AUTHOR: Christopher Coache

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A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program (Part 5 – Risk Assessments)

NFPA 70E®, Standard for Electrical Safety in the Workplace® Section 110.5(H) requires that a risk assessment procedure be developed as part of an electrical safety program (ESP). NFPA 70E is not a how-to manual for detailing a risk assessment procedure. It is also not appropriate for training an employee how to conduct the assessment. 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. Section 110.5(H) requires a minimum of three things to be addressed and documented before any employee begins a task. The risk assessment procedure must detail the process that will be used to: identify hazards assess risks implement the hierarchy of risk controls Consistency is important when conducting risk assessments. Without it an employee conducting an assessment may tolerate a risk level that is not acceptable, ignore hazards that have been previously recognized, or improperly apply the hierarchy of risk controls. Training an employee to follow NFPA 70E Section 110.5(H) rather than your documented procedure will introduce such unsafe practices. Identify Hazards – NFPA 70E defines an electrical hazard as a dangerous condition such that contact or equipment failure can result in electric shock, arc flash burn, thermal burn, or arc blast injury. The two hazards (shock and arc-flash) currently covered by NFPA 70E are easily recognizable. The potential for an electrical shock typically at starts at 50 volts. An arc-flash burn begins at 1.2 cal/cm2. Contact burns can occur at temperatures as low as 44°C (110°F) if the contact is prolonged and as quick as a second above 80°C (186°F).  There currently is no consensus on what an arc-blast hazard is. NFPA 70E does not specify where any of these hazards exist. It is the role of the ESP to cover how equipment is evaluated to determine if these hazards are present during any task performed on equipment. Assess Risks - Human factors are generally recognized as being among the leading causes of injury and the potential for human error must be addressed in a risk assessment. This takes knowledge not only of the assigned task but also the location of the task, the equipment to be worked on, the tools to be used, competency of the employee assigned, and other issues. Working above a piece of equipment provides an opportunity for items to be dropped into ventilation openings or for an employee to choose to stand on the lower equipment rather than use an appropriate platform. Maybe an employee could confuse a Category I meter for a Category III meter because of a similar design. The risk assessment procedure should address what is to be considered a potential human error when conducting the specific task on the equipment in its installed location. Implement the Hierarchy of Risk Controls - The hierarchy of risk controls must also be addressed. It is beneficial to include a requirement for a risk assessment prior to purchasing or installing equipment to achieve the maximum benefit of the hierarchy. For installed equipment, requiring the assessment to retroactively apply the hierarchy to mitigate risks before the same task is performed again can increase workplace safety. The risk assessment procedure must require that elimination be the first control considered when planning a task. It must address why elimination was not used or required before applying other controls including personal protective equipment (PPE). Not having a documented procedure for conducting risk assessments is dangerous. Acceptable and unacceptable risks will vary. Electrical hazards will not be properly addressed. The use of PPE as the sole means of protecting employees will become commonplace. Inconsistency in risk assessments could put an employee at a higher risk of injury when conducting the same task on different equipment. Make sure a documented risk assessment procedure is part of your ESP and is used for every risk assessment.
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A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program (Part 4 – Lockout)

Does your electrical safety program (ESP) lockout program require that employees follow NFPA 70E®, Standard for Electrical Safety in the Workplace® Article 120? That ESP does not comply with NFPA 70E and employees are being improperly trained if it does. NFPA 70E requires that a lockout program be established and procedures to be developed. It provides requirements that must be addressed but does not provide a procedure for any specific equipment lockout. A lockout program in the ESP must comply with the minimum NFPA 70E requirements even if it refers to an employer’s lockout program. NFPA 70E cannot detail the requirements referenced in Article 120. It is not typical for every employee to have the same experience or training. Does the documented procedure cater to the least experienced or a higher level? The lockout procedure must be applicable to the experience and training of the employee and the conditions in the workplace. It is probable that different lockout conditions are encountered at various locations in the workplace. A mechanical lockout procedure might be different than an electrical one. It is possible for a basic lockout procedure to be developed and a standardized procedure mitigates the potential for human error. A specific lockout procedure could be necessary for a given piece of equipment which in turn requires additional training. Equipment installed before the NEC requirement for a permanent locking means could require additional locking mechanisms which alter the basic procedure. The program must address the use of simple and complex lockout procedures. An ESP could permit a contractor to use their own lockout procedure or contractors could be trained on the facility lockout program. Whose program will be followed and who is responsible for training employees affected by a different lockout procedure? If contractor procedures are permitted, an employee must be assigned to review those procedures to determine that safety standards of the facility are being met. Without a review, it is possible that the contractor does not have one, or that their program is less stringent than the facility’s lockout program. There could be situations when multiple contractors from various trades are affected further complicating the lockout procedure to be used and the training required.  Remember that the lockout process is only one necessary step in establishing an electrically safe work condition. A well-developed lockout program is not as simple as it appears. A generic lockout procedure could address most equipment. A detailed lockout procedure might be necessary to fill in the gaps when using it on specific equipment. Affected people might include facility employees as well as contract employees. Sections 110.5(M)(3) and (M)(4) require a documented annual audit of the lockout program and procedures including witnessing their use in the field.  The ESP must address more issues than this blog points out. Make sure your lockout program and its procedures cover all the bases.
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A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program (Part 3 - Procedures)

NFPA 70E®, Standard for Electrical Safety in the Workplace® requires that an electrical safety program (ESP) be established and documented. Section 110.5(G) requires that electrical safety procedures be developed, and Annex E provides guidance on things to include in a detailed procedure. It is the employer’s responsibility to document procedures applicable to the tasks performed by employees and to train employees on using those procedures. Procedures are required to be in place before an employee conducts a task. NFPA 70E does not contain safety procedures that an employee can be trained to follow. An ESP that directs an employee to follow NFPA 70E, Section 120.5 as the procedure for establishing an electrically safe work condition (ESWC) in the specific workplace violates the 110.5(G) requirement. Section 120.5 is the process necessary for establishing an ESWC. It is not a proper procedure for doing so on any specific piece of equipment. However, Section 120.5 is a good start of what to include in the procedure. Conceivably, a detailed procedure should be developed for any task an employee may perform on equipment. Using the ESWC as an example, the requirement to determine all possible sources of electrical supply to the specific equipment is not a procedure for a piece of equipment. An employee should not be required to determine power sources each time they work on the equipment. The procedure for Motor Starter #4 should direct them to Subpanel #2 to open Circuit Breaker #15. The procedure should say wait 15 minutes after removal of power to allow stored energy to dissipate rather than need to determine how to release stored electrical energy each time. Section 120.5(6) indicates that it is not appropriate to be used as a procedure; “apply lockout/tagout devices in accordance with a documented and established procedure.” This is often a separate, detailed procedure rather than being part of the ESWC procedure. The remaining ESWC requirements need to be detailed for the specific equipment. Correct your ESP if it depends on employees using NFPA 70E as the documented procedure for establishing an ESWC or for any other task. Just documenting a procedure is not enough. It is beneficial to try out a new procedure on the equipment to identify missing steps, expose shortcomings, determine necessary tools, or reveal improvements before it is applied by an employee in the field. Once completed, employees must be trained to understand and use the procedure. Although the EMP must include regular auditing of a procedure (Sections 120.5(M)(2) and 120.5(M)3)), employees should be encouraged to suggest improvements to the procedure anytime they find the procedure lacking. The ESP principles that are used as the basis for procedures typically do not change. A procedure should not be as rigid. Increased electrical safety depends on continuous improvement throughout the entire ESP. Do not let your ESP become stagnant.

A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program (Part 2 - Principles)

May is Electrical Safety Month which is a good time to review your company’s Electrical Safety Program (ESP). Electrical safety does not start with the employees, it starts with management before the first employee steps into a facility to conduct any task. It is impossible to properly train employees in electrical safety in any facility without it. There can be no improvement in electrical safety without a well-established and documented ESP. Management must first determine central safety principles when setting up the program. Section 110.5(E) of NFPA 70E®, Standard for Electrical Safety in the Workplace® requires that the principles be identified. What is a principle? One definition of the term is a fundamental, primary, or general law or truth from which others are derived. This is perhaps the best definition of how the term should be applied in NFPA 70E. Management must commit to protecting employees by establishing principles. Principles are the broad statements of how electrical safety will be handled within the facility. NFPA 70E, Annex E includes some things that could be used as a safety principle. Principles could include the following. Achieving a zero-injury facility Inspecting and evaluating all electrical equipment Maintaining electrical equipment’s integrity Assessing employee abilities Documenting procedures Planning every job Identifying electrical hazards and reducing the associated risk Anticipating unexpected events before tasks are started Establishing an electrically safe work condition as the primary safe work procedure Protecting employees from recognized electrical hazards Using the right tools for the job Addressing all employee safety concerns Auditing the principles, policies, and procedures NFPA 70E does not set principles. It is the employer’s responsibility to do so for their facility. Principles must be documented to form the basis for detailed safe work procedures. For example, a detailed procedure would address what is involved under the principle of planning every job or task. Care should be taken when setting principles since they are typically not changed by the nature of being a safety principle. The principles must be considered whenever a policy or procedure is developed. Most importantly, management must allow employees to work under the documented principles to advance safety in the workplace.
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A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program

Are employees trained on the requirements of NFPA 70E®, Standard for Electrical Safety in the Workplace® or are they trained on your Electrical Safety Program (ESP) requirements which are based on NFPA 70E? Someone must be trained on the NFPA 70E requirements to assure that the ESP complies. But an employee who gets exposed to an electrical hazard during the workday does not need to be specifically trained on NFPA 70E. It is your documented ESP that provides direction to each employee on what is necessary to protect themselves from the electrical hazards in your specific workplace. NFPA 70E is the 10,000-foot view for developing an ESP. Protecting employees from electrical hazards involves more than NFPA 70E details. The employer is required to establish procedures, conduct risk assessments, protect employees from electrical hazards, and provide appropriate PPE. However, NFPA 70E does not detail how to achieve this in a specific workplace. It is the employer’s responsibility develop an overall ESP that directs activity appropriate to the risk associated with electrical hazards in the workplace. An employer must establish, document, and implement safety-related work practices and procedures. Those are the procedures and practices that an employee must be trained to follow. An ESP that requires that employees follow NFPA 70E for electrical safety issues is not an established ESP. Do you have the required ESP? Does that ESP include what NFPA 70E requires? Most people consider Article 130 to be the most important NFPA 70E article. I don’t believe that for most employees. Articles 105 and 110 are perhaps the most important since that is where the responsibility to protect employees resides. An employer must be committed to improving electrical safety no matter where an employee works. Overriding principles to protect employees must be established. Management must provide guidelines for protecting employees. To establish safety-related practices and procedures, the employer must understand the electrical hazards and risks their employees face as during assigned daily tasks. This is the first of a twelve-part series that will run through Section 110.5, Electrical Safety Program. Section 110.1 sets the goal of an ESP. The requirement is synonymous with the OSHA requirement that employees not be exposed to known hazards. This requires that the ESP include the priority be that at a hazard be eliminated before an employee is exposed to it. Under NFPA 70E, this means eliminating the hazard by design, installation, or an electrically safe work condition. Without a statement in the ESP and commitment to achieve elimination, exposure to hazards will be considered part of remaining employed. It will lead to improper justification for energized work. Several of my blogs have discussed that an authorization to work energized due additional hazards, increased risk, or infeasibility is often unwarranted. Just having the words in the ESP do not provide safety. Employees are occasionally directed to expose themselves to hazards as a matter of expediency, revenue, or pressure regardless of the ESP. Employees must know that management stands behind the policy regardless of the situation. Does management allow an employee to follow the documented ESP and remove hazards so that they increase the likelihood of returning home unharmed?
Conceptual design

A Better Understanding of NFPA 70E: Correctly Using the Incident Energy Analysis and Arc-Flash PPE Category Methods

The 2009 Edition of NFPA 70E®, Standard for Electrical Safety in the Workplace® clearly stated that one of the two provided methods be used for the selection of personal protective equipment (PPE) when an arc-flash hazard was present. The two methods of choice are the arc-flash PPE category method and incident energy analysis method. Although not as plainly stated before 2009, it has been required to use only one method on a piece of equipment for twenty years. Why do some NFPA 70E users ask how to combine PPE category method requirements with an incident energy analysis? A few editions ago, the public expressed concern regarding the phrase, one of the following methods shall be used. Apparently, this phrase did not fully convey that only one method could be used on a piece of equipment, or that the two methods could not be combined. So, the requirement was revised to include the statement, either, but not both methods shall be permitted to be used on the same piece of equipment. This was to clarify that one does not include both methods. I am not sure how the words one, either, and not both are being misunderstood. Also, other requirements state not to use both methods. Section 130.7(C)(15) states its requirements apply when the arc flash PPE category method is used and that it is not permitted to specify an arc flash PPE category based on the results of an incident energy analysis. Each of these were added to further clarify the misunderstanding. However, the question was asked once again last week. When shown these specific requirements prohibiting the use of both methods, their response led me to believe that an untrained or unqualified person is conducting the assessment. It is often revealed that the person has not read NFPA 70E or worse do not possess a copy. Often, a computer program has been used to calculate the incident energy and the person has been supplied with a copy of the PPE Category Table to specify PPE. Sometimes, that program automatically and incorrectly converted the incident energy into a PPE Category. These revelations should be troubling because the employer and the person assigned to do the risk assessments are putting employees at risk of injury. Make sure that you have been properly trained and fully understand the requirements when conducting assessments. It is also necessary to have access to an entire NFPA 70E to properly apply the requirements since there is more to electrical safety than an using a table. Consider that these people asking this question are not the only ones who have misapplied the requirements. Confirm that the requirements have been properly applied in your workplace. If not, correct the issue before it is too late. NFPA 70E and the NEC are now available in NFPA LiNK™, the association’s information delivery platform with NFPA codes and standards, supplementary content, and visual aids for building, electrical, and life safety professionals and practitioners. Learn more at nfpa.org/LiNK.
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