The safety officer at your company held three meetings in September to educate the staff on the revised 2018 Edition of NFPA 70E regulations that outlines the “work code: for how personnel should work on electrical equipment safely. In a recent article, we reviewed the “Hierarchy of Controls” put forth by the NFPA where Elimination was at the top of the Hierarchy and Substitution was the second tier. To comply with the regulations, your company is considering adopting Infrared Inspection Windows to eliminate hazardous conditions when electrical assets are inspected. You have heard about IR Inspection Windows; however, you would not be comfortable defining the term to your peers. So, you decide to research the term and self-educate for a complete understanding. What is an Infrared (IR) Inspection Window? Let’s find out!
An Infrared Inspection Window is a window that is used to separate environments of differing pressures or temperatures while allowing light energy at a specified electromagnetic wavelength to pass between the two environments. IR Windows are also called viewports or viewing panes and must meet the strength and environmental requirements for the type of equipment in which they are fitted. The Windows must also be compatible with the infrared equipment being used. The Windows can be various shapes and sizes (square, round, rectangular or custom). IR Windows are an inspection point that is designed to allow infrared radiation to transmit to the outside environment so that a data point can be recorded using a thermal camera.
Why are Infrared Inspection Windows Desirable?
Electrical inspections must be performed on equipment that is energized and under “full load” conditions. Thousands of electrical workers are injured or killed each year on the job while performing electrical surveillance or maintenance on energized electrical systems because they open the panel to collect the data and expose themselves to energized electrical components. Per the NFPA 70E Hierarchy of Controls, if the hazard of a “fully loaded” asset can’t be eliminated, is there something that can be “substituted” that would eliminate the hazard? The answer is yes, IR Inspection Windows.
IR Inspection Windows enable the following:
1. Collection of real-time, condition status data on critical electrical systems and components under full load using the window without opening panels.
2. Mitigates the risk of injury or death of electrical workers who perform these inspections because the window maintains an enclosed and guarded condition, so personnel can perform temperature readings, thermal imaging and visual inspection without exposure to energized compartments.
3. A comprehensive, safe and intelligent protocol be designed and used for performing essential energized inspections on electrical equipment
IR Windows are one example of an Electrical Maintenance Safety Device [EMSD] that allows safe access for a thermographer to inspect energized electrical equipment. A previous article discussed EMSDs and why they are important in today’s environment.
What is an Ideal Infrared Inspection Window?
The ideal IR Window should have high transmittance, low emittance and low reflectance. It should allow all the infrared radiation to pass through it with zero loss. While windows cannot achieve zero loss of infrared radiation, they are very close to this ideal goal.
Types of Infrared Windows
There are different types of IR Windows:
1. Viewing Panes – windows that have a lens secured in a housing. Because the lens forms a seal between the internal and external environments, the inspector is not directly exposed to energized components and minimizes or eliminates the need for high levels of Personal Protective Equipment (PPE).
2. Inspection Grills – a window that contains a grill or “mesh” in place of a solid optic and typically found in mechanical applications for machinery guards or where both infrared and ultrasound data can be captured from the same access point. When opened, a grill does not maintain an IP65/NEMA 4 enclosed seal to protect workers from the energized components; therefore, elevated PPE is required.
3. Inspection Ports – infrared ports are usually no more than 15mm in diameter and can contain specialty lenses or adapters. The ports can be open (like a grill) or sealed with a lens (like viewing panes). The inspector must understand whether the port is open or sealed to determine the level of PPE required.
4. Custom Solutions – certain assets previously determined to be “un-inspectable” due to high energy levels or because a metal obstruction prohibits viewing the bus joints or connections may require a custom design of IR Window. It is possible to design custom IR Windows in various shapes and sizes to accommodate these situations.
Inspection Windows Are Evolving
Technology has enabled Inspection Windows to evolve providing more benefits to end-users. A perfect example of this is an Infrared Inspection Window that now has an ultrasound port which expands the utility of that window to include ultrasound, visual and infrared inspection capabilities. Future articles on IR Windows will explain the types of lenses used, advantages of polymer vs. crystal windows, applications for IR Windows, emissivity and financial benefits using IR Windows.
Conclusion: “Infrared Window” is a generic term as there are several categories of IR Windows available. When installed on energized electrical equipment, IR Windows should maintain an “enclosed and guarded” condition for the cabinet enclosure providing a safe working environment and minimizing the need for high levels of PPE. Inspectors must always understand if they are working with open or sealed environments to determine the level of PPE required to protect themselves from hazards. Windows are evolving as newer technologies become available.
In our last blog titled Can You Explain the New Safety Regulations from NFPA 70E 2018 to Your Team?, we learned that, for the first time, NFPA states that human error must now be considered as part of the Risk Assessment Procedure (RAP). Can human error be eliminated or only minimized in electrical inspections? Let’s find out!
Workplace electrical accidents such as shock, electrocution, arc flash and arc blast, claim hundreds of lives and cause thousands of burn injuries each year In the United States. In the 2018 edition of NFPA 70E, a guideline was added that human error must now be considered as part of the RAP and must address the potential for human error and its negative consequences on people, processes, the work environment and equipment. The NFPA 70 E document includes a helpful segment titled Informative Annex Q which is not part of the requirements but provides information on what to consider when evaluating the RAP as it pertains to human error and offers tools for incorporation into the RAP to minimize the occurrence of human error.
Studies have reported that human error is often the root cause of incidents in high-risk industries. In the last blog, we learned about the Hierarchy of Controls established by NFPA 70E to reduce the likelihood of an incident occurring or to prevent/mitigate the severity of consequence should an incident occur. No control is infallible – therefore, human error most likely can only be minimized but not eliminated in every situation.
Information Annex Q defines Error Precursors as situations where the demands of the task or the environment the task is performed in exceed the capabilities of the individual or the limitations of human nature. There are four types of error precursors:
1. Task demands: when specific mental, physical or team requirements to perform a task either exceed the capabilities or challenge the limitations of the individual doing the task
2. Work environment: describes influences of the workplace, the organization or cultural conditions that affect an individual’s performance
3. Individual capabilities: when an employee’s mental, physical and emotional characteristics do not match the demands of the task
4. Human nature: when a person’s traits, disposition or limitations common to all people cause an individual to err under unfavorable conditions
Once error precursors are recognized, an organization can review their procedures to determine what precautions or necessary steps can be implemented to reduce the occurrence of incidents caused by human error.
Human Performance Tools
Some helpful suggestions in Informative Annex Q are called Human Performance Tools that could help reduce the likelihood of error when applied to error precursors. Incorporation of some or all of these tools into an organization’s processes and procedures could result in best practice work and help minimize human error.
1. Job Planning/Pre-job Briefing: A job plan along with briefings helps employees focus on the task, the performance of the task and their role in executing the task. Critical steps of the task need to be explained in detail along with the risk and consequences should human error occur. Contingency plans should include steps to prevent or recover from an error.
2. Job Site Review: A physical viewing of the job site with employees and pointing out the hazards and barriers could be performed before initiating the job.
3. Post-Job Review: This is a perfect opportunity for employees and managers to share feedback and discuss lessons learned making future jobs safer or less risky. This review could also provide as a learning tool for new or less experienced employees.
4. Procedures: Using a written step wise procedure to complete a task and having the employee read and understand the purpose, scope and intent of the task will prepare the employee for the work and hopefully reduce the risk of human error.
5. Self-Check: STAR is a great self-check tool and stands for – STOP, THINK, ACT and REVIEW. Using this approach before, during and after a task helps keep the employee focused on the work at hand and hopefully increases their awareness of any hazards associated with the task.
6. Three-Way Communication: If applicable, this is a verbal issuance of a command from a sender to a receiver followed by the receiver repeating the command back to the sender confirming accuracy of the message.
7. Stop When Unsure: Enables an employee to stop working on a task if they are unable to understand a procedure or if something unexpected occurs. It also can be used if the employee has a gut-feeling that something is not right.
8. Flagging or Blocking Tools: Marking or labeling a piece of equipment to properly identify it ensures that the actual piece of equipment can be visually identified by employees. This is important if there are many pieces of equipment in the space or multiple pieces of equipment that are different but may look alike. Blocking tools are ways of physically preventing access to an area or piece of equipment. Examples of blocking tools could be hinges, switches, barricades, fences, etc.
NFPA 70E is the “work code” that defines how personnel should work on electrical equipment safely. Workplace culture is controlled by the management team. A management team that embraces procedures that help prevent errors, values employee safety, encourages open communication among all employees and incorporates human performance tools will cultivate a safer work environment.
Your Occupational Safety Manager asked you to present the 2018 changes from NFPA 70E at the next team meeting in a few weeks. You saw something about the release of these new regulations on an industry website, but you never had the time to investigate what was new. Upon reviewing the length and depth of the new publication, you realize that you will only have enough time to present the highlights of the new regulations at the next team meeting. As you begin preparing for your presentation, two questions come to mind: 1) What are the highlights of NFPA 70E 2018? 2) More importantly, how will they impact our job responsibilities? Let’s find out!
Workplace electrical accidents such as shock, electrocution, arc flash and arc blast, claim hundreds of lives and cause thousands of burn injuries each year In the United States. OSHA requested that NFPA 70E be created because as new technologies become available, it is recognized that most of these fatalities and injuries could be prevented; hence the publication NFPA 70E: Standards for Electrical Safety in the Workplace® evolved.
There are three key changes in NFPA 70E:
- Mandatory application of a “Hierarchy of Controls” to any work task to reduce risk
- Human error must now be considered as part of the Risk Assessment Procedure
- Removal of the 40cal/cm2 limit statements because 1.2 cal can be dangerous to workers not using the proper Personal Protection Equipment
You have decided to focus solely on the Hierarchy of Controls for your presentation and recommended that several team meetings be scheduled to properly cover the remaining elements of the new regulations. So, let’s explore the Hierarchy of Controls section of NFPA 70E 2018.
Hierarchy of Controls
The Hierarchy of Controls must be applied in ORDER reducing the level of risk as low as possible. As you move down the Hierarchy, the level of human error will increase. Let’s explore the hierarchy:
First Control – Elimination of the Hazard
Most electrical equipment must be inspected under ‘normal’ load to obtain accurate infrared or ultrasound data; therefore, de-energizing the equipment and eliminating the hazard is not possible. Note – inconvenience to the facility’s operation is not sufficient cause to move to the next Hierarchy of Control.
Second Control – Substitution
Can the item with the hazard be replaced with something that does not produce a hazard? Fortunately, new technologies have resulted in new product designs, called “Safety by Design”, enabling electrical inspections to be performed under normal load without opening the equipment doors or covers that expose workers to risk. These new products, Electrical Maintenance Safety Devices (EMSDs), fall under the substitution control and have redefined how inspection procedures of electrical assets can be performed. Although there is a cost associated with implementing EMSDs, the benefits of making inspection procedures easier and safer outweigh the cost and, insure that procedures are in compliance with the Hierarchy of Controls. Note – cost of implementation alone is not justification to go to the next Hierarchy of Control!
Third Control – Engineering Controls
This control involves a physical or design change to the equipment rather than relying on the worker’s behavior or requiring workers to wear protective clothing. Engineering controls must protect the worker from himself or implement design changes to reduce hazard levels. Examples include adding more insulating guarding or finger safe components; using high resistant grounding in place of solid grounded systems; installing arc resistant switchgear and even installing tamper resistant hardware and door interlocks that prevent access to hazardous energized electrical equipment. By implementing engineering controls, the work task will expose the qualified person to reduced electrical hazards and consequently reduce the resultant potential for injury. Note – cost of implementation alone is not justification to go to the next Hierarchy of Control!
Fourth Control – Awareness
Documented Job Safety Plans, created by qualified personnel, must be in place and must identify the work tasks, electrical hazards associated with each task, a documented shock risk and arc flash risk assessment for each task and define procedures involved with each task along with any special precautions. Signage is part of this control. Signs must be installed on electrical equipment identifying the type of equipment and include arc flash and shock labels if necessary. Note – without a plan, you cannot move to the next Hierarchy of Control.
Fifth Control – Administrative Controls
Safe work procedures and employee training go hand-in-hand. Training must be documented, and re-training or certification must be scheduled at proper intervals. Unqualified personnel must also receive basic training on electrical safety practices. Note – only after Awareness and Administrative controls are in place can you advance to the last Control!
Sixth Control – Personal Protective Equipment (PPE)
PPE is the least effective means of controlling hazards and risk. PPE can be damaged, worn improperly or incorrectly selected for the task/hazard at hand. Certain PPE can cause worker fatigue or heat stroke if periodic breaks or rest periods are not used. Note – PPE will only limit burn injuries to 1st and 2nd degree burns but will not prevent contusions, lacerations, concussions or broken bones should an arc blast pressure wave occur.
NFPA 70E is the “work code” that defines how personnel should work on electrical equipment safely. The Hierarchy of Controls is mandatory for work tasks and must be followed in order from the First Control to the Sixth Control. Risk and hazards increase in frequency as you move down the Hierarchy and there are distinct warnings stating that inconvenience or cost does not justify moving to the next control level. Fortunately, technological advances have enabled new devices and equipment be available to meet the Second Control of Substitution. These Electrical Maintenance Safety Devices are easy to adopt and use by personnel and they help achieve the ultimate goal of increasing personnel safety in the workplace.
Your plant management team has held several employee meetings in preparation for replacing the current calendar-based inspection program with a condition-based program. During these meetings, Electrical Maintenance Safety Devices were introduced and will be used by the asset inspectors. A few co-workers asked what industries have already adopted EMSDs. Since your management team strongly supports peer-to-peer training, you volunteered to research the answer to this question for the next meeting. What industries use EMSDs? More importantly, why do they use them? Let’s find out!
The adoption of electrical maintenance safety devices in industrial applications increases annually. Industries acquire EMSDs by purchasing new equipment or by retrofitting their existing equipment. What factors are driving this adoption? It’s all about worker safety and risk reduction.
Organizations focused on safety and risk reduction continuously revise their standards and regulations as technology becomes available. Using electrical safety as an example, new standards and regulations from OSHA, NFPA, CSA, IEEE, ANSI and NETA drive companies to evaluate their existing procedures to determine if they are compliant with the latest regulations. As equipment becomes more complex and standards become stricter, most companies must make changes and many times, those changes involve upgrading existing equipment or purchasing new.
Electrical Maintenance Safety Devices enable companies to save money by increasing the efficiency and safety of work processes. Their use decreases or eliminates unproductive man-hour labor by reducing or eliminating the use of personal protective equipment (PPE) and high-risk tasks such as removing electrical panel covers. The new inspection process using EMSDs will streamline the work, eliminate up to 95% of the unproductive man-hour labor costs, increase personnel safety and improve the quality of the inspections.
Clients using or needing EMSDs come from a variety of industries. Basically, any industry that relies on the constant flow of electricity as critical to operations would benefit from using EMSDs. Let’s list a few of these industries:
- Electrical Component Manufacturers
- Electrical Supply Houses
- Service Companies such as Call Centers
- Beverage Producers
- Chemical Plants
- Offshore Platforms
- Shipbuilders & Ship Owners
- Data Centers
- Power Generation Plants
- Consumer Electronics
- Food Processing
- Large buildings/Office Complexes
- Metal Processing Plants
- Municipal Water & Waste Water Plants
- Paper Mills
- Pharmaceutical Plants
- Printing Plants
- Electric Railroads
As you can see, this is an extensive list of industries and there are probably some missing too. Imagine the loss of revenue if power at an airport or offshore platform goes out. Imagine the customer inconvenience if a power generation plant or telecommunication company goes offline due to an electrical failure.
Adopting EMSDs as part of electrical maintenance inspections offers many values to multiple types of industries. Improved operational reliability and productivity can be accomplished by implementing electrical maintenance safety devices [EMSDs] to monitor, maintain and anticipate problems with their electrical systems. These industries, after adopting EMSDs, recognize safer working environments, compliance to standards and regulations and overall improvements to reliability which in turn minimizes downtime and the potential loss of revenue. You are now equipped with information to present at your next team meeting!
Manufactured in 2013, the Maersk Intrepid is a drilling rig that has been designed
to operate in the extremely harsh environment of the North Sea. Up to 150 people
stay on the rig at any one time so, safety and fire prevention are paramount and to
minimise the risk Maersk operates a rigorous preventative maintenance programme
for all electrical equipment on board, in line with NFPA 70E and SOLAS regulations.
This proactive client wanted to monitor the electrical panels and disconnects
throughout his facility daily versus annually. Delta T Alert’s installed on all critical
enclosures within the facility. The Delta T units were programmed to record
temperature rise within the enclosures two times a day.
Who purchases Electrical Maintenance Safety Devices [EMSDs]? Who uses them? These are questions asked by employees when technological advances, like EMSDs, become available. What if your company has a go-live date in 120 days for incorporating [EMSDs] as part of the electrical asset inspection routes throughout the plant? Perhaps the management team has conducted a few team meetings to introduce the new inspection program and the new EMSDs that will be used. Employees will have questions. Why is it so important to change the inspection program and use EMSDs? Why are EMSDs attractive to the management team? What benefits will the end-user recognize while using EMSDs?
It is well documented that electrical equipment requires periodic maintenance to maintain normal operations and that these inspections are performed on the assets operating under full load conditions. Prior to the innovation of EMSDs, these inspections were time-intensive and required access panels to be opened which is extremely dangerous to the personnel performing the inspection. In the last blog, we defined what an EMSD was and what types of EMSDs are available to perform safe and reliable inspections of electrical assets with minimal to no PPE required. The overall outcome is to find the fault before the asset fails! Now, let’s talk about why companies are adopting EMSDs for their maintenance inspection programs, who buys them, who uses them and why.
Companies are focused three key initiatives: Reliable operations, providing the highest level of safety to their employees and controlling operational costs. The use of EMSDs provides value to all three initiatives.
1. Constant flow of electricity is critical to operations and profitability
2. Improve overall reliability by maintaining manufacturing infrastructure and electrical assets
3. Using EMSDs for electrical equipment monitoring to avoid faults and failures that could result in costly downtime
4. Strong commitment to employee safety and strong aversion to accidents and regulatory fines (OSHA)
5. Desire to improve the efficiency and accuracy of equipment monitoring and data collection
What’s In It For the Technical Buyer?
The technical buyer of EMSDs is most likely in a management role and is responsible for managing either the employee safety program or the asset inspection program or perhaps, both. Their titles may be Environment, Health and Safety Manager, Maintenance Leader, Reliability Leader, Electrical Program Manager or Electrical
Engineer. Regardless of title, their goals are common: Keep the Plant Operations Running and Maintain Employee Safety. They are responsible for tracking data associated with:
* Risk Management
* Avoidance of unplanned downtime
* Labor hour efficiency
* Data Management
* Compliance to standards and local regulations
The technical buyer recognizes that using EMSDs as part of a condition-based maintenance program will ensure safety, accuracy, efficiency and long-term ease of use for the users with minimal supervision. They are able to provide data to upper management illustrating how the use of EMSDs provides a clear and meaningful return on investment (ROI).
What’s In It For The Economic Buyer?
The economic buyer is part of the company’s upper management and is responsible for facility profitability and managing overall costs. Their titles may be Plant Manager, Facility Manager, Corporate Purchasing Agent or Corporate Reliability Leader. Loss of production time due to an unplanned stoppage is this person’s worst nightmare. This manager is driven to search for ways of doing more with less – in other words, increasing efficiency and cutting out excess costs. Their responsibilities include making purchasing decisions based on:
* Cost benefit analyses (ROI)
* Ensuring overall plant safety by reducing accidents
* Purchasing the best fit products at the lowest price
* Peer Case Studies
Once the economic buyer recognizes the ROI of using EMSDs in the inspection and maintenance programs, they will support the purchase of EMSDs and feel confident in their decision.
What’s In It For The End User?
The end user is the person who actually uses the EMSDs while they perform the routine inspections. Their titles may be Maintenance Technician, Condition Based Maintenance Technician or Maintenance Engineer. They are responsible for periodic inspections, data collection and record keeping. Safety is a top priority, so these are the people that have historically worn the Personal Protective Equipment (PPE) for extended periods of time. Their motivators are:
* Ease of Use
* Minimizing time wearing PPE
* Accurate inspection data collection
The end users will easily adapt to using EMSDs when they see how simple they are to use during an inspection and that minimal to no PPE has to be worn.
The benefits of adopting EMSDs as part of maintenance inspections offers many values to multiple types of employees within a facility. Improved operational reliability and productivity can be accomplished by implementing electrical maintenance safety devices [EMSDs] to monitor, maintain and anticipate problems with their electrical systems. The end user finds EMSDs easy to use while eliminating the need for wearing PPE.
The Technical buyer gains efficiency in operations and minimizes safety risks. The economic buyer can demonstrate efficiency while reducing overall operating costs. The company recognizes overall improvements to reliability which in turn minimizes downtime and loss of revenue.