AUTHOR: Derek Vigstol

Electrical worker

OSHA and NFPA 70E: A History of Powerful Protection for Employees on the Job

NFPA 70E®, Standard for Electrical Safety in the Workplace® and OSHA have had a long history of working together. In fact, OSHA is a large part of why NFPA 70E even exists. In the late 1970s, it became apparent that the hard line that OSHA had taken on work exposing employees to hazards needed some modifications when it came to electrical work. However, OSHA realized that as fast as the electrical industry was changing, it would be very difficult for the Occupational Safety and Health Act to keep up with changing trends. Because of this, OSHA decided that an organization like NFPA, with a long history of developing codes and standards for the fire, life safety, and electrical safety worlds, would be a great fit for developing a standard on electrical safety when it came to employees in the workplace. Today that history continues as NFPA celebrates 125 years of helping protect the world from these hazards. This is how OSHA became the “what we have to do” and NFPA 70E became the “how we accomplish what OSHA requires.” I often am asked exactly how these two critical components of electrical safety in the workplace play off one another. Helping employers make heads or tails of these two separate but related entities is critical for the protection of employees especially in today’s world where electrical infrastructure and technology is evolving so rapidly. A firm understanding of this relationship is instrumental in an employer’s ability to keep up with the hazards present in this ever-expanding electrical landscape. First, we must examine exactly what the requirements around electrical safety are when it comes to OSHA. This involves a deep dive into OSHA standards. For this blog, we can limit our deep dive to two of the more important standards for electrical safety: 1910 for general industry and 1926 for construction workplaces. When it comes to electrical safety, we first need to understand that the general duty clause of OSHA requires an employer to provide their employees a place of employment that is free from known and recognized hazards. Then specific standards, such as 1910 subpart S give shape to OSHA’s electrical safety requirements. 1910.331 lays out that subpart S requirements apply to both qualified and unqualified workers. This same section shows exactly what type of work is covered and what is not covered. This helps us understand exactly who will be following the requirements laid out in Subpart S. In 1910.333, we find that it requires safety related work practices to prevent electric shock or other injuries resulting from either direct or indirect electrical contacts. There is also a requirement that all live parts to which an employee might be exposed be placed in a deenergize state before the employee works on or near them. However, there are some exceptions for when the employer can demonstrate that deenergizing creates additional hazards or an increased risk to personnel or if they can demonstrate that deenergization is infeasible due to the equipment design or certain operational limitations. An example of infeasibility might be a task that requires a current reading to be taken - it needs the power on in order to make that measurement. For instances that fall under these two reasons for permitting energized work, OSHA also states that other safety related work practices must be used to protect employees who are going to be exposed to the electrical hazards involved with this type of work. So, where does it say in Subpart S what those work practices are? This is where NFPA 70E comes into the picture. The relationship of 70E to these two requirements in OSHA is critical. First, by requiring all energized parts to be placed in a deenergized state, we need a process for what that state looks like. This is what 70E refers to as an “electrically safe work condition.” Article 110 in NFPA 70E states that an electrically safe work condition shall not be established until all the requirements of Article 120 have been met. Section 120.5 spells out multiple requirements that must be met to accomplish an electrically safe condition to work on equipment. The important thing to remember is that the major steps here are to deenergize the circuit, implement provisions to prevent reenergization, and verify that the voltage has indeed been disconnected and apply any temporary grounds, if needed to prevent accidental reenergization or induced voltages. What do we do when we don't have a deenergized state? Again, OSHA doesn't spell out what safe electrical work practices employees must follow, and we find ourselves falling back on NFPA 70E to spell out what these work practices entail. In NFPA 70E, we find requirements performing risk assessments for both shock and arc flash hazards. The results of these assessments help employers and employees develop a plan for mitigating the risk to the employee during work. Risk being defined in NFPA 70E as the combination of likelihood of occurrence and the severity of injury resulting from an incident. Once we have the results of the risk assessments, we can take the appropriate steps based on the hierarchy of risk control methods to reduce risk to a more acceptable level. It is important to note that this may entail employees selecting and wearing the appropriate personal protective equipment (PPE) level based on the severity of the hazard involved. However, as the hierarchy shows, PPE must be used as a last resort. On the construction side, we find OSHA’s electrical safety requirements in 1926 subpart K. Like 1910.333, 1926 requires employers to prohibit work in such a proximity to electric circuit parts such that an employee could come in contact with these parts unless the employee is protected from shock by deenergization or by effective guarding such as insulation. However, who defines what this proximity entails? Once again, we look to NFPA 70E for guidance. 70E spells out what this proximity is since Article 100 defines the limited approach boundary as the distance from exposed energized parts at which a shock hazard exists and the restricted approach boundary as the distance from live parts at which an increased likelihood of shock exists. The restricted approach boundary is thereby the distance at which qualified people must be insulated from the shock hazard and the limited approach boundary is the distance at which 70E requires an electrically safe work condition, unless one cannot be established. This relationship between what we must do and how we do it has been an area of discussion almost since the beginning of OSHA. Having a firm understanding is paramount to keeping employees safe. This is one of the reasons that I am so looking forward to hearing about how this relationship has developed over the years when NFPA kicks off our 125th Anniversary Conference Series on May 18 with an entire day dedicated to electrical safety! One of the sessions during our “Empowering Electrical Design, Installation, and Safety” program centers around using 70E to help stay compliant with OSHA requirements. It’s being presented by none other than the retired OSHA Director of Engineering Standards, Mr. David Wallis. You won’t want to miss this session! Join us as Mr. Wallis explains the development of what we now have come to expect as a certain level of electrical safety in the workplace. Learn more about our one-of-a-kind 125th anniversary conference series and register today to participate in the full-day electrical program on May 18. I look forward to seeing you there!
Building under construction

Protecting Electrical Workers on Building Under Construction Sites

Electrical safety on construction sites is a topic that is being talked about more and more these days. So when I was asked to write about it, the safety nerd in me immediately started rattling off OSHA 1926 standards and quoting NFPA 70E requirements in my head. Then I remembered back to the days when I was probably more at home in a building under construction than I was in my own living room. Getting all nostalgic reminded me to put my safety nerd back in the cage for a second and return to this world where I now help keep my brothers and sisters on job sites safe from electrical hazards. For anyone who has spent the better part of the last 30 years on or around a construction site, it probably comes as no surprise when I say that enforcement of safety rules has become a priority on many of these sites around the world. For instance, the mindset has shifted from wearing hard hats only when exposed to an overhead hazard of falling objects to the mentality of now putting it on the second we step out of our vehicles. Safety glasses and dust masks soon followed. Driving all of this was the organization that was created to improve safety for the worker, OSHA. It didn’t take long for the larger general contractors to make safety a way of life on their sites, which was great for the crews working on the big projects, but what about the smaller ones? How do we address safety on these sites? As is human nature, when a worker has been operating the same way for the last 20 years, it is highly unlikely that their behavior will change without some level of external motivation. For me, there was no shortage of job superintendents and foremen on site to remind me of my mistakes and eventually it became second nature. Safety and PPE on construction sites act no differently than for example, wearing seatbelts in a car. Yet, there are still people who have are not motivated enough to seek safety as a culture on their own. Recently, I attended a virtual conference where electrical safety was the overall theme and one thing that kept popping up was a rules-based approach versus a skills-based approach to safety. It quickly became apparent to me that what we have here is a rules-based approach. In other words, we teach people how to do the job and then once they know the job, we throw a book of rules at them and say, “Here, follow these!” The challenge begins when the individual has potentially already picked up some bad habits. Without a force looking over his/her shoulder to ensure they follow the rules, they are likely to continue the same bad behavior. A friend recently said to me, “We can write all the requirements for safety that we want, and they can be the best safety practices for any given task, but if the worker doesn’t follow them, well, then we failed in our attempt to protect the worker.” Just about everything you and I do at this very moment in time was learned by someone showing us how to do it. With a skills-based approach, the worker only learns how to do the task with all the safety requirements in place. In other words, this approach creates a work force where the safe work practices are how they learn to become a carpenter, plumber, or electrician in the first place. In areas where this approach has been the norm, the statistics show much fewer injuries and fatalities. For example, at that same electrical safety conference, discussions revolved around multiple presentations that showed how the UK has a significantly lower number of occupational fatalities from electricity. The good news is that the winds of change are upon us here in the US. Many schools are beginning to teach safety as a skill from day one now, and we are starting to see the impact in the workforce. To see these results though we need to focus on the growing gap in injuries between the various age demographics. A quick search of the U.S. Bureau of Labor Statistics data tables shows that workers between the age of 20-24 accounted for 409 electrical injuries while the 45-54 age demographic accounted for 343 injuries back in 1999. 20 years later in 2019, these numbers have shifted to 300 and 610 injuries respectively for the same age groups. In both tables, the percentage of the workforce that each age group makes up remained about the same. Therefore, we can see that the gradual integration of electrical safety into worker training on the front end is having an impact and making the next generation of workers better equipped to avoid being injured on the job. However, simply because we can see a trend in the numbers that suggests things are working, does not in any way imply that we can back off the intensity with which we promote electrical safety. In fact, as the BLS data for 2019 illustrates, there are still 1,900 injuries resulting from exposure to electricity and that is too many. Things might be getting better, but we still have a very long way to go. We can and will get better but only if we approach workplace safety from all sides including requirements, education, and enforcement. Through this type of approach, our construction sites will naturally grow to be a safer work environment for all involved. Workers will be better equipped to recognize hazards and avoid the associated risks. Not only will this reduce the liability that many contractors face, but it will also improve productivity and help contractors avoid costly down time. A job site with fewer injuries that finishes on or ahead of schedule and with no money paid out due to injuries or worse, is a job site we can all be proud of. If you want to learn more about how data is informing safety practices and other related topics, you won’t want to miss NFPA’s upcoming 125th Conference series. This one-of-a-kind educational series features 10 one-day programs for building, electrical, and life safety professionals and practitioners and focuses on the topics you care most about. Engage in informative education sessions, get innovative content, and participate in industry roundtable discussions, networking opportunities, live chat sessions, exhibitor demonstrations, and more. It kicks off on May 18 with a one-day Electrical Program aimed at issues related to design and installation, new and emerging technology, and workplace safety in the electrical landscape. Sign up to get updates on the electrical program by visiting nfpa.org/conference. We look forward to seeing you there! Remember, it’s a big world, let’s protect it together!

Latest NFPA Podcast Introduces Doctor Team Dedicated to the Research and Care of Patients with Electrical Injuries

As electrical professionals, I think we have all, at one point in our career, heard the somewhat tongue-in-cheek warning about electrical hazards that goes something along the lines of, “Warning: Electricity hurts and it hurts the whole time you are dying!” I use the phrase, “somewhat tongue-in-cheek” because many of the images floating around on various social media channels tend to post this as satire rooted in a truth that we in the electrical industry know all too well. However, the fact is, most electrical injuries do not result in death. Death is a real possibility and more likely with electrical hazards than most other hazards, but a lot of workers who experience shock and arc flash incidents do survive. Many, though, often find themselves wishing they hadn’t, and nothing can prepare the individual for what comes next. That’s why, during the recovery process, medical professionals aim to treat the whole individual and not simply the injury. Recently, I had the opportunity to sit down (virtually) with a team of doctors who head up the Chicago Electrical Trauma Rehabilitation Institute, or CETRI for short. The goal of this discussion was for me to fully understand what goes into helping an individual recover after such a drastic event in their lives. Among my esteemed guests are Dr. Raphael Lee, a surgeon who has spent a lot of his career dealing with and researching, electrical injuries, and who has contributed many books and papers on what it takes to recover from an injury. I was also joined by Dr. Neil Pliskin, who specializes in neuropsychology and helps a patient recover not just from the physical injury but address the damage that has occurred psychologically. The third member of our panel is Dr. David Weiss. Dr. Weiss specializes in the physical rehabilitation of the patient often after the patient has left the hospital.  I could go on and on about what I learned in this conversation, but I could never explain it as well as they can. That’s why I’m pleased to invite you to listen to our conversation in the latest episode of The NFPA Podcast series, The Mysteries of Electrical Injuries. With this week being National Burn Awareness Week, it seems only fitting to share this Podcast with the world! Understanding the process and the multi-disciplinary approach it takes to treat these patients really opened my eyes to the importance of what we do here at NFPA. Protecting people from electrical hazards is at the core of who we are. Whether it’s installation, workplace safety, or maintenance, our mission is to help make sure you never have to experience an electrical injury. It also helped me to reflect on NFPA’s slogan, “It’s a big world, let’s protect it together!” Through this experience, I have come to see how this is not just some catchy phrase that accompanies the NFPA logo, but rather, it’s a guiding light for my career.  When we interact with people like the team from CETRI, it really becomes a way of life! Listen to the Podcast and share it with others you know. Inset photo: Drs. Lee, Pliskin, and Weiss take a moment out of their busy day to talk with clinical coordinator, Kyley McCollum.
Electrical workers

Electrical Safety the Focus of National Burn Awareness Week: NFPA Explains the All-Important Safety Relationship Between Energized Work, 70E, and OSHA

This week, February 7 – 13, marks National Burn Awareness Week, an annual event sponsored by the American Burn Association. This year’s focus is on raising awareness about being safe around electrical hazards. In fact, the theme is, “Electrical Safety from Amps to Zap (A to Z)!” While it probably comes as no surprise that NFPA promotes #NBAW since helping to eliminate loss of life and injury from fire, life safety, and electrical hazards is at the core of what we do (it’s our mission statement!), it is great to see electrical safety being brought into the conversation. I have no doubt that raising awareness of the hazards electricity can present in our homes and workplaces will help to make the world a safer place. As electrical professionals, we’re probably all aware of the fact that if we touch an exposed energized surface, it is going to hurt. If we touch the wrong exposed energized surface, we might not even get the chance to learn from our mistakes. However, in many conversations I have had over the years, it has become obvious that many are aware of the dangers, but maybe not so well versed on what comes into play before we choose to perform work that exposes us to an electrical hazard. Many folks I have spoken with still believe that energized work is fine, just throw on some PPE and you’re good to go! Of course, this means we must right then and there begin a conversation about what is actually required, both by NFPA 70E and OSHA. I love having this conversation because I feel as though we still have a tremendous amount of work to do in making the industry realize that we must only do energized work when it has to be done energized. After all, none of us want to find ourselves in the fight of our lives recovering from a shock or arc flash any time soon. In fact this reminds me of a conversation that I had with someone recently where they shared a story about how they were asked to work on a motor control center while energized even though all loads that the MCC supplied where not in operation at the time because it was a scheduled maintenance day. As if this wasn’t bad enough, the response from many who he shared his story with was along the lines of … this is something only a trained electrician should be doing. Is it though? First and foremost, let’s dive into OSHA requirements to see if this is the case, being that OSHA is the law. OSHA standard 1910.333(a)(1) clearly states that live parts to which an employee will be exposed, must be deenergized before the work begins unless the employer can demonstrate that deenergizing: Introduces additional or increased hazards Is infeasible due to equipment design or operational limitations Equipment operating at less than 50V to ground need not be deenergized provided there are no additional risks for burn injuries or an explosion from electrical arcs. NFPA 70E reflects these requirements in Article 110. However, NFPA 70E provides a bit more guidance than what OSHA requires. This makes sense as OSHA is often described as the “What” and NFPA 70E is the “How” or in other words, OSHA is what you have to do and NFPA 70E contains work practices and information so that you can achieve what is required by OSHA. Let’s take a look at how NFPA 70E does this. First, the OSHA requirement states that live parts must be deenergized before work can begin. NFPA 70E goes a step further and defines when you must perform this deenergization and what the process is for ensuring that the equipment is maintained in a deenergized state. To do this, NFPA 70E defines what is called an “electrically safe work condition” or ESWC, as opposed to just saying “deenergized,” as an ESWC is a state in which not only has the power been removed, but steps have also been taken to ensure it won’t come on without our knowledge, and we have verified through an adequately rated test instrument that the voltage is at 0V. We also find section 110.3 which tells us when we must place equipment in an ESWC. However, unlike OSHA, which is rather vague in simply stating “before work begins,” NFPA 70E specifically defines two reasons why an ESWC must be established. Those reasons are: An employee will be within the limited approach boundary. An employee interacts with equipment in a manner that increases the likelihood of injury from arc flash, even with the covers on and doors shut. The limited approach boundary being the distance from exposed live parts at which a shock hazard exists. So, NFPA 70E is going beyond saying turn it off before you touch it. NFPA 70E requires an ESWC long before a worker will make physical contact with live parts. Then there is also the second item to consider. Certain tasks that find employees interacting with equipment pose a risk of causing an arc flash in addition to the shock hazard. Now, if these circuit parts are exposed, there is a good probability that the employee will be injured, however, they are already required to be placed in an ESWC due to the shock hazard. However, what about those tasks if the circuit parts are not exposed? In these instances, we must consider things like the physical condition of the equipment and how well this equipment has been maintained. Both are factors in how likely an employee is to be injured should there be an arc flash incident. If there is a likelihood of injury, then we must establish an ESWC. Lastly, there are times when establishing an electrically safe work condition simply is not possible or is not needed. These permitted reasons for performing energized work might sound a bit familiar. Energized work is permitted if the employer can demonstrate that deenergizing poses a greater hazard or increased risk, or, if deenergization is not feasible due to what the task is or the equipment design that makes it impossible to deenergize. There are also two other conditions which allow work on energized circuit parts due to the risk of injury being so low. One condition allows work on live parts operating at less than 50V, provided that there is no increased exposure to burns or explosions due to electrical arcs. The other condition is that the task represents the normal operation of equipment in a normal operating condition. This means operating the equipment in a manner that is its intended operation as designed by the manufacturer. For example, operation of the handle on a disconnecting means to a large industrial machine. However, this switch must be in a normal operating state which includes having been properly installed and maintained, used in accordance with manufacturer’s instructions, with all covers and doors closed and secure, and no evidence of impending failure. So, before we just jump in PPE and start performing work that could potentially result in injury, it is important that we understand the law when it comes to energized work. Keep in mind that this law was passed to keep employees from becoming another statistic in the long list of fatalities and injuries from shock and arc flash hazards on the job. Regardless of the law or what NFPA 70E requires, it just makes good sense to approach our work with the mentality that we won’t perform energized work unless we must. Energized work puts us at risk but also risks damaging the equipment being worked on. Why take chances at getting hurt or ruining the electrical infrastructure of a building unless it is the only way? Afterall, is any job worth dying for in order to save time or increase profits? In the future if we can all remember to deenergize unless we can’t, and follow the guidance of OSHA and NFPA 70E, we will eventually see a day where these types of injuries are just a distant memory. For more information about 70E, visit the NFPA electrical safety webpage. Additional information about Burn Awareness Week can be found by visiting the American Burn Association’s campaign page.
Electrical safety audit

Year End Wrap Up: Performing an Electrical Safety Program Audit to Help Protect Employees in the New Year

As we enter this time of year where reflection seems to be on everyone’s mind, it seems fitting to take a look at what that might mean for electrical safety. After all, many of us work in a field where electrical hazards often present a very real danger that we might not make another family Thanksgiving dinner or another company holiday party. However, someone had our best interests in mind when they put together a plan aimed at making sure that we not only make it to the next big family get together, but that we make it home at the end of every day. And that certainly is something to be thankful for this time of year. However, does that electrical safety program continue to protect employees year after year without any checks and balances by the authors? NFPA 70E®, Standard for Electrical Safety in the Workplace® actually requires that an electrical safety program get audited and reviewed on a regular basis to ensure that the program is still in alignment with applicable safety requirements. It is this auditing that helps a company continuously improve their electrical safety program. By reviewing the year in safety, we can see where additional safety measures need to be implemented and reinforce the existing measures that have served us well. So, what exactly are the auditing requirements that can be found in NFPA 70E? Well, for starters we can find the requirements for auditing the electrical safety program in section 110.5(M). This section requires that an electrical safety program that is based on NFPA 70E be reviewed to ensure that it is still in alignment with requirements found in the standard. This auditing is something that must take place at intervals not to exceed three years. This corresponds to the revision cycle timeframe of NFPA 70E and as requirements change within the document, we need to be making the corresponding changes to our electrical safety program. Next, field work audits are also required to be performed to verify that the procedures within the electrical safety program are being followed in practices in the field. Field audits are something that must be performed on a yearly basis. If these audits find that either the procedures are inadequate to protect employees or that employees are simply not following them, then steps must be taken by the employer to adjust the program policies and procedures in a way that will lead to better procedures and more buy-in from the workers. Keep in mind that just about anything that affects or has to do with electrical safety in the workplace is also going to be required to be documented. Consulting documentation about incident investigations and near-misses can markedly improve an employer’s ability to assess whether the electrical safety program is successfully providing for the safe work environment employers must provide their employees. Another required audit that must be performed is on the employer’s lockout/tagout (LOTO) program. This audit must also take place on a yearly basis and has certain aspects that it must cover. The LOTO program audit must identify and correct any deficiencies found in the program and procedures. The audit must also look at the LOTO training program to verify that the training is adequate to train employees on the proper methods for controlling hazardous energy. One way this becomes obvious is when the audit is performed on the worker execution of a procedure. Therefore, the LOTO program audit must be performed to cover at least one lockout/tagout procedure in progress. After all what better way to see if the workers have been trained on proper procedures and the training is effective than to observe the way that they apply the requirements? Keep in mind that all efforts made by an employer to audit all of these programs is going to need to be documented. This is important as it aids in the employer’s ability to track the effectiveness and improvement of the program over time. Also, should the need arise to show proof that the program is being audited regularly, then those records will be available. In addition to auditing the procedures within an electrical safety program, we also want to make sure that we are auditing other critical safety measures that are required to be maintained and accurate. Some examples of this are equipment labeling required by NFPA 70E. As the owner of the electrical equipment containing such a label, a facility must make sure that any labels that state information such as available fault current or incident energy level be verified to still be accurate. If these labels are found to be inaccurate, or if the system changes in a manner that renders them inaccurate, they must be updated. This information about labels must be reviewed at least every five years to ensure they are still applicable. However, keep in mind that if nothing has changed that would warrant the need for new labels, existing labels that followed previous editions of NFPA 70E are not required to be changed or updated until they are found to be inaccurate. Electrical safety is a fluid process. It seems like every time we feel as though we have it all figured out, something pops up that teaches us just how much we have yet to learn. By reflecting on what went well and what maybe didn’t go so well, we can look back on the year and identify the learning opportunities and reinforce our strong suits. And as we look back on the year that has been 2020, even though I think we would all rather not, hopefully the bright shining star we see in our rear-view mirror is that we all had a safe and productive year in safety. Even with a year marked with successful job outcomes, there will always be some hiccups, as we know. But by learning from our mistakes we can use these lessons to prepare for the following year ahead. Now’s the time to get our safety plans into good shape and step into 2021 with safe work practices that work. It’s a big world; let’s protect it, ourselves, and each other and make the new year a successful one for all. Learn more about NFPA 70E and find related resources by visiting the NFPA 70E electrical solutions webpage.
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