arc-flash PPE will prevent an injury are wrong. Testing determines the incident energy level at which the PPE has a 50% probability of successfully preventing an injury. Half of the time there is a possibility of a second-degree burn if the rating is based on the arc thermal performance value (ATPV) and the incident energy exposure does not exceed that rating. Remember back to my post on consensus standards. It discussed how you determined the incident energy level and whether PPE rated for that exact level was a best practice. The arc-rated PPE that you are wearing has an increased probability of success if subjected to an incident energy lower than its rating. This also ties into my last blog on compliant PPE because if your employer has provided you with substandard equipment, the severity of your injury will most likely be greatly increased.
Another side point to this discussion is that the working distance for equipment is generally stated as 18 or 36 inches. If the incident energy is calculated to be below 1.2 cal/cm2 at this distance, how much closer to the origin of an arc-flash are your hands, arms or head when you perform the energized task? Those body parts could suffer worse than a second-degree burn if not protected.
Compliant and properly rated PPE should limit your injury to a second-degree burn when a higher incident energy is present during an incident. The minimum requirements of the consensus standard use 1.2 cal/cm2 because there is a probability that you will not suffer a permanent physical injury. The standard has no requirement to provide you with arc-flash protection below 1.2 cal/cm2. Only you and your employer can decide if a second-degree burn is acceptable.
Next Time: Working below 1.2 cal/cm2
WOW! The complaints from the field are overwhelming. The equipment that was purchased is wrong. An employee was injured. The equipment was substandard. How can NFPA 70E® allow such things? What is the subject of this discussion? Compliant PPE. NFPA 70E has a requirement that the employer provide the employee with appropriate PPE. How do you know what is appropriate? Appropriate is not only concerned with the claimed equipment rating but that the PPE has the ability to perform as needed to protect the employee. You are likely aware of PPE that is not only labeled incorrectly but also labeled as conforming to a standard when in fact the PPE does not conform. There are many pieces of PPE available that are counterfeit. How do you verify that the PPE really has been tested and conforms to the applicable standard? Even when something appears to be labeled correctly how do you know it is valid or that the standard stated is the correct one?
Past NFPA 70E editions had a requirement that the PPE conform to specific listed standards. The 2018 edition will still require that PPE conform to appropriate standards but will provide reference to several standards in informational form. Manufacturers of PPE have not been required by any NFPA 70E edition to evaluate their equipment to a standard. This means that YOUR ROLE IN SPECIFYING PPE HAS NOT CHANGED IN ANY WAY. Whether you realized it or not NFPA 70E has required that YOU verify conformance without telling you how to do it. YOU are still responsible for doing what you have done for several years. YOU are still the one who must make sure the appropriate standards for the specific PPE have been followed and that the PPE has been proven to meet the requirements. YOU are still the one responsible for providing PPE that will prevent the death of your employee when an incident occurs. YOU are still the one who must approve the PPE before you distribute it to your employees.
How do you do to determine that the PPE that you purchased complies with specific standards before being given to your employee as their last line of defense for limiting the severity of an injury. Are you even aware that there are standards addressing this? Did you purchase those standards to learn what they covered? Do you compare the PPE that you purchased to the standard to determine that it actually conforms? Do you just accept whatever the label states? Do you ask the manufacturer for something regarding compliance to any standard? Do you accept whatever the manufacturer sends without question? Do you know what is covered by the standard that the manufacturer claims compliance to? Do you conduct your own tests? This list could go on and on. But the point is regardless of what edition of NFPA 70E you use, YOU were and still are the authority having jurisdiction (AHJ) when it comes to approving PPE for your employees. YOU are the one who must decide what the appropriate PPE to purchase is and verify that the appropriate standard was used for the evaluation of that PPE. You do not have to accept anything that does not seem correct. No standard or code forces you to approve any specific piece of equipment even if it is listed by a third party.
Who verifies that PPE conforms to a standard? Does a claim equate to conformance? What does it all mean? In the past, NFPA 70E did not provide you with guidance on things to ask for. So what do YOU do now? The manufacturer may have provided a label on the PPE. They may have sent a letter stating that the PPE conforms to a standard. The manufacturer probably did not provide anything unless you specifically asked for it. Have YOU ever asked? The 2018 edition will require that the PPE manufacturer be able to provide you with one of three forms to address PPE conformity. YOU must ask for it. If a document is supplied, YOU must verify the truth behind that claim. Whatever method you use to verify the compliance, YOU are responsible for approving the PPE. This has been YOUR ROLE since PPE was first addressed in NFPA 70E. Regardless of the method you use for approving the purchase of PPE, the goal is to provide protection for the employee who is put a risk of injury when authorized to perform energized work. Your employee will trust that YOU have done all of this for them.
Next time: Do you mind getting a really bad sunburn.
NFPA 70E allows you to put one of four things on the equipment label when it comes to arc-flash PPE. You can mark it with the incident energy, a PPE category, a minimum required rating or a site specific designation. Some confusion comes with the requirement’s wording that the label must include at least one of these. Several NFPA 70E users ask about using both the incident energy and PPE category on a label. The first thing that enters my mind when that comment is made is that this person does not fully understand how to use NFPA 70E.
That statement is made because the standard only allows one method of conducting an arc-flash risk assessment on a single piece of equipment. This would mean that either the incident energy analysis (arc-rating) or a PPE category would be used. Since PPE category is not an incident energy and an incident energy is not a PPE category, these two should never appear on a label together. Redefining a PPE category as a site specific rating could be done but then why put both on the label if they are exactly the same thing? Calculating the incident energy (arc-rating) then changing it to a site specific rating is common. A facility could use this method label all the equipment with a few PPE levels when the incident energy analysis method calculated dozens or hundreds of energy levels. It's not clear on why someone would simplify the method then make it more complex and confusing by including both. Another common method is specifying the calculated incident energy but require a minimum PPE rating above that energy level.
NFPA 70E is about protecting the worker and confusing the worker when safety is at risk is a dangerous thing. If the equipment is labeled with the incident energy or minimum required arc-rating, the worker can utilize equipment with at least that rating. Equipment labeled with a PPE category provides specifics on what the worker can use. With site specific ratings, the worker is likewise provided with specific gear or rating necessary for protection. So why not include them all? Worker safety.
Assume that equipment has been determined to have an incident energy of 1.1 cal/cm2, 1.5 cal/cm2, 3.5 cal/cm2, 4.7 cal/cm2 and 8.9 cal/cm2. If these were placed on the equipment labels as the minimum arc-rating necessary for PPE, anything rated higher for each piece of equipment would be acceptable. Now, assume that the facility safety system intends to use site-specific category BLUE for 4 cal/cm2 or less and ORANGE for over 4.0 cal/cm2 up to 12 cal/cm2. Three pieces are also marked BLUE and two are marked ORANGE. Now the employer also decides to require a minimum rating that is 2 cal/cm2 above the incident energy to increase the probability of successfully preventing a thermal injury. For the last one, assume that NFPA 70E is incorrectly used and the equipment is also labeled as no PPE Category, PPE Category 1, PPE Category 1, PPE Category 2 and PPE Category 3. The labels would look like:
Can you train your employee on how to follow all four ratings on the label? Could they comply with all four or are they following the one that results in the highest rated gear? Would you permit them to select the lowest rated gear for specific equipment? Does your package for ORANGE contain specific equipment? What happens when the worker is wearing a 1.8 cal/cm2 shirt because they did not want to put on a heavier one for Equipment #1? Which piece of equipment would you let your employee work on while wearing a 2.1 cal/cm2 shirt? Which piece of equipment specifies PPE rated for at least 25 cal/cm2? Is it confusing what to wear based on these applied labels?
Maybe now you see why clearly stating the appropriate PPE, as well as using the standard correctly, is critical. The common labeling methods which include the incident energy require clear procedures so that employees understand that the specified required gear or specified minimum rating, not the incident energy, defines the only permitted PPE rating. It is often best to simplify matters to make compliance easier for the employee. Pick something for clarity. Training and enforcement will be easier. NFPA 70E is about worker safety. Why confuse the issue?
Next time: Something you don’t consider yourself to be the authority having jurisdiction for but you really are.
Is it normal operation to throw the switch of a circuit breaker? What about opening an access panel to get to that breaker? How about racking out a breaker? Or replacing a light bulb? The manufacturer probably states that the switch on the breaker is meant to be thrown, the access panel is intended to be opened, the breaker is designed to be racked out and the light bulb is intended to be replaced. That makes each of these tasks part of normal operation of the equipment. Doesn’t it? And if it is, doesn’t that mean that the task can be performed while the circuit is energized?
Not only is this equipment intended to do these things they are designed to do these things. That circuit breaker is only intended to be used as a switch if it has been evaluated as such. The handle itself does not make throwing the switch normal operation of the breaker. You may think that replacing a light bulb is not normal operation (even though the bulb is accessible, is intended to be replaced, and the base is designed to have the bulb removed). You may also think that there is no need to replace a light bulb while it is energized. You may think that way for a light bulb but may see a difference with racking out a breaker without de-energizing. (I know these next statements will be controversial so I don’t intend to reply to all the negative comments that will be made.) A breaker is meant to function as a circuit protective device. That is its intended normal function. If the breaker has to be racked out to function as a protective device, I would consider that normal operation. The breaker may be designed to be removed and so is that light bulb but removal is not part of their normal operation. That is the installation of those pieces of equipment. Yes, the equipment may be arc-rated or there might be justification for energized work but that is not what I am addressing. This discussion is about normal operation.
A piece of equipment is designed to perform a function. It could be overcurrent protection, temperature measurement, power conversion, or to provide light. That equipment is also designed to have an operator interact with it in order for it to perform that function. There are ON/OFF switches, dials to turn, and buttons to press. These things are what I consider normal operation of the equipment. It is what an operator must do to get the equipment to perform its function once it has been installed.
NFPA 70E® does not define normal operation for any piece of equipment because that is well beyond its scope. So the interpretation is up to you. NFPA 70E does define conditions when normal operation is permitted. You must determine that those conditions have been met before permitting your employee to interact with equipment in a manner that meets your perception of normal operation of that piece of equipment.
Next time: What your label says about personal protective equipment (PPE)
This is a continuation of my last blog on normal operating conditions. Safe use of equipment under NFPA 70E is based on the equipment meeting these conditions. Although the conditions are a starting point for all electrical work, the conditions are necessary before an employee operates the equipment for its normal function. Properly installed, properly maintained and closed doors were addressed in the previous blog.
Covers in place and secure – This takes a little judgement of the operator. Remember that this is also in the section addressing normal operation. Using the example of the access door for the panelboard circuit breaker, the hinged door is on a bolted cover that is intended to stay in place when operating the breaker. You must make sure that any equipment covers are properly secured. This will require proper training of the person interacting with the equipment. If the covers are absent or unsecured, your employee is potentially at risk of an injury if they attempt normal operation of that equipment. This safety issue is not addressing the tasks that require an energized work permit. This covers the person operating a HID breaker to turn the factory lights on each morning, for example.
No signs of impending failure – This is a tough one. Typically the employer/owner is not aware of the condition of individual equipment in their facility. The burden of determining this is often the responsibility of the person (think AHJ) interacting with the equipment since conditions can change on a daily basis. This involves training that person to understand the potential failure modes and to identify signs of the impending failure of the equipment. These signs vary greatly by the type of electrical equipment. The smell of ozone, presence of smoke, sound of arcing, visible damage, or warning lights are all possible indication of potential equipment failure. If any of the signs are present, that person is potentially putting themselves at risk of an injury if they attempt normal operation of that equipment. This safety issue is not addressing the tasks that require an energized work permit. This covers the person operating a HID breaker to turn the factory lights on each morning, for example.
Instructions – Regardless of the equipment meeting the normal operating conditions, for an employee to safely interact with equipment they must understand the conditions, methods, functions and sequences for safely operating the equipment. Equipment typically is supplied with manufacturer’s operating instructions. If the equipment is listed, these instructions typically include the specifics necessary to operate the equipment within the parameters of that listing. Operating equipment contrary to the instructions puts the employee at risk of an injury whenever they attempt to operate of that equipment. This covers the person operating any electrical equipment including proprietary or production line equipment.
There is no reason to believe that normal operation of equipment meeting these conditions inherently presents a unacceptable risk of injury to a person. No interaction with equipment would be permitted if it did. A computer, light switch or elevator would be a hazard with an unacceptable risk level. Society has come to terms with the concept that normal operation of equipment does not pose an unacceptable risk of injury to persons under these conditions. In your facility, you are responsible for assuring that the conditions which permit normal operation have been meet before allowing your employees to interact with your equipment.
Next time: Does normal operation cover everything that a manufacturer claims the equipment can do?
As I put this blog together I realized that it would be lengthier than I expected. So bear with me for two blogs regarding this issue. Normal operation seems like an easy concept to grasp but the number of questions regarding this issue is astounding.
NFPA 70E® does not define normal operation. Regardless of what you considered to be “normal operation” of your equipment, NFPA 70E has conditions before it is permitted to occur. These are properly installed, properly maintained, closed and secured doors, covers in place and secure, and no sign of impending failure. Normal operation is also a condition addressed in the manufacturer’s operating instructions. What do these mean? (Remember back to one of my first blogs where you are the authority having jurisdiction (AHJ) for NFPA 70E. It comes into play here.)
Properly installed – Someone will need to determine that the equipment installation meets not only any applicable standard but also any requirements set by the manufacturer. This is not limited to electrical standards since things like improperly installed pressure systems for electrical equipment may affect the electrical safety of that equipment. Often building systems are inspected by an authority outside of the employer/owner. A lot of equipment that falls under NFPA 70E does not have the local electrical inspector verifying that the installation follows any rules. Equipment is installed by an employee or sometimes by an outside contractor. There is no governmental oversight. How do you enforce the National Electrical Code® for equipment installed by an employee? You must make sure that any equipment is properly installed. If not you are potentially putting your employee at risk of an injury if they attempt normal operation of that equipment. This safety issue is not addressing the tasks that require an energized work permit. This covers the person operating a HID breaker to turn the factory lights on each morning, for example.
Properly maintained – Equipment was in a new condition when it was installed and at that time everything is expected to be in order. The fact is that the equipment slowly begins to show signs of wear and tear. Motors, circuit breakers, even transformers are not pieces of equipment that should be left alone. They require maintenance. Most manufacturers will provide recommendations on what is minimally required to maintain their equipment. Some industries provide guidance on maintenance. NFPA® 70B, Recommended Practice for Electrical Equipment Maintenance contains a wealth of information on the subject. Proper maintenance is not just the act of fixing, adjusting or filling fluids. There is a time aspect that is just as important. A piece of equipment may only need proper maintenance every year or two in one installation. That same piece of equipment in another installation may require monthly maintenance to be considered properly maintained. You must make sure that any equipment is properly maintained. If not you are potentially putting your employee at risk of an injury if they attempt normal operation of that equipment. This safety issue is not addressing the tasks that require an energized work permit. This covers the person operating a HID breaker to turn the factory lights on each morning, for example.
Closed and secured doors – This one causes a lot of heartburn to some. This takes a little judgement of the operator. Use the knowledge that this is in the section addressing normal operation. A hinged door to get access to a panelboard is meant to be opened for someone to gain access for the normal operation of that HID circuit breaker. That is not the same for an access door that is intended to be closed and secured during operation of a transformer. You must make sure that equipment doors are properly secured. This will require proper training of the person interacting with the equipment. If the inappropriate doors are open, your employee is potentially at risk of an injury if they attempt normal operation of that equipment. This safety issue is not addressing the tasks that require an energized work permit. This covers the person operating a HID breaker to turn the factory lights on each morning, for example.
Next Time: The rest of the things needed before normal operation is consider safe (PART 2).
Occasionally the concept of exceptions to the energized work permit comes into question. Being a consensus standard, NFPA 70E® has four exemptions to requiring a work permit. Although a work permit “shall not be required” for the exemptions it does not state that you are forbidden from doing one (remember back to my posts on consensus standards and best practices.) An exemption to the work permit is allowed for testing, troubleshooting, and voltage measuring. The other three exemptions are for nonelectrical work being conducted outside of the restricted approach boundary. There is a saying that “if it has not been documented it did not happen.” Would I go without an energized work permit?
Before covering whether I would or would not do a work permit look at the terms used in the exemption: TESTING – TROUBLESHOOTING – VOLTAGE MEASUREMENT. Everyone has the idea of what these terms mean. I have spent some time in the instrument and test field so I have my own opinion. Not one of these terms means repair. Some may disagree and consider repair as part of troubleshooting. General terms are not defined in NFPA standards. The definitions come from general sources. Just typing the words into an online dictionary here are the first definitions I saw. I hope I don’t have to look up voltage measurement.
Testing - the means by which the presence, quality, or genuineness of anything is determined; a means of trial.
Troubleshooting – discovering the cause of trouble in mechanical equipment, power lines, etc. (A troubleshooter eliminates the trouble.)
Regardless of your stance on this, this blog is discussing the need for a work permit. With or without a work permit, the qualified person has to be provided with and use appropriate safe work practices. If the task is voltage measurement, the employee must be informed of that fact. They must have the correct test instrument. They must wear the appropriate shock and arc-flash PPE. They must know the procedures for conducting voltage measurements on that specific piece of equipment.
You might say that since the person is qualified an energized work permit is not necessary. The minimum requirements of the standard permit that. I, on the other hand, probably would require a work permit. Why? What procedures, test instrument, PPE, etc. were used for the task? I can tell you. Who conducted the work? I can tell you. We all know that qualified or not people do unexpected things. A loose lug was seen during a voltage measurement. It was tightened and the equipment was damaged. Was that part of the task? I can tell you. Can you tell me? Going back to “if it has not been documented it did not happen.” Justified electrical work does not mean that the task will be completed without an incident or injury. What do you do when tightening that loose lug initiates an arc-flash? The facts of what was believed to have occurred prior to an incident often get muddled up after the incident.
I am not saying that I would always require a work permit. A lot you may not since you consider the work to be so menial or routine. Before you never require one under the exemptions, think about it.
Next time: The conditions which permit normal operation.
I sure am glad that I am not a contract employer. Their calls to me often end up with same statement being made at one point or another. That statement is “if I don’t do the work energized my competitor will”. Take the job to get paid or pass up on the job and don’t get paid. That is the decision in a nutshell. Unfortunately, when it comes to electrical safety there is another decision that you are making at the same time. That decision is whether or not to risk your safety or the safety of your employee.
Often the host employer wants energized work to be conducted because they do not want to lose revenue. They have already made their decision that your safety is not as important as their bottom line. That is a scary prospect in its own right. You explain the issues with this. You cover everything from equipment damage, extended downtime, and loss of production anyway. That may not sway them and they may still want to risk your safety. You then cover the lead time in getting the new gear in, the cost of that new gear and finish up with the potential for injury or death. Finally, the host employer sees the light.
This very often leads to the next problem that you often face. A meeting is held to go over the host employer and your duties (Article NFPA 70E®, Article 110 addresses some of the things to consider for each role.) The host not only has no knowledge of any electrical hazards but has no equipment labels, no single line drawings, no safety program and no maintenance program. This concerns you since the seemingly simply task of operating a disconnect switch now presents a far greater hazard and risk of injury then if these things had been done. You show them your lockout/tagout procedure, provide information on the work procedures that you will use and explain the benefits of proper PPE. Luckily for you the host wants to do things right. They now realize that their employees are at risk of injury each time they operate equipment. Not only do they want you to do the original work but want you revamp the entire electrical system during the scheduled week long shutdown. Damage equipment is repaired or replaced. Circuit breakers and fuses are installed with the correct ratings. The short circuit current ratings of equipment are verified to be suitable for that point on the distribution network. All equipment is labeled to facilitate establishing an electrically safe work condition. Before you leave the work site, you educate them on justified energized work, help them establish lockout/tagout procedures, move them in the right direction for equipment maintenance, and leave them a copy of NFPA 70E. From that point on you are their electrical contractor.
We all know this is all too often a fairy tale. Equipment maintenance is sacrificed. What was on the truck has been installed even if it is not quite correct for the installation. In house installations do not comply with the National Electrical Code®. Short cuts are taken to maximize revenue. Someone not knowledgeable about safety may take the job. Safety may give way to receiving a paycheck. Imagine though if everyone did what is right. Everyone proactively implements electrical safety policies and procedures. An equipment maintenance program is not seen as being unnecessary but a critical aspect of safety for anyone interacting with electrical equipment. The default electrical work procedure is an electrically safe work condition. When energized work is conducted, it is justified for the task and protective measures are taken to minimize the worker’s injury if an incident does occur. Both the host employer and you follow NFPA 70E. In that world you do not have to consider risking your own or your employee’s safety to get paid. Utopia. Until then I am glad I don’t have to make the decisions you are faced with.
Next time: Going without an energized work permit.
We all know that the primary work procedure required by both NFPA 70E® and federal regulations is that electrical equipment be placed into an electrically safe work condition before work has begun. [Here in the northeast, if the facility or the specific equipment has no ability to be supplied by automatic secondary power, I might consider that the loss of power (or establishing an electrically safe work condition) is not a concern to the owner and that energized work would never be necessary. If a sudden, unexpected power loss is not a concern, how could a scheduled outage possibly be?] We also know that there are only three reasons for permitting energized work. These are increased hazard, increased risk and infeasibility. I don’t intend to address what these mean or whether the energized work is justified. For this discussion I am going to assume that these reasons have been used to justify the work.
Assume something along the line of a patient on life support or a process that has the potential to ignite a hazardous location. If the equipment is shut off, the patient will die. The building will blow up if the process is stopped. You surely don’t want either to occur. These are typical reasons someone uses to illustrate the need to justify energized electrical work. What is surprising that although both of these are used as examples, most often neither is the reason I am given as justification for energized electrical work.
If you claim justification of the energized work to keep the patient alive or the process operating, doesn’t that meet the requirement? Not really. Just making the claim does not make it true. It could be true if that single, critical piece of equipment can be repaired while staying in full operation. If it is not a single, critical piece of equipment, is the energized task justified? What happens if the equipment fails before the justified work even begins? What if the equipment cannot be repaired? Justified energized work does not guarantee uninterrupted equipment operation. What happens when the worker drops a screw into the equipment and the equipment is accidentally and suddenly shut-down? That patient’s life that you used to justify the energized work has ended. That explosion that you wanted to prevent has leveled the building. Something you tried to avoid has occurred. And if those results did not or will not occur due to equipment failure, was the energized work truly justified?
We have all seen photographs of things gone horribly wrong when work is conducted on energized equipment. Before the task began do you think they thought; today is the day I will get injured or will die. Did they think; I will make a mistake that will shut this equipment down. Or did they think; it will not happen to me. Either way they were injured when something did not go as expected. If the work was justified and they followed NFPA 70E, their injuries should have been recoverable. Good for the worker but what about the reason for the justification?
On the other hand, there is no way that those pieces of equipment were brought back online quickly enough to prevent this hypothetical death or explosion from happening. The down time in a majority of these cases was considerably longer than a scheduled shut down would have been. Should they have anticipated all the possible faults? Should they have had a “Plan B”? If they had a Plan B, shouldn’t they have had it in operation so that the work could be performed in an electrically safe work condition? Was moving the patient to another area or using other life support equipment possible? Should they have considered how long the equipment could be de-energized before the situation would turn bad? Maybe the process could be shut down for more than an hour before the hazard became an issue and a five minute de-energized repair is the way to go.
This does not mean that there is never a legitimate reason for justifying energized electrical work. What it means is that often it is still selected as the norm rather than the exception without truly justifying the task or considering other things. You should consider everything before putting your worker at risk by performing energized electrical work.
Next time: I am glad I don’t have to make the decisions some of you make.
There seems to be a gap between the NFPA 70E® knowledge of the employee actually conducting justified energized work and everyone else who uses the standard. There are a lot of requirements that the employee must follow but somehow they are unaware of many of them. The employee may know something about PPE but not much more. Even the PPE knowledge may be minimal. They may be aware of the work permit but are only concerned with certain aspects of it. Often, the employee is told what needs to be done and they do it. No questions asked. Regardless of the employer’s plan, it is the employee who has the biggest impact on their own electrical safety. You are the one who being placed into harm’s way. Your safety is at risk. You should take a proactive role in it.
An employer is required to provide safety-related work practices and training to you as part of your job. They must teach you to be self-aware of the hazards and actions you take. They should also instill in you a sense of self-discipline. Your employer must also train you to perform the tasks, recognize the hazards, to understand the potential injury from those hazards and how to protect yourself from those hazards. You are responsible for implementing each of these into your work. Many of these are synonymous with common sense. Your employer may train you, audit you, and retrain you. No matter what is taught to you, it is you who will make decisions and take actions that either injure you or not. Only you can determine if you are truly qualified to perform a task on a piece of equipment. The following scenario is a typical thought process that you should have when assigned a task.
Consider that you are handed an energized electrical work permit (EEWP) to perform a task. The EEWP is filled out and signed by everyone but you. Do you accept that it is justified for you to be put at risk of injury? If it is not justifiable work do you speak up? Is your potential injury worth it? Those signing may agree that it can be done safely. Do you feel that it is not as safe as they believe? Maybe some of the steps to safely perform the task are missing. Do you point them out? Is a potential 2nd degree burn something you would rather live without? Are there some other controls that could be implemented which would significantly reduce the hazard or risk to you? These should be implemented and the permit modified. Maybe you know of a way for the work to be done in an electrically safe work condition. If you will not sign the EEWP for legitimate reasons the work should not be conducted. You should not feel forced to put yourself at unnecessary risk.
Everyone, including you, finally agrees that the energized work is justified and can be conducted safely. Hopefully you aware that a job briefing is required before the task is conducted. This must cover many things. A sample checklist is provided in NFPA 70E. If a briefing is not held you should not begin the task. You now have another opportunity to address any concerns you have about the task and your safety. You should discuss the work procedure so that it is fully understood before beginning the task. What happens when you realize that you are not qualified to open the gear or perform the task? You are the only one who knows whether or not you are truly qualified to perform that task on the specific piece of equipment. A more appropriate person should be assigned to do the task. This is not about saving face. It is about putting yourself in a situation that you are ill equipped to handle. You should not attempt something you are not qualified to do.
You acknowledge that you are qualified to conduct the task on the specific equipment. You are given all the tools necessary to perform the task. Do you inspect the gear? Do you reject anything that is questionable? Do you verify that it is properly rated for the task you are conducting? The equipment is from a different manufacturer than expected. Do you use it? You have not been trained on it. You should not assume that it functions the same way and using it the same way could put you at risk. Finally, you have everything you need to perform the task. You suit up and are about to open the gear but notice that something is not quite right. There is a wisp of smoke drifting from a ventilation opening. Do you open the gear anyway? You should not since the parameters of the EEWP could be exceeded. Your equipment may no longer protect you from the unexpected hazards inside. A new risk assessment must be performed before you continue on.
The new risk assessment determines that there is no greater hazard or risk of injury so you return to conduct the authorized task. This time when you about ready to start pulling the cables you notice that you cannot see into the location. There are several bad things you could do that are not specifically covered by the standard and should not be done, but a few are specifically called out since they should never be done in energized equipment. One of those is blind reaching. You must be able to see the location where your task will be conducted. There is no way to assume that the task can be safely performed if you cannot see what you are doing. Work must stop again.
The permit and task are changed to specify access from another direction. Back at the equipment this time, you realize that it is too dark on that side of the equipment. Do you grab a flashlight? This was not part of the EEWP or job briefing. Holding a flashlight while performing the task can dramatically alter the risk you are exposed to. You should not perform the work until appropriate and sufficient light is available. By the time temporary lighting is available you have been called off the task and have moved on to another more pressing issue. You are well into overtime but your employer wants you to finish up the original task before you head home. You had bad fish for supper and are sick. Only you can recognize that you are fatigued or ill and are no longer capable of performing the work safely. Do you risk it or speak out for your safety?
Many of these are things that you should consider even without having any knowledge of NFPA 70E. I also have not covered things that are not your responsibility under the requirements of NFPA 70E. You must be able to work safely. You know when something does not seem quite right or safe. You make the decision to use a short cut at the cost of risking your safety. You should read and understand what your employer’s and your roll is when it comes to electrical safety in the workplace. NFPA 70E is not just about the actions your employer took before the incident investigation. NFPA 70E is about preventing you from being injured. Your family wants you to return home at the end of the day. When the time comes only you can decide if you are qualified for the assigned task on the specific equipment and are working safely. Your actions and decisions will directly affect your personal safety more than anything anyone else does. They are your choices. Make the right ones.
Next time: Have you really justified energized electrical work?
One of the most frequent issues faced when responding to questions regarding NFPA 70E® is that it does not tell someone exactly what to do. Why doesn’t the standard tell me that I have an arc flash hazard? Why doesn’t the standard tell me how to train my employees or what I should be training them about? Why doesn’t the standard tell me who should sign the energized work permit? Why doesn’t the standard tell me who is qualified to do the work? These questions stem from a desire to have a cookbook on what exactly to do rather than thinking of what is trying to be accomplished when it comes to worker safety.
Qualification is not only equipment and manufacturer based but also task based. No one and no standard can determine 100% of the worker qualifications needed for 100% of the potential tasks on 100% of electrical equipment in 100% of the possible installation locations along with 100% of the potential outcomes, hazards or risks associated with 100% of the possible situations 100% of the time. You must determine the most appropriate way to qualify your employee to conduct the task that you will assign for your specific situation.
A lot of what NFPA 70E requires is based on a worker who is a qualified person. This is someone who has demonstrated skills and knowledge related to the construction and operation of electrical equipment and installations and has received safety training to identify and avoid the hazards involved. Seems clear to me when I consider what NFPA 70E is trying to accomplish. That is electrical safety in the workplace. Everyone may have their own theory of what qualified means. Here is mine.
NFPA 70E addresses electrical safety. So the first thing is that the person needing qualification is interacting with or is around electrical equipment. If nothing is electrical there is no need to use NFPA 70E. Are they knowledgeable about the electrical equipment they are interacting with? An administrative assistant who turns the lights on at a breaker each day should at least be aware of what is involved with the operation of the equipment in that regard. They may not need to know as much as the electrician who works within the panel but some knowledge of the equipment is necessary.
The next is demonstrated skills. Keeping with the assistant turning on the lights, shouldn’t they know ON from OFF? Maybe the panel is full, shouldn’t they be able to show which breaker is for the lights? The electrician better demonstrate more along the lines of how to disconnect the main, swap out a breaker and establish an electrically safe work condition.
Does the assistant need any training on the installation? Probably nothing specific beyond what has already been shown. But they should have knowledge on the construction. A panel typically has a hinged cover. To open it, know which way it swings, etc. requires some concept of its construction. Once again the electrician better know more such as where the busbar is, whether there is an internal terminal block cover, what the grounding scheme is or what power sources feed the panel.
The assistant should be trained to recognize and avoid hazards. The assistant should trained to recognize that crackling, arcing or a hot switch on the breaker could be problem. They should know the potential danger if a breaker slot was left uncovered. They should be trained to know if the breaker should be thrown or not in these cases. They will have recognized and avoided the hazard. The electrician of course is exposed to more hazards and must have a more detailed training.
Think about it in a broad context. Shouldn’t any person doing any task have the training to do that task, to know something about the equipment they are interacting with and know how not to get injured? Seems simple to me. I most likely would consider the assistant as qualified for operating that circuit breaker to turn on the lights each morning in that specific panel. I would not recognize them to turn something else off in that panel or at another panel until I qualified them to do that. (This assistant is not really a qualified person under NFPA 70E but an unqualified worker who has been shown what is necessary for them to conduct the task safely. It was just to prove a point). The electrician would be qualified to work in that panel but not in a piece of switchgear without additionally being qualified for that. Just what the definition says.
Next time: Are you the employee whose safety is put at risk by working on energized electrical equipment?