What does the term electrical safety really mean? Stop reading for a moment and think about what electrical safety means to you. The hazards are electrical shock, arc-flash and arc-blast. Electrical safety is achieved by taking all of the necessary steps to provide our homes with safe electrical systems and by ensuring that everyone goes home from the job at the end of each day without suffering from shock, arc-flash or arc-blast.
When we discuss electrical safety, we must realize everyone uses and is exposed to electrical energy every day. We achieve the necessary level of electrical safety for all individuals both at home and on the job through two methods: (1) providing an electrical installation free from electrical hazards, and (2) through the implementation of electrical safe work practices.
Electrical Installation Requirements
Through the use of the National Electrical Code we provide installations that are essentially free from electrical hazards for the general public. This level of electrical safety achieved through implementation of an installation code, the NEC, also protects employees in their workplace. It is important to note that these safety-driven installation requirements are intended to protect persons who do not encounter exposed live parts or interact with electrical equipment. Electricians, inspectors, HVAC technicians, elevator technicians, maintenance personnel and others are exposed to electrical hazards when and where they access energized parts and/or interact with electrical equipment. As these employees become exposed to energized parts or they interact with electrical equipment, the safety-driven installation requirements of the NEC no longer protect them from electrical hazards.
Electrical Safe Work Practices
Protecting persons who are exposed to live parts or persons who interact with electrical equipment requires another level of safety, which is not provided by an installation code like the NEC. These individuals need to implement electrical safe work practices. Federal law requires that all employees be protected from all electrical hazards. OSHA requires that persons exposed to electrical hazards be protected. In both the 1926 Construction and in the 1910 General Industry Standards, OSHA mandates that employers shall protect employees. OSHA requirements for protecting employees who are exposed to live parts or interact with electrical equipment are for the most part “performance based” and do not give the employer adequate methods and means to protect employees from electrical hazards. NFPA 70E shows the employer when energized electrical work is justified and how to provide the necessary protection for the employee. NFPA 70E is a consensus standard and is not adopted locally as is the NEC. An employer who complies with NFPA 70E will meet the required levels of protection mandated by OSHA. To many electricians, inspectors and other workers who may be exposed to electrical hazards, it seems that the requirements of NFPA 70E are new. The talk around the gang-box on many jobsites and over lunch becomes a debate on whether or not we need to comply with these requirements. The reality is that Federal law requires that employers protect all employees from the hazards of electricity. OSHA is the shall and NFPA 70E shows the employer how.
The Requirements of the NEC
The NEC contains many safety-driven installation requirements that protect employees in the workplace. These requirements range from workspace clearances, GFCI protection, overcurrent protection, bonding/grounding and many other installation-based requirements designed to protect persons and property from hazards that may arise from the use of electricity. The NEC has evolved over the last few cycles by beginning to incorporate requirements during the installation of electrical systems that will provide safer working conditions for those who will repair, maintain, modify or renovate the electrical system.
The NEC has embraced multiple changes over the last few cycles that illustrate the trend in our industry to provide safer working conditions for all persons exposed to electrical hazards. These changes include but are not limited to the following sections in the 2005 NEC:
Article 100 definition of Qualified Person
110.16 marking requirements to warn persons of arc-flash hazards
110.26(C) and 110.33(A) requirements for doors to open in the direction of egress
210.4(B) simultaneous disconnect for multiwire branch circuit supplying more than one device or equipment on the same yoke
210.5(C) identification of ungrounded branch-circuit conductors
215.12 identification of all feeder conductors
240.86 engineered series rated systems in existing buildings
404.15(B) requires the term off to completely disconnect all ungrounded conductors
410.73(G) requires disconnecting means for ballast replacement
422.31(B) provisions for adding a lock to a disconnect
430.102(B) disconnect within sight of motors
490.46 ground bus for connection of safety grounds
These are just a few examples of how the NEC is recognizing the needs of those who will maintain, repair and renovate electrical systems. These revisions provide those who will maintain repair or renovate these systems with necessary information and modifications to facilitate safe working conditions.
The 2008 NEC has continued the trend towards providing installations that facilitate safe maintenance, repair and renovation. Dozens of locations in the NEC have been modified to require that a means to lock or add a lock to a required disconnect remain in place with or without the lock installed. This will allow anyone to effectively lock out a disconnect with just a lock. Electrical workers should not be expected to carry dozens of different types of lockout devices and hope that they have one to fit every switch or circuit breaker which needs to be locked out.
NFPA 70E, Standard for Electrical Safety in the Workplace
Implementing safe electrical work practices begins with an overall electrical safety program that directs activity appropriate for the voltage, energy level and circuit conditions to which employees may be exposed. The development of a written electrical safe work practice plan documents the overall program. All employees must be trained in electrical safety. The level of training in many cases may be different depending upon the tasks to be performed by the individual. NFPA 70E recognizes two categories of employees with respect to electrical safe work practices, qualified and unqualified. An electrical contractor or inspection agency may employ both qualified and unqualified employees. The difference is that an unqualified person is not recognized as being capable of working exposed to energized parts or interacting with energized electrical equipment.
At a minimum all employees must be trained (1) to understand and recognize all electrical hazards and their effects on the human body—shock, arc-flash, arc-blast, and (2) how to recognize an electrically safe work condition.
An electrically safe work condition is in essence a situation free from all electrical hazards. An electrically safe work condition exists when an individual is working on a piece of equipment or circuit which cannot be energized from any source. This situation is only possible: (1) when the equipment or circuit cannot be energized because the conductors to supply the equipment have not been installed, or (2) the equipment is effectively locked out and tagged out. See NFPA 70E, section 120.1, for detailed steps to achieve an electrically safe work condition.
In addition to understanding electrical hazards and an electrically safe work condition, qualified persons must receive additional training. Qualified persons must be trained to distinguish energized parts from other parts, to determine nominal voltages, to determine approach distances and in the decision-making process for determining the degree and extent of a hazard and the necessary planning and personal protective equipment needed to perform the task safely.
The Role of the Electrical Inspector
The electrical inspector plays a critical role in electrical safe work practices. Inspectors must take prudent steps to protect themselves from electrical hazards. In-house training of all inspectors in safe work practices is not an option; it is a requirement. The inspector gets to see firsthand how the electrical contractor operates. As an inspection is occurring, the inspector will certainly see if energized work has been or is being performed. The inspector should require that the electrical contractor schedule an inspection before the equipment is energized. Exposing yourself and others to electrical hazards to perform an inspection may not be justified by NFPA 70E and may create serious safety and liability concerns. NFPA 70E recognizes energized work as being justifiable in two situations: (1) infeasibility, the task cannot be performed deenergized, such as voltage testing, or (2) greater hazard, deenergization of the equipment creates a more significant hazard such as interruption of life support equipment.
Electrical contractors look to the inspector for guidance in the electrical installation; the inspector is the authority having jurisdiction. When the inspector embraces safe electrical work practices and demands that contractors properly plan their work and schedule inspections with all of the work completed in a deenergized state, everyone gets a safer workplace.
Change
The real challenge of implementing an effective electrical safe work practice plan is getting everyone involved to change their working habits and the way each job or task is planned. We all resist change in our lives to some degree. How did we survive before computers and cell phones? We are all very comfortable in our environment and our working habits. It is natural that we resist change. A visit to a local hospital with a burn center may help one accept the change that an electrical safe work practice plan brings to the workplace. As safety coordinator for IBEW Local 98 in Philadelphia, I have seen my fellow members, friends of mine, in the burn center after an arc-flash incident. It is not something you want to experience for yourself. In fact, by embracing safe electrical work practices you can help prevent an accident.
Why would anyone work hot? Why would they expose themselves to those dangers when they could arrange a shutdown? In the electrical construction field, not involving line work or a service truck, 95 percent of energized work is done for one of two reasons, (1) poor planning, and (2) convenience. Poor planning occurs when a contractor energizes equipment before all work in that equipment is complete. For example, a project is to occur in two phases. The contractor must complete phase-1 before phase-2 begins. The switchboard in phase-1, however, will supply two feeders for phase-2. The contractor can take proactive steps by installing both feeders for phase-2 from the overcurrent devices into junction boxes which can be accessed for a splice, in a deenergized, locked and tagged out state as phase-2 of the project is completed. This eliminates exposure as well as a shutdown of the phase-1 project. Energized work also occurs regularly because of convenience. A typical mindset considering energized work justifies that work by thinking, “By the time I schedule a shutdown, I could have this done.”
This type of working culture that includes poor planning and convenience translates into a type of Russian roulette. There is not one live round, five empty chambers and one player. There is one live round, thousands of empty chambers and multiple players. Eventually something goes wrong. Burn centers and graveyards across the country are where the individuals who find the live round end up.
I would like to leave you with a thought about change. A quote from W. Edwards Demming sums up the reason that we must embrace safe electrical work practices: “It is not necessary to change. Survival is not mandatory.”
Electrical safe work practices are being embraced and implemented all over the country. It is difficult for some individuals and contractors to change. Survival makes the change easier to accept. Many electrical contractors and inspection agencies are forced to change. In order to survive, they develop written electrical safe work practice plans, lists of qualified persons and documentation of training because owners and developers demand it. We want everyone to survive. Electrical safety is changing and you are a major player in this arena. Take the next step. Implement an electrical safe work practice plan. When someone asks why you are making this change, tell him or her that you choose to survive.