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.