Organizations forced to send workers into the teeth of energized electrical equipment face a generally toothier set of rules for ensuring their safety heading into 2015. The National Fire Protection Association’s newly revised Standard for Electrical Safety in the Workplace (2015 NFPA 70E) seals off routes of escape from best safety practices and nudges organizations in the direction of more efficiently maintaining electrical equipment, adequately training workers, and sizing up risk more prudently.
Beneath the surface, though, the revisions also attempt to achieve a delicate balance between better protection of workers under any and all circumstances and unburdening employers from the varied costs that can stem from overestimating hazards. But if anything, the updated standard is a much more prescriptive document that demands more out of those responsible for ensuring the safety of those working with and around electricity. Yet it does so in a way that strives to inject more common sense and logic into the process of establishing a safer work environment.
At the revision’s core is a new, more explicit emphasis on gauging the actual risk of workers encountering the twin deadly hazards of electric shock and arc flash. It lays the groundwork for assessing risk based on all of the variables that come into play, including the nature and potential magnitude of the hazard; the state and condition of the equipment in question; the likelihood of its occurrence; the task at hand; and the extent of detailed analysis performed to establish a hazard level. Prioritizing the determination of tangible risk over merely identifying the hazard in isolation, the new 70E is ultimately designed to establish a new mindset geared to marshaling all resources to produce an optimally safe work environment for electrical workers.
“We’ve focused on identifying hazards in the standard over the last 20 years, but now we’ve taken a step and said, ‘Okay, we’ve got a hazard or a potential hazard, now what’s the risk to an employee?’” says Dennis Neitzel, a principal committee member of the NFPA 70E Technical Committee who is director emeritus of AVO Training Institute, Inc., a Dallas-based electrical safety training and consulting company. “Risk assessment is a significant part of determining what needs to be done to protect employees. Hazards exist everywhere, but the question that has to be answered is whether exposure to the hazard actually exists.”
New definitions in 70E reflect the committee’s intent to emphasize the consideration of tangible risk and to justify numerous fundamental changes to prescribed procedures, calculations, and methodologies for assessing and mitigating it properly.
Risk is now formally defined as “a combination of the likelihood” of injury or damage and its severity “that results from a hazard.” Risk assessment is deemed “an overall process that identifies hazards, estimates the potential severity of injury or damage to health, estimates the likelihood of occurrence….and determines if protective measures are required.” In some places, the word “hazard” has been tossed out; the term, “arc flash hazard analysis,” for instance, is now “arc flash risk assessment,” and such substitutions were made for the conventional terms “shock hazard analysis” and “electrical hazard analysis.”
Beyond the semantics, however, are some important changes to how things have typically been done. In pursuit of a higher margin of workplace electrical safety, the revised standard lays out a more rigorous, and perhaps smarter, approach to a wide variety of tasks performed ahead of placing workers in harm’s way. Let’s focus on five key areas of the new standard where revisions have been made to dovetail with the increased focus on understanding risk.
The “table method.”
The use of tables to quickly determine arc flash boundaries, and the permitted maintenance, diagnostic, and testing work and appropriate personal protective equipment (PPE), carries more restrictions in the new standard. Fearing reliance on the tables was leaving the door too open to perform technically unsafe work, the committee restricted the applicability of the tables.
Specifically, the task in question must appear in the table, and the system must meet the listed criteria for short circuit current and speed-of-response protection. If these conditions are not met, the tables now cannot be used, and an engineering analysis must be performed to formulate tailored arc flash protection and PPE requirements.
The procedure for using the tables has changed with the revision. First, a single task-based table that covers both AC and DC systems is consulted to determine whether arc flash PPE is needed based on task and equipment condition. If it is, users consult new equipment-based tables for either AC or DC systems. Those tables list the equipment, arc flash PPE category, and the arc flash boundary.
While more cumbersome, Neitzel believes the new multi-step procedures will help ensure workers are properly protected. The old requirements often resulted in workers resorting to too much or not enough PPE for the task. The change will help ensure that the potential hazard is clearly identified and that the most appropriate PPE is used.
“With the arc flash, we have to know the incident energy in order to determine what the protection boundary and PPE requirements would be,” he says. “Even if the PPE category tables are used in lieu of the incident energy analysis, which the standard allows, the short circuit current and protective device clearing times must be known, so that does not go away. Even though we don’t state hazard analysis, it is still something that must be done.”
Equipment condition
Properly maintained equipment is one of the first lines of defense against electrical injury, and the revised 70E addresses that risk factor more directly.
Section 130.2, for instance, is clearer now on what equipment conditions must exist for workers to undertake “normal operations” on enclosed equipment. Such operations may be considered to pose lower arc flash hazards and thus may not require PPE. Section 130.2(A)(4) was added to clarify that “normal operation” is permissible when “the equipment is properly installed (conforming to manufacturer recommendations and industry codes); properly maintained (in accordance with manufacturer recommendations and applicable codes and standards); all equipment doors are closed and secured; equipment covers are in place and secured; and there is no evidence of impending failure (such as arcing, overheating, loose or bound equipment parts, visible damage, or deterioration.”
With more clarity on when normal operations can be done safely without PPE, workplaces may have a greater incentive to keep equipment in a safe condition, says Hugh Hoagland, founding principal of e-Hazard, a Louisville, Ky.-based arc flash testing/PPE and training consultancy, who has studied the revised 70E. While many workplaces may still choose to put these workers into PPE, the standard’s new language will help those who see a value in using prevention as a risk management tool alongside protection.
“More are adopting a philosophy of ‘what if we just try to maintain this stuff better?’” he says. “They’re saying, let’s just try to make it not hazardous; let’s properly install it and maintain it so it doesn’t blow up when they operate it.”
The revised standard also firms up the guidelines and best practices for keeping the margin of safety high on all types of electrical equipment that workers may encounter during operation, repair, or maintenance procedures. Now, for instance, maintenance, inspection, and documentation are required for equipment overcurrent protection devices that serve a fail-safe function. Section 205.3 mandates maintenance for adherence to manufacturer specifications or industry standards. And the standard makes it clear that responsibility for maintenance and associated documentation rests solely with the equipment owner.
Worker capabilities
Because actual worker risk is reduced, the more they understand the electrical equipment, PPE, and precautionary techniques, the 70E committee sets a higher bar for determining qualifications in the new standard. Now, training and education on their own are insufficient.
To attain qualification to work on or around electrical equipment, workers must be able to demonstrate proficiency. Specifically, the standard says workers must show they can use special precautionary techniques; PPE, including arc flash suits; insulating and shielding materials; and insulated tools and test equipment.
Upping the requirement for exhibiting proficiency is logical, especially in light of the new emphasis on tangible — not hypothetical — risk reduction, says Doug Tellin, owner of Electrical Safety Specialists, a Louisburg, Kan.-based safety training company.
“Qualified used to mean trained, but now we’ve added the phrase “demonstrated skills,” he says. “So just watching a video, say, on arc flash isn’t enough. It requires classroom and hands-on time — and the ability to have proficiency documented.”
Labels
While the new standard might be summed up as encouraging closer approximations of specific risks using engineering analyses, new language does speak to the importance of not overlooking the need for clearly presenting accurate system information as a starting point.
Imprecise language included in past standards referenced the need for electrical equipment labeling. Picking up where the 2012 standard left off, the new 70E names equipment subject to the requirement and the type of information needed. Switchboards, switchgear, panelboards, industrial control panels, meter socket enclosures, and motor control panels are specifically noted. And the standard now makes it clear that field labels must reveal nominal system voltage; arc flash boundary, minimum arc rating of clothing needed; site-specific level of PPE; and either available incident energy/safe working distance, or arc flash PPE category for the equipment. Additionally, the standard now requires that labels be current; Sec. 130.5 states that if major modifications or renovations occur, updates may be needed if an arc flash risk assessment conflicts with the label. This section also requires the electrical distribution system to be reviewed periodically, not to exceed five years, to determine if changes have been made that would affect the results of the arc flash risk assessment.
“It’s important to determine what kind of exposure an employee may have, and this is part of the new message — that employers have to identify the risks so workers can be properly protected,” Neitzel says.
Related work
Because a fair number of electrical accidents occur outside the scope of direct maintenance or operation of equipment, the standard extends the risk assessment concept to work that can lead to unexpected contact with exposed energized electrical conductors or circuit parts.
Section 130.10 now requires an employer to conduct a risk assessment before cutting or drilling into equipment, floors, walls, or structural elements that may contain energized electrical system components. The likelihood of the work making contact must be assessed, and steps should be taken to limit the risk of electrical injury.
“That’s something that’s been implied but never spelled out, and it’s significant,” Neitzel says. “I’ve seen situations where people have drilled through a concrete floor and directly into a 13.8kV feeder line. There have been far too many cases of things like that happening, and that’s why we spelled it out. It’s part of the mindset of assessing the situation to find out if it’s safe before you do something.”
And that’s precisely what NFPA is encouraging more of in its 2015 standard — one that appears to take a fresh, more thoughtful approach to an ageless problem.
Zind is a freelance writer based in Lee’s Summit, Mo. He can be reached at [email protected].
SIDEBAR: Finding Common Ground
The daylight between the National Fire Protection Association’s (NFPA’s) standard for workplace electrical safety and the rules the “feds” can enforce may be narrowing. As NFPA rolls out revisions to its standard focusing on better risk assessment, the Occupational Safety & Health Administration (OSHA) is clamping down in tandem.
For one thing, OSHA regulations and NFPA standards appear to have drawn closer on worker electrical safety training. The 2015 NFPA 70E standard now mirrors OSHA’s definition of a “qualified person” permitted to engage in some riskier electrical maintenance work. Both organizations now mandate demonstrable skills.
“What OSHA wants is documentable, demonstrable proficiency,” says Doug Tellin, owner of Electrical Safety Specialists, a Louisburg, Kan.-based safety training company. “You’ll find the majority of the information now in one place, versus having to refer to other standards.”
OSHA also is picking up the baton from NFPA on better addressing arc flash risk in the workplace. A new OSHA rule took effect last fall that requires electric utilities and industrial facilities to develop better training and procedures for addressing high-voltage arc flash hazards. There are indications, Tellin says, that OSHA is using the new tools it has more aggressively.
“I was told by an OSHA compliance officer recently that agency enforcement in the electrical safety area has been increasing dramatically,” Tellin says.
OSHA also is armed with new authority to poke around in the wake of worker injuries, opening a new avenue to cite employers for non-compliance, according to an occupational health and safety attorney, Mark Lies, with Seyfarth Shaw, LLP, in Chicago.
“Now, if there’s an electrical accident that results in a hospital admission, an employer must notify OHSA within a day,” he says. “And that can trigger inspections.”
