NFPA Journal

In my travels this year, one thing has become very clear: the electrical industry is in high gear over safety. Everywhere I turn, I see news of a speaker on NFPA 70E®, Electrical Safety in the Work-place®, a presentation around safe work practices, or how maintenance plays a role in keeping workers safe.

This is fantastic news, of course. Even so, I’m bothered by a persistent thought: Are we all telling a consistent story?

How electrical safety is implemented within a company’s overall safety program is important, and communicating a consistent message is critical to getting buy-in across an organization. Imagine if you worked for five different employers over a span of 15 years and each one had a different interpretation of what steps to follow—it’s safe to say this would lead to some head scratching and doubt. No one wants to follow a plan they lack confidence in.

Consider the requirement in the 2018 edition of NFPA 70E that all preventative and protective risk control methods must be implemented according to the following hierarchy: elimination, substitution, engineering controls, awareness, administrative controls, and personal protective equipment. Since this hierarchy of risk control methods became part of NFPA 70E, I have heard different ideas of how the hierarchy works from all over the electrical industry. Having different opinions of where a control falls on the list, however, can have tragic consequences. It is important to understand that there can be multiple controls employed in order to reach the ultimate goal of eliminating the hazard.

A great example of how this works is the process of establishing an electrically safe work condition. Article 120 includes the steps necessary to establish that safe condition; only after all of those steps have been taken—especially the final one that verifies the absence of voltage with a properly rated test instrument that has been operationally tested before and after on a known voltage source—can a hazard be considered eliminated. However, the process of getting to the end goal of elimination requires the utilization of multiple control methods. That’s why it’s important to approach this task as multiple tasks, each employing its own method for risk control.

A lock out/tag out program, for instance, has written procedures that an employee must follow. If any of these steps are not followed, the final de-energized state cannot be considered an electrically safe work condition. What if the skipped step was locating all possible sources? Absence of voltage could be verified from one source, but not a second service or backup generator. Because of all the steps and procedures included in a proper lock out/tag out, the process becomes an administrative control combined with awareness, requiring employee training to be performed correctly.

Another example is in the verification that electrical energy has been removed. While there are new products entering the market that allow for verifying zero voltage without exposing employees, the tried-and-true method remains manual testing with a test instrument. And since the hazard isn’t gone until it has been verified, it must be assumed that the employee performing this test is exposed to the full hazard. This usually means that an employee will put on personal protective equipment to reduce the severity of injury should the unexpected occur.

This is the story we need to consistently tell: the act of establishing an electrically safe work condition is the combination of a multitude of individual tasks, a process that exposes employees to electrical hazards. It is not an elimination control. All of the controls mentioned apply to the individual tasks, and only when those tasks are combined do we reach the end goal of eliminating employee exposure to electrical hazards. However, not until these other controls have been implemented is the pinnacle of safety hierarchy achieved: elimination of the hazard. Skip even one step and all bets are off.

DEREK VIGSTOL is an NFPA technical lead, Electrical Tech Services.