Implementing 70E in the Electrical Construction Workplace

The development of NFPA 70E–2000 provides a roadmap for any employer to develop an extremely effective electrical safety program, which if followed, would most probably eliminate future electrical injury and fatalities. I believe there would also be a side benefit of increasing both management’s and their electricians’ overall safety awareness of other hazards as well. Many electrical contractors have both real financial roadblocks and misconceptions that are impediments that hinder implementation of many components of 70E. The roadblocks of misconceptions consist of: perceived costs associated with implementation, such as special equipment and hours of employee training; acceptance and willingness to implement the program by their electricians; and the horrific belief by both management and electricians that shock, injury, and fatalities are just part of the job and only those who are careless or lack skills suffer the fate of injury.

At the 2003 IEEE IAS Electrical Safety Workshop, several statistics provided by Dr. Mary Capelli-Shellpheffer indicate just how much of a problem we face in eliminating just electrically caused injuries. Between 1992 through 1998 there were 32,309 non-fatal electrical injuries, and in 1999 there were 278 fatalities from contact with electrical current and 216 from fire and explosion in construction alone. Financial costs of one electrical injury example cited was: $650,000 of initial medical treatment which included five major surgeries, $250,000 for five repeat admissions for reconstructive surgery, and $250,000 for five years of rehab of over 100 patient visits. (One cannot imagine the emotional costs or the pain that the injured individual has gone through and is going through even now.) The company had an additional $350,000 of direct costs. Multiply the total of $1,500,000 by your choice of recognized factors for indirect costs (between 3 and 8). How does a company recover from costs such as these?

If one does a root cause analysis on any injury or fatality, the bottom line is almost always human error by the victim or by another, and the injured individual was the event that occurred just before the incident. The human error factor can be either eliminated or its probability significantly reduced to almost zero potential of occurrence through exerting as much diligence in achieving safety as in obtaining and doing the work. The axiom “Work must be part of the safety environment” instead of “Safety is part of the work environment” must be the company’s attitude. NFPA 70E provides the framework to establish the safety environment.

Whether management is willing to accept it or not, improper management is always a significant factor that is revealed in a root cause analysis. Those management factors that are most often delineated are: failure to provide proper training; failure to provide proper procedures; failure to provide proper tools for the job; failure to provide proper protection; failure to recognize the potential for a hazard; failure to correct or eliminate improper behavior and work practices by employees; and last but not least, the all encompassing failure to provide a safe place of employment.

The electrician contributing factors are just as serious: failure to follow training that was provided; failure to follow proper procedures; failure to utilize proper tools; failure to practice safe behavior; failure to recognize the hazard; and failure to create a safe work environment for one’s self and others.

Both sides share one common factor, which is the failure to acknowledge that there is a potential hazard. How often has one heard, “This is construction, there are dangers, just learn to live with it. Only those that are careless and don’t pay attention get injured!” Electrical hazards are different. Sure, we can see that the extension cord is damaged, but it still works and we think, “I’ll fix tomorrow.” We cannot see electricity or the power it possesses, so we ignore the hazard. We cannot see the wrench inadvertently left in the panel by the previous person to work on it, so we ignore the potential for hazard when the bolts are removed to service an electrical panel. There is also a belief held by many electricians that if an arc flash occurs, they can jump out of the way (physically impossible), much like if they see an object falling off a scaffold, they can jump out of harm’s way. If there is an electrical incident, most people will not acknowledge that their actions or lack of actions; the ignored work conditions; their past training; or lack of training were major contributing factors in getting injured or causing the incident to occur. When an individual completes his or her apprenticeship and is given journeyman status, there is a major misconception that he/she is now qualified for any kind of electrical work, when in fact, just like any profession, the learning process is just beginning and is a continuous process. The basics are usually present but not the learning that experience brings. In many cases, the on-the-job instructor taught his unsafe shortcuts to the apprentice, just as they had been taught to him. There are still practicing electricians who will test for voltage on 220-V AC and lower by “walking the panel with thumb and finger.” Or how about the practice of wrapping the shaft of the screwdriver with electrical tape to insulate it so they will not get shocked? Or even worse, is the instruction of the left hand rule for disconnects. We acknowledge the potential for the disconnect to blow-up and best procedure we can instruct an electrician to do is to risk you’re his or her left hand to serious injury! We all know of other unsafe practices that are still being done today and passed down to a younger generation. We do not acknowledge the hazards because it would mean a 180-degree change of how things are done.

Over the years of the changing work environment of compressed building schedules, productivity demands on every trade, higher current levels in use coupled with new and improved electrical components, and pressures to do more with less all combine to increase pressures on the individual electrician as well as on the contractor. The last thing a contractor wants is another set of perceived untested and unneeded regulations that he believes will slow down production and cost money. Many contractors, to this day, believe that OSHA regulations have cost them money and have slowed down productivity. Many electricians I work with believe that wearing personal protective equipment (PPE) required by OSHA regulations increases the likelihood of their getting hurt because of increased risk-taking, instead of protecting from something they have only heard about others getting hurt from. Many electricians also believe that utilizing PPE is more dangerous because of the increased difficulty in performing tasks. In reality, however, it is usually due to improper fit, improper training or, at the worst instance, the hazard was not engineered out to eliminate the need for the PPE.

The decision to implement electrical safe work practices for your company begins by acknowledging that the problems discussed previously really do exist and that electrical injury or the potential for injury must cease. Management commitment for electrical safety must be absolute in the value of the program, not just from the potential for financial gain but from the humanitarian aspect. A zero tolerance for unsafe electrical work must be adopted, and defining what constitutes unsafe work is a major hurdle but it is concisely spelled out in 70E. The steps to be taken and the responsibility to make things happen must apply across all levels of your company. There also needs to be a careful analysis of whether outside help, an independent safety professional who is trained in electrical hazard recognition and mitigation, is going to be needed. Smaller contractors have safety as a part of their human resources department or someone that is doing the bookkeeping for the workers compensation. Larger contractors and organizations may have someone that may be skilled in OSHA regulations and/or has a safety degree, but it is rare to find individuals that understand the many consequences of electrical injury and what constitutes an electrical safe work practices program. In many cases a contractor has the 2-inch binder generic safety program purchased off the shelf or maybe an electrical trade association generated program that is collecting dust on the shelf. To establish an electrical safe work practices program will mean to discard many past beliefs, practices and programs and perhaps search out those who can provide proper guidance to develop such a program if the knowledge and ability is not in-house.

The process begins with an analysis of the types of electrical work in which the contractor engages. For instance, if the contractor is strictly a residential contractor working on a maximum voltage of 220 V, the electrical safety program requirements are quite different than for a commercial/industrial contractor. Do not think that just because your company’s work is residential that 70E requirements do not apply, for 70E does not specifically differentiate between residential, commercial, or industrial work; instead the hazard potential of the arc flash and shock are the determinants for work practices which are implemented. The safe work practices of 70E are drastically different from those in OSHA 29 CFR 1926 Subpart K. For example, the arc-flash hazard is not recognized in the construction standard because it was not even a recognized hazard by OSHA till the mid 1990s so there is no mention of PPE, use of voltage-rated tools or arc-flash hazard analysis. Also the extremely inadequate LOTO guidelines in Subpart K provide no guidance on what constitutes a safe lockout/tag-out procedure or program. A contractor that utilizes Subpart K as a guide for safe work practices is constantly placing its electricians in danger of severe injury or death. If Subpart K is an effective standard, then why are all the electrocutions and other electrical injuries occurring? Subpart K provides little guidance as to what electrical safety procedures are for the electrician other than 1926.416(a)(1): “No employer shall permit an employee to work in such proximity to any part of an electrical power circuit that the employee could contact the electric power circuit in the course of work, unless the employee is protected against electric shock by de-energizing the circuit and grounding it or by guarding it effectively by insulation or other means.” Yet the electrical contractor’s electricians are routinely told they cannot shut it down because of inconvenience to the customer; and, besides, aren’t electricians supposedly trained to work on energized conductors carefully and not get shocked!

NFPA 70E roadmap begins with a concept similar to OSHA, i.e., the employer provides the structure, equipment and training for safety and the employee, once trained by the employer, shall implement the safe practices [70E Part II, 1-3 Responsibility]. Developing the structure to implement the program is the first hurdle the employer has to cross. The safety policy will have to clearly state the practice of avoiding work on energized electrical conductors. If work on energized conductors is needed, an energized work authorization will have to be completed. The authorization will have to clearly identify reasons for the work and what procedures will be followed. NFPA 70E in Parts II through V have many of the safe work procedures explained, but also refer to other publications such as IEEE Standard 902 Maintenance, Operation, and Safety of Industrial and Commercial Power Systems and the NFPA Electrical Safety in the Workplace by Ray A. Jones and Jane G. Jones for other procedures. The structure for identifying and evaluating the skills of the electricians as well as providing the training necessary to equip them with the necessary knowledge for the work they will undertake is perhaps the most daunting component, next to actually doing the evaluation and making the financial commitment to conduct the training. The last hurdle to overcome initially is to provide the ability to obtain cooperation of the electricians to implement the program and encourage each electrician to be honest in self-assessment of his or her ability to do a particular job in addition to the management assessment. (Of course, an electrician is never asked to do a job prior to a hazard assessment!)

The evaluation and training will perhaps represent the largest financial outlay for a company, though the purchasing of equipment may appear to be the largest initial outlay. The training will usually necessitate a significant amount of time for which the electrician is not productive and still being paid so the cost is double the benefits normally paid. The training that is necessary is specific for the work to be done. The requirements are contained in Part II, 1-5: “…shall be trained to understand the specific hazards associated with electrical energy. They shall be trained in safety related work practices and procedural requirements as necessary to provide protection from electrical hazards associated with the respective job or task assignments. …trained in first aid and emergency procedures…” All the training is necessary to get the electrician to be a qualified person as outlined in 1-5.4.1, which is, in short terms, a person that can correctly identify and understand all the hazards associated with the task and knows how to keep himself and others in the area safe from injury, both from the aspect of how to avoid initiating an incident and what is mandatory for safety if an uncontrolled release of electrical energy should occur. The training is not going to be a one-time occurrence, but rather an ongoing lifetime of training to keep procedures current as technology changes. An electrician is expected to know everything about the job he is assigned to from the moment he starts, but the question is, is it a reasonable expectation? For example, just look at the number of types, and manufacturers of panels, disconnects, and motor control centers. Each type of unit has a specific point that the manufacturer has determined to be the best grounding point for application of the leads of a meter. Without the electrician being trained or given the information from the manufacturer on what is the manufacturer’s approved test ground point, the electrician risks obtaining an incorrect meter reading which could have disastrous consequences. It will be important to utilize an individual(s) that is competent to conduct the training and can keep the training current.

Most of the training will be for naught if the proper tools are not provided for safe work to occur. The proper tools such as voltage-rated tools and proper voltage testers will be needed as well as training for their use and care. Personal protective equipment, such as properly fitted voltage-rated gloves and FR clothing, which have been selected for level of potential hazard are also needed. Some items might be the type that could be utilized by several individuals at various times such as 30-calorie-and-above-rated suits, but others such as Class 00 and 0 gloves would be best served as personal equipment. The equipment has to be readily available when the electrician needs it for the work, not when the warehouse can deliver it to the jobsite. The equipment has to be appropriate for the task for the electrician to want to use it. To get a 100 ATPV rated suit because it can be utilized for a variety of exposures on different jobs is going to be shortsighted, because instead of making the sound financial choice to obtain several suits appropriate for the anticipated exposures developed from hazard assessments that several individuals could wear, they now have to worry about having a protective suit when it is needed at two different locations. Having only one or two suits will also limit who can use the suit due to size limitations. The electrician has to be instructed in the care and use of the equipment along with the equipment’s limitations. It is also important to have a supplier of the tools and PPE that is knowledgeable of the hazards that an electrician faces. The supplier needs to know how to best assist the contractor in selecting the best PPE by having a good understanding of the various ANSI standards that the FR clothing and tools must meet.

NFPA 70E is one of several extremely useful tools available to enable an electrical contractor to achieve an electrically safe workplace. The first step is the hardest. At some point we have to stop doing the same old thing of allowing electricians or other employees to perform tasks on energized conductors that could be easily de-energized. We have to end the belief that if they get injured, it was because they were careless or that risk to life and limb is just part of the job. The potential rewards are great for the company as well as for each employee. There is a saying “Realize that today is a gift that enables one to be present tomorrow.” Start today implementing NFPA 70E as the framework for your electrical safety program.