How Do You Respond to Unsafe Working Conditions?

Ideally, you would never encounter an unsafe working condition on the job. Realistically, you will encounter such a condition as a matter of routine. Routinely encountering these can lead to complacency.

You may accept as normal, for example, loose bolts on the ladder going up to the mezzanine where electrical panels have been installed above the equipment they serve. You could keep reporting this, or you could tell your supervisor you are replacing the nuts with self-locking ones to eliminate the problem. This repair doesn’t take long.

But what if a solution is time-consuming or expensive? If you “handle it,” there are resource issues outside your discretion. What if the repair is outside your skill area as an electrician? Maybe the ladder had broken welds instead of loose bolts. What if the unsafe condition is due to unsafe acts by other trades? Perhaps the drywall work is scheduled at the same time as a transformer replacement job in an adjacent area.

You must assess whether the risk affects you or may affect you. If not, then report the condition; that’s as far as your responsibility goes. If it does, it is your primary concern until the issue is resolved. That process begins with a risk assessment, followed by a risk control decision.

Risk assessment, control

NFPA 70E, Informative Annex F provides a concise treatment of the subject of risk assessment. The core of it is a three-step process:

Identify the hazard. What exactly is the condition that poses a danger to you?
Analyze the sources of risk. What are the factors that create the condition you just identified?
Evaluate the level of risk. How severe are the potential consequences, and how likely are they to happen?

After assessing the risk, you identify a means of reducing it. This is called risk control. It’s easy at this stage to default to personal protective equipment (PPE). But PPE is your last resort.

The first attempt at control should be to eliminate the risk. In our drywaller example, the risk can be eliminated by rescheduling one or both jobs so they are not done at the same time.

It is not always possible to eliminate the risk. You may be able to reduce it, however. In our drywaller example, the risk can be reduced if that crew uses silica dust collection measures and/or wet sanding to reduce at the source. The risk to the electrical crew can also be reduced by erecting a barrier, such as hanging plastic sheets between the two areas.

Each time a risk elimination or reduction measure is implemented, you reassess the risk to see if it is below acceptable limits. If not, you go through this process again.

In our drywaller example, a combination of silica collection and a plastic barrier has reduced the dust considerably, enough that it’s not going to be a problem for the new transformer because any dust that gets inside the case can be vacuumed out. But there is no way to vacuum silica dust from human lungs. If silica dust is present, the risk to unprotected lungs is unacceptably high. At this point, you finish the risk reduction through the use of PPE.

Because these are your lungs and there’s no way to fix damage from silica dust, it is ultimately your responsibility to assess and control the risk down to zero.

This same logic applies to unsafe working conditions not involving silica dust. These include:

Tripping hazards. These include power cords, process scrap, work in progress, boxes, and crates.
Slipping hazards. These include loose material on the floor, fluid spills, and fluid drips.
Fire hazards due to issues with combustibles such as boxes or crates being located next to electrical equipment.
Shock hazards due to bonding deficiencies. Current is trying to get back to the source. If there’s not a low impedance path, it will flow through equipment and people to get there.
Poor lighting. The typical response is to adapt to a bad situation rather than fix it. The primary adaptation is the use of a flashlight or other portable lamp. Generally, people who use this adaptation do not climb up into the ceiling and hang enough of these to provide good ambient lighting (actually, nobody does). This solution is, in essence, a PPE adaptation rather than a hazard-eliminating solution. If lighting is poor, the visibility hazard should be eliminated by adding sufficient permanent lighting.
Insufficient working space. You have to determine “sufficient” based on how much space is needed to adequately service the equipment [110.26]. You also need to evaluate for conformance with Table 11026(A)(1) of the NEC (same table exists in the OSHA regulations, as it’s taken directly from the NEC). The solution may involve an equipment move, installation of insulating material, a redesign of the work process, or a combination of the aforementioned.
High noise. The normal response is to reach for the PPE. This is often the only practical response because we know PPE is highly effective and we often cannot eliminate or reduce the noise. But again, PPE is your last resort (excess noise causes other problems than hearing damage). If you can shut off that nearby 2-ton punch press, reschedule the work for after the crew with the jackhammers leaves the area, or do some prefab in the lower noise environment of the shop, you can eliminate or reduce the hazard.

In simply reaching for the PPE, you may protect yourself against a hazard you identified. By using control strategies first, you are likely to eliminate or reduce strategies that you had not identified as well. Your first response to unsafe working conditions should be to eliminate or reduce those conditions.