More than likely, the old cliché of “Dress for Success” is a familiar phrase, but one could argue that it takes on an entire new meaning when used in reference to an electrical worker. Appropriate dress can and does make a difference for those who work in and around electrical equipment. Professionals working with electricity, including installers, maintenance personnel and, yes, even electrical inspectors, need to understand that appropriate PPE for the job is important if not critical to a better chance of a trip home and not to some other less desirable destination. It also happens to be something OSHA finds to be very important. Personal protective equipment is not just something you buy and put on like other clothing, this equipment is life safety related and should be handled, treated and understood as such.
In the last edition of this column, various images were presented that some readers recognized as not sending a good message when it comes to electrical safe work practices. I was pleased to see the attention that was received. It was those that responded that sparked (no pun intended) the subject of this edition of Safety in Our States. All too often, marketing literature from many different organizations, including power point presentations and even textbooks, present application-type images of situations that are intended to educate on a specific topic but may inadvertently send the wrong message when it comes to electrical safe work practices. The saying is very true that a picture is worth 1000 words and sometimes the words represented aren’t what the writer or author originally intended. An image as simple as a person installing an electrical receptacle without the proper PPE may educate on how to install the receptacle but also propagate the act of doing such activity without proper protective equipment. Some of the images in the last edition compelled readers to ask for attention to this important piece of electrical safety. I was pleased to see the attention to detail — one of those great fine-tuned qualities of an electrical inspector! So, in this edition of Safety in Our States, we’ll take a look at the topic of Personal Protective Equipment and a peek into what NFPA and OSHA have to say about its role in electrical safety.
Personal Protective Equipment (PPE)
Personal protective equipment (PPE) is equipment that is worn to minimize exposure to hazards that may result in serious workplace injuries. PPE can offer protection from contact with chemical, physical, electrical, mechanical or other workplace hazards. This equipment includes such protective clothing and accessories as gloves, glasses, shoes, earplugs, hard hats, respirators, coveralls and vests as just a start. There are many other examples of PPE that are utilized to ensure a job is done, while minimizing exposure to the hazards faced. PPE may vary for different trades and professions as the letters / acronym “PPE” is familiar to more than just those in the electrical industry.
Having the proper equipment for the job is only the first step for proper protection. Proper use and donning of protective equipment is a critical aspect to provide more assurance that the equipment performs as expected and desired. Equipment that is comfortable to wear removes some excuses of not wearing it. Equipment that is properly sized helps ensure proper protection is provided as well as removes excuses to not wear it. Remember that having safety equipment and properly utilizing safety equipment are two separate subjects. Even before acquiring PPE, a clear understanding of what equipment is required for the work that is typical for each individual is the first step in this process. Once the proper equipment is acquired, the next important step is an education on the proper way to don and maintain this protective equipment. Protective equipment must be of a safe design / construction and maintained in a clean and reliable fashion. As I noted above, this equipment is life safety related, and it is important to treat it as such.
Some of the main reasons people do not wear their protective equipment, even when it is available, include comfort, training, suitability and appearance. Equipment has to fit properly, be comfortable, and those who use it must know when it is needed, what is needed, and the proper ways to don, doff, adjust and wear it. There are many organizations out there that offer PPE for the electrical contractor. Ensure that the equipment purchased has the appropriate arc ratings and is tested to proper ASTM standards. The world of personal protective equipment is growing as we speak. This equipment is becoming more readily available and in many different styles; it is always worth a review of the latest available PPE solutions. Throwing a bag of equipment in your truck that includes safety gear you have never donned and of which you have no knowledge may not produce intended/expected results. Studies confirm that equipment not used properly will not provide the intended results.
Electrical inspectors are not an exception in our industry, and even NFPA 70E recognized this with an expansion in the 2014 version of this document to include “inspection” as part of the scope of this document, Section 90.2. This section now reads such that the standard “. . . addresses electrical safety related work practices for employee workplaces that are necessary for the practical safeguarding of employees relative to the hazards associated with electrical energy during activities such as the installation, inspection, operation, maintenance, and demolition of electric conductors, electric equipment, signaling and communications conductors and equipment, and raceways.” The word “inspection” expands the requirements of NFPA 70E to the electrical inspector. Photo 1 illustrates how an electrical inspector may need to be dressed when inspecting energized structures. The level of protective equipment must fit the amount of incident energy present and the type of inspection being conducted. Photo 2 illustrates the importance of protecting the boundaries when inspecting or working. We can read this image a few different ways. One way as an example of an electrical inspector properly equipped but not protecting his boundaries and keeping the electrical contractors out of the arc flash boundary, or we can read this as two electrical inspectors looking on as the electrical contractor prepares the equipment for inspection. Any way you cut it, photo 2 is an example of what is not appropriate. I could make a clear argument that none of those working in photo 2 are qualified individuals.
It is very important to understand the requirements of NFPA 70E, to know the incident energy levels, and to dress and conduct yourself in a qualified manner.
It is amazing that when equipment is applied properly, it will perform properly. I think that can be said about many things. Incorrect donning of PPE or donning the wrong PPE for the event can have devastating results. A study conducted in 2009 and then expanded upon in 2010 reviewed data from real-life arc flash events with the goal to evaluate the performance of PPE in these real-life situations. This information was presented at the Institute of Electrical and Electronic Engineers (IEEE) Electrical Safety Workshop, an annual event where the subject of electrical safety is discussed at great length and in great detail. This study analyzed 40 events that impacted 54 workers. The authors of this research sought to determine how well PPE performs in real-world incidents as compared to results of PPE lab testing. What they learned and shared in their report was revealing and very educational.
Their findings showed that in general, arc-rated clothing and equipment performed as expected. What was very interesting was that of the 54 workers, 31 received burn injuries that ranged from minor to severe and even life changing, even though they wore personal protective equipment.
A good number of the injuries (45%) were due to the individual wearing insufficient PPE for the task at hand. There were ignitions of natural fiber clothing, instances where the PPE worn had ratings below the hazard exposure level encountered, and instances of burns on the skin where there was an insufficient overlap between sleeve and gloves.
In addition, an almost equal number of the injuries (42%) were due to not wearing all of the PPE elements that should have been worn for the work performed. Injuries included instances of hands being burned because no gloves were used, faces being burned because no face mask was used, arms burned because long sleeves were not worn. In one instance, an individual donned flammable jeans instead of the proper pants. Another example was found where the individual’s hard hat was not clipped to the hood properly. These examples illustrate that a lackadaisical approach to PPE — thinking that a properly rated shirt is enough, or that wearing “some” of the appropriate PPE is enough — is just not the right approach.
It was the next 7% of individuals that proved to be very revealing, illustrating that it is not only the outer clothes you wear for protection, but also those clothes close to the skin that can make a difference as well. There were two instances of where the individual’s bra melted and/or ignited. In one instance, high-voltage arc tracking was found inside of the FR jacket that ignited the cotton underlayers; and, finally, one instance of where the flammable clothes that were worn burned up the torso under the rated jacket that was worn.
This study found that those individuals who received injuries — even though they were wearing PPE — were either:
(1) not wearing all of the elements of PPE needed for the work being performed, or
(2) wearing insufficiently rated PPE for the hazard, or
(3) experienced melting/ignition of flammable underlayers, or as in some cases,
(4) experienced more than one of these issues.
This team concluded that arc rated protective clothing and equipment performed as expected when matched to the exposure and work in accordance with NFPA 70E. They noted that even when hazard analyses are performed, workers frequently wear inappropriate PPE elements for the activity.
An interesting conclusion noted that flammable underlayers such as cotton T-shirts, nylon or spandex bras, cotton work shirts and other similar clothing worn under arc rated clothing can ignite and/or melt. It was found that the fabrics on externally worn rated clothing can break open and expose the undergarments to the event. They noticed that such materials as nylon and spandex when worn under arc-resistant (AR) clothing can melt even when not exposed directly to the event, due to AR clothing breaking open. There was a clear need for rated T-shirts, bras and briefs demonstrated, and wearing such proper PPE can reduce the risk of injury.
Codes and Standards
To help understand when and where PPE needs to be worn, we can reference some key documents in our industry including NFPA 70E, Electrical Safety in the Workplace (www.nfpa.org/70E) and OSHA requirements (https://www.osha.gov/law-regs.html). OSHA has a great reference in the following URL: https://www.osha.gov/Publications/osha3151.html. These documents provide requirements and guidance around the topic of PPE. There is a wealth of information at both the NFPA and OSHA websites.
In addition to other sections in NFPA 70E, Section 130.7 “Personal and Other Protective Equipment,” speaks directly to requirements around PPE. Through an informational note, this document acknowledges an important fact that PPE and the requirements around PPE intended to protect a person from arc flash and shock hazards could result in burns to the skin, even with proper protection selected. The burns experienced while wearing PPE are intended to be reduced and survivable. Many people think just the opposite about the protective equipment they wear. Such events like arc flash are very violent with heat, light, sound and even flying debris. Your protective equipment will help increase the likelihood that you will survive that event. Section 130.7 of NFPA 70E addresses head, face, foot, neck, and chin (head area) protection, eye, hearing, body, hand and arm protection, as well as shock and arc flash protection. In addition, other important PPE aspects are addressed which include its maintenance and use, movement and visibility, and the factors that are involved when selecting protective clothing. The resource available in NFPA 70E is very helpful when it comes to personal protective equipment selection and application.
OSHA too assumes an important role in this discussion of PPE. OSHA, as an organization, has its origins as far back as December 1970, when the Occupational Safety and Health (OSH) Act was signed into law by President Richard M. Nixon. Shortly thereafter, April 1971, OSHA was established. The first standard that this organization issued was related to Asbestos. It was in 1972 that construction safety standards entered the market to protect construction workers operating electric power transmission and distribution equipment, aerial lifts and helicopters. A notable PPE event occurred in January 1981, when the Hearing Conservation Standard was released; it required that workers exposed to noise levels above 85 decibels to be provided with hearing protection. It also requires employers to perform hearing tests on workers to monitor how these protection measures were working.
It is in 29 CFR 1910, “Occupational Safety and Health Standards,” that you will find Subpart I, “Personal Protective Equipment.” Subpart I includes 1910.132 through 1910.138 which all focus on PPE. 1910.132, “General Requirements” includes requirements for training of employees that must use PPE. As we noted above, protective equipment must be treated as safety equipment and not just another piece of clothing. OSHA requires that the employee be trained to know when PPE is necessary, what PPE is necessary, how properly to don, doff, adjust and wear PPE, the limitation of PPE and the proper care, maintenance, useful life and disposal of PPE.
OSHA has issued many hefty fines to organizations that do not adhere to the requirements around PPE. Understanding what OSHA requires as well as following the guidance of NFPA 70E when it comes to PPE is important for safety sake.
As always, keep safety at the top of your list and ensure you and those around you live to see another day.