AUTHOR: Christopher Coache

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A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program (Part 3 - Procedures)

NFPA 70E®, Standard for Electrical Safety in the Workplace® requires that an electrical safety program (ESP) be established and documented. Section 110.5(G) requires that electrical safety procedures be developed, and Annex E provides guidance on things to include in a detailed procedure. It is the employer’s responsibility to document procedures applicable to the tasks performed by employees and to train employees on using those procedures. Procedures are required to be in place before an employee conducts a task. NFPA 70E does not contain safety procedures that an employee can be trained to follow. An ESP that directs an employee to follow NFPA 70E, Section 120.5 as the procedure for establishing an electrically safe work condition (ESWC) in the specific workplace violates the 110.5(G) requirement. Section 120.5 is the process necessary for establishing an ESWC. It is not a proper procedure for doing so on any specific piece of equipment. However, Section 120.5 is a good start of what to include in the procedure. Conceivably, a detailed procedure should be developed for any task an employee may perform on equipment. Using the ESWC as an example, the requirement to determine all possible sources of electrical supply to the specific equipment is not a procedure for a piece of equipment. An employee should not be required to determine power sources each time they work on the equipment. The procedure for Motor Starter #4 should direct them to Subpanel #2 to open Circuit Breaker #15. The procedure should say wait 15 minutes after removal of power to allow stored energy to dissipate rather than need to determine how to release stored electrical energy each time. Section 120.5(6) indicates that it is not appropriate to be used as a procedure; “apply lockout/tagout devices in accordance with a documented and established procedure.” This is often a separate, detailed procedure rather than being part of the ESWC procedure. The remaining ESWC requirements need to be detailed for the specific equipment. Correct your ESP if it depends on employees using NFPA 70E as the documented procedure for establishing an ESWC or for any other task. Just documenting a procedure is not enough. It is beneficial to try out a new procedure on the equipment to identify missing steps, expose shortcomings, determine necessary tools, or reveal improvements before it is applied by an employee in the field. Once completed, employees must be trained to understand and use the procedure. Although the EMP must include regular auditing of a procedure (Sections 120.5(M)(2) and 120.5(M)3)), employees should be encouraged to suggest improvements to the procedure anytime they find the procedure lacking. The ESP principles that are used as the basis for procedures typically do not change. A procedure should not be as rigid. Increased electrical safety depends on continuous improvement throughout the entire ESP. Do not let your ESP become stagnant.

A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program (Part 2 - Principles)

May is Electrical Safety Month which is a good time to review your company’s Electrical Safety Program (ESP). Electrical safety does not start with the employees, it starts with management before the first employee steps into a facility to conduct any task. It is impossible to properly train employees in electrical safety in any facility without it. There can be no improvement in electrical safety without a well-established and documented ESP. Management must first determine central safety principles when setting up the program. Section 110.5(E) of NFPA 70E®, Standard for Electrical Safety in the Workplace® requires that the principles be identified. What is a principle? One definition of the term is a fundamental, primary, or general law or truth from which others are derived. This is perhaps the best definition of how the term should be applied in NFPA 70E. Management must commit to protecting employees by establishing principles. Principles are the broad statements of how electrical safety will be handled within the facility. NFPA 70E, Annex E includes some things that could be used as a safety principle. Principles could include the following. Achieving a zero-injury facility Inspecting and evaluating all electrical equipment Maintaining electrical equipment’s integrity Assessing employee abilities Documenting procedures Planning every job Identifying electrical hazards and reducing the associated risk Anticipating unexpected events before tasks are started Establishing an electrically safe work condition as the primary safe work procedure Protecting employees from recognized electrical hazards Using the right tools for the job Addressing all employee safety concerns Auditing the principles, policies, and procedures NFPA 70E does not set principles. It is the employer’s responsibility to do so for their facility. Principles must be documented to form the basis for detailed safe work procedures. For example, a detailed procedure would address what is involved under the principle of planning every job or task. Care should be taken when setting principles since they are typically not changed by the nature of being a safety principle. The principles must be considered whenever a policy or procedure is developed. Most importantly, management must allow employees to work under the documented principles to advance safety in the workplace.
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A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program

Are employees trained on the requirements of NFPA 70E®, Standard for Electrical Safety in the Workplace® or are they trained on your Electrical Safety Program (ESP) requirements which are based on NFPA 70E? Someone must be trained on the NFPA 70E requirements to assure that the ESP complies. But an employee who gets exposed to an electrical hazard during the workday does not need to be specifically trained on NFPA 70E. It is your documented ESP that provides direction to each employee on what is necessary to protect themselves from the electrical hazards in your specific workplace. NFPA 70E is the 10,000-foot view for developing an ESP. Protecting employees from electrical hazards involves more than NFPA 70E details. The employer is required to establish procedures, conduct risk assessments, protect employees from electrical hazards, and provide appropriate PPE. However, NFPA 70E does not detail how to achieve this in a specific workplace. It is the employer’s responsibility develop an overall ESP that directs activity appropriate to the risk associated with electrical hazards in the workplace. An employer must establish, document, and implement safety-related work practices and procedures. Those are the procedures and practices that an employee must be trained to follow. An ESP that requires that employees follow NFPA 70E for electrical safety issues is not an established ESP. Do you have the required ESP? Does that ESP include what NFPA 70E requires? Most people consider Article 130 to be the most important NFPA 70E article. I don’t believe that for most employees. Articles 105 and 110 are perhaps the most important since that is where the responsibility to protect employees resides. An employer must be committed to improving electrical safety no matter where an employee works. Overriding principles to protect employees must be established. Management must provide guidelines for protecting employees. To establish safety-related practices and procedures, the employer must understand the electrical hazards and risks their employees face as during assigned daily tasks. This is the first of a twelve-part series that will run through Section 110.5, Electrical Safety Program. Section 110.1 sets the goal of an ESP. The requirement is synonymous with the OSHA requirement that employees not be exposed to known hazards. This requires that the ESP include the priority be that at a hazard be eliminated before an employee is exposed to it. Under NFPA 70E, this means eliminating the hazard by design, installation, or an electrically safe work condition. Without a statement in the ESP and commitment to achieve elimination, exposure to hazards will be considered part of remaining employed. It will lead to improper justification for energized work. Several of my blogs have discussed that an authorization to work energized due additional hazards, increased risk, or infeasibility is often unwarranted. Just having the words in the ESP do not provide safety. Employees are occasionally directed to expose themselves to hazards as a matter of expediency, revenue, or pressure regardless of the ESP. Employees must know that management stands behind the policy regardless of the situation. Does management allow an employee to follow the documented ESP and remove hazards so that they increase the likelihood of returning home unharmed?
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A Better Understanding of NFPA 70E: Correctly Using the Incident Energy Analysis and Arc-Flash PPE Category Methods

The 2009 Edition of NFPA 70E®, Standard for Electrical Safety in the Workplace® clearly stated that one of the two provided methods be used for the selection of personal protective equipment (PPE) when an arc-flash hazard was present. The two methods of choice are the arc-flash PPE category method and incident energy analysis method. Although not as plainly stated before 2009, it has been required to use only one method on a piece of equipment for twenty years. Why do some NFPA 70E users ask how to combine PPE category method requirements with an incident energy analysis? A few editions ago, the public expressed concern regarding the phrase, one of the following methods shall be used. Apparently, this phrase did not fully convey that only one method could be used on a piece of equipment, or that the two methods could not be combined. So, the requirement was revised to include the statement, either, but not both methods shall be permitted to be used on the same piece of equipment. This was to clarify that one does not include both methods. I am not sure how the words one, either, and not both are being misunderstood. Also, other requirements state not to use both methods. Section 130.7(C)(15) states its requirements apply when the arc flash PPE category method is used and that it is not permitted to specify an arc flash PPE category based on the results of an incident energy analysis. Each of these were added to further clarify the misunderstanding. However, the question was asked once again last week. When shown these specific requirements prohibiting the use of both methods, their response led me to believe that an untrained or unqualified person is conducting the assessment. It is often revealed that the person has not read NFPA 70E or worse do not possess a copy. Often, a computer program has been used to calculate the incident energy and the person has been supplied with a copy of the PPE Category Table to specify PPE. Sometimes, that program automatically and incorrectly converted the incident energy into a PPE Category. These revelations should be troubling because the employer and the person assigned to do the risk assessments are putting employees at risk of injury. Make sure that you have been properly trained and fully understand the requirements when conducting assessments. It is also necessary to have access to an entire NFPA 70E to properly apply the requirements since there is more to electrical safety than an using a table. Consider that these people asking this question are not the only ones who have misapplied the requirements. Confirm that the requirements have been properly applied in your workplace. If not, correct the issue before it is too late. 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.
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A Better Understanding of NFPA 70E: Your Risk Tolerance

NFPA 70E®, Standard for Electrical Safety in the Workplace® changed from an arc-flash hazard analysis to an arc-flash risk assessment several editions ago. Users are still having issues with the change. The most common complaint is that risk should not be a consideration when considering the electrical hazards an employee might be exposed to. Many want the standard to provide an absolute solution to what the employer should do to protect their employees. They don’t want to have to decide what to do, they want to be told what to do. They can apply the current that way if they wish. Others want guidance which is what the current edition provides. It allows for more leeway in determining the course of action to be taken for a given task on a piece of specific equipment. The hazard analysis determined the flash boundary, the incident energy at the working distance, and the personal protective equipment (PPE) necessary. The risk assessment first determines if an arc-flash hazard exists. If the hazard exists, the risk assessment then determines appropriate safety-related work practices, arc flash boundary and PPE to be used. Both methods require that the worst-case condition be labeled on the equipment to provide appropriate warning of the hazard lurking inside regardless of the assigned task. There is not much of a difference between the two except for determining if an arc flash hazard exists for a specific task. Imagine a battery system in a room with two terminals of the dc system in another room. If the conductors from the battery system are shorted together there is a potential for an arc-flash with an incident energy of 42 cal/cm2. However, that energy level only exists if the two conductors are shorted together. The positive conductors are brought into the terminal room on the left side and the negative conductors are brought in on the right. Those two covered terminals are separated by 12 feet. The first component after the terminals is an overcurrent device which lowers the incident energy to 14 cal/cm2. The entry to room is correctly labeled to require a 42 cal/cm2 arc-rated suit as the worst-case condition regardless of the task to be performed. Under the old system, at least a 42 cal/cm2 suit would have to be worn every time someone enters the room. Under the current method, when does the 42 cal/cm2 arc-flash hazard exist? The full amount of incident energy is always present in the room. The arc-flash hazard might exist if there is way to connect the two conductors. A task that involves pulling conductors around the room, using tools with a long span, or having conductive fluid present may exposure a worker to the full incident energy. Employee error while in the room may warrant concern. Under a risk assessment for the assigned task, you might determine that it is not possible for a worker to connect ahead of both overcurrent device terminals based on the assigned task. Would you let an employee enter that room wearing 14 cal/cm2 rated gear to perform the assigned task? If you believe that a risk assessment should not be part of the standard, you are not required to accept any risk. The risk assessment method allows you to decide that the worst-case incident energy always presents an arc-flash hazard regardless of the task performed on the equipment. If you can accept that a twelve-foot span cannot be bridged by the employee based on all possible factors, you might permit something different for the task. There are many things that might affect your acceptance of some risk instead of having a zero-risk tolerance. Regardless of your risk-tolerance, remember that it is the employee’s well-being that is wagered on your decision. NFPA 70E is available on 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.
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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.
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