Wednesday, October 17, 2018

Can You Explain the New Safety Regulations from NFPA 70E 2018 to Your Team?

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:

1. Mandatory application of a “Hierarchy of Controls” to any work task to reduce risk
2. Human error must now be considered as part of the Risk Assessment Procedure
3. 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.

New Safety Regulations

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 1^st and 2^nd degree burns but will not prevent contusions, lacerations, concussions or broken bones should an arc blast pressure wave occur. 

Conclusion: 

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.