AUTHOR: Christopher Coache

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A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program (Part 10 – Incident Investigations)

Does an employee get punished when they make a mistake? Are they afraid of notifying a supervisor when something goes wrong? Is an employee who points out a safety issue sent back to work without having the issue resolved? One NFPA 70E®, Standard for Electrical Safety in the Workplace® requirement that is occasionally not well addressed in an electrical safety program (ESP) is the incident investigation requirement in Section 110.5(J). The reason is that with electricity no incident should be treated as minor. Every 120-volt electric shock is a brush with death. However, electric shocks, minor burns, and unjustified live work are not reported until a greater injury occurs. Investigations required by NFPA 70E are not for the purpose of assigning blame. They are to improve employee safety. An ESP must include the details of how, why, when and what happens with incident investigations. Incident investigations should not be limited to those where an employee is injured to the point where medical attention is required. An electric current’s path through a human body affects each person differently. An employee with a pacemaker may have a problem days after an incident. Employees should be trained and encouraged to report any dangerous situation as well as any injury regardless of the cause or severity. The investigation could reveal that the ESP, work procedures, protective equipment, training, or test instruments require revision to prevent a future occurrence, injury, or death. Without an investigation into what occurred there is possibility that a fatality could happen the next time that same task is conducted. The employee could have received an electric shock due to unjustified energized work, insufficient training, damaged equipment, wrong qualification for the task, inappropriate personal protective equipment, flawed job planning, or errors in the procedure. But none of that will matter unless this near-death situation is reported and the cause rectified. Employers and employees must accept their responsibilities and work together to find the cause of any incident. Although electrical incidents are often the result of human error, an employee does not intentionally initiate an electrical incident. However, it is important that an enforcement program be established for willful violations of safety regulations. The ESP must assign responsibility for each step in the incident investigation. The procedure must not only cover what is required as part of an investigation but the training for the investigator. The incident and investigation must be documented. There can be no improvement in safety without a final step requiring that necessary changes be incorporated. If it is determined that training was the culprit, modification of the training program could include increasing the frequency of training or adding follow-up verification of compliance. The ESP must address who is be responsible for incorporating the improvements. Do not use incident investigations as means to punish but to gain knowledge and to educate. Involving employees in the process gives them a personal stake in improving workplace safety. For the ESP to work, employers and employees must cooperate and trust that safely returning home each day is paramount in the workplace. 

A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program (Part 9 – Safety Planning)

Section 110.5(I) in NFPA 70E®, Standard for Electrical Safety in the Workplace® requires that an electrical safety program (ESP) include that both a job safety plan and job briefing be completed before a task is performed. A safety plan will vary by task and equipment. The briefing will vary based on the plan. An employee should not be directed to follow NFPA 70E when conducting the planning and briefing. NFPA 70E addresses what is required to be addressed but does not detail what is necessary for a specific task. The ESP will contain specifics on what is necessary in a facility. A job safety plan must be completed by a qualified person. The ESP will detail the qualification and training necessary to complete the documented plan. A plan must include details of the equipment and task, results of the risk assessments, and the documented procedures and the equipment necessary to conduct the task. The job planning procedure should address if the person planning the job is solely responsible or if other employees will provide information needed to complete the plan. The plan should identify who and what qualifications are necessary to conduct the proposed task. The plan will identify other employees possibly affected by the work. The documented planning procedure must address other concerns specific to the facility, task, and equipment. The ESP must require that a job briefing be held before the task begins. The documented procedure should address when and if the employee conducting the task may conduct their own briefing. Perhaps, a lead employee is responsible for giving the briefing for any task under their purview regardless of the one assigned the task. The ESP should address whether the person conducting the briefing has the authority to alter the plan or if the person who set the plan needs to approve it. How are safety concerns raised during the briefing addressed and documented? If anything changes once the task has begun, the procedure must address how a change in scope must halt work until the planning and briefing address the change. It is the documented procedure not NFPA 70E that will provide these necessary details. A well-developed procedure for job safety planning and briefing is crucial. These are typically the last opportunities for anyone to address safety before a task has begun. Planning and briefing may not only expose shortcomings but also introduce improvements for the planning procedure or the assigned task. Make sure your ESP contains the details necessary to protect employees from electrical hazards.
Neon sign

A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program (Part 8 - Awareness)

Some electrical safety requirements in NFPA 70E®, Standard for Electrical Safety in the Workplace® are overarching concepts. Section 110.5(D) is one such requirement. An electrical safety program (ESP) must be designed to instill awareness and self-discipline in employees. By learning awareness and self-discipline, employees will begin to accept that their actions are often among the primary causes of injuries. The employer must develop policies and procedures that flesh out the requirement to achieve this safety goal. Training employees to be vigilant of the electrical hazards lurking in the workplace is difficult. There are things that every employee should know for their safety. For example, recognizing when a flexible cord is damaged is a skill everyone can benefit from. An employee operating an overhead electric crane needs focused training to know specific hazards and warning signs that may be present. An ESP must contain policies, procedures, and a training program to address this. Having awareness of potential hazards serves no purpose if there is no awareness on how to avoid the hazard. Requiring an employee to conduct a task that exposes them to a reported hazard or to a hazard that they are not trained to avoid will quickly undermine a well-intentioned ESP. Awareness also means awareness of others around oneself. Employees need to be aware of how their work affects the safety of others. Employees should be taught to help others be aware of hazards and inappropriate behavior that puts someone at risk.  Management must be committed to encouraging this awareness. Self-discipline, the other half of the requirement, is also difficult to teach. The ESP program must incorporate policies that encourage and remind employees that safety starts with them. Requiring and allowing an employee to choose safety is the first step. They are the only one who knows if they are wearing meltable undergarments. They can recognize that they are suffering fatigue after six hours into a double shift or are suffering from an illness that puts them at risk. They are solely responsible for properly donning personal protective equipment. They must be taught that their action or inaction will decide the outcome of day. This takes commitment from management. An employee who has the awareness and self-discipline to report that proper tools are not present onsite must not be reprimanded for waiting to be given the appropriate equipment nor should the task be given to an employee willing to risk safety.  Teaching by example goes a long way in complying with these requirements but first it takes a well-developed ESP to lay the foundation for electrical safety. As a safe work practice standard, NFPA 70E does not detail how to instill these principles in an employee. Not all training methods or concepts are appropriate for every workplace or every employee. The employer must decide how to incorporate awareness and self-discipline into an ESP and the best way to pass that information to their employees. It is the ESP policies and procedures that employees will be trained to follow not the NFPA 70E requirement for awareness and self-discipline.
Destroyed monitor

A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program (Part 7 – Equipment Condition)

NFPA 70E®, Standard for Electrical Safety in the Workplace® does not detail the policies and procedures that must be in an electrical safety program (ESP). However, it is not possible to comply with NFPA 70E without filling in the details. Section 110.5(C) requires that the condition of maintenance of equipment to be part of the ESP. Condition of maintenance is the state of the electrical equipment considering the manufacturers’ instructions, manufacturers’ recommendations, and applicable industry codes, standards, and recommended practices. Normal operation is permitted when the equipment is properly installed, properly maintained, used in accordance with instructions, equipment doors are closed and secured, all equipment covers are in place and secured, and there is no evidence of impending failure. Operating condition and condition of maintenance are two different things. Maintenance is only part of the operating condition. The ESP will detail what the acceptable condition of maintenance is any piece of equipment. Equipment that is under normal operating conditions is considered to be free from exposed hazards whereas equipment that is not is rightfully considered a risk for electrical injuries. All employees should be able to determine that the equipment they are interacting with is under normal operating conditions. The condition of maintenance is often not within an equipment operator’s knowledge base. With all the variables, NFPA 70E does not specify what is acceptable or how to assess condition of maintenance. There are thousands of pieces of equipment from hundreds of manufacturers with their own maintenance requirements, used in different environments, under different loads, and subject to different types of damage throughout a facility. Determining an appropriate equipment condition is more detailed than many think. It might not be realistic to require that equipment be kept clean. Such a requirement would dictate constant, unnecessary cleaning of a motor designed to safely operate in a dust atmosphere. Equipment might have a different acceptable condition. A grease smudge on a switch might not warrant the same response as a transformer covered in debris. Equipment that has an operator or is used every day could be evaluated by the employee using it. That employee must be trained to determine the equipment condition and know what to do if the condition is unacceptable. There are many pieces of equipment that are not often viewed by someone. An employee might be assigned to inspect that equipment. The interval might vary. For example, equipment in a loading dock might need more frequent inspection and maintenance than equipment in an electrical closet. Maintenance personnel might be solely responsible for assigning the condition of maintenance of all equipment that any employee interacts with or relies on for electrical safety. This takes an understanding of the definition of condition of maintenance and the ESPs definition of an acceptable maintenance condition. NFPA 70E is a safe work practice standard that does not provide the details necessary for assessing the condition of maintenance of equipment. In the United States of America, equipment that is under normal operating conditions is not considered a risk for exposure to electrical hazards. The condition of equipment and an employee’s ability to recognize when it is no longer acceptable are important aspects of the ESP. The ESP policies and procedures must detail the equipment condition assessment method as well as what is an acceptable condition to advance safety in the workplace.

A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program (Part 6 - Inspections)

NFPA 70E®, Standard for Electrical Safety in the Workplace® has requirements for what should be included in an electrical safety program (ESP) but does not provide details. The requirement in Section 110.5(B) to inspect electrical equipment is one where it is the employer’s responsibility to fill in the gaps. A properly documented ESP does not exist until that has been accomplished. The policies and procedures in your ESP are what employees must be trained to follow. The ESP must address the inspection of newly installed or modified equipment. Does your ESP have a way to assign this responsibility? A newly hired, residential electrician may not be the appropriate inspector for a smelting facility. The local electrical inspector often does not inspect equipment that falls under NFPA 70E. Equipment is installed, maintained, repaired, and replaced by an employee or an outside contractor. The responsible person will need to not only determine that an installation meets the applicable manufacturer requirements but also those of applicable standards. This is not limited to electrical standards since things like improperly installed pressure systems in electrical equipment may affect safety. What are the ESP policies and procedures for these inspections? An ESP that requires that equipment be verified as complying with the NEC is not enough. Electrical system and equipment compliance with the NEC is often only determined during building construction. The NEC does not address maintenance nor is internal electrical circuits part of the NEC. However, technicians maintaining motor control equipment must know the applicable NEC requirements. A contracted HVAC technician may be required to provide documentation that their work complies with applicable standards and codes, as well as the facilities requirements. Is their work inspected by a facility employee? Who is authorized to inspect repairs on custom production line equipment? It might not be desirable for the employee performing the work to also perform the inspection. The ESP must address not only these issues but also the training of the employee conducting inspections. The ESP might permit some types of electrical work to be completed without additional inspection. Do employees know which specific equipment is permitted to be energized before or without the additional inspection? A contractor may not follow the same safety protocol. Perhaps, it is not the equipment but the task that directs an inspection before energization. The ESP must address how to document all of this and what is to happen with the results. A requirement for the inspector to evaluate alternate installation methods may provide a means to mitigate hazards or repeated exposures. However, this most likely will not happen without a statement to do so in the ESP.  Proper installation, repair, and modification of electrical equipment play a major role in protecting every employee from electrical hazards. Inspection to determine that fact is a requirement in NFPA 70E. NFPA 70E is a safe work practice standard that is not appropriate to be used as the procedure for equipment inspection. It is critical to train an employee on inspection policies and procedures contained in the documented ESP.
Person on a tightrope

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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