Significant injury or loss of human life due to insufficient electrical management expertise is every employer’s worst nightmare — and not simply because of the monumental costs involved. It’s the kind of event that can haunt someone for an entire career and destroy lives. Unfortunately, many electrical professionals have seen or experienced incidents or accidents they hope to never see again. But in order to keep history from repeating itself, we have to be beyond diligent when it comes to applying safety principles and procedures on the job.
NFPA 70E — also known as the Standard for Electrical Safety in the Workplace — is the national consensus standard covering requirements for safe work practices to protect personnel by reducing exposure to major electrical hazards. It is designed to help companies and employees comply with Occupational Safety and Health Administration (OSHA) regulations and avoid workplace injuries and fatalities due to shock, electrocution, arc flash, and arc blast. Often confused, arc flash and arc blast are very different concepts. An arc flash is part of an arc fault — a type of electrical explosion that results from low-impedance connection to ground or another voltage phase in an electrical system. An arc blast is an explosive release of molten material from equipment caused by high amperage arcs.
Because working on energized equipment has become so commonplace in most industries, we must all remain vigilant in safeguarding against electrical fires, explosions, and other hazards in the facilities we service, operate, or work in. To protect against these electrical hazards, companies should not only understand the requirements of NFPA 70E, but also actively implement them as soon as possible.
How do you reduce these risks?
The requirements surrounding NFPA 70E are fairly complex and extensive. They can also be difficult to grasp. Every day we hear the same questions: Do I need to be compliant? What are the risks of non-compliance? How do I start a program? What are the most important aspects of NFPA 70E? What is my time line for compliance?
OSHA and the NFPA require all facility owners and managers to perform a hazard/risk analysis on their electrical distribution system prior to allowing anyone to work on or near energized electrical equipment. During the initial hazard/risk analysis, an expert should perform/deliver the following:
• Updated one-line drawings
• Coordination study
• Short circuit analysis
• Arc flash hazard analysis
• Arc flash labels applied to all equipment
• Recommendations to mitigate hazards
• Outline a continuous change management program
You must analyze these components periodically — not to exceed five years — with the following criteria being met to ensure NFPA 70E electrical safety compliance is continuously being met:
• Engineering: Design, study, assessment, and review of the electrical system and connected loads.
• Data: Obtaining the equipment and feeder information, maintaining system one-lines, updating a database of the electrical assets and proper labeling of each device.
• Maintenance: Testing, exercising and condition verification of protective devices per manufacturer’s recommendations.
• Training: Annual employee training on electrical safe work practices and known hazards in your facilities.
Employee training
As a property owner or manager, you have a responsibility to stewardship. That means employing professionals who are trained and knowledgeable to recognize specific electrical hazards. These professionals need to be able to do three things well:
1) Recognize voltages;
2) Identify energized parts; and
3) Accurately assess the available fault current.
Most people with an electrical background can fulfill the first two components fairly quickly — the third, not so much.
Correctly labeling and identifying electrical hazards is obviously crucial. What may not be so self-evident is providing site-specific hazard training to those who deal with this equipment — specifically, providing arc flash awareness and protective boundaries (Figure) for personnel in the workplace. In our experience, very few clients train their people to safely use and maintain this equipment. By training your people properly, you’re not just keeping them safe — you’re instilling a sense of stewardship in them as well.
The key to understanding NFPA 70E can be found in Art. 110, which details requirements placed on the building, ownership, employees, and contractors.
Best practices
Article 110 of NFPA 70E clearly outlines the responsibilities placed on the employer (e.g., building owner, management company) to ensure that any individual working on the electrical system in their facility is trained and equipped with the proper personal protective equipment (PPE) — and can demonstrate they know how to use it. Unfortunately, experience shows that even these basic requirements are many times unmet (see Top 4 Safety Problems).
Article 110 also outlines the relationships that should exist between the facility workers and the outside service personnel working at the facility. Host employer responsibilities include informing contract employers of known hazards related to the contract employer’s work that might not be recognized by the contract employer or its employees. It also calls for providing information about the employer’s installation that the contract employer needs to make during the requisite assessments. In addition, it covers the responsibilities of the contract employers themselves. A documented meeting between the host employer and the contract employer is necessary as well.
The employer is expected to implement and document an overall electrical safety program that directs activity appropriate for the electrical hazards, voltage, energy level, and circuit conditions. This includes testing and rating equipment, ensuring it is designed for the environment to which it will be exposed, performing a visual inspection, and verifying its operation.
One area that often gets overlooked is underground electrical lines and equipment. Before excavation starts — and where there exists a reasonable possibility of contacting electrical lines or equipment — the employer must take the necessary steps to contact the appropriate owners or authorities to identify and mark the location of the electrical lines or equipment. When it has been determined that a reasonable possibility for contacting electrical lines or equipment exists, a hazard analysis shall be performed to identify the appropriate safe work practices that shall be used during the excavation.
Common challenges in maintaining NFPA 70E compliance
Many facility managers are burdened by years of deferred electrical system engineering and maintenance of their systems, which makes the upgrades necessary to be compliant seem cost prohibitive. More often than not, we find that even basic exercises like testing breakers and disconnect switches haven’t been performed because of the expense — or the fact that it’s inconvenient to de-energize the equipment. To further complicate matters, loads, fuses, and breakers are being changed every year, and equipment is constantly being modified, deleted, or added. It’s rare to find a facility with an up-to-date engineering review that accurately assesses and verifies the impacts of the changes on the safety of the system.
Be aware that the risks of deferring electrical management are high. When electrical accidents or failures occur, the effects are unpredictable because the equipment has not been proactively maintained. The costs from injuries and equipment repairs exponentially exceed the savings from not having engineering review and proactive system maintenance.
Ultimately, NFPA 70E is a matter of protection — protecting your personnel, your tenants, and your business. When anyone comes into your building to address its electrical assets, it is vital that they are safe, aware, and trained.
Risks and potential fines associated with non-compliance
It’s no secret that if you experience a workplace injury or fatality, you can expect a visit from OSHA. What’s more, inspectors will undoubtedly be very curious whether you are compliant with NFPA 70E. While the chances of receiving a random inspection by OSHA are fairly slim, it is possible. The only way to guarantee you are not fined is to be NFPA 70E compliant.
In 2009, OSHA cited an electric company in New York for 14 alleged serious violations of safety standards after a company employee was burned in an electrical arc flash. The incident occurred as employees were performing maintenance on 34.5kV electrical switches and transformers. OSHA’s inspection found that one of the switches had not been de-energized as required before employees began their work, nor had the switches been properly barricaded and tagged to prevent exposure to live electrical parts. OSHA also determined that the injured worker and other employees had not been adequately informed about and supplied with appropriate personal protective clothing. Furthermore, they had not been adequately trained in electrical safe work practices and in proper hazardous energy control procedures.
Make no mistake: OSHA issues significant citations when death or serious physical harm is likely to result from hazards about which the employer knew or should have known. In the case described above, OSHA proposed $88,200 in fines. The fines for a fatality actually begin at $750,000. However, as I hope we’ve made clear, the costs for improper electric management practices are far greater than just dollars and cents.
Wilkins is a national accounts manager with ABM Electrical and Lighting, Phoenix. He has 27 years of electrical experience in construction, service, maintenance, design and safety. He can be reached at [email protected].
Top 4 Safety Problems
Following are the four most common issues electrical professionals encounter when working at a typical facility:
1. Building management either has no single-line diagram or an outdated single-line diagram.
2. Building management has completed an arc flash study but their equipment is missing the proper labels. They don’t have an updated single-line diagram mounted in the main electrical room. Employees aren’t properly trained, and can’t recognize the hazards that are now present.
3. A lack of accountability with employees and contractors that should be following NFPA 70E standards when working in and around the electrical system.
4. Electrical panels have unplugged holes, exposed live electrical components, improper labeling, and missing screws.
