AUTHOR: Christopher Coache

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A Better Understanding of NFPA 70E: The Employee's Responsibility

What are the primary NFPA 70E®, Standard for Electrical Safety in the Workplace® requirements for an employee? Section 105.3(B) lists one. An employee must comply with the safety-related work practices and procedures provided by the employer. Public Law 91-596, “Occupational Safety and Health Act of 1970” SEC. 5.(b) requires that each employee comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to the Act which are applicable to his own actions and conduct. Most employees do not know the law but expect that their employer ensures that they are following it. One way for them to comply with respect to electrical hazards is to follow NFPA 70E. However, the employee's compliance with the law is typically dependent on the quality of the employer's electrical safety program.>  An employee has a great responsibility after being trained to use and follow the safety-related work practices and procedures for the tasks assigned. Once out in the workplace conducting daily assigned tasks, employees make decisions to apply that training and the steps detailed in the provided procedures. Following documented procedures is the easiest part of the employee's responsibility. However, the employee's safety is not solely addressed by following procedures. Safety training, safe work practices, and safety policies also include things often not part of the detailed work procedure for the assigned task.  The employee's training should teach them to recognize that new technology, new types of equipment, or changes in procedures affect their safety. They must recognize that their skills may not be sharp if they have not performed the task regularly. They must recognize that safety-related work practices not normally used during regular job duties may necessitate additional training. Although the employer must document employee training, the employee should question their training if job duties change.  Employees must be instilled with an awareness of potential electrical hazards and the self-discipline to control their own safety when working around electrical hazards. Awareness is entirely dependent on the employee. An employee must always be alert where electrical hazards might exist. An employee must recognize that they are impaired due to illness, fatigue, or other reason. Even a supervisor may request that the employee perform a task not originally assigned and the employee must recognize that that changes during the work that might affect their safety. The employee must be alert that reaching blindly into areas affects their safety.  The employee's training must also address illumination. The employee must realize that they should not enter a space unless the lighting enables them to perform the work safely. They must also use their training to recognize that a task should not be performed if insufficient lighting or an obstruction prevents them from seeing the location where the task is be performed. The employee is responsible for applying the training that conductive articles of jewelry and clothing should not be worn within the restricted approach boundary or where they present an electrical contact hazard. Only the employee can handle conductive materials, tools, and equipment in a manner that prevents unintentional contact with energized electrical conductors or circuit parts. The employee must apply the training to secure doors and hinged panels to prevent their swinging into them. The employee's training directs them to keep the working space clear to permit safe operation and maintenance of electrical equipment. Qualified and unqualified employees must use their training to anticipate equipment failure and that they should be protected from those hazards by suitable barricades and other alerting techniques.  The training provided to an employee must address these issues and more. Following detailed procedures is relatively easy. Following electrical safety principles and practices that were provided during training is a little more difficult for employees. The safe work practice that conductive jewelry not be worn should be discussed during training but it is typically not addressed in a detailed procedure. However, the employee is responsible for applying that safe work practice daily. Safety training must be provided by the employer. It is the employee's consistent use of this training that will dictate if they will be returning home uninjured at the end of the day. Remember, it is the law. Next time: Is the contractor printing labels or are they doing risk assessments. Want to keep track of what is happening with the National Electrical Code® (NEC®)? Subscribe to NFPA Network to stay informed of new content. The newsletter also includes NFPA 70E information such as my blogs.

A Better Understanding of NFPA 70E: The Employer's Responsibility

What are the primary NFPA 70E®, Standard for Electrical Safety in the Workplace® requirements for an employer? Section 105.3(A) narrows it to basically two. The first is that the employer establish, document, and implement safety-related work practices and procedures. The second is that the employer provide safety-related work practices and procedures training to employees. From the federal side, 1910.332(b)(1) states that employees must be trained in and familiar with the safety-related work practices that pertain to their respective job assignments. Before any of this starts the employer must be committed to improving electrical safety within their facility. Overriding principles to protect employees must be established. Management must commit to protecting the employee by providing guidelines. Establishing an electrically safe work condition will be the primary safe work procedure. All electrical equipment will be inspected and maintained. All work tasks will be planned. Proper tools and equipment will be provided. Employee qualifications will be ensured. Electrical installations will comply with the National Electrical Code (NEC). All employee safety concerns will be addressed. These principles should be documented in order to form the basis for the safe work procedures. order to establish safety-related practices and procedures, the employer must understand the electrical hazards and risks that employees face as part of their daily tasks. Do employees use portable tools? Does a security guard turn the production floor lights on at a panelboard? What voltages are present in the facility? Are contractors hired to work on electrical equipment? Do contractors engage in energized work? Do electricians install equipment, or do they also maintain it? Do employees open electrical equipment enclosures? Once it has been determined that employees are at risk, it is necessary to determine steps to protect them. With an understanding of the tasks performed and risks faced, and by overlaying the safety principles, the employer can establish safe work procedures. Employee involvement in developing procedures typically increases the likelihood of the procedure being used. What are the steps necessary to safely operate Circuit Breaker #23 in Subpanel #8 to turn on the production floor lights? How does a cord-and-plug connected drill get inspected before use? What is the proper method of establishing an electrically safe work condition for Acme Company, Model 123 motor starter as it has been installed on Production Line #5? What about the starter on Production Line #1? What is the correct lockout procedure for a hydraulic press? What is the applicable testing protocol for insulated gloves? The procedures will be used as part of the required field audits. They should be detailed and controlled so that continued improvement can be implemented. Once all this is documented, the practices and procedures must be implemented. Placing the documents into a file cabinet without this stage is a job poorly done. How will all this safety information be distributed? Who is responsible for making sure the proper information is given to those in need? How will training be implemented? Who oversees implementation of the safety program? How will revisions be incorporated? Lastly, employees must be trained to follow the procedures. How will they be trained? Is there necessary prequalification? Who is qualified to train an employee for a specific task? Who verifies that they are qualified to perform the task? Does the ability to follow the procedure qualify an employee for the task? How will general safety training occur when a detailed procedure may not be necessary, such as how to properly unplug equipment from a receptacle? How does an employee recognize that it is safe to operate electrical equipment? How will a qualified person demonstrate the skills necessary for a task? How will the training be documented? How will the field audits address training or procedure deficiencies? Safe work practices, policies, and procedures will be part of the larger electrical safety program. Electrical safety is not a static thing. Lessons learned through field audits and employee feedback should be evaluated to improve safety. Procedures should be reviewed for relevance and new ones developed when necessary. The goal is to minimize risk and work towards elimination of employee injuries. Next time: An Employee's Responsibility. Want to keep track of what is happening with the National Electrical Code (NEC)? Subscribe to the NFPA Network to stay informed of new content. The newsletter also includes NFPA 70E information such as my blogs. As all of us continue to navigate the evolving situation with COVID-19, NFPA remains committed to supporting you with the resources you need to minimize risk and help prevent loss, injuries, and death from fire, electrical, and other hazards. For information on NFPA's response to the coronavirus, pleasevisit our webpage.

A Better Understanding of NFPA 70E: Conducting Risk Assessments for Electrical Safety Month

Rather than a blog on manufacturer's responsibility, this blog is about risk assessment. Once again it is May and National Electrical Safety Month, sponsored by Electrical Safety Foundation International (ESFI) to raise awareness of electrical hazards both on the job and at home, and this week I'm focusing on risk assessments. Once a hazard is identified, it is necessary to determine if there is risk of injury. This process is called a risk assessment in NFPA 70E®, Standard for Electrical Safety in the Workplace®. Shock and arc-flash risk assessment procedures are required to be part of the documented electrical safety program. There are hundreds of valid methods of performing risk assessments for the thousands of tasks that could be conducted on the millions of pieces of equipment available. NFPA 70E is not a how-to manual for detailing a risk assessment procedure. However, what is necessary as part of an assessment is addressed. A risk assessment identifies hazards, estimates the likelihood of occurrence of injury, estimates the potential severity of injury, and determines if protective measures are required. This is the basis for any applied method of risk assessment. Sections 110.1(H), 130.4 and 130.5 require that risk assessments be conducted before an employee begins a task. The person conducting the assessments is presented with many dilemmas. That person must identify the hazards and risks presented by different equipment, understand the training of employees, be knowledgeable of tasks to be performed, determine the operating condition of the equipment and protective devices, assess potential for human error, and verify proper equipment installation. There are many more issues, and each requires a decision. Equipment is required to be labeled with the highest voltage and incident energy or PPE category determined by the risk assessments. This protects the employee with the highest level of protection without regard for the task assigned. Without any additional criteria these are the hazards that any employee opening the enclosure must be protected from. However, a risk assessment could address other tasks performed within the equipment.  First, identify the the hazards associated with the task. A shock hazard typically exists if there is 50 volts or more. This voltage itself does not mean there is a shock hazard if the equipment is under normal operating conditions and there are no exposed energized parts. If the enclosure is opened for either justified energized work or to establish an electrically safe work condition, there might be exposure to shock hazards. There might be two separate sections within the enclosure; one with a power supply and another with control circuitry. If both sections are uncovered, the employee is exposed to the highest voltage and might be within a restricted approach boundary. But what if the power supply section is surrounded by grounded metal? Does the assessment method allow for this? Perhaps only the supply input terminals are finger-safe with a plastic cover and there are exposed 240-volt portions of the power supply. A 24-volt switching power supply might present a different hazard than a transformer supply. The task might only require access to the 24-volt control section. Capacitors and inductors in the control circuit could alter where a shock hazard exists. Next determine the risks associated with the shock hazard. Parts operating above 50 volts may be exposed when the enclosure is opened. A cover over the supply may need to be removed to verify the absence of voltage. The interior covers may not require a tool for removal. The finger-safe plastic on the terminal may have an insulating value, or it may only be a guard. A guard should be properly spaced from energized parts and rigid enough to prevent deflection. Tools required for the assigned task might defeat the finger safe protection. The required tool might extend the shock boundary. Both the risk and hazards may be very different if the equipment is not properly maintained. The documented risk assessment procedure may not accept any less risk regardless of the task. The arc-flash hazard and risk also need to be determined. Using the PPE category method, a piece of equipment will be marked with a minimum PPE Category 1. Using the incident energy analysis method an arc-flash hazard does not exist below 1.2 cal/cm2. Is the risk of a second-degree burn acceptable? The low incident energy might be based on a working distance of 18 inches. The hands could be nearer to the arc-flash source during performance of the task. Does an incident energy equate to an arc-flash hazard and what are the risks associated with an arc-flash capable incident energy? The control section could present a different arc-flash hazard than the supply section. Using the same equipment examples as in the previous paragraph, does an enclosure or cover remove the arc-flash hazard? Does the arc-flash hazard in the grounded metal covered supply section apply if a task is only performed within the control section? Does the arc-flash hazard exist if two specific supply points must be under a bolted fault and those two points are in separate, inaccessible sections? Determining the maximum shock and arc-flash hazard present within an enclosure is relatively easy. These worst-case conditions are required to be on the label. The next part is why the qualification and knowledge of the person conducting a task specific risk assessment matter. The worst case can be used for 100 percent of tasks associated with the equipment. Although providing the maximum level of protection is always permitted, what about tasks in Table 130.5(C)? For example, working on 24-volt control circuits is not likely to create an arc flash when no parts above 125 volts are exposed. If the assigned task only involves the second cabinet section does the maximum arc-flash hazard present in the unopened, high-power first cabinet section apply? The employer's risk tolerance could be zero. If the risk assessment procedure is predicated on poor equipment maintenance, untrained employees, inadequate procedures, and human error, a worst-case scenario may be required for all tasks. Some risk may be tolerated. An employer's risk assessment procedure might allow a situation where access to hazards within the equipment is controlled. Interior protective covers might only be removed by a special tool that is not available to employees. However, the person conducting the assessment might consider hazards behind those covers if willful negligence is considered. When a risk assessment determines that electrical hazards exist and there is risk to the employee, the next step is to determine the necessary protective measures. To many this means specifying personal protective equipment (PPE) but that is incorrect. The hierarchy of risk controls must be applied to further mitigate the hazard or risk. If the assessment is being conducted before equipment selection or installation, elimination, substitution, and engineering controls might be possible. Awareness requires knowledge of and possible revision of employee qualifications and training for the specific task being assessed. A detailed procedure for the task and specific equipment needs to be developed under administrative controls to address remaining hazards and risks. Implementing any of these controls may necessitate another run through the assessment to determine their effectiveness. After this, it is possible to specify required PPE. Even this requires some decision by the person conducting the risk assessment. Does the employer accept the risk of using 6.3 cal/cm2 PPE for a calculated incident energy of 6.3 cal/cm2? NFPA 70E does not detail any of this. An entire encyclopedia might not cover it all. For an employer following NFPA 70E and OSHA regulations, the task being assessed most often should be establishing an electrically safe work condition. Remember, the purpose of these assessments is to prevent injury or death of an employee. The employer develops the risk assessment procedures to use. Those procedures must identify hazards, estimate the likelihood of occurrence of injury, estimate the potential severity of injury, and determine the required protective measures. To do so, the person conducting the risk assessment must be competent.  Next time: An Employer's Responsibility. Want to keep track of what is happening with the National Electrical Code (NEC)? Subscribe to the NFPA Network newsletter tostay informed of new content. The newsletter also includes NFPA 70E information such as my blogs. As all of us continue to navigate the evolving situation with COVID-19, NFPA remains committed to supporting you with the resources you need to minimize risk and help prevent loss, injuries, and death from fire, electrical, and other hazards. For information on NFPA's response to the coronavirus, pleasevisit our webpage.

A Better Understanding of NFPA 70E: Employees at Greater Risk of an Electrical Injury

I have written several blogs regarding employees at risk of an electrical injury. Many of those blogs point out that electrical injuries and fatalities are not limited to those solely in an electrical occupation. It has been a while since I looked through 29 CFR 1910. Standard 1910.332 applies to training employees who face a risk of electric shock that is not reduced to a safe level. A table associated with 1910.332(a) (summarized below) indicates occupational categories considered to be a greater risk of electrical injury than other occupations. Notice that more non-electrical occupations are listed than electrical ones. An included note further states that employees in the listed occupations are required to be trained. You may want to remedy the situation if your occupation is on this list and no documented electrical safety program exists at your company. For more information on 70E, read my entire 70E blog series on Xchange. Want to keep track of what is happening with the National Electrical Code® (NEC®)? Subscribe to NFPA Network to stay informed of new content. The newsletter also includes NFPA 70E information such as my blogs. Next time: An Employer's Responsibility. As all of us continue to navigate the evolving situation with COVID-19, NFPA remains committed to supporting you with the resources you need to minimize risk and help prevent loss, injuries, and death from fire, electrical, and other hazards. For information on NFPA's response to the coronavirus, please visit our website.

A Better Understanding of NFPA 70E: Putting an Employee's Life at Unnecessary Risk

Many people miss the point of providing a workplace that is free of electrical hazards for an employee. The main point of the federal law as well as NFPA 70E®, Standard for Electrical Safety in the Workplace® is to not put an employee's life at risk when it is not absolutely necessary to do so. Electrocution was a known electrical hazard prior to 1900. In 1970, it was federally mandated that employers protect employees from known workplace hazards. Still, over 600 employees were electrocuted in the workplace annually before the first edition of NFPA 70E was issued in 1979. Employers thought they knew how to protect them. In 2018, 160 employees were electrocuted in the workplace according to the Bureau of Labor Statistics (BLS). Forty years after the first NFPA 70E, these employers also thought they knew how to protect an employee from electrical hazards. I have written many articles, blogs, and handbooks which attempt to drive the point home that unless justified, an employee should not be put at risk of becoming a fatality. However, it seems just as many believe it should not be a requirement to shut equipment off before working on or near the electrical hazards present in that equipment. Rather than providing this highest level of protection, the decision to perform unjustified energized work typically (whether consciously considered or not) weighs the cost of an employee injury against the cost of shutting off equipment. Protect the worker by a less effect means, just hope that everything will be fine. Read my blog regarding three employers who felt they had it covered. It may also be beneficial to read my blog about what employers think they know. All of the fatalities involving electricity that I am aware of did not involve one task that was either infeasible or created a greater hazard if power had been removed. Fluorescent light ballasts were replaced. Motor starters repaired. Circuits were extended. Electrical enclosures were vacuumed out. Blown fuses were replaced. Conductors were stripped. Maintenance was performed on circuit-breakers. Residential HVAC units were repaired. Damaged receptacles were replaced. BLS data since 2011 shows 21% of electrical contact fatalities occur at or below 220 volts. Also, with each of these fatalities at least a portion of the electrical system was down for a period of time that was not decided by the employer. These tasks had no justification to be conducted while energized. Not that it should be a criterion, but almost all did not have a significant financial impact to the employer until the fatality occurred. None of the tasks involved more than a localized shut-down. Many of the tasks involved equipment or circuits that were already without electrical power. Other than some emergency lights, no other electrical equipment was on an electrical power back-up system because sudden loss of power to the equipment was not a concern. Almost all the tasks could be conducted in a matter of minutes not hours. Why were these employees fatally injured while at work when their employer knew that they would be exposed to known hazards? A major problem with unjustified energized electrical work is that it typically means that only select requirements (if any) are implemented for protecting an employee from injury or death. The employer decided which electrical safety requirements to follow and which ones to ignore. Incorrectly chosen and ignored requirements can cause fatalities. In the over 30 years of being involved with electrical safety, I have no knowledge of any employee being fatally injured by electricity when electrical hazards were not present. There are two ways to reach that state. The first is not to have electrical hazards present in the electrical system from the start. The second way is to establish an electrically safe work condition (ESWC). Properly protecting an employee from electrical hazards while establishing an ESWC greatly minimizes their risk and exposure to the hazards. Establishing an ESWC also qualifies as justification for performing that portion of energized electrical work. Using a lesser level of protection as reasoning for permitting unjustified energized electrical work is willfully exposing the employee to undue electrical hazards. In those same 30 years of electrical safety, I am aware of many fatalities, injuries and damaged equipment under that condition. For more information on 70E, read my entire 70E blog series on Xchange. Additional information to help guide you through the understanding of safe work practices can be found in our latest "Safe Electrical Work Practices Online Training" series. Want to keep track of what is happening with the National Electrical Code® (NEC®)? Subscribe to the NEC Connect newsletter to stay informed of new content. The newsletter also includes NFPA 70E information such as my blogs. Next time: Employees at greater risk of an electrical injury. As all of us continue to navigate the evolving situation with COVID-19, NFPA remains committed to supporting you with the resources you need to minimize risk and help prevent loss, injuries, and death from fire, electrical, and other hazards. For information on NFPA's response to the coronavirus, please visit our webpage.

A Better Understanding of NFPA 70E: A Host Employer Has Some Responsibility for the Safety of a Contract Employee

I have written a few blogs about host and contractor employer responsibilities. Over the past year, I have pointed out many times that  NFPA 70E®, Standard for Electrical Safety in the Workplace® has minimum issues that need to be addressed between the two employers. NFPA 70E requires a documented meeting but does not detail exactly what should be documented. NFPA 70E refers to known electrical hazards but it really is how the contract employee will be protected from those hazards that should be addressed. A host employer is responsible for safety in their facility regardless of purpose of a visit. No one should violate the host's established safety procedures regardless of their employment status. A host employer is not given carte blanche to allow contract employees to willfully expose themselves to the risk of an injury or fatality. Host employers have been cited by OSHA for incidents involving contract employees. At the very least the host and contract employers should review each other's applicable safety procedures. They should then document how the contract employee will conduct the task. A host employer may find it hard to justify hiring a contract employer who has no safety policy, procedures or training for the task to be performed in their facility. It is also possible that the contract employer must educate, train and document what is to occur due to lack of a host employer safety policy. A consensus should be reached on how to educate and train contract employees. This must occur before an employer begins the task. If it is not documented, it did not happen. I pulled up the BLS database for fatal occupational injuries incurred by contracted workers (2011-2017) to provide some data to illustrate the need for a host and contract employer to be in the same ball park. During this time there were 1,049 fatalities, including 440 contract employees, from exposure to electricity in all occupations. I expect that an employee is either working for a host (employer) or a contract employer. A simplistic view with all things being equal would be a 50/50 split if there was an equal number of employees. Contract employees account for 42% of all contact fatalities. Contract workers in the database are not limited to those in the electrical industry. Employees from cleaning services, HVAC, plumbing, groundskeeping, and other non-electrical trades are included. The following charts show the percentage of contact fatalities attributed to contracted workers compared to all other workers. Note that fatalities due to >220 volts may be included within the other three sub-categories.   From this data, it seems as if the contract employee is not fully aware of the distribution system or equipment at the host's site when performing an assigned task. This unfamiliarity results in contract employees accounting for a higher percentage of building wiring and switchboard, switch and fuse fatalities than for all contact fatalities. It could also be the reason behind the slightly higher percentage of contract electrician fatalities. The minor rise in >220 volt contact fatalities may be due to contract employees being exposed to higher voltages than seen while performing typical tasks. Contract employee fatalities due to contact with powerlines is consistent with the overall contact fatalities. Host employers may be taking a hands-off attitude with electrical safety when using a contact employer. Host employers may be hiring contract employers without implementing a safety program with them. Host employers may not be verifying that a qualified or a properly trained unqualified contract employee is assigned the task. The contract employer may not be enforcing their own safety protocols while at a host employer facility. The contact employer may not be ensuring that an employee is qualified or trained for the specific task to be conducted and to recognize the electrical hazards associated with the host's specific equipment. A contract employer must address the safety of their own employees regardless of the work location and assigned task whether it is electrical or not. A host employer is not only responsible for the safety of their own employees but also contract employees from any trade. A host may assume that a contract employer has a well-developed and documented electrical safety program (ESP) and that only qualified or trained contract employees will be assigned work. The host may assume that the contract employer's ESP addresses issues within the host's facility. We all know about assumptions. When it comes to electrical safety and keeping an employee alive or uninjured, an assumption does not provide the correct answer. A host and contract employer must be sure and it should be documented. For more information on 70E, read my entire 70E blog series on Xchange. Want to keep track of what is happening with the National Electrical Code® (NEC®)? Subscribe to the NEC Connect newsletterto stay informed of new content. The newsletter also includes NFPA 70E information such as my blogs. Next time: Putting an Employee's Life at Risk for No Reason
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