A Better Understanding of NFPA 70E: Using OSHA Top 10 Violations to Identify Known Electrical Hazards
We are all creatures of habits. We do something over and over because it works for us. However, we tend to ignore a need for change even when what we do occasionally doesn’t work. There has been a substantial decrease in fatalities caused by electricity since NFPA 70E®, Standard for Electrical Safety in the Workplace® was first issued (over 600 electrocutions annually compared to 166 recently). However, the number of electrocutions over the last decade is hovering around 155 per year. So, something is broken. The National Institute for Occupational Safety and Health (NIOSH) and Occupational Safety and Health Administration (OSHA) have published reports for over forty years summarizing workplace safety issues. Each year OSHA releases its top 10 violations. Online, 1991 was the earliest located for OSHA’s top 10. The violations listed below are for those that have remedies in NFPA 70E. OSHA Most Frequent Violations Violation FISCAL YEAR RANKING 1991 2000 2006 2014 2018 2020 Head protection from impact, falling or flying objects and electrical burns 2 Ground fault protection not provided 3 Electrical path to ground missing or discontinuous 4 Appropriate PPE not used for specific operation 7 Lockout/tagout (1910.147) 5 5 6 5 6 Electrical - wiring methods, components, and equipment (1910.305) 6 7 7 Electrical - general requirements (1910.303) 7 10 10 Lifesaving equipment – eye & face protection (1926.102) 10 10 It is difficult to improve electrical safety without first properly installing the equipment. As recent as 2017, there were many citations for electrical installations that did not follow the National Electrical Code® or National Electrical Safety Code®. In some industries, such as oil and gas extraction, these citations are still in the top 10. OSHA citations are issued to a facility that has been investigated due to an injury. Improper installations might exist in other facilities until a fatality and injury investigation. There are many who consider previously installed equipment to be nearly exempt from the operating conditions or hierarchy of risk controls because NFPA 70E is not an installation or maintenance standard. However, a fatality should not be the trigger for implementing a program to address electrical safety and to identify known electrical hazards. Although not solely an electrical issue, it is disturbing that lockout/tagout has be in the middle of the pack for a quarter of a century. The basic concept is simple but proper training and application seems to be falling on deaf ears. OSHA and NFPA 70E have specific requirements for lockout and tagout as well as their use in establishing an electrically safe work condition (ESWC). OSHA 29 CFR 1910.147 covers the servicing and maintenance of machines and equipment in which the unexpected energization or startup of the machines or equipment, or release of stored energy, could harm employees. It establishes minimum performance requirements for the control of such hazardous energy. This is analogous to the lockout, tagout and establishing an ESWC requirements in NFPA 70E. The citations might also be due to employers continuing to put employees at risk rather than shutting equipment off for maintenance or repair. OSHA 29 CFR 1926.102 requires that employers ensure that affected employees use appropriate eye or face protection when exposed to eye or face hazards from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation. Although it is probable that few citations are due to exposure to electrical hazards, NFPA 70E addresses this under the required face and eye protection. A NIOSH study of 224 electrocutions determined that at least one of the following five factors was present in each fatality; (1) established safe work procedures were either not implemented or not followed, (2) adequate or required personal protective equipment was not provided or worn, 3) lockout/tagout procedures were either not implemented or not followed, (4) compliance with existing OSHA, NEC, and NESC regulations were not implemented, and (5) worker and supervisor training in electrical safety was not adequate. NFPA 70E addresses each of these. Another NIOSH study reported on 152 fatalities involved in installation, maintenance, service, or repair tasks on or near machines, equipment, processes, or systems. Factors in each of these fatalities included failure to completely de-energize, isolate, block, and/or dissipate the energy source, failure to lock out or tagout energy control devices and isolation points after de-energization, and failure to verify that the energy source was de-energized before beginning work. Lockout and tagout procedures, PPE, safe work procedures, training and establishing an ESWC are requirements in NFPA 70E. The General Duty Clause requires an employer to provide employees proper protection from known hazards. OSHA’s 2018 Top 10 violation press release concluded with the statement; ”While many of these standards are repeated each year, it provides a good place for employers to start identifying hazards in their own workplace.” How many decades does a hazard or violation need to be listed before all employers start identifying them as known hazards in their workplace. These OSHA violations, from an electrical hazard viewpoint, could be a thing of the past if NFPA 70E requirements were universally and properly implemented. The last two Top 10 violations that include electrical safety issues are low hanging fruit. Without changing our work habits to address them, they will remain on the violation tree for another quarter of a century. 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.