By Daryn Lewellyn
CEO, Lewellyn Technology
The best way to protect employees from electrical hazards is always to establish an Electrically Safe Work Condition when working around electrical hazards.
The NECplus.org —a fantastic National Fire Protection Agency website—states,
The most effective way to prevent an electrical injury is to completely remove the source of electrical energy and eliminate the possibility of its reappearance.
Having a “No LiveWork” Policy, which is what most of us call it in the ﬁeld, is really great, and I applaud your efforts, but a “No Live Work” approach comes with its own hazards … which are often missed.
To achieve an Electrical SafeWork Condition the procedures of your organization’s Lockout/Tagout policy must be followed. Those procedures must include veriﬁcation of isolation. This means a qualiﬁed person must choose an appropriate voltmeter to test the circuit to verify an absence of voltage. This is live work.
It’s live work because, until you have veriﬁed it, you do not yet have an Electrical SafeWork Condition. Every circuit is live until we have veriﬁed it’s not, no matter how sure we are that we turned it off. We can never be indecisive about this.There are thousands of stories out there involving someone being electrocuted because they contacted a circuit they knew was off. We also have to verify the voltmeter is working properly before and after we check the circuit. Doing the voltage test is live work.
You can’t work de-energized without ﬁrst doing live work. So the idea that some facilities don’t need 70E because they have a “No LiveWork” Policy is wrong. Everyone still needs 70E and the PPE it requires.
If your facility doesn’t have the following, you have work to do:
• Written Lockout/Tagout Policy
• PPE program for shock and arc ﬂash
• Written Electrical SafeWork Practices
• Hazard assessment to determine shock and arc ﬂash hazards
• Lockout/Tagout training
• Qualiﬁed electrical maintenance personnel with 70E training
• Lockout/Tagout equipment
• Appropriate voltmeters
• Insulated tools
This list is not complete, but it will get you started.
Even facilities with a “No LiveWork” Policy need these things. I hope this helps you navigate your way through 70 implementation.
Watch Workplace Safety Show Episode 18 on “No Live Work” Policies:Posted in arc flash, electrical safety, maintenance training, safety training | Tagged 2012 nfpa 70e, 70e, arc flash, arc flash accidents, arc flash analysis, arc flash consultants, arc flash consulting, arc flash hazards, arc flash safety, electrical hazards, electrical news, electrical safety, electrical training, lewellyn technology, lockout tagout, nfpa 70e, osha, ppe, ppe requirements, worker electrocuted, worker shocked, workplace safety | Comments Off
By Daryn Lewellyn
President & Founder
The following list of citations for electrical hazards is real. These citations happened recently and they will be eye-opening for some. I wrote this with the hope that it might help facility personnel better evaluate their facilities. If OSHA is looking for these kinds of hazards, you should be looking for them also, well ahead of an OSHA visit. Finding these kinds of hazards will help prevent injuries and at the same time avoid a costly OSHA citation. I thought the best way to show you what to look for in your own facility was to share with you, in OSHA’s own words, actual violations written up by OSHA field personnel. You don’t have to have a vast knowledge of electrical equipment to recognize these hazards.
Lack Of Hazard Assessment
1910.132(d)(2) The employer did not verify that the required workplace personal
protective equipment hazard assessment was performed through a written certification
that identified the workplace being evaluated; the person certifying the evaluation
had been performed; the date(s) of the hazard assessment; and which identified the
document as a certification of hazard assessment.
Hazard assessment for shock and arc are required by OSHA. You won’t have any idea what PPE to utilize if an assessment is not done. NFPA 70E includes hazard assessment methods.
Lack of FR Clothing and Insulated Gloves
1910.335(a)(1)(i) Employees working in areas where there were potential electrical
hazards were not provided with, and did not use, electrical protective equipment that
was appropriate for the specific parts of the body to be protected and for the work to be
Facility Wide – maintenance personnel who performed electrical work… were not
provided with and did not wear flame-resistant clothing (FRC) or insulated gloves.
FR clothing seems to be what everyone thinks of first when they think of NFPA 70E. People have told me they won’t implement 70E until it is the law. OSHA doesn’t seem to be waiting. They don’t have a problem with penalizing companies now. NFPA 70E includes PPE selection methods. Employees need protected now.
Unused Opening in Electrical Enclosures Left Open
1910.303(b)(7)(i) Used openings in boxes, raceways, auxiliary gutters, cabinets,
equipment cases or housings were not effectively closed to afford protection
substantially equivalent to the wall of the equipment.
Knock-outs left open, circuit breakers removed and not properly covered, offer a place where dirt, moisture, conductive articles and fingers can access the live conductors inside. It doesn’t take an electrical engineer to figure out you have a hole in your electrical enclosure. These are easy to spot and easy to fix, and very costly if you don’t, because OSHA will hit you for every occurrence.
Breakers and Disconnects Not Labeled
1910.303(f)(2) Each service, feeder and branch circuit, at its disconnecting means or overcurrent device, was not legibly marked to indicate its purpose, unless located and
arranged so the purpose was evident.
Neither the busway, nor the bus plugs were marked or labeled as to what electrical
equipment, installations or apparatus they supplied.
None of the circuit breakers located inside of electrical panel were marked or labeled…
All circuit breakers and fuses feeding loads must be correctly labeled as to what they feed. This is easy for non-electrical people to spot and easily rectified.
Plugs Without Ground Prongs
1910.334(a)(3)(ii) Attachment plugs and receptacles were altered in a manner which
prevented proper continuity of the electrical equipment grounding conductor at the point where plugs were attached to receptacle.
In order to make the three-prong plugs on each of the lighting fixtures fit into twoconductor electrical receptacles, the grounding pins were cut off and/or removed from each of the plugs.
This was a common thing to see thirty years ago when people were just getting used to those new three pronged plugs. It’s inexcusable now and beyond words how this could still be happening. Do you have some old lighting fixtures that have been plugged in for thirty years and the ground prong removed? Easy to spot. Easy to fix.
1910.333(b)(2) While any employee was exposed to contact with parts of fixed electrical
equipment or circuits which had been de-energized, the circuits energizing the parts
were not locked out or tagged out or both.
…maintenance employees did not apply locks and/or tags on all of the electrical disconnects, electrical circuits or shut-off points prior to performing electrical work.
The employer must develop proper lockout/tagout procedures and train the employees on those procedures. The employer must also provide the locking and tagging devices as well as other equipment for the employees to carry this out.
Lack of Electrical Safe Work Practices Training
1910.332(b)(1) Employees were not trained in and familiar with the safety-related work
Maintenance employees who performed electrical work…were not provided electrical
training on topics such as…potential hazards associated with electrical work (including
arc flash or arc blast.)
“Safety-related work practices shall be employed to prevent electric shock or other injuries.” Employees must be trained on those practices. All training must be documented, including the contents of the training.
All of these citations, as well as the potential injuries that might result are easily avoidable. Use these citations to learn what it is OSHA might be looking for and make sure your plant is current with all of the latest OSHA and NFPA 70E requirements. Take a walk through your plant and look for these hazards. If you aren’t comfortable doing this, bring in an outside company to do the inspection. Just get this done before OSHA shows up and looks for themselves.
View Workplace Safety Show Episode “Electrical Safety in OSHA’s Words”:Posted in arc flash, electrical safety, safety training | Tagged 2012 nfpa 70e, 70e, arc flash, arc flash analysis, arc flash consultants, arc flash consulting, arc flash hazards, arc flash safety, electrical dangers, electrical hazards, electrical safety, lewellyn technology, osha, ppe, ppe requirements, workplace safety | Comments Off
Wow! What a great Implementing NFPA 70E session, so thank you for all of you that came out and met with us. We’re working on getting you the items we promised. Thanks again to all and we look forward to hearing from you soon!last week in Denver. It was great to see so many clients and colleagues as well as many new faces. It’s good to hear that Electrical Safety is still atop the priority list for many of you. We had great attendance in our
Jay Smith, Jr.
Executive Vice President
When most people think of injuries from electrical hazards, I’m sure they see visions of utility lineman, factory maintenance personnel or maybe electricians on a construction site. Visions of fast food restaurants or big box hardware stores probably don’t come to mind, but they should. Retail facilities, no matter the size, can harbor electrical hazards that threaten the employees, contractors and customers.
A quick search of OSHA’s website can turn up numerous injuries and citations that have occurred in retail. Every retail establishment should have a plan for auditing locations for these hazards and a plan to eliminate these hazards. Electrical safety in any facility relies heavily on training staff to recognize electrical hazards and when not to perform a certain task or use a piece of equipment that is unsafe. You don’t have to employ electricians for your employees to be exposed to electrical hazards.
President & Founder
While reading through an electrical safety forum today, I became a bit saddened by the attempts of many to throw electrical safety companies under the bus – companies who encourage their clients to have an arc flash hazard assessment completed for their facilities. Sure, there are marketing/broker/reseller and certain equipment manufacturing companies that are merely trying to upsell products using “safety” as the buzzword. However, there are real safety companies that have been in business for decades. Sure, safety companies make money doing arc flash assessments – of course they do. But to say that arc flash analysis is a commodity is just plain crazy. Complete facility arc flash analysis has barely been around for 10 years. It’s still relatively new so of course people are going to fight it because it involves CHANGE! Knowing what we now know about these hazards, we are, in many cases, able to mitigate the hazard. So why would you not do that? I hear of companies that try and avoid spending the money on electrical safety and just “do the bare minimum.” WHY?! IEEE 1584 states that PPE is the last line of defense. Why debate tables, trip times, and tasks when you can find out exactly what the hazard is and mitigate it? And if not, why not at least train and dress employees in appropriate PPE?
Jay Smith, Jr.
Executive Vice President
Just wanna thank everyone that came to the La Cima Club in Irving, TX to hear us speak about Implementing NFPA 70E. Great crowd, great venue, great food. Thank you Firewall International and Milliken for hosting and inviting me to speak and thanks to everyone that attended!
Jay Smith, Jr.
Exec. Vice President
There seems to be a lot of confusion regarding the 2012 NFPA 70E and IEEE 1584. I have been hearing that the rules have now changed on the <240V <125kVA rule for arc flash analysis requirements and many people are changing their thinking or all together panicking! So whoa, wait a minute here folks, the rules did not change. NFPA 70E 2012 states that you still must look to IEEE 1584 for information on arc flash hazards on 3-phase systems rated less than 240 volts. Remember, NFPA 70E is a great tool, it can save lives and has saved lives, but at the end of the day it is still a collaborative experience and opinion of a very educated group of individuals. IEEE, however, is based on actual physical evidence, that’s why NFPA 70E still requires that you follow IEEE 1584. So, protect your employees, have a study done per the IEEE standard and nothing should change in the way you approach electrical arc and shock protection.
Jay Smith, Jr.
Executive Vice President
Posted in arc flash, electrical safety, safety training | Tagged 2012 nfpa 70e, 70e, arc flash, arc flash analysis, arc flash hazards, arc flash safety, electrical hazards, electrical safety, ieee, ieee 1584, lewellyn technology, nfpa 70e, osha | Comments Off