Most companies trying to comply with electrical safety standards start with personal protective equipment (PPE) or a written program. Even though the old adage goes, “PPE should be the last resort,” PPE is needed almost every day in electrical work and should be put into place quickly.
From a program perspective, a company should quickly standardize approaches, such as developing energized work permits, implementing training programs, conducting engineering studies, and adding arc flash and shock hazard labels to equipment. But these projects take time, and companies are often concerned that they will buy more PPE than they actually need in the meantime. However, this isn’t typically a valid concern. Our firm has had clients who had employees die while they were commissioning arc flash studies, so don’t ignore the PPE — but don’t stop there either.
A common outline for developing a safety program is as follows:
1. Establish the value of safety as a goal, not just a priority that can be shifted.
2. Create a safety program by:
• Hazard identification
• Risk assessment
• Hazard control
3. Educate management and supervision so they support, value, and grow the program (this is a commonly skipped step).
4. Begin measuring safety as a part of job performance.
5. Make safety (and planning for it) valued on the job site.
6. Make all employees responsible and accountable for safe behavior.
The problem with most safety programs from an electrical standpoint is that the safety departments often do not have the technical expertise to do electrical safety. But electrical safety must be managed as part of an overall safety program.
OSHA has electrical safety requirements, but they are insufficient to build an electrical safety program around, except in the case of electric utilities [29 CFR 1910.269, especially since 2014 when this standard superseded the National Electric Safety Code (NESC)]. Most OSHA 10-hour courses have an electrical safety component, but they tend to be very cursory (adequate in most cases if a plant does not employ electricians or do its own electrical work). For an effective electrical safety program, build the overall safety improvement process into the technical electrical safety program.
The NFPA 70E Technical Committee recognized this and added two new Informational Notes in Sec. 110.1(A) of the 2015 Edition of the standard. Although non-mandatory, they encompass a whole range of changes in how electrical safety will be done in the future. The other two Informational Notes in this Section have been in the standard since 2009. The notes state:
“Informational Note No. 1: Safety-related work practices, such as verification of proper maintenance and installation, alerting techniques, auditing requirements, and training requirements provided in this standard, are administrative controls and part of an overall electrical safety program.
“Informational Note No. 2: ANSI/AIHA Z10, American National Standard for Occupational Health and Safety Management Systems, provides a framework for establishing a comprehensive electrical safety program as a component of an employer’s occupational safety and health program.
“Informational Note No. 3: IEEE 3007.1, Recommended Practice for the Operation and Management of Industrial and Commercial Power Systems, provides additional guidance for the implementation of the electrical safety program.
“Informational Note No. 4: IEEE 3007.3, Recommended Practice for Electrical Safety in Industrial and Commercial Power Systems, provides additional guidance for electrical safety in the workplace.”
They may be simple statements, but using the ANSI Z10-2005 and IEEE standards brings a holistic approach to electrical safety. Note that even though Informational Notes are non-mandatory; they often foreshadow upcoming moves by the Technical Committee or important thoughts it believes is good practice. Let’s consider some of the requirements of ANSI Z10:
1. Requires a safety management system. This is a proactive, standardized process for continuously assuring and improving element effectiveness.
2. Requires establishing policy and objectives that use an organizational structure with systematic documented roles, responsibilities, processes and resources to obtain objectives.
3. Emphasizes continuous improvement and systematic elimination of root causes of deficiencies.
4. Requires management leadership and employee participation.
5. Requires planning and ongoing review, assessment and prioritization of objectives by implementation of plans and allocation of resources.
6. Implementation of the Occupational Health and Safety Management System, which includes the following elements:
• Hierarchy of controls
• Design review and management of change
• Procurement
• Contractors
• Emergency preparedness
• Education, training, and awareness
• Communication
• Document and record control process
• Evaluation and corrective action
• Monitoring and measurement
• Incident investigation
• Audits
• Corrective and preventive actions
• Feedback to the planning process
• Management review: outcomes and follow-up
Many companies have their safety program operating in the ANSI Z10 format to some extent, but they often place electrical safety under the engineering department — only parts are actually “owned” by safety. In order to get real compliance improvement, the safety process must infiltrate the electrical maintenance world. NFPA 70E and CSA Z462 are the U.S. and Canadian standards for electrical safety. Implementing a strong consensus standard within a continuous improvement process framework will bump up the quality of any electrical safety program.
e-Hazard.com recommends the following elements for an electrical safety program (See NFPA 70E, Annex E):
• Inspect/evaluate the electrical equipment for code compliance.
• Maintain the electrical equipment’s insulation, enclosure integrity and operational reliability, especially breakers and fuses.
• Plan every job and document first-time procedures.
• De-energize whenever possible.
• Anticipate unexpected events.
• Identify and minimize the hazard.
• Protect the worker from shock, arc and other hazards.
• Use the right tools and PPE for the job.
• Assess, audit, and document worker’s skills.
• Audit the principles of the applicable standards.
• Audit employees, contractors, and service personnel for proper electrical safety (contract employees are not covered under your company’s worker’s compensation insurance and represent a greater liability if not working safely).
• Report and investigate incidents and near misses.
• Put action items in place from audited issues and improve the program document, written procedures, PPE and any other findings from audits and incident root cause analysis.
How do you gain >40% compliance?
Train
e-Hazard.com’s research shows that training raises compliance by 10% to 50%, depending on the behaviors. The general study was on basic behaviors like wearing hard hats, etc. Electrical safety habits are new and often not as well-known as basic safety.
Set goals and measure
You have to measure the right things. Start by measuring behaviors like:
• De-energizing, lock out/tagout
• Wearing of rubber insulating gloves
• Verification of meter and absence of voltage
• Wearing of basic arc rated daily wear
• Wearing flash suits for higher level exposures
• Use of insulated tools
• Testing of rubber insulating gloves, blankets and other insulated equipment
This list isn’t inclusive, but these behaviors are easy to measure and yield big results. Most incidents involve no injury when the elements above are used.
Audit, audit, audit
Our firm recommends a three-tier auditing strategy:
Year one: Have an outside firm do an audit, giving you a basic audit framework.
Year two: Have one of your safety people audit your own site.
Year three: Have another safety/electrical person from within your company audit your site, and you audit their site (cross-pollination).
Then start the process over again.
This three-step approach to auditing will be more cost effective and get better results than a single-step approach. Auditing is a learning tool. Outside firms and other people have different approaches, and you can learn from them and then teach others about what you have learned or seen.
Training is great, but it isn’t a “be all, end all.” When I say training here, I mean event training. High-impact training can get some results — it gets attention and introduces concepts. Detailed technical training is also effective, but goes over the heads of some workers and is no more successful in changing behavior than high-impact training.
Companies that want to operate safely must have systems that allow for learning and evaluation of behavioral change. Training alone is not enough to reach compliance in most cases. Statistically, it has been shown that training, goal setting, auditing, and communication of results have been effective in increasing company compliance to safety standards. Implementing both training and auditing into your compliance toolbox will raise the bar in your company more than most methods.
Hoagland is a senior managing partner with e-Hazard.com. He can be reached at [email protected].
SIDEBAR 1: Learning Doesn’t Equal Doing
— a personal experience from Hugh Hoagland, senior managing partner with e-Hazard.com
I walked into the room to do electrical safety training like I have done thousands of times before, and looked around the room. It was a Saturday; I was in my hometown. We do training all over the world, but when I train at home I can’t help but wonder if these guys are someone I know. Are they husbands or wives of friends? Do my kids go to school with them?
Like so many times before, I walked into a company that had received an OSHA citation due to an employee complaint. Because of this, the company decided to join the OSHA VPP (Voluntary Protection Program) to improve its safety program. VPPs began in California under Cal-OSHA in 1979, and were embraced by federal OSHA in 1982. Then, they were offered to all employers in 1998. The VPP sets performance-based criteria for a managed safety and health system, and one of their current foci is electrical safety. Since electrical incidents are the fifth leading killer of employees, it is an important focus, made even more so since the NFPA 70E made arc flash a household term in the year 2000.
Through the VPP, OSHA regularly audits and helps companies improve their safety program. If improvement is seen, they do not cite the company for violations. The site I visited on this day had been in the VPP process for some time and had just identified the electrical safety need after an OSHA consultation.
After my Saturday class, I returned the next Saturday to train the day crew. I was shocked to see the same PPE kit was still there with all the tags still on each piece. This was their only kit to share with five workers on each shift. They had not implemented anything taught the week before! The employees clearly understood what was communicated, but their learning had not translated into doing.
In talking with the employees, I found out that the plant manager kept the kit locked up in his office, and the night shift had no access. “That kit was expensive, and I don’t want them ruining it. Besides, they are not supposed to do energized work,” the plant manager reportedly told the safety director, who had since left the company. When we went back for a free audit the next month, things were a little better, but my feedback that day had begun a slow slog toward real safety change. I’ll admit I was angry at the safety director at first, and still am angry at the plant manager who didn’t have enough time to listen to a qualified safety director and learn that even voltage testing requires PPE.
SIDEBAR 2: How Auditing and Training Lead to Results
To really succeed in the safety profession, we must be students of learning and adult psychology. In 1984, David A. Kolb published a ground-breaking book entitled “Experiential Learning: Experience as the Source of Learning and Development” (Englewood Cliffs, Prentice Hall). The book exposed the principle that a person would learn through discovery and experience. Kolb developed a learning cycle (Figure) after extensive research, and it can help with understanding why auditing is so important.
All learners go through phases of learning. Some of these phases happen quickly, if the behavior is readily understandable or easy to implement. Behaviors can change quickly, but many factors (such as individual learning differences) can make behavior change more difficult. Even if a new behavior takes little effort initially, some people may reject it because they don’t believe it’s important.
How do adults learn? Kolb says we experience, reflect/review, learn/conclude and try it out every day. In event training, if the learning can’t be implemented because of hindrances in the workplace, peer pressure, or whatever reason, it will often be unlearned or forgotten.
Goal setting and auditing help training get implemented. When you set goals and audit them, it helps identify failures in motivation, systems (you can’t wear rubber insulating gloves if you don’t have them), and understanding (with new behaviors, especially complex ones, people may not fully comprehend the requirements). Auditing spurs more training, helps clarify the behavioral goals, and tweaks the system so these objective goals can be met and have the desired effect of no injuries.
