A Path Toward Effective Electrical Safety
Robert S. LeRoy, CESCP, CUSP
LeRoy Electrical Enterprizes, Inc.
PO Box 6025 Lakeland, Florida 33807 USA
bob@leeinc.org

​Abstract:
Controlling worker behavior to model safe work practice expectations often seems like a futile task. Safety managers and supervisors plan and strategize using creative ideas, policies and programs and still the less than desirable results remain.
 
The electrical industry worldwide has embarked on a mission to increase training and hazard awareness that is showing some positive results in lowering accident rates and worker loss time incident (LTI) rates. Unfortunately history shows that too often workers view these programs as an event that is endured to satisfy the goals of the safety program. Sustainable lowered rates are not achieved, as the worker’s habits have not been addressed. When faced with the stress or pressure of a task needing performed they often digress to their old habits. When working in a culture that is driven by convenience or comfort accidents are unavoidable.  In recent years newer thoughts among safety managers are attacking the problem in a more holistic way. All safety initiatives are directed from the top of an organization but driven by the ones who must implement the ideas and concepts in real-world field applicable task performance.
 
This presentation will examine the responsibilities of electrical system designers, building and equipment owners and all those who operate or maintain electrical equipment travelling the path towards an effective safe work culture. Focusing on single milestones along this path may bring temporary success but do not bring the organization to its desired destination of sustainable incident free operations. Only when all gaps hindering this journey are discovered and effectively filled with appropriate measures are lasting results achieved.
 
Index Terms:  Electrical Safety, High Occupancy Building Safety, Safety Management, Safety Programs,
Safety Awareness, Safety Training
 
I.  Introduction
Safety experts worldwide often disagree on the most effective way to move workers toward experiencing a safer work culture. Accident reports are reviewed in hopes of discovering the gaps that allowed an incident, accident or fatality to occur. In hopes of inducing a more proactive and alert work ethic safety initiatives such as a company gift of a shirt or other identified prizes are proposed when a specified number of safe work hours are achieved. Health, Environmental and Safety (HES) managers often meet to exchange ideas on advancing this initiative. In all these efforts the gap that seems the hardest to fill in discovering the right path forward towards electrical safety for our unique company and work environments is determining how highly experienced and qualified workers manage to get themselves hurt. What is missing that allowed events to spiral out of control? Too often the attention is focused solely on the worker’s mistakes that may have caused the accident to occur.
 
The answer to this complex dilemma is best understood when taking a more holistic approach to the problem. 
1.      Endorsement at all levels of a thoroughly detailed electrical safety program as well as consistent enforcement of its principals is crucial for sustaining the energies to follow this path.
2.      Safety continues with an electrical system designed for safe operation. Engineers and designers must understand the important role they play in operations and maintenance worker safety by carefully choosing electrical equipment that utilizes the safest technologies available. 
3.      Facility managers and building engineers play an equally important role in supervising safe work practices. Ensuring equipment is used within design limitations and that it receives the appropriate maintenance attention is a crucial milestone in continuing on this pathway to effective safety.  Maintaining equipment as directed by the manufacturer, using industry best practices and considering the harsh environment in which it is installed is likely to move the plan closer to meeting this goal but often falls short in realizing lasting change. 
 
 
II.  The Pathway      

Whether the work culture is a qualified worker following safe work practices performing tasks on unsafe equipment or workers using unsafe work practices on properly maintained electrical equipment the undesirable result of injury and damage can be the same.
 
The workplace culture must change to one solely driven by safety. Too often company slogans such as “We put safety first” or “Safety is Number 1” are diluted and have no effect by inconsistencies in application. Utilizing the safest technologies for the system and building should always be of primary consideration. The electrical safety program must drive the key players beyond decisions based on economic analysis alone. Even the safest technologies can be rendered useless in the hands of inexperienced or unknowledgeable workers.
Previously were described three (3) key areas to consider when taking a holistic approach to changing the safety culture within an organization. A closer individual look reveals milestones to gauge the progress along this path.
First is the electrical safety program. The program must be written and best developed by a safety committee within the company comprised of representation from all levels. It should be exhaustive to cover all the areas of electrical hazard exposure and mitigation means available. This high level document must direct all policies, procedures and practices that will ensure safety. Writing and gaining endorsement of such a program is the hardest part of the journey. Without appropriate levels of commitment from the members of this safety team and continued support from management the efforts can soon succumb to lack of importance. If safety truly is #1 then this effort must receive the prompt attention it deserves. 
Globally accepted standards and best practices such as NFPA 70E, Electrical Safety in the Workplace, a US standard and CSA Z462-16, Workplace Electrical Safety, a Canadian standard are available to help company owners build an effective safety program. [1] [2] Unfortunately interpreting these standards in an effective and acceptable way can be quite confusing to the in experienced safety professional.
Often companies will outsource this activity to presumed expert consultants in this area. Great care should be exercised in the selection of such consultants. Only those with extensive knowledge and experience in the following areas should be chosen: 
1.      Awareness to governing laws and regulations as well as
2.      Electrical safety by design techniques and
3.      Human performance guidelines and measures
Consultants should work closely with the company safety team and facilitate change agents from within the company. Change that comes from within typically has a greater chance of being sustained in the hard times than does any change that is driven by outward pressure.
This safety program should include appropriate policies to direct all worker activities around electrical hazards. These policies will be based upon principles that drive a worker towards utilizing safer work practices. Examples would include clear justification for performing electrical work on energized equipment, thoroughly planning all work prior to work performance and assessing workers abilities to perform specific tasks prior to work assignments. The policies and principles must be audited annually and any time industry standards or best practices changes to ensure application to the work actually being performed. Pre-authorized safe work procedures will guide the entire workforce into doing specified tasks in a consistent manner. Hazard analysis and risk analysis techniques must be clear and precise so that each worker is analyzing the hazards encountered in the same way every time.   
Establishing an effective safety program continues with following a hierarchy of controls to eliminate, mitigate or control all hazards encountered.  ANSI/AIHA Z10, American National Standard for Occupational Health and Safety Management Systems provides the following hierarchy or controls guidance when implementing risk control procedures for worker safety.
1.      Eliminate the Hazard
a.      Unfortunately electricity is needed in the process so this option is not available 
2.      Substitute other technologies, equipment or processes
a.      An example may be utilizing arc resistant switchgear whenever possible to limit worker arc flash exposures to an acceptable level
3.      Use engineering controls
a.      Remote operation of equipment removing the worker from the area of hazard is a good option
4.      Awareness training
a.      Too many workers are unaware of the level of hazard encountered or the appropriate mitigation techniques to be used. Effective training must be provided which is focused to the hazard and appropriate for the expected task.
5.      Administrative controls
a.      Lock out / Tag out procedures and the use of Energized Electrical Work Permits provide clear guidance when energized hazards are encountered
6.      Personal Protective Equipment (PPE)
a.      Availability and use of all the appropriate PPE for the task is essential. PPE is considered the last line of defense. Workers should be trained to look higher up this hierarchy of controls list to appropriately mitigate the hazard and risk before defaulting to using PPE alone.
 
Workers must demonstrate proficiency in the hazard analysis procedures but the risk to perform a specified task must lie with their employer. Too often workers determine whether to perform a task based upon their perception of risk. This perception is biased by their experience, comfort level and convenience to do the task. If the culture is to be changed, clear written expectations must be given in the form of the electrical safety program.
 
Engineers and designers must understand the important role they play in operations and maintenance worker safety by carefully choosing electrical equipment that utilizes the safest technologies available. Use of industry guides such as IEEE P1814, Recommended Practice for Electrical System Design Techniques to Improve Electrical Safety  [4] will give designers and engineers grater understanding of techniques available to enable them to specify equipment features, apply protective schemes and make informed system installation choices to improve worker safety. At present this guide is still in development by the IEEE Industry Applications Society but many creative ideas are now included in the draft revisions that can be reviewed by IEEE members. Many SME consultants have access to these documents and can be utilized in the design stage of new installations or modifications to existing systems. Taking the safe work practice decision-making role out of the hands of the worker by appropriately applying the first 3 steps of the ANSI/AIHA Z10 Hierarchy of Control methodology is a wise investment. These newer technologies will likely cost more in the front end of a project but pay lasting benefits in safe reliable operation for years to come. 
 
Maintaining electrical systems and equipment is essential to sustaining the safe work initiative. Industry standards such as NFPA 70B, Recommended Practice for Electrical Equipment Maintenance [5] are excellent guides in establishing appropriate maintenance cycles for electrical equipment. Decision –making criteria is based upon equipment or system criticality, use within or outside of design criteria and ambient environmental conditions that may increase equipment deterioration beyond accepted norms. Worker training should include content on determining maintenance cycles required and using maintenance reports and sensory inspection (sight, smell, sound) to determine equipment condition prior to attempting any work task. Normal operating condition analysis includes:
1.      Was the equipment initially installed correctly?
2.      Has the equipment been appropriately maintained?
3.      Are all the design protections (door, covers, breaker trip settings, etc.) in place?
4.      Has there been any modification to the manufacturer’s design? And finally,
5.      Are there any signs of impending failure such as abnormal smells, observed damage or unusual operational sounds?
 
Determining current equipment condition is critical in their decision-making procedures on whether it is safe to proceed with the planned work. It is prudent to be reminded that one can never maintain out a bad installation. Worker training must include the appropriate content to provide the tools necessary to determine normal operating condition.
 
When considering maintenance it is wise to remember these same criteria apply to the worker’s condition as well. “Readiness for Work” guidelines should be included in the overall safety program. Workers must be given the responsibility and tools to determine their condition prior to any work performance. Criteria for this determination include:
1.      Has the worker been trained on the task?
2.      Has the worker demonstrated their understanding and skills proficiency to safely perform the task?
3.      Have they done this task successfully in the recent past? A guideline of “in the past 12 months” is typically used. Workers should be encouraged to examine their confidence to perform the task safely even if it has been a relatively short time since last performing the task and encouraged to ask for help when that confidence level is ever in doubt.
4.      Are there any physical or mental limitations today that might impair their ability to achieve safe work performance? 
 
There are many parts to assemble in developing, implementing and sustaining an effective electrical safety program. Use of checklists provided by SME consultants is a useful tool to ensure no steps are overlooked. [See Appendix A]
 
III.  Conclusion
To embrace this change a progression of steps must be followed with equal passion from the company management down to the lowest job description on the organizational chart. 
Acknowledge the need 
a.           Own the culture  

b.           Establish the guidelines 

Acquire the knowledge 
a.           Train for the expectations 

b.           Provide positive mentoring 

Apply the solution 
a.           Monitor the process 

b.           Document the effectiveness                                           
 
An effectively written electrical safety program will include clear guidance for workers to complete their tasks in safety. Providing clear guidance with policies, principles and procedures sets the vision and possibility of attaining the goal. Training with documented skills assessments of worker understanding and compliance establishes the expectations. Achieving a safer workplace through safety by design criteria and completing appropriate maintenance on that equipment and system helps to sustain the initiative.
 
In all of these efforts the weak link remains with the worker themselves. Ensuring their skills remain at a high level is achieved through annual assessments of their compliance. Using objective and measurable techniques areas of deficiency can be recognized and appropriately met with coaching, re-training or re-assignment prior to an incident occurring.
 
Achieving an incident free operation (IFO) is possible.
No body said it would be easy. 
 
IV.  References 
[1]  NFPA 70E, Electrical Safety in the Workplace,
National Fire Protection Association, www.nfpa.org ,
ISBN: 978-145590926-1, 2015
 
[2]  CSA Z462, Workplace Electrical Safety, Canadian
Standards Association, www.csa.org , ISBN 978-177139-696-7, 2015
 
[3]  ANSI/AIHA Z10, American National Standard for
Occupational Health and Safety Management Systems,
www.webstore.ansi.org , ANSI Z10-2012
 
[4]  IEEE P1814, Recommended Practice for Electrical
System Design Techniques to Improve Electrical Safety, IEEE Standards Association,
https://standards.ieee.org/develop/project/1814.html  
 
[5]  NFPA 70B, Recommended Practice for Electrical Equipment Maintenance, National Fire Protection
Association, www.nfpa.org , ISBN: 978-145591332-9,
2016  
 
V.  Vitae
​Robert S. LeRoy, CESCP, CUSP is the CEO of LeRoy Electrical Enterprizes, Inc. He is an independent electrical safety and code compliance consultant. He has 44 years experience in the utility, industrial and commercial electrical systems and equipment. During his nearly 20 years with a utility generating facility Mr. LeRoy was an active member and leader of the utility’s voluntary emergency response team as first response to chemical, fire and medical emergencies. Responding to countless emergency situations has given him a passion for safety and perspective on the role of human behavior in averting these events.
 
Mr. LeRoy is a master electrician, IAEI NCPCCI-2B Certified Electrical Inspector, NFPA Certified Electrical Safety Compliance Professional, Certified Utility Safety Professional and a member of NFPA, IAEI, ASSE, USOLN and IEEE. He has worked with several international clients to adapt US based NFPA electrical standards (NEC, 70B electrical maintenance practices and 70E electrical safe work practices) in melding them with local country regulations. Mr. LeRoy has conducted accident reports and forensic installation and work practice studies to assist clients in identifying any deficiencies and develop processes and procedures to remediate any gaps to establishing a safer work environment.
 
He can be reached at: bob@leeinc.org +1-863-944-3369

​Electrical Safety Program Preliminary Audit Checklists
 Used when preparing for a full audit

​An effective electrical safety program contains many elements to adequately establish a safe work environment. Each element requires appropriate analysis to determine its application. Electrical safety programs are best when written by a team of company individuals representing all levels of employees. The program should be clearly documented, appropriate to expected work tasks and endorsed by all representatives so that all users can embrace it. 
 The following checklists will assist prior to an in-depth audit of existing safety elements and identify gaps in expectations. Senior management support of the developed electrical safety program is essential to ensure sustaining the safety initiatives. 

​This checklist is only intended to cover basic information required to provide a safe work environment. Each company and workplace must be evaluated against country and local governing laws and regulations, industry standards and best practices to ensure the greatest effectiveness of the electrical safety program. This goal is best realized when utilizing third party (3rd party) SME consultants to ensure an in-depth unbiased evaluation is conducted. Only when all gaps in existing programs, policies and procedures are discovered can the goal of incident free operations (IFO) be achieved for all.