Enhancing Electrical Safety
Without Touching a Tool [1]
Copyright Material IEEE Paper Number ESW2016-2
978-1-4673-9922-7/16/$31.00 ©2016 IEEE
Robert S. LeRoy LeRoy Electrical Enterprizes, Inc.
PO Box 6025 Lakeland, Florida 33807 USA Bob@leeinc.org
Abstract – When dealing with electrical safety the most critical points can often be missed. Much focus has been placed on wearing appropriate PPE to meet or exceed the hazard level encountered. Worker training has been placed into overdrive resulting in reduced injury severity and greater awareness of individual responsibility where exposed and energized parts and conductors are encountered. PPE is showing up in the workplace at record numbers and manufacturers are responding with innovative and costeffective technologies. The required PPE has become not only an affordable part of even the smallest of employer’s cost of doing business but also comes in varieties, colors and options which brings greater worker comfort and acceptance. Worker day-of-use testing, inspecting and utilizing PPE are of major importance. Too often we skip to the conclusion and deal with what is left rather than analyzing the parts and placing a greater importance on safety management instead of simple injury protection.
Unfortunately the electrical construction sector is not as convinced when and where electrical hazard awareness is appropriate and PPE required when conducting tasks such as setup or commissioning on these same systems. The line between de-energized construction and energized verification is not as hard to determine, as it is to enforce. It is in this arena the electrical inspector or inspecting engineer can have a huge effect on ensuring electrical safety without even touching a tool.
Those in the inspecting role can have a much greater effectiveness in advancing electrical safety than they may realize. With a good working knowledge of standards such as NFPA 70E and CSA Z462 and understanding of design best practices and the upcoming guide IEEE P1814, Electrical Safety by Design they can set the bar and take electrical safety into arenas previously untouched. This paper will explore the awareness required, the understanding needed and the potential impact expected by simply expressing expectations.
Index Terms – hazard analysis, risk assessment, behavioral safety, NFPA 70E, CSA-Z462, arc flash safety, shock safety, OSHA, best practices, electrical safety program, monitoring electrical safe work practices, inspecting for safety, modeling expectations, inspecting, commissioning
I. INTRODUCTION In the early 1900’s, as the modern industrial revolution, scientific discoveries and technological explosions were in their infancy, academia was forced to endure a questioned existence. More emphasis was placed upon accomplishments than the processes that produced them. Even the critical thinkers and literary pioneers of the day got on the bandwagon. “He who can does, he who cannot, teaches” [2] is unfortunately one of the most enduring and quoted sayings from the day. Attributed to George Bernard Shaw in his 1903 play Man and Superman / Maxims for Revolutionists, it was meant to portray people who are able to do something well can do that thing for a living, while people who are not able to do anything that well can make a living by teaching about it. In the response to the societal shift of the second half of the 20th century, the pendulum swung away from the “simply do it” mentality of the early 1900’s to actively seeking greater knowledge through higher education. Many were unsuited or unmotivated for higher education and became frustrated with the process. With the higher level of knowledge they had gained the obvious career choice was in education. The baby-boom era demanded more teachers and employment was easy to find. Too often in this era these educators were not always dedicated to the teaching profession. Most were convinced that teaching is a noble profession as long as you’re good at it. Unfortunately many confessed there were people who became teachers simply because they couldn’t do anything else. With the absence of dedication to the rewards teaching can afford, many unknowingly fulfilled those prophetic words spoken by Mr.
Shaw so many years earlier.
In his 1977 screenplay, Annie Hall, Woody Allen takes the insult of the educational process to even higher levels. “Those who can't do, teach. And those who can't teach, teach gym.” [3]. So even today the stigma exists. Those with the talent, skills and drive “do” while all others simply observe.
To put the axiom in the context of this paper, there are two competing camps within our industry. Each perceives their value greater than the other yet both must coexist with some sense of civility. On one side are the active participants who skillfully use tools and equipment for installation and maintenance pursuits. And on the other are those that oversee its correct application.
Today we may say, “Those that can, do. Those that can’t, inspect”. While much effort has been expended lately to ensure those performing installation and maintenance activities are well-trained and prepared with appropriate procedures and PPE to survive that interaction, the opposite is true for those observing. Unfortunately those managing, supervising or performing less active roles like inspecting and commissioning have been conditioned they need less direct protection and safety knowledge based upon their lesser expected lack of potential electrical hazard exposure and contact.
Several papers have been presented at the IEEE-IAS ESW events in the past few years detailing the need to audit and monitor the behaviors of those actively interacting with energized electrical systems and conductors. Data has been collected to emphasize the need for diligence in clear, precise direction provided by the employers to ensure expected compliance. Discovering and mitigating the three cultures that exist in the workforce is a never-ending activity. Competent and skilled workers tend to exhibit an alarming combination of at least three behaviors. [4] [5]
1. Work to a level of convenience
2. Justify convenience based upon a level of confidence or comfort and
3. Validate their work practices based upon the lack of direction to which they conclude is their employer’s consent.
It is in this vacuum of clear and precise direction that the commissioning and inspecting roles must navigate.
II. AWARENESS REQUIRED
Safety professionals are too often tasked with conducting a series of interviews and investigations after an incident has occurred. This process, known as a root cause analysis, or RCA is both excruciatingly painful and exhaustive. Its purpose is to dive down to the real conditions that caused the incident to occur, not just the surface reasons of direct cause and effect. Workplace cultures are then uncovered and worker actions that thrive in those cultures are identified.
A way to overcome behaviors within a culture is to have clear, concise and enforced directives guiding work practices. It may be true workers have to be convinced before they change their ways but giving them clear direction results in increased awareness and voluntary movement towards a safer behavior. Training is critical to establish awareness and expectations but absent employer endorsement during work task performance these efforts are not sustained.
Several past RCA’s conducted by this author concluded the following reasons for the incident or fatality under investigation.
1. No written work plan prior to commencing work to set the boundaries when the work scope exceeded the expected work performance.
2. The lack of the written work plan resulted in the worker doing tasks outside of their area of expertise or training. The worker never identified areas outside of their training and awareness and did not limit activities outside the original work scope.
3. No secondary person with a written work plan in his or her hands to watch the work being performed. They could have spoken up and stopped the worker when their actions exceeded the plan.
4. Fatigue. The workers pushed themselves beyond reason even though completely fatigued in a misguided effort to meet the perceived expectations of their employer. If the employer had written selfassessment guidelines, sometimes called “fitness for duty” criteria in their electrical safety program these workers would have felt justified in stopping themselves without fear of any repercussions.
As it was in all the cases this author has investigated or reviewed the lack of these four simple guidelines results in work performance that borders on carelessness and not the successful results expected. Carelessness that is perceived by the worker as employer consent to their actions.
A recent article referenced in a prestigious international electrical inspector’s bi-weekly email quoted an electrical engineering portal study concerning 10 common causes of arc-flash and shock incidents. [6]
1. Carelessness
2. Worn or broken conductor insulation
3. Exposed energized live parts
4. Loose wire connections
5. Improperly maintained switches and circuit breakers
6. Obstructed disconnect panels
7. Water or liquid near electrical equipment
8. High voltage cables
9. Static electricity
10. Damaged tools and equipment
Although the data upon which the above list was derived was not presented in the article one clear understanding does emerge. The #1 inexcusable reason of an arc-flash or shock incident to occur is carelessness.
A myriad of other studies over the years have concluded that three major factors influence the likelihood of an electrical incident.
1. Human factors:
a. Includes work practices
b. Involves selection and proper use of tools 2. Design and installation factors:
a. Understanding “safety by design”
b. Properly using all the designed safety built in the equipment during operation and maintenance activities
3. Maintenance (or more accurately “lack of maintenance”) factors
a. Lack of detailed “as built data”
b. Scheduling (or skipping) maintenance cycles based on budget or production demands
Commissioning of new or revamped electrical systems and equipment is estimated to be 1% - 1.5% of the total job cost. [7]. The return on this small investment has shown to be very impressive in an overall increase in system reliability and reduced operating costs. It also has a positive effect on establishing a baseline upon which maintenance efforts are reflected in the years that follow. Unfortunately in today’s world of “cost-cutting and get it operational today” mandates safety guidelines are overridden for immediate results and greater deficiencies may arise in the future.
Often those tasked with inspecting or validating an installation may not have an extensive electrical background. In major industry environments it may the project engineer tasked with these duties. Too often that person’s expertise is as a process, mechanical or even chemical engineer. Their awareness of electrical hazards revolves around the possibility of getting shocked and arc flash understanding is not extensive if even existent.
In the general industry, especially construction environments, many inspection authorities have chosen to utilize a “crosscraft” multi-disciplined inspector who may have even less electrical hazard awareness. Any training and PPE offered by their employer is limited to their expected electrical exposure. Since inspection falls into the “observational” disciplines there is no expected electrical shock exposure as determined by their employer. In many cases the existence of this thing called “arc flash” is either unknown or never expected to be encountered since their inspection duties are “just looking” and not the “interacting with” actions of the installer. The fact that they may be well within an arc flash boundary where training, safe work practices and PPE is required to survive is totally missed.
In the past 3 years this author has had the distinct opportunity to either speak directly with other electrical inspectors on this topic or conduct training for them. In nearly all cases the safe approach boundary distances and the required work practices were completely misunderstood. Very few understood even the safe work practices and PPE the qualified electrical workers should exhibit during their inspection process. A survey posted on the official inspector’s “LinkedIn” site where nearly 4000 inspectors are registered garnered 7 respondents. These inspectors were asked three questions in hopes of uncovering a common culture that could then be understood and guided.
• Do you as an inspector have and use rubberinsulating gloves with leather protectors, arc rated clothing and an arc rated face shield for use when needed?
• Do you inspect for government (state, county or local) or private inspection authority?
• Are you convinced as an inspector that NFPA 70E with all its glory applies to you?
A slim but eye-opening result of the survey revealed the following:
1. All the respondents recognized the “energized” hazard
2. One had the required PPE purchased by his employer. He worked in the private sector.
3. A second had purchased his own. Municipal or government employers felt exempt from this requirement.
4. Two responded they were either not allowed by government regulation (Australia) or employer mandate to inspect energized equipment. The electrical contractor was responsible to open the equipment and then place it into an electrically safe work condition (de-energized state) prior to any inspection activity occurring.
5. All responded there is a great need to inform and “train” their management of the hazards encountered and their responsibility to either direct safe-work practice guidelines or provide the needed PPE.
A disappointing and very small response from a large potential group of respondents and therefore a conclusion following any scientific pattern is impossible. What is clear is that inspectors are not the doers and there remains a definite gap in those supervising them of understanding the electrical hazards involved during those activities and their responsibility to appropriately respond.
III. UNDERSTANDING NEEDED
Anyone in the workplace is exposed to hazards, depending on the work tasks they are performing, and in this case the electrical hazards of shock and arc flash would require the worker be a “qualified person”. In recent years NFPA 70 series documents have evolved their definition of a qualified person to be in alignment with the current OSHA definition and each other. A clearer understanding then emerges for the inspector to enter these areas and the responsibility of the electrical workers who have control of the equipment and area while energized hazards are exposed.
OSHA Qualified person. One who has received training in and has demonstrated skills and knowledge in the construction and operation of electric equipment and installations and the hazards involved. [8]
NFPA 70 Qualified Person. One who has skills and knowledge related to the construction and operation of the electrical equipment and installations and has received safety training to recognize and avoid the hazards involved.
Informational Note: Refer to NFPA 70E-2012, Standard for Electrical Safety in the Workplace, for electrical safety training requirements. [9]
NFPA 70E Qualified Person. One who has demonstrated skills and knowledge related to the construction and operation of electrical equipment and installations and has received safety training to identify and avoid the hazards involved. [10]
Even though the wording of each definition is not identical the intent brings all three definitions in alignment with each other. It is important to understand that when OSHA looks at training and training programs the question is not so much did training occur but was that training “effective”? Effective training must be relevant, timely and ensure understanding. To discover the effectiveness of a training program, feedback must be accomplished to determine a level of individual understanding which that then can be measured to gauge effectiveness and when additional training may be appropriate. In this sense when NFPA 70 says a qualified person has “received training to identify and avoid the hazards involved” it is more than attendance to a class. Installation qualification must involve discerning the potential electrical hazards that could expose an unknowledgeable user to injury and mitigating that hazard with installation or operational strategies. When a construction electrician encounters energized electrical equipment and potential exposure to electrical hazards through commissioning, troubleshooting or other activities it is imperative a different level of qualification be understood. The worker that removes electrical box covers opens door or in any other way exposes themselves to electrical hazard has now accepted responsibility for themselves and any others in the approach boundaries where a shock or arc flash could reach out and touch someone.
In today’s work environment a qualified electrical person has shown mastery and proficiency in more areas than ever before. Fig 1.
1. There must be a competency in technical matters such as installation and design techniques utilized to establish a safer electrical work environment.
2. They must also be able to discern a “normal from abnormal” operating condition and the minimum maintenance that is required to ensure the longevity of the safe design.
3. Finally there must be a clear and thorough understanding of work practices to mitigate or avoid exposure to the electrical hazards involved and a firm belief that working de-energized is ALWAYS the first choice and that PPE is the last line of defense.
It must be understood due to changes in work tasks, equipment or technologies that the development of qualified workers is not an event. Those employers that implement an evergreen process of continual development and assessment to ensure deploying a workforce both current in knowledge and skills and compliant to current safe work practice expectations.
Fig 1. Qualified Electrical Worker Circle of Development
Inspectors or those in charge of commissioning electrical installations must also understand this process along with the electrical hazards encountered and the survival techniques required. Any person entering the limited approach boundary for shock or arc flash boundary around exposed energized conductors or circuit parts needs a good dose of electrical hazard awareness training. Whether the duties are “hands-on” or “just looking ” those electrons don’t know. Being in the wrong place at the right time or the right place at the wrong time can end in a very undesirable event. One variant of the
“Danger” sign says it all. Fig 2
Fig 2. Self-Explanatory Danger Sign
Whether the regulations or employer guidelines direct no energized work is to be done or an unexpected encounter occur, just being inside the shock and arc flash boundaries requires appropriate caution and protection. The inspector, inspecting engineer or project manager involved in commissioning or verification activities should at least consider the following check list of guidelines prior to entering the area of exposed electrical hazards.
Commissioning recommendations:
ü Ensure the company electrical safety program (ESP) includes commissioning or startup guidelines. This is often the place where moving a wire from one terminal to another to fix the installation mistake, especially those 120 volt circuits perceived to be less hazardous, are done while still energized to save time and money. The results can be very costly. The company ESP must clearly define “energized work” and give commonly encountered examples of accepted and unaccepted tasks. ü Adopt a personal culture that doing most if not all work in a de-energized state is the goal. Working while the circuit remains energized is no longer the expected norm. Testing, diagnosing or commissioning any system needs to be done in a deenergized state as a matter of rule not just a voluntary work practice.
ü Develop a written work plan and a procedure for your intended activities. Don’t leave it up to memory, verbal plans or past experience.
ü Ensure manufacturer’s representatives understand the company guidelines and expectations for safe work. These manufacturer’s technicians may be the subject matter experts on that equipment but likely are not the best examples for doing it safely. Constraints to get the job done quickly often override the obvious safe performance. Often times their familiarity with the equipment and greater experience drives these lesser work practices.
ü Overcome the perception that PPE is just for electrical maintenance work. Electrical installation activities cease when the power is turned on. There is no maintenance versus construction where exposed energized electrical conductor or circuit parts and electrical hazards are encountered. If the power is to be left on then appropriately selected, tested, inspected and utilized PPE is the only way to reduce risk to an acceptable level.
ü Express your expectations and raise the bar for safe work practice expectations where it may be lacking.
Inspection recommendations: ü Clearly understand the intended equipment to inspect and any other potentially energized electrical equipment hazard in the area. This includes the various voltages that may be present inside a single enclosure or system.
ü Observe from a close but safe distance the work practices and PPE utilized by the installer when removing box covers and while exposing the equipment to be inspected. Whether or not they are using safe work practices, establishing safe zones by means of barricades or warning tape or utilizing the appropriate PPE will tell you a lot about their overall qualifications. Observing shortcuts here can likely mean other shortcuts were taken during installation.
ü Witness the verification of absence of voltage. Most inspecting authorities do not allow their inspectors to put hands on the equipment or even remove the covers to expose the different devices and wiring to be inspected. This results in the installer either opening the equipment or de-energizing it prior to the inspector’s arrival. The inspector has the “right to know” the electrical hazard has been eliminated and the responsibility to verify that state. Have the installer verify it in your presence. After all, you are placing your life in the hands of the person whose livelihood is in yours.
ü Apply your own locks to the disconnecting devices prior to inspection. Your activities may require a close inspection of wire sizes and terminal markings. If the disconnecting means does not have the inspector’s personal lock applied someone not involved with the inspecting activities could unexpectedly turn it on creating a serious electrical hazard to both the inspector and anyone else affected by that circuit unexpectedly receiving power. ü Express your expectations and raise the bar for safe work practice expectations where it may be lacking.
IV. CONCLUSION, POTENTIAL IMPACT
In the installer’s world three employer actions provide employees protection from electrical shock, arc flash and blast. Written polices provide the foundation on what can and cannot be done. For work that is allowed, a written plan and procedures are developed and followed to ensure consistency of outcomes. Where procedures are followed personal protective equipment (PPE) is utilized to mitigate or lessen any potential injury. PPE is often related as the last line of defense. Physical equipment such as rubber-insulating gloves with leather protectors or arc-rated clothing is most often the mental picture we envision. It is time the workers and employers alike realize PPE is much more than simple equipment. Thorough planning followed by appropriate preparation are two critical steps prior to execution of any work performance. Inspecting, commissioning and startup timelines must reflect the realistic expectations of standards, regulations and industry best practices required of those maintaining those same systems including all of the electrical safe work practices, procedures and PPE.
Fast-tracked projects focusing on turn over or project end dates alone are a fertile ground for growing the absence of safe work practices. Employers and employees alike can embark on a path of applying ANSI/AIHA Z10 risk control hierarchy methodology [11] by following a practical course of the three P’s. Sometimes we must use what we have at hand.
Fig 3
Fig 3 Hierarchy of Practical Protection
During inspection or commissioning engagements the observers should hear some of the following statements.
1. “I need to don my PPE before going any further”
2. “Please stand over here behind the barricade while I remove the cover”’
3. “Let me get my insulated tools” or
4. “I de-energized everything before you got here. The disconnecting means is over here and this is my lock. You need to place your lock here then witness my verification of absence of voltage.”
Those in the inspecting and commissioning roles can increase their safety as well as increase safety awareness by being aware of and following the same path. These “observers” must have the same level of electrical hazard awareness and safe work practices that should be utilized as the “doers”. Commissioning or inspecting activities must follow the same Plan – Prepare – Perform/Execute guidelines where Policies, Procedures and PPE are utilized to ensure safe and effective work performance.
Employers of those actively interacting with energized circuit conductors and parts are required to periodically audit both their electrical safety program and their workers understanding of and application compliance to it.
• Audit their overall program at least every 3 years for continued compliance with regulations and 70E [12]
• Field audit their program at least annually or anytime new work functions are added to their services for thorough applicability with the expected work tasks encountered [12] and
• Annual inspections (assessments) of each worker to indicate compliance (e.g. understanding and application) of their electrical safety program and designated safe work practices.
[14]
Too often these audits are applied only to the doers. Observers should take note and follow a similar path to safety and success.
It may be true that “those that can, do and those that can’t observe”. These really are not competing camps. We must all remember that those that care are the ones that can make a difference. We are all in this together, us “doers” and “observers” with one common enemy. Armed with appropriate levels of electrical hazard awareness knowledge, the expectations of everyone following electrical safe work practices while utilizing properly tested and inspected PPE are known, the expressed electrical safety can be enhanced without even touching a tool.
V. REFERENCES
(1) LeRoy, Robert S., “Enhancing Electrical Safety Without Touching a Tool”, 2016 IEEE IAS
Electrical Safety Workshop Conference Record
(2) http://www.quotationspage.com/quotes/George_ Bernard_Shaw
(3) http://www.goodreads.com/work/quotes/2611796annie-hall-faber-reel-classics
(4) LeRoy, Robert S. and McCoy, Tim, “Moving from Training to Compliance, Practical methodology to monitor worker compliance to electrical safe work practices”, IEEE Paper No. ESW 2014-33
(5) LeRoy, Robert S., “Hazard or Risk Analysis, Overcoming the Human Factor”, IEEE Paper No. ESW 2015-19
(6) IAEI Weekly Update, August 12, 2015, http://electrical-engineering-portal.com/10common-causes-of-arc-flash-and-otherelectrical-accidents
(7) 2013 NFPA 70B, Recommended Practice for
Electrical Equipment Maintenance, Chapter 31.7 and Table 31.7, page 70B-130
(8) 29 CFR 1910.399 “Qualified Person”
(9) 2014 NFPA 70 National Electrical Code, Article
100, definitions
(10) 2015 NFPA 70E Standard for Electrical Safety in the Workplace, Article 100, definitions
(11) ANSI/AIHA Z10 American National Standard for Occupational Health and Safety Management Systems
(12) 2015 NFPA 70E Standard for Electrical Safety in the Workplace, Article 110.1 (I)(1)
(13) 2015 NFPA 70E Standard for Electrical Safety in the Workplace, Article 110.1 (I)(2)
(14) 2015 NFPA 70E Standard for Electrical Safety in the Workplace, Article 110.2 (D)(3)(1)
978-1-4673-9922-7/16/$31.00 ©2016 IEEE
VII. VITAE
Robert S. LeRoy, CESCP is the president of LeRoy Electrical Enterprizes, Inc. (www.leeinc.org). He is an independent electrical safety and compliance consultant and former Director of Electrical Programs for an international training company. He has 44 years experience in the utility, industrial and commercial electrical systems and equipment. During his nearly 20 years with a municipal utility power 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. He has conducted over 500 classes in NEC, NFPA 70E, NFPA 70B/NETA, 1910.269, NESC, Grounding and Bonding and Hazardous Locations to thousands of students worldwide.
As a master electrician, IAEI NCPCCI-2B Certified Electrical Inspector, NFPA Certified Electrical Safety Compliance Professional and a member of NFPA, IAEI, ASSE and IEEE he assists clients in the utility, oil and gas, manufacturing and aviation industries in gap analysis for compliance to electrical safety regulations and procedures, developing a well-trained electrical workforce and provides monitoring tools to measure compliance and training effectiveness. Mr. LeRoy 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 or international client requirements for acceptance and use in 18 countries around the world. Mr. LeRoy is the author of two previous ESW papers. He 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.
Unfortunately the electrical construction sector is not as convinced when and where electrical hazard awareness is appropriate and PPE required when conducting tasks such as setup or commissioning on these same systems. The line between de-energized construction and energized verification is not as hard to determine, as it is to enforce. It is in this arena the electrical inspector or inspecting engineer can have a huge effect on ensuring electrical safety without even touching a tool.
Those in the inspecting role can have a much greater effectiveness in advancing electrical safety than they may realize. With a good working knowledge of standards such as NFPA 70E and CSA Z462 and understanding of design best practices and the upcoming guide IEEE P1814, Electrical Safety by Design they can set the bar and take electrical safety into arenas previously untouched. This paper will explore the awareness required, the understanding needed and the potential impact expected by simply expressing expectations.
Index Terms – hazard analysis, risk assessment, behavioral safety, NFPA 70E, CSA-Z462, arc flash safety, shock safety, OSHA, best practices, electrical safety program, monitoring electrical safe work practices, inspecting for safety, modeling expectations, inspecting, commissioning
I. INTRODUCTION In the early 1900’s, as the modern industrial revolution, scientific discoveries and technological explosions were in their infancy, academia was forced to endure a questioned existence. More emphasis was placed upon accomplishments than the processes that produced them. Even the critical thinkers and literary pioneers of the day got on the bandwagon. “He who can does, he who cannot, teaches” [2] is unfortunately one of the most enduring and quoted sayings from the day. Attributed to George Bernard Shaw in his 1903 play Man and Superman / Maxims for Revolutionists, it was meant to portray people who are able to do something well can do that thing for a living, while people who are not able to do anything that well can make a living by teaching about it. In the response to the societal shift of the second half of the 20th century, the pendulum swung away from the “simply do it” mentality of the early 1900’s to actively seeking greater knowledge through higher education. Many were unsuited or unmotivated for higher education and became frustrated with the process. With the higher level of knowledge they had gained the obvious career choice was in education. The baby-boom era demanded more teachers and employment was easy to find. Too often in this era these educators were not always dedicated to the teaching profession. Most were convinced that teaching is a noble profession as long as you’re good at it. Unfortunately many confessed there were people who became teachers simply because they couldn’t do anything else. With the absence of dedication to the rewards teaching can afford, many unknowingly fulfilled those prophetic words spoken by Mr.
Shaw so many years earlier.
In his 1977 screenplay, Annie Hall, Woody Allen takes the insult of the educational process to even higher levels. “Those who can't do, teach. And those who can't teach, teach gym.” [3]. So even today the stigma exists. Those with the talent, skills and drive “do” while all others simply observe.
To put the axiom in the context of this paper, there are two competing camps within our industry. Each perceives their value greater than the other yet both must coexist with some sense of civility. On one side are the active participants who skillfully use tools and equipment for installation and maintenance pursuits. And on the other are those that oversee its correct application.
Today we may say, “Those that can, do. Those that can’t, inspect”. While much effort has been expended lately to ensure those performing installation and maintenance activities are well-trained and prepared with appropriate procedures and PPE to survive that interaction, the opposite is true for those observing. Unfortunately those managing, supervising or performing less active roles like inspecting and commissioning have been conditioned they need less direct protection and safety knowledge based upon their lesser expected lack of potential electrical hazard exposure and contact.
Several papers have been presented at the IEEE-IAS ESW events in the past few years detailing the need to audit and monitor the behaviors of those actively interacting with energized electrical systems and conductors. Data has been collected to emphasize the need for diligence in clear, precise direction provided by the employers to ensure expected compliance. Discovering and mitigating the three cultures that exist in the workforce is a never-ending activity. Competent and skilled workers tend to exhibit an alarming combination of at least three behaviors. [4] [5]
1. Work to a level of convenience
2. Justify convenience based upon a level of confidence or comfort and
3. Validate their work practices based upon the lack of direction to which they conclude is their employer’s consent.
It is in this vacuum of clear and precise direction that the commissioning and inspecting roles must navigate.
II. AWARENESS REQUIRED
Safety professionals are too often tasked with conducting a series of interviews and investigations after an incident has occurred. This process, known as a root cause analysis, or RCA is both excruciatingly painful and exhaustive. Its purpose is to dive down to the real conditions that caused the incident to occur, not just the surface reasons of direct cause and effect. Workplace cultures are then uncovered and worker actions that thrive in those cultures are identified.
A way to overcome behaviors within a culture is to have clear, concise and enforced directives guiding work practices. It may be true workers have to be convinced before they change their ways but giving them clear direction results in increased awareness and voluntary movement towards a safer behavior. Training is critical to establish awareness and expectations but absent employer endorsement during work task performance these efforts are not sustained.
Several past RCA’s conducted by this author concluded the following reasons for the incident or fatality under investigation.
1. No written work plan prior to commencing work to set the boundaries when the work scope exceeded the expected work performance.
2. The lack of the written work plan resulted in the worker doing tasks outside of their area of expertise or training. The worker never identified areas outside of their training and awareness and did not limit activities outside the original work scope.
3. No secondary person with a written work plan in his or her hands to watch the work being performed. They could have spoken up and stopped the worker when their actions exceeded the plan.
4. Fatigue. The workers pushed themselves beyond reason even though completely fatigued in a misguided effort to meet the perceived expectations of their employer. If the employer had written selfassessment guidelines, sometimes called “fitness for duty” criteria in their electrical safety program these workers would have felt justified in stopping themselves without fear of any repercussions.
As it was in all the cases this author has investigated or reviewed the lack of these four simple guidelines results in work performance that borders on carelessness and not the successful results expected. Carelessness that is perceived by the worker as employer consent to their actions.
A recent article referenced in a prestigious international electrical inspector’s bi-weekly email quoted an electrical engineering portal study concerning 10 common causes of arc-flash and shock incidents. [6]
1. Carelessness
2. Worn or broken conductor insulation
3. Exposed energized live parts
4. Loose wire connections
5. Improperly maintained switches and circuit breakers
6. Obstructed disconnect panels
7. Water or liquid near electrical equipment
8. High voltage cables
9. Static electricity
10. Damaged tools and equipment
Although the data upon which the above list was derived was not presented in the article one clear understanding does emerge. The #1 inexcusable reason of an arc-flash or shock incident to occur is carelessness.
A myriad of other studies over the years have concluded that three major factors influence the likelihood of an electrical incident.
1. Human factors:
a. Includes work practices
b. Involves selection and proper use of tools 2. Design and installation factors:
a. Understanding “safety by design”
b. Properly using all the designed safety built in the equipment during operation and maintenance activities
3. Maintenance (or more accurately “lack of maintenance”) factors
a. Lack of detailed “as built data”
b. Scheduling (or skipping) maintenance cycles based on budget or production demands
Commissioning of new or revamped electrical systems and equipment is estimated to be 1% - 1.5% of the total job cost. [7]. The return on this small investment has shown to be very impressive in an overall increase in system reliability and reduced operating costs. It also has a positive effect on establishing a baseline upon which maintenance efforts are reflected in the years that follow. Unfortunately in today’s world of “cost-cutting and get it operational today” mandates safety guidelines are overridden for immediate results and greater deficiencies may arise in the future.
Often those tasked with inspecting or validating an installation may not have an extensive electrical background. In major industry environments it may the project engineer tasked with these duties. Too often that person’s expertise is as a process, mechanical or even chemical engineer. Their awareness of electrical hazards revolves around the possibility of getting shocked and arc flash understanding is not extensive if even existent.
In the general industry, especially construction environments, many inspection authorities have chosen to utilize a “crosscraft” multi-disciplined inspector who may have even less electrical hazard awareness. Any training and PPE offered by their employer is limited to their expected electrical exposure. Since inspection falls into the “observational” disciplines there is no expected electrical shock exposure as determined by their employer. In many cases the existence of this thing called “arc flash” is either unknown or never expected to be encountered since their inspection duties are “just looking” and not the “interacting with” actions of the installer. The fact that they may be well within an arc flash boundary where training, safe work practices and PPE is required to survive is totally missed.
In the past 3 years this author has had the distinct opportunity to either speak directly with other electrical inspectors on this topic or conduct training for them. In nearly all cases the safe approach boundary distances and the required work practices were completely misunderstood. Very few understood even the safe work practices and PPE the qualified electrical workers should exhibit during their inspection process. A survey posted on the official inspector’s “LinkedIn” site where nearly 4000 inspectors are registered garnered 7 respondents. These inspectors were asked three questions in hopes of uncovering a common culture that could then be understood and guided.
• Do you as an inspector have and use rubberinsulating gloves with leather protectors, arc rated clothing and an arc rated face shield for use when needed?
• Do you inspect for government (state, county or local) or private inspection authority?
• Are you convinced as an inspector that NFPA 70E with all its glory applies to you?
A slim but eye-opening result of the survey revealed the following:
1. All the respondents recognized the “energized” hazard
2. One had the required PPE purchased by his employer. He worked in the private sector.
3. A second had purchased his own. Municipal or government employers felt exempt from this requirement.
4. Two responded they were either not allowed by government regulation (Australia) or employer mandate to inspect energized equipment. The electrical contractor was responsible to open the equipment and then place it into an electrically safe work condition (de-energized state) prior to any inspection activity occurring.
5. All responded there is a great need to inform and “train” their management of the hazards encountered and their responsibility to either direct safe-work practice guidelines or provide the needed PPE.
A disappointing and very small response from a large potential group of respondents and therefore a conclusion following any scientific pattern is impossible. What is clear is that inspectors are not the doers and there remains a definite gap in those supervising them of understanding the electrical hazards involved during those activities and their responsibility to appropriately respond.
III. UNDERSTANDING NEEDED
Anyone in the workplace is exposed to hazards, depending on the work tasks they are performing, and in this case the electrical hazards of shock and arc flash would require the worker be a “qualified person”. In recent years NFPA 70 series documents have evolved their definition of a qualified person to be in alignment with the current OSHA definition and each other. A clearer understanding then emerges for the inspector to enter these areas and the responsibility of the electrical workers who have control of the equipment and area while energized hazards are exposed.
OSHA Qualified person. One who has received training in and has demonstrated skills and knowledge in the construction and operation of electric equipment and installations and the hazards involved. [8]
NFPA 70 Qualified Person. One who has skills and knowledge related to the construction and operation of the electrical equipment and installations and has received safety training to recognize and avoid the hazards involved.
Informational Note: Refer to NFPA 70E-2012, Standard for Electrical Safety in the Workplace, for electrical safety training requirements. [9]
NFPA 70E Qualified Person. One who has demonstrated skills and knowledge related to the construction and operation of electrical equipment and installations and has received safety training to identify and avoid the hazards involved. [10]
Even though the wording of each definition is not identical the intent brings all three definitions in alignment with each other. It is important to understand that when OSHA looks at training and training programs the question is not so much did training occur but was that training “effective”? Effective training must be relevant, timely and ensure understanding. To discover the effectiveness of a training program, feedback must be accomplished to determine a level of individual understanding which that then can be measured to gauge effectiveness and when additional training may be appropriate. In this sense when NFPA 70 says a qualified person has “received training to identify and avoid the hazards involved” it is more than attendance to a class. Installation qualification must involve discerning the potential electrical hazards that could expose an unknowledgeable user to injury and mitigating that hazard with installation or operational strategies. When a construction electrician encounters energized electrical equipment and potential exposure to electrical hazards through commissioning, troubleshooting or other activities it is imperative a different level of qualification be understood. The worker that removes electrical box covers opens door or in any other way exposes themselves to electrical hazard has now accepted responsibility for themselves and any others in the approach boundaries where a shock or arc flash could reach out and touch someone.
In today’s work environment a qualified electrical person has shown mastery and proficiency in more areas than ever before. Fig 1.
1. There must be a competency in technical matters such as installation and design techniques utilized to establish a safer electrical work environment.
2. They must also be able to discern a “normal from abnormal” operating condition and the minimum maintenance that is required to ensure the longevity of the safe design.
3. Finally there must be a clear and thorough understanding of work practices to mitigate or avoid exposure to the electrical hazards involved and a firm belief that working de-energized is ALWAYS the first choice and that PPE is the last line of defense.
It must be understood due to changes in work tasks, equipment or technologies that the development of qualified workers is not an event. Those employers that implement an evergreen process of continual development and assessment to ensure deploying a workforce both current in knowledge and skills and compliant to current safe work practice expectations.
Fig 1. Qualified Electrical Worker Circle of Development
Inspectors or those in charge of commissioning electrical installations must also understand this process along with the electrical hazards encountered and the survival techniques required. Any person entering the limited approach boundary for shock or arc flash boundary around exposed energized conductors or circuit parts needs a good dose of electrical hazard awareness training. Whether the duties are “hands-on” or “just looking ” those electrons don’t know. Being in the wrong place at the right time or the right place at the wrong time can end in a very undesirable event. One variant of the
“Danger” sign says it all. Fig 2
Fig 2. Self-Explanatory Danger Sign
Whether the regulations or employer guidelines direct no energized work is to be done or an unexpected encounter occur, just being inside the shock and arc flash boundaries requires appropriate caution and protection. The inspector, inspecting engineer or project manager involved in commissioning or verification activities should at least consider the following check list of guidelines prior to entering the area of exposed electrical hazards.
Commissioning recommendations:
ü Ensure the company electrical safety program (ESP) includes commissioning or startup guidelines. This is often the place where moving a wire from one terminal to another to fix the installation mistake, especially those 120 volt circuits perceived to be less hazardous, are done while still energized to save time and money. The results can be very costly. The company ESP must clearly define “energized work” and give commonly encountered examples of accepted and unaccepted tasks. ü Adopt a personal culture that doing most if not all work in a de-energized state is the goal. Working while the circuit remains energized is no longer the expected norm. Testing, diagnosing or commissioning any system needs to be done in a deenergized state as a matter of rule not just a voluntary work practice.
ü Develop a written work plan and a procedure for your intended activities. Don’t leave it up to memory, verbal plans or past experience.
ü Ensure manufacturer’s representatives understand the company guidelines and expectations for safe work. These manufacturer’s technicians may be the subject matter experts on that equipment but likely are not the best examples for doing it safely. Constraints to get the job done quickly often override the obvious safe performance. Often times their familiarity with the equipment and greater experience drives these lesser work practices.
ü Overcome the perception that PPE is just for electrical maintenance work. Electrical installation activities cease when the power is turned on. There is no maintenance versus construction where exposed energized electrical conductor or circuit parts and electrical hazards are encountered. If the power is to be left on then appropriately selected, tested, inspected and utilized PPE is the only way to reduce risk to an acceptable level.
ü Express your expectations and raise the bar for safe work practice expectations where it may be lacking.
Inspection recommendations: ü Clearly understand the intended equipment to inspect and any other potentially energized electrical equipment hazard in the area. This includes the various voltages that may be present inside a single enclosure or system.
ü Observe from a close but safe distance the work practices and PPE utilized by the installer when removing box covers and while exposing the equipment to be inspected. Whether or not they are using safe work practices, establishing safe zones by means of barricades or warning tape or utilizing the appropriate PPE will tell you a lot about their overall qualifications. Observing shortcuts here can likely mean other shortcuts were taken during installation.
ü Witness the verification of absence of voltage. Most inspecting authorities do not allow their inspectors to put hands on the equipment or even remove the covers to expose the different devices and wiring to be inspected. This results in the installer either opening the equipment or de-energizing it prior to the inspector’s arrival. The inspector has the “right to know” the electrical hazard has been eliminated and the responsibility to verify that state. Have the installer verify it in your presence. After all, you are placing your life in the hands of the person whose livelihood is in yours.
ü Apply your own locks to the disconnecting devices prior to inspection. Your activities may require a close inspection of wire sizes and terminal markings. If the disconnecting means does not have the inspector’s personal lock applied someone not involved with the inspecting activities could unexpectedly turn it on creating a serious electrical hazard to both the inspector and anyone else affected by that circuit unexpectedly receiving power. ü Express your expectations and raise the bar for safe work practice expectations where it may be lacking.
IV. CONCLUSION, POTENTIAL IMPACT
In the installer’s world three employer actions provide employees protection from electrical shock, arc flash and blast. Written polices provide the foundation on what can and cannot be done. For work that is allowed, a written plan and procedures are developed and followed to ensure consistency of outcomes. Where procedures are followed personal protective equipment (PPE) is utilized to mitigate or lessen any potential injury. PPE is often related as the last line of defense. Physical equipment such as rubber-insulating gloves with leather protectors or arc-rated clothing is most often the mental picture we envision. It is time the workers and employers alike realize PPE is much more than simple equipment. Thorough planning followed by appropriate preparation are two critical steps prior to execution of any work performance. Inspecting, commissioning and startup timelines must reflect the realistic expectations of standards, regulations and industry best practices required of those maintaining those same systems including all of the electrical safe work practices, procedures and PPE.
Fast-tracked projects focusing on turn over or project end dates alone are a fertile ground for growing the absence of safe work practices. Employers and employees alike can embark on a path of applying ANSI/AIHA Z10 risk control hierarchy methodology [11] by following a practical course of the three P’s. Sometimes we must use what we have at hand.
Fig 3
Fig 3 Hierarchy of Practical Protection
During inspection or commissioning engagements the observers should hear some of the following statements.
1. “I need to don my PPE before going any further”
2. “Please stand over here behind the barricade while I remove the cover”’
3. “Let me get my insulated tools” or
4. “I de-energized everything before you got here. The disconnecting means is over here and this is my lock. You need to place your lock here then witness my verification of absence of voltage.”
Those in the inspecting and commissioning roles can increase their safety as well as increase safety awareness by being aware of and following the same path. These “observers” must have the same level of electrical hazard awareness and safe work practices that should be utilized as the “doers”. Commissioning or inspecting activities must follow the same Plan – Prepare – Perform/Execute guidelines where Policies, Procedures and PPE are utilized to ensure safe and effective work performance.
Employers of those actively interacting with energized circuit conductors and parts are required to periodically audit both their electrical safety program and their workers understanding of and application compliance to it.
• Audit their overall program at least every 3 years for continued compliance with regulations and 70E [12]
• Field audit their program at least annually or anytime new work functions are added to their services for thorough applicability with the expected work tasks encountered [12] and
• Annual inspections (assessments) of each worker to indicate compliance (e.g. understanding and application) of their electrical safety program and designated safe work practices.
[14]
Too often these audits are applied only to the doers. Observers should take note and follow a similar path to safety and success.
It may be true that “those that can, do and those that can’t observe”. These really are not competing camps. We must all remember that those that care are the ones that can make a difference. We are all in this together, us “doers” and “observers” with one common enemy. Armed with appropriate levels of electrical hazard awareness knowledge, the expectations of everyone following electrical safe work practices while utilizing properly tested and inspected PPE are known, the expressed electrical safety can be enhanced without even touching a tool.
V. REFERENCES
(1) LeRoy, Robert S., “Enhancing Electrical Safety Without Touching a Tool”, 2016 IEEE IAS
Electrical Safety Workshop Conference Record
(2) http://www.quotationspage.com/quotes/George_ Bernard_Shaw
(3) http://www.goodreads.com/work/quotes/2611796annie-hall-faber-reel-classics
(4) LeRoy, Robert S. and McCoy, Tim, “Moving from Training to Compliance, Practical methodology to monitor worker compliance to electrical safe work practices”, IEEE Paper No. ESW 2014-33
(5) LeRoy, Robert S., “Hazard or Risk Analysis, Overcoming the Human Factor”, IEEE Paper No. ESW 2015-19
(6) IAEI Weekly Update, August 12, 2015, http://electrical-engineering-portal.com/10common-causes-of-arc-flash-and-otherelectrical-accidents
(7) 2013 NFPA 70B, Recommended Practice for
Electrical Equipment Maintenance, Chapter 31.7 and Table 31.7, page 70B-130
(8) 29 CFR 1910.399 “Qualified Person”
(9) 2014 NFPA 70 National Electrical Code, Article
100, definitions
(10) 2015 NFPA 70E Standard for Electrical Safety in the Workplace, Article 100, definitions
(11) ANSI/AIHA Z10 American National Standard for Occupational Health and Safety Management Systems
(12) 2015 NFPA 70E Standard for Electrical Safety in the Workplace, Article 110.1 (I)(1)
(13) 2015 NFPA 70E Standard for Electrical Safety in the Workplace, Article 110.1 (I)(2)
(14) 2015 NFPA 70E Standard for Electrical Safety in the Workplace, Article 110.2 (D)(3)(1)
978-1-4673-9922-7/16/$31.00 ©2016 IEEE
VII. VITAE
Robert S. LeRoy, CESCP is the president of LeRoy Electrical Enterprizes, Inc. (www.leeinc.org). He is an independent electrical safety and compliance consultant and former Director of Electrical Programs for an international training company. He has 44 years experience in the utility, industrial and commercial electrical systems and equipment. During his nearly 20 years with a municipal utility power 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. He has conducted over 500 classes in NEC, NFPA 70E, NFPA 70B/NETA, 1910.269, NESC, Grounding and Bonding and Hazardous Locations to thousands of students worldwide.
As a master electrician, IAEI NCPCCI-2B Certified Electrical Inspector, NFPA Certified Electrical Safety Compliance Professional and a member of NFPA, IAEI, ASSE and IEEE he assists clients in the utility, oil and gas, manufacturing and aviation industries in gap analysis for compliance to electrical safety regulations and procedures, developing a well-trained electrical workforce and provides monitoring tools to measure compliance and training effectiveness. Mr. LeRoy 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 or international client requirements for acceptance and use in 18 countries around the world. Mr. LeRoy is the author of two previous ESW papers. He 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.
Back to Articles Page
