AUTHOR: Christopher Coache

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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.

A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program (Part 6 - Inspections)

NFPA 70E®, Standard for Electrical Safety in the Workplace® has requirements for what should be included in an electrical safety program (ESP) but does not provide details. The requirement in Section 110.5(B) to inspect electrical equipment is one where it is the employer’s responsibility to fill in the gaps. A properly documented ESP does not exist until that has been accomplished. The policies and procedures in your ESP are what employees must be trained to follow. The ESP must address the inspection of newly installed or modified equipment. Does your ESP have a way to assign this responsibility? A newly hired, residential electrician may not be the appropriate inspector for a smelting facility. The local electrical inspector often does not inspect equipment that falls under NFPA 70E. Equipment is installed, maintained, repaired, and replaced by an employee or an outside contractor. The responsible person will need to not only determine that an installation meets the applicable manufacturer requirements but also those of applicable standards. This is not limited to electrical standards since things like improperly installed pressure systems in electrical equipment may affect safety. What are the ESP policies and procedures for these inspections? An ESP that requires that equipment be verified as complying with the NEC is not enough. Electrical system and equipment compliance with the NEC is often only determined during building construction. The NEC does not address maintenance nor is internal electrical circuits part of the NEC. However, technicians maintaining motor control equipment must know the applicable NEC requirements. A contracted HVAC technician may be required to provide documentation that their work complies with applicable standards and codes, as well as the facilities requirements. Is their work inspected by a facility employee? Who is authorized to inspect repairs on custom production line equipment? It might not be desirable for the employee performing the work to also perform the inspection. The ESP must address not only these issues but also the training of the employee conducting inspections. The ESP might permit some types of electrical work to be completed without additional inspection. Do employees know which specific equipment is permitted to be energized before or without the additional inspection? A contractor may not follow the same safety protocol. Perhaps, it is not the equipment but the task that directs an inspection before energization. The ESP must address how to document all of this and what is to happen with the results. A requirement for the inspector to evaluate alternate installation methods may provide a means to mitigate hazards or repeated exposures. However, this most likely will not happen without a statement to do so in the ESP.  Proper installation, repair, and modification of electrical equipment play a major role in protecting every employee from electrical hazards. Inspection to determine that fact is a requirement in NFPA 70E. NFPA 70E is a safe work practice standard that is not appropriate to be used as the procedure for equipment inspection. It is critical to train an employee on inspection policies and procedures contained in the documented ESP.
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A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program (Part 5 – Risk Assessments)

NFPA 70E®, Standard for Electrical Safety in the Workplace® Section 110.5(H) requires that a risk assessment procedure be developed as part of an electrical safety program (ESP). NFPA 70E is not a how-to manual for detailing a risk assessment procedure. It is also not appropriate for training an employee how to conduct the assessment. There are hundreds of valid methods of performing risk assessments for the thousands of tasks that could be conducted on the millions of pieces of equipment available. Section 110.5(H) requires a minimum of three things to be addressed and documented before any employee begins a task. The risk assessment procedure must detail the process that will be used to: identify hazards assess risks implement the hierarchy of risk controls Consistency is important when conducting risk assessments. Without it an employee conducting an assessment may tolerate a risk level that is not acceptable, ignore hazards that have been previously recognized, or improperly apply the hierarchy of risk controls. Training an employee to follow NFPA 70E Section 110.5(H) rather than your documented procedure will introduce such unsafe practices. Identify Hazards – NFPA 70E defines an electrical hazard as a dangerous condition such that contact or equipment failure can result in electric shock, arc flash burn, thermal burn, or arc blast injury. The two hazards (shock and arc-flash) currently covered by NFPA 70E are easily recognizable. The potential for an electrical shock typically at starts at 50 volts. An arc-flash burn begins at 1.2 cal/cm2. Contact burns can occur at temperatures as low as 44°C (110°F) if the contact is prolonged and as quick as a second above 80°C (186°F).  There currently is no consensus on what an arc-blast hazard is. NFPA 70E does not specify where any of these hazards exist. It is the role of the ESP to cover how equipment is evaluated to determine if these hazards are present during any task performed on equipment. Assess Risks - Human factors are generally recognized as being among the leading causes of injury and the potential for human error must be addressed in a risk assessment. This takes knowledge not only of the assigned task but also the location of the task, the equipment to be worked on, the tools to be used, competency of the employee assigned, and other issues. Working above a piece of equipment provides an opportunity for items to be dropped into ventilation openings or for an employee to choose to stand on the lower equipment rather than use an appropriate platform. Maybe an employee could confuse a Category I meter for a Category III meter because of a similar design. The risk assessment procedure should address what is to be considered a potential human error when conducting the specific task on the equipment in its installed location. Implement the Hierarchy of Risk Controls - The hierarchy of risk controls must also be addressed. It is beneficial to include a requirement for a risk assessment prior to purchasing or installing equipment to achieve the maximum benefit of the hierarchy. For installed equipment, requiring the assessment to retroactively apply the hierarchy to mitigate risks before the same task is performed again can increase workplace safety. The risk assessment procedure must require that elimination be the first control considered when planning a task. It must address why elimination was not used or required before applying other controls including personal protective equipment (PPE). Not having a documented procedure for conducting risk assessments is dangerous. Acceptable and unacceptable risks will vary. Electrical hazards will not be properly addressed. The use of PPE as the sole means of protecting employees will become commonplace. Inconsistency in risk assessments could put an employee at a higher risk of injury when conducting the same task on different equipment. Make sure a documented risk assessment procedure is part of your ESP and is used for every risk assessment.
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A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program (Part 4 – Lockout)

Does your electrical safety program (ESP) lockout program require that employees follow NFPA 70E®, Standard for Electrical Safety in the Workplace® Article 120? That ESP does not comply with NFPA 70E and employees are being improperly trained if it does. NFPA 70E requires that a lockout program be established and procedures to be developed. It provides requirements that must be addressed but does not provide a procedure for any specific equipment lockout. A lockout program in the ESP must comply with the minimum NFPA 70E requirements even if it refers to an employer’s lockout program. NFPA 70E cannot detail the requirements referenced in Article 120. It is not typical for every employee to have the same experience or training. Does the documented procedure cater to the least experienced or a higher level? The lockout procedure must be applicable to the experience and training of the employee and the conditions in the workplace. It is probable that different lockout conditions are encountered at various locations in the workplace. A mechanical lockout procedure might be different than an electrical one. It is possible for a basic lockout procedure to be developed and a standardized procedure mitigates the potential for human error. A specific lockout procedure could be necessary for a given piece of equipment which in turn requires additional training. Equipment installed before the NEC requirement for a permanent locking means could require additional locking mechanisms which alter the basic procedure. The program must address the use of simple and complex lockout procedures. An ESP could permit a contractor to use their own lockout procedure or contractors could be trained on the facility lockout program. Whose program will be followed and who is responsible for training employees affected by a different lockout procedure? If contractor procedures are permitted, an employee must be assigned to review those procedures to determine that safety standards of the facility are being met. Without a review, it is possible that the contractor does not have one, or that their program is less stringent than the facility’s lockout program. There could be situations when multiple contractors from various trades are affected further complicating the lockout procedure to be used and the training required.  Remember that the lockout process is only one necessary step in establishing an electrically safe work condition. A well-developed lockout program is not as simple as it appears. A generic lockout procedure could address most equipment. A detailed lockout procedure might be necessary to fill in the gaps when using it on specific equipment. Affected people might include facility employees as well as contract employees. Sections 110.5(M)(3) and (M)(4) require a documented annual audit of the lockout program and procedures including witnessing their use in the field.  The ESP must address more issues than this blog points out. Make sure your lockout program and its procedures cover all the bases.
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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.
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