AUTHOR: Christopher Coache

A Better Understanding of NFPA 70E: Part I – Comparing Four Decades of Electrical Injuries and Fatalities

To assist all employers in reducing, if not eliminating, workplace electrical injuries and fatalities, I decided to investigate how far electrical safety has progressed over the last 40 years. Information from the National Institute for Occupational Safety and Health (NIOSH) and the Bureau of Labor Statistics (BLS) database has been used for 1980, 1990, 2000, 2010 and 2020. This will be a multipart blog series investigating different aspects of electrical injuries and fatalities. There were 7,405 fatal injuries in the workplace in 1980, and 4,764 in 2020 (a Covid year with significantly fewer fatalities than the previous years). For comparison, excluding 2020, there has been an average of 5,222 fatalities since 2015. It is encouraging that progress has been made in all causes of workplace fatalities, but how is protecting employees from electrical hazards working out? Electrocution was the fifth-leading cause of death in the workplace by the end of the 1970s; there were approximately 600 electrocutions annually at the time, accounting for about 8% of all workplace fatalities. The first edition of NFPA 70E®, Standard for Electrical Safety in the Workplace®, was issued in 1979 to address those fatalities. What has happened since? Drum roll please … Exposure to electricity is no longer a stand-alone leading cause of workplace fatalities. It is included in a group of exposures to harmful substances or environments that together are currently the sixth-leading cause of fatalities—a vast improvement since NFPA 70E began addressing electrical safety. RELATED: The 2024 edition of NFPA 70E is due out soon. Learn more. It is amazing that in the 1970s exposure to electricity alone caused nearly as many deaths (about 600) as this entire exposure group now does (672 in 2020). Unfortunately, of the named harmful substances or environments, exposure to electricity is the leading cause of fatalities by a factor of 2 and accounts for one-fifth of all these 2020 exposure fatalities. In addition, exposure to electricity is once again on OSHA’s “Fatal Four” for the construction industry. The chart below shows the decrease in exposure to electricity fatalities and injuries (no 1980 online data for injuries) at the end of each decade. Great strides have been made, but there are still some areas where electrical safety can improve. Exposure to electricity fatalities were nearly halved from 582 to 310 in the decade after NFPA 70E was first issued. It took two more decades to halve the fatalities from 310 to 164. Although there were 126 fatalities in 2020, exposure to electricity fatalities has stagnated at around 150 over the last decade. As a percentage of all workplace fatalities, exposure to electricity fatalities has decreased from 8% in 1980 to 3% in 2020. Electrical injuries requiring time away from work have nearly been cut in half (4,806 to 2,380) since 1990. These are good signs that employers have embraced protecting all employees in all workplaces from electrical hazards. The bad news is that, in 2020, 2,380 employees just missed becoming a fatality by dumb luck. Vast improvements in electrical safety have been made in all occupations, but any fatality or injury is cause for further refinement. No employer should be satisfied with an employee electrical injury. Workplace fatalities due to exposure to electricity are preventable. It may seem difficult to further reduce the number of fatalities, but it is easier than it seems. There are four things that an employer can do. First, properly install and maintain equipment so that not only your employees but also groundskeepers, contract workers, painters, and plumbers are protected from electrical hazards whenever they are near or interacting with your electrical equipment. Second, train your employees to recognize and avoid electrical hazards wherever their work environment may be. Third, create or improve your electrical safety program and follow it. The last thing only takes a second because it is simply a matter of flipping a switch to save someone’s life before they might be exposed to an electrical hazard. The use of the most up-to-date edition of NFPA 70E is a key component to establishing electrical safety in the workplace. The 2024 edition of the standard is due out next month. The digital version of the new edition will also be added to NFPA LiNK® next week; visit nfpa.org/LiNK to learn more.

A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program (Part 12 – Program Controls)

NFPA 70E®, Standard for Electrical Safety in the Workplace® Section 110.5(M)(1) requires auditing of your electrical safety program (ESP) to determine if the ESP continues to comply with current NFPA 70E requirements. Section 110.5(F) requires that the ESP identify the controls by which it is measured and monitored. Electrically safety in the workplace will stagnate without this step where improvements for safety are implemented. Controls are the electrical safety metrics for determining if an ESP is effective and efficient. To evaluate a system, you need to know where you started and how far you have come. Controls must be both measurable and actionable. Metrics are measurable points to determine performance. They are used to determine if improvements to the safety program are required and, if so, what needs to be changed. NFPA 70E requires controls but it is the documented ESP that details what they are and how they are used. It is necessary to identify who is responsible for analyzing the data and incorporating necessary changes. There are two common metrics used to determine the effectiveness of something: lagging and leading. Lagging metrics provide a reactive view of an ESP. Lagging metrics might include the time lost to injuries, the money spent on worker compensation, or the amount of training an employee has received. Under this metric, an injury occurs, and the ESP is changed to address it. A shock is reported, and a change is made. Leading metrics identify and correct contributing factors before an incident occurs. Leading metrics might include the number of hazards identified and eliminated, the reduction in the number of authorized energized work permits, or the number of work procedures altered for de-energized work. Under this metric, a decrease in electricity injuries might be evident after hazard elimination was instituted or after every employee had been trained on the proper use of with extension cords. A combination of these metrics can enhance a safe work program. The next step is determining where further improvements could be made to the system. The ESP must detail what controls are implemented, how they are evaluated, how data is collected, how changes are incorporated, and who is responsible for maintaining the control system. The process should address how much change may occur at one time. Incremental steps are easier to monitor than whole scale changes. If the system heads in the wrong direction it is easier to correct its course, then try something else. Make sure that your ESP has appropriate controls to keep electrical safety progressing in your workplace. This concludes the 12-part series on an ESP. NFPA 70E requirements cannot be used as appropriate procedures or for training for any specific task. A well-developed ESP is critical to achieving electrical safety in the workplace as well as for complying with NFPA 70E and OSHA regulations. Without it there are no policies and procedures available for employee training and there can be no qualified persons without proper training. Review your ESP to make sure all requirements and safety issues are properly addressed.
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A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program (Part 10 – Incident Investigations)

Does an employee get punished when they make a mistake? Are they afraid of notifying a supervisor when something goes wrong? Is an employee who points out a safety issue sent back to work without having the issue resolved? One NFPA 70E®, Standard for Electrical Safety in the Workplace® requirement that is occasionally not well addressed in an electrical safety program (ESP) is the incident investigation requirement in Section 110.5(J). The reason is that with electricity no incident should be treated as minor. Every 120-volt electric shock is a brush with death. However, electric shocks, minor burns, and unjustified live work are not reported until a greater injury occurs. Investigations required by NFPA 70E are not for the purpose of assigning blame. They are to improve employee safety. An ESP must include the details of how, why, when and what happens with incident investigations. Incident investigations should not be limited to those where an employee is injured to the point where medical attention is required. An electric current’s path through a human body affects each person differently. An employee with a pacemaker may have a problem days after an incident. Employees should be trained and encouraged to report any dangerous situation as well as any injury regardless of the cause or severity. The investigation could reveal that the ESP, work procedures, protective equipment, training, or test instruments require revision to prevent a future occurrence, injury, or death. Without an investigation into what occurred there is possibility that a fatality could happen the next time that same task is conducted. The employee could have received an electric shock due to unjustified energized work, insufficient training, damaged equipment, wrong qualification for the task, inappropriate personal protective equipment, flawed job planning, or errors in the procedure. But none of that will matter unless this near-death situation is reported and the cause rectified. Employers and employees must accept their responsibilities and work together to find the cause of any incident. Although electrical incidents are often the result of human error, an employee does not intentionally initiate an electrical incident. However, it is important that an enforcement program be established for willful violations of safety regulations. The ESP must assign responsibility for each step in the incident investigation. The procedure must not only cover what is required as part of an investigation but the training for the investigator. The incident and investigation must be documented. There can be no improvement in safety without a final step requiring that necessary changes be incorporated. If it is determined that training was the culprit, modification of the training program could include increasing the frequency of training or adding follow-up verification of compliance. The ESP must address who is be responsible for incorporating the improvements. Do not use incident investigations as means to punish but to gain knowledge and to educate. Involving employees in the process gives them a personal stake in improving workplace safety. For the ESP to work, employers and employees must cooperate and trust that safely returning home each day is paramount in the workplace. 

A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program (Part 9 – Safety Planning)

Section 110.5(I) in NFPA 70E®, Standard for Electrical Safety in the Workplace® requires that an electrical safety program (ESP) include that both a job safety plan and job briefing be completed before a task is performed. A safety plan will vary by task and equipment. The briefing will vary based on the plan. An employee should not be directed to follow NFPA 70E when conducting the planning and briefing. NFPA 70E addresses what is required to be addressed but does not detail what is necessary for a specific task. The ESP will contain specifics on what is necessary in a facility. A job safety plan must be completed by a qualified person. The ESP will detail the qualification and training necessary to complete the documented plan. A plan must include details of the equipment and task, results of the risk assessments, and the documented procedures and the equipment necessary to conduct the task. The job planning procedure should address if the person planning the job is solely responsible or if other employees will provide information needed to complete the plan. The plan should identify who and what qualifications are necessary to conduct the proposed task. The plan will identify other employees possibly affected by the work. The documented planning procedure must address other concerns specific to the facility, task, and equipment. The ESP must require that a job briefing be held before the task begins. The documented procedure should address when and if the employee conducting the task may conduct their own briefing. Perhaps, a lead employee is responsible for giving the briefing for any task under their purview regardless of the one assigned the task. The ESP should address whether the person conducting the briefing has the authority to alter the plan or if the person who set the plan needs to approve it. How are safety concerns raised during the briefing addressed and documented? If anything changes once the task has begun, the procedure must address how a change in scope must halt work until the planning and briefing address the change. It is the documented procedure not NFPA 70E that will provide these necessary details. A well-developed procedure for job safety planning and briefing is crucial. These are typically the last opportunities for anyone to address safety before a task has begun. Planning and briefing may not only expose shortcomings but also introduce improvements for the planning procedure or the assigned task. Make sure your ESP contains the details necessary to protect employees from electrical hazards.
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A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program (Part 8 - Awareness)

Some electrical safety requirements in NFPA 70E®, Standard for Electrical Safety in the Workplace® are overarching concepts. Section 110.5(D) is one such requirement. An electrical safety program (ESP) must be designed to instill awareness and self-discipline in employees. By learning awareness and self-discipline, employees will begin to accept that their actions are often among the primary causes of injuries. The employer must develop policies and procedures that flesh out the requirement to achieve this safety goal. Training employees to be vigilant of the electrical hazards lurking in the workplace is difficult. There are things that every employee should know for their safety. For example, recognizing when a flexible cord is damaged is a skill everyone can benefit from. An employee operating an overhead electric crane needs focused training to know specific hazards and warning signs that may be present. An ESP must contain policies, procedures, and a training program to address this. Having awareness of potential hazards serves no purpose if there is no awareness on how to avoid the hazard. Requiring an employee to conduct a task that exposes them to a reported hazard or to a hazard that they are not trained to avoid will quickly undermine a well-intentioned ESP. Awareness also means awareness of others around oneself. Employees need to be aware of how their work affects the safety of others. Employees should be taught to help others be aware of hazards and inappropriate behavior that puts someone at risk.  Management must be committed to encouraging this awareness. Self-discipline, the other half of the requirement, is also difficult to teach. The ESP program must incorporate policies that encourage and remind employees that safety starts with them. Requiring and allowing an employee to choose safety is the first step. They are the only one who knows if they are wearing meltable undergarments. They can recognize that they are suffering fatigue after six hours into a double shift or are suffering from an illness that puts them at risk. They are solely responsible for properly donning personal protective equipment. They must be taught that their action or inaction will decide the outcome of day. This takes commitment from management. An employee who has the awareness and self-discipline to report that proper tools are not present onsite must not be reprimanded for waiting to be given the appropriate equipment nor should the task be given to an employee willing to risk safety.  Teaching by example goes a long way in complying with these requirements but first it takes a well-developed ESP to lay the foundation for electrical safety. As a safe work practice standard, NFPA 70E does not detail how to instill these principles in an employee. Not all training methods or concepts are appropriate for every workplace or every employee. The employer must decide how to incorporate awareness and self-discipline into an ESP and the best way to pass that information to their employees. It is the ESP policies and procedures that employees will be trained to follow not the NFPA 70E requirement for awareness and self-discipline.
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A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program (Part 7 – Equipment Condition)

NFPA 70E®, Standard for Electrical Safety in the Workplace® does not detail the policies and procedures that must be in an electrical safety program (ESP). However, it is not possible to comply with NFPA 70E without filling in the details. Section 110.5(C) requires that the condition of maintenance of equipment to be part of the ESP. Condition of maintenance is the state of the electrical equipment considering the manufacturers’ instructions, manufacturers’ recommendations, and applicable industry codes, standards, and recommended practices. Normal operation is permitted when the equipment is properly installed, properly maintained, used in accordance with instructions, equipment doors are closed and secured, all equipment covers are in place and secured, and there is no evidence of impending failure. Operating condition and condition of maintenance are two different things. Maintenance is only part of the operating condition. The ESP will detail what the acceptable condition of maintenance is any piece of equipment. Equipment that is under normal operating conditions is considered to be free from exposed hazards whereas equipment that is not is rightfully considered a risk for electrical injuries. All employees should be able to determine that the equipment they are interacting with is under normal operating conditions. The condition of maintenance is often not within an equipment operator’s knowledge base. With all the variables, NFPA 70E does not specify what is acceptable or how to assess condition of maintenance. There are thousands of pieces of equipment from hundreds of manufacturers with their own maintenance requirements, used in different environments, under different loads, and subject to different types of damage throughout a facility. Determining an appropriate equipment condition is more detailed than many think. It might not be realistic to require that equipment be kept clean. Such a requirement would dictate constant, unnecessary cleaning of a motor designed to safely operate in a dust atmosphere. Equipment might have a different acceptable condition. A grease smudge on a switch might not warrant the same response as a transformer covered in debris. Equipment that has an operator or is used every day could be evaluated by the employee using it. That employee must be trained to determine the equipment condition and know what to do if the condition is unacceptable. There are many pieces of equipment that are not often viewed by someone. An employee might be assigned to inspect that equipment. The interval might vary. For example, equipment in a loading dock might need more frequent inspection and maintenance than equipment in an electrical closet. Maintenance personnel might be solely responsible for assigning the condition of maintenance of all equipment that any employee interacts with or relies on for electrical safety. This takes an understanding of the definition of condition of maintenance and the ESPs definition of an acceptable maintenance condition. NFPA 70E is a safe work practice standard that does not provide the details necessary for assessing the condition of maintenance of equipment. In the United States of America, equipment that is under normal operating conditions is not considered a risk for exposure to electrical hazards. The condition of equipment and an employee’s ability to recognize when it is no longer acceptable are important aspects of the ESP. The ESP policies and procedures must detail the equipment condition assessment method as well as what is an acceptable condition to advance safety in the workplace.
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