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.