Section 110.3 of NFPA 70E provides the general requirements for an electrical safety program. In Part 2, we covered Subsections 110(A) through (G). Subsection (H) addresses the risk assessment procedure.
It’s broken down into three areas:
- Elements.
- Human error.
- Hierarchy of risk control methods.
Elements
This procedure must address employee exposure to electrical hazards and identify the process to be used before work is started. That process consists of three steps:
- Identify hazards.
- Assess risks.
- Implement risk control per the hierarchy of risk control methods.
This is followed by two Informational Notes. The first one gives an example and the second one refers you to Informative Annex F. That Annex includes two flow charts, two tables, and a concise explanation of risk assessment and control.
Human error
The risk assessment must address, relative to the electrical hazards in the workplace, the potential for human error and the negative consequences for:
- People.
- Processes.
- The work environment.
- The equipment.
The Informational Note refers you to Annex Q. This annex runs almost five pages. It’s a good introduction to the topic of human performance and workplace electrical safety. For a manager, supervisor, or trainer, this is a “must read”. It is not possible to eliminate human error, but it is possible to reduce or eliminate contributing factors. A key concept is that the potential for human error varies with factors such as tasks and the work environment.
Hierarchy of risk control methods
A hierarchy isn’t just a list. It’s a ranking. In your company, perhaps a helper reports to a Journeyman who reports to a master electrician who reports to a project manager who reports to a vice president who reports to the CEO. The CEO is at the top and is the most powerful person in the company.
With risk control methods, the “CEO” is elimination. This is the most efficient way to address safety. Here’s the whole hierarchy, and notice what is at the very bottom:
- Elimination.
- Substitution.
- Engineering controls.
- Awareness.
- Administrative controls.
- PPE.
Let’s use an example that isn’t electrical but is good for illustrating this principle because it’s easy to visualize. Suppose you have two compressors for plant air on a mezzanine. Four people have fallen off and been injured. Here’s the hierarchy in action:
- Remove them from the mezzanine, and install them at grade.
- Cut the hazard exposure time in half by replacing them with one big compressor.
- Move the pressure gages to grade.
- Put up signs announcing the potential to fall off, red tape the floor, and red tape the open end.
- Update the CMMS to stretch out the maintenance intervals.
- Install a removable guard rail (a permanent one would not allow removing the compressors if needed) and/or lanyard anchors, and require the wearing of fall protection while on the mezzanine.
This last one would require quite a few anchors to be bolted or welded in since the lanyard can’t exceed 6 ft. But simply relocating the compressors to grade would eliminate the hazard entirely. The measures in between can only reduce the hazard, not eliminate it. But in many cases, an intermediate method is all that is practical and you may get a “better than acceptable” risk by combining two or more.
Spend some time studying Informative Annex F and seeing how it might be possible to move up the hierarchy for one hazard at a time. Maybe you can’t eliminate a flash hazard for thermographers or those racking out breakers, but you can protect them much better than PPE can with engineering controls such as infrared windows and remote racking.
