Safety & Health Effects of Shift Work - ASSE Members

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ELECTRICAL SAFETY BY MICHAEL KOVACIC NFPA 70E: Fact, Fiction or Fad Knowledge, and the desire and ability to implement that knowledge, saves lives and prevents injury. Afew months ago, I was giving several short sessions on NFPA 70E at a national safety conference. One of the attendees, whom I have known for years, saw me outside the conference room in between sessions and said, “Are you still talking about 70E” I quickly responded, “Of course! Employees are still being injured and killed by electricity, aren’t they” But I thought about that comment for weeks . . . what did he mean, still talking about it And then, a comment from a customer a few weeks ago put it into the perspective I was missing: “I wish we would get over this 70E fad already!” I realized that “NFPA 70E” and “arc flash” have become such buzz words that many employers and employees who do not understand the core of what NFPA 70E is trying to accomplish see it as simply the latest safety fad. And some people even promote “fiction” in an effort to sell more product or services. So, what are the basic facts about NFPA 70E Fact: NFPA 70E is not a new standard; the first NFPA 70E committee was established in 1976 and the first edition of NFPA 70E was published in 1979. The primary focus of what NFPA 70E is, electrical safety-related work practices, made an entrance with the 1981 edition 30 years ago. If you do not currently own NFPA 70E, it is time to get a copy. If you have never looked at NFPA 70E, the National Fire Protection Association has the text available to view (you cannot copy or print from the viewer) on its website. Fact: Arc flash and arc blast are not new electrical hazards made up by sales people to sell PPE. The book, Electrical Injuries—Their Causation, Prevention and Treatment, by Charles A. Lauffer, M.D., was first published in 1912. The first chapter discusses the cause, prevention of and treatment of arc flash injuries. So, arc flash hazards have been discussed for at least 100 years. Numerous statistical and research organizations have produced various studies about workplace injuries over the last few years, but they all conclude the same general information. Between five and 10 arc flash incidents occur in electrical installations in the U.S. every day, representing a significant number of injuries and fatalities each year. Workplace electrical injuries represent a significant cost to employers each year, and lockout/tagout and electrical regulations continue to make OSHA’s top ten most cited regulations each year. Fact: OSHA has not adopted NFPA 70E. Sections 1910.331-.335 of Subpart S of the OSHA regulations essentially mirror NFPA 70E. In many ways, Subpart S is the “protect your workers” regulation, and NFPA 70E is the how-to guide. OSHA does, and will continue to, reference and enforce NFPA 70E in its compliance and consultation activities, so if you have been waiting for OSHA to adopt NFPA 70E before you start implementation at your facility, you can stop waiting and start implementing. UNDERSTANDING & IMPLEMENTING NFPA 70E FOR A SAFER WORKPLACE Chapter 1 of NFPA 70E, titled “Safety-Related Work Practices,” addresses the electrical safety-related work practices and procedures necessary to safeguard employees from hazards arising from the use of electricity in the workplace. The chapter provides a progressive guide to implementing safe work practices in your workplace. KNOWLEDGE IS KEY Knowledge, and the desire and ability to implement that knowledge, saves lives and prevents injury. OSHA documentation shows that it is often unsafe work practices that lead to electrical injury and death, while additional investigation data indicate that employees who used unsafe work practices often did not have knowledge of safety-related work practices. Chapter 1 of NFPA 70E addresses employee training requirements quickly. Section 110.6, titled “Training Requirements,” outlines the need for training “employees who face a risk of electrical hazard not reduced to a safe level by the applicable installation requirements [National Electrical Code and OSHA 1910.301-.308].” As almost every workplace uses electricity, this one simple statement tells employers that all employees need a level of training adequate to understand the “specific hazards associated with electrical injury,” the relationship between electrical hazards and possible injury,” and the “safety-related work practices and procedural requirements necessary to provide protection from those electrical hazards.” The section also addresses the specific training necessary for “qualified” persons and provides a basis for establishing who actually is qualified. One of the most important changes to the 2009 edition was the addition of Section 110.6(D)(1)(e), which requires that persons considered “qualified” be able to demonstrate the appropriate use of a voltage detector. The added requirement helps clarify that additional and specific skills and knowledge are necessary for an employee to be considered “qualified.” This section of NFPA 70E closely corresponds with 20 Safely Made www.asse.org 2011
W STANDARDS Electrical Safety in the Workplace the requirements of OSHA 1910.332, as well as providing retraining guidelines and training documentation requirements. PROVIDING PRACTICES & PROCEDURES What is training without procedures to follow NFPA 70E gives responsibilities to both the employee and the employer when it comes to safety-related work practices. The employer must provide safety-related work practices for employees (Section 110.3) and while it is necessary to implement safety-related work practices found throughout the standard, Section 110.7, Electrical Safety Program, specifically requires that the employer “implement and document an overall electrical safety program.” The section lays out a minimum basis for a written electrical safety program, including the need to audit the program to ensure that the program works [Section 110.7(H)]. Having a written program that does not address safe work practices or a program that employees do not even know exists, does not accomplish the overall goal of providing a safe work place. ESTABLISHING AN ELECTRICALLY SAFE WORK CONDITION If electrical energy is removed from the equipment, all hazards are also removed and employees can work safely. Most employers have an established lockout/ tagout (LOTO) program in one form or another. Very often, this program has been based on the requirements of OSHA 1910.147, The Control of Hazardous Energy, which is generally accepted as OSHA’s primary regulation when discussing LOTO. What is often overlooked about 1910.147 is the scope: “1910.147 – Control of Hazardous Energy (a) Scope, application and purpose. (a)(1) Scope (a)(1)(ii) This standard does not cover the following: (a)(1)(ii)(C) Exposure to electrical hazards from work on, near, or with conductors or equipment in electric utilization installations, which is covered by Subpart S of this part.” NFPA 70E, Article 120, in connection with 1910.333- (b), establishes additional requirements specific to employees exposed to electrical hazards while working on equipment. NFPA 70E goes above and beyond 1910.333 by providing a specific six-step process necessary to establish an electrically safe work condition, with the most significant difference being the need to actually use test equipment to verify a truly deenergized condition. There is no need to establish a completely new program to address electrical lockout/tagout; however, NFPA 70E and 1910.333(b) requirements must be integrated into existing programs for complete compliance and safe work practices. WORK INVOLVING ELECTRICAL HAZARDS The last section of Chapter 1 of NFPA 70E, Article 130, addresses those scenarios where it may not be possible to deenergize equipment. Because significant injuries and fatalities related to electricity primarily occur during such times, this section seems to have become the focus of what NFPA 70E is all about, often referred to as the “arc flash standard.” NFPA 70E is about a complete safe work practices program, which includes protecting employees during the most dangerous of work. Article 130 establishes the requirements for energized work, when deenergizing would present a greater hazard or is infeasible. Those requirements include, but are not necessarily limited to: •justification for the work; •established safe work practices, including, but not limited to PPE, job briefings, protection of unqualified persons; •a shock hazard analysis; •a flash hazard analysis; •approval by management or similarly authorized personnel. NFPA 70E does not, as many believe, exclude testing, troubleshooting, voltage measuring and visual inspections as energized work tasks. Article 130 establishes that these tasks are considered energized work, but excludes these tasks only from the requirements for an energized work permit; all other safe work practices must be followed. NFPA 70E does not deviate from OSHA requirements or provide for additional requirements not supported by OSHA, as many believe. 1910.132(d)(1) requires that “the employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of PPE,” while 1910.335(a)(1)(i) requires that “employees working in areas where there are potential electrical hazards shall be provided with, and shall use, electrical protective equipment that is appropriate for the specific parts of the body to be protected and for the work to be performed.” NFPA 70E provides the specifics of how this is to be accomplished through a flash hazard analysis and PPE for each body part. 21 Safely Made www.asse.org 2011
Page 1 and 2: A TECHNICAL PUBLICATION OF ASSE’S
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