Hazard or Risk Analysis,
Overcoming the Human Factor
Copyright Material IEEE Paper Number ESW2015-19
978-1-4799-4782-9/15/$31.00 ©2015 IEEE
Robert S. LeRoy LeRoy Electrical Enterprizes, Inc. PO Box 6025 Lakeland, Florida 33807 USA Bob@leeinc.org
Abstract – Governing bodies such as OSHA in the US and OH&S in Canada firmly place on the shoulders of the employer the responsibility of workplace safety. Job hazard assessments are a critical component in the job planning process. These regulatory agencies have a simple statement when dealing with the electrical hazard. “Turn it off.” Although this is the ultimate means of protection it is too often not followed. Common activities such as testing, troubleshooting, setup and commissioning preclude that mandate. Leaving circuits in an energized state could result in an electrical incident and injury. Any injury is unacceptable so what is an employer to do when electrical tasks must be done in an energized state? NFPA 70E begins with the same “deenergize the system” mandate but continues with an entire section detailing steps to follow when you don’t. (1) Employees must be trained to identify hazards, assess risks and recognize signs of impending failure in the job preparation procedures if their safety is to be ensured.
One thing seems certain. When left up to employee decision alone, skilled and qualified workers tend to default to what is convenient or comfortable or what they have always done and this may likely not be the recognized safest best practice. This is extremely important in the construction industry where employees continually move from the relative safety of a deenergized installation to the dangerous arena of energized setup, commissioning or maintenance.
Electrical safety programs must contain detailed policies where working around energized systems is encountered. Where this is not possible objective and measurable matrixes must be established guiding the worker to make the appropriate decisions in the field. This paper will examine the additional processes and training required for employees to conduct the electrical task risk assessments intended by their employer and the procedural tools that may be required.
Index Terms – hazard analysis, risk assessment, behavioral safety, NFPA 70E, arc flash safety, shock safety, OSHA, best practices, electrical safety program, monitoring electrical safe work practices
I. INTRODUCTION
A skilled workforce is essential to attaining safety in the workplace. Much time, effort and budget is expended in developing such a team and the returns on those expenditures are quickly realized with equipment efficiency, longevity and many years of safe operation. Unfortunately, technically competent workers do not always follow the safest of work practices. An employer must have a detailed, written electrical safety program that directs all activities within their facility where any worker interacts with electrical equipment or systems. Through the years technically competent workers develop habits that serve them and their employer well by completing work tasks often under budget, in less than the expected time and decreased downtime to plant production. These workers are rewarded for providing such a value added service to their employer, re-enforcing the behaviors that likely are not the safest or follow the best practices now widely accepted based on industry standards and expectations. They are recognized and rewarded for these successes until the unimaginable takes place, an incident resulting in personal injury or death to themselves or others. Many safety minded supervisors and health and safety officers lament, “We didn’t see that coming”, when asked to immediately comment on the event.
When a deeper look is taken at the steps that unfolded to end with this undesirable event common themes emerge. Had there been processes in place to discover these themes on an ongoing basis, the event likely would not have occurred.
All competent, skilled, trained electrical workers have at least three common traits they have developed throughout their career. Regardless of age and length of service each tend to demonstrate consistent behaviors. These workers have developed an internal work culture that is convenient, comfortable and operates under the employer’s consent. A behavior of convenience is achieved as the environment, personal fatigue or perceived emergency of the task drives the work practices that are chosen. Without clear guidelines to follow, these workers are able to mask these behaviors unless constant supervision is supplied. The comfortable attitude is shown in a worker who expresses they have done this so many times they can do it in their sleep. Often the assignment of work tasks takes this in to consideration, especially when a supervisor has other more pressing issues at hand. Workers definitely need to be confident in whatever task they are assigned. Confidence comes from thorough knowledge of the equipment, installation, process and task. Over-confidence quickly leads to taking shortcuts whose path leads directly to a demonstration of convenience and comfort.
The third skilled worker behavior is the one most likely to be overlooked yet controls the inevitability of the other two. This is the one most easily detected but least likely to be changed unless processes are put in place to uncover and root it out at its deepest depth. Consent to perform tasks where convenience or comfort drive the work practices is given by default where there is an absence of clear, concise and consistent expectation. In other words, if we their supervisors, managers or employers do not tell them otherwise, silence is all the affirmation they need. It is often said that silence is deafening. In this arena of silence the mind is left to wander into paths unknown, which often leads to a destination not at all intended. The lack of audible sounds is often used as a definition for silence. A lack of written guidelines and expectations can also be a form of employer silence achieving the same end. Creativity and innovation in the workforce is essential to world-class global success. Creativity and innovation left to run free within a culture where not guided or controlled can be more deadly than simply dangerous. It is easy then to understand why the NFPA 70E committee placed expectations on the employer to discover and remedy these work behaviors within their workforce.
“The employer shall determine, through regular supervision or through inspections conducted on at least an annual basis, that each employee is complying with the safety-related work practices required by this standard.” (2)
At the 2014 IEEE-IAS ESW conference held Feb, 2014 in San Diego, Ca, several papers were presented exploring the role of employee behaviors in ensuring safety and compliance to accepted safe work practices. One such paper explored the methodology to monitor worker compliance to a host employer’s electrical safe work practices.(3) This presentation and paper detailed an ongoing assessment program with a large host employer and several contract electrical employers and their employees. The data presented was both eyeopening and disturbing in shedding light on training retention and understanding of their employer’s safe work practices after many months had passed since the training had been received. What was most enlightening was the consistency in which the workforce had developed their misunderstanding and thus non-compliance to basic selection and inspection processes with PPE and workflow.
As a foundation to the premise suggested in this presentation a quick review of the data collected, conclusions drawn from the referenced paper and an update to more recent 2014 data is essential.
Data in 2013 was gathered against a procedural standard from both the employers and their workers performing both electrical construction or maintenance activities. The employer’s were objectively measured for compliance to the mandates detailed in 2012 NFPA 70E, Article 110. Their workers were assessed based on their understanding and expectations as given to them by their employers in several key work practice areas.
• Selection of a pre-approved work plan (SOP)
• Applicability of the selected SOP based on work site, equipment and worker conditions (JHA/JSA analysis techniques)
• Using employer provided processes to develop a work plan where no SOP exists
• Recognizing the difference between “energized or de-energized” conditions
• Appropriate selection, inspection, use, maintenance and storage of PPE
The employers are responsible to ensure hazards are both recognized and controlled to ensure worker safety. It is their responsibility to provide worker protection in the form of policies, or work procedures performed while using appropriate PPE. Monitoring processes and personnel must be in place per 2015 NFPA 70E to ensure worker understanding and compliance.
These employers received scores ranging from a low of 42% for contract employers to a high of 90% for the host employer indicating a workplace culture more or less compliant to NFPA 70E expectations. Once their workplace culture was discovered, action plans could then be put in place to remediate any deficiency.
Data was assembled for 2013 and 2014 comparing large electrical contractors (>100 electrical workers), small electrical contractors (<100 electrical workers) and manufacturer’s whose technicians perform only electrical troubleshooting and repairs on their own equipment.
• Large Electrical Contractor
o 2013 – 76% o 2014 – 92%
• Small Electrical Contractor
o 2013 – 48% o 2014 – 82%
• Manufacturer with electrical technicians
o 2013 – 42% o 2014 – 46%
Fig 1. Comparison 2013 to 2014 Company Data
Objective task performance landmarks based upon standards, industry recommended practices and the employer’s electrical safety program where detailed in assessment procedures given their workers. Each landmark was assigned a weighted numeric value based on its importance. As a pre-requisite to the worker’s assessments they were to have received training on the aspects of each assessment by either their employer or a third party approved by their employer. Once an expected skill or knowledge indicator was either seen or heard with a correct response, the worker was given the points associated with it.
Worker assessment scores ranged from the low 40 percentile to 100% in some cases. Typically workers scored much higher on workflow assessments, i.e. using company JHA/JSA and SOP processes than was achieved for assessments dealing with PPE, tools and equipment. These low scores were attributed to a lack of knowledge and the subject absent in employer training curriculum in most cases. In other cases it was apparent, often from responses given, that the workers had developed a work ethic where in their comfort and convenience the new protective measures did not easily fit. By establishing a work culture of both awareness and higher expectation using this assessment process these low scores have greatly increased in 2014. Typical recent scores range from a low in the 64 percentile to most achieving 85% or greater. The recommendations of NFPA 70E concerning employer supervision and safe work practice auditing have shown great success in improving awareness, understanding and compliance.
Data was assembled for 2013 and 2014 comparing large electrical contractor workers (>100 electrical workers), small electrical contractor workers (<100 electrical workers) and manufacturer’s technicians performing electrical troubleshooting and repairs on their own equipment.
• Large Electrical Contractor
o 2013 – 70% o 2014 – 91.5
• Small Electrical Contractor
o 2013 – 65% o 2014 – 90%
• Manufacturer with electrical technicians
o 2013 – 40% o 2014 – 64%
Fig 2. Comparison 2013 to 2014 Worker Data
The gains from 2013 to 2014 were significant and almost cause for celebration until two things were considered. Any misunderstanding of requirements or deficiency in skills performance less than 100% leaves open the door for incidents to occur. Most alarming upon deeper analysis of the data was that of the several hundred worker’s assessed during 2014, over 60% of the electrical workers could not consistently recognize when their task at hand had crossed the line into an “energized work task” requiring the need for greater permission and protection. Workers were demonstrating appropriate skills performance as the word got around the crews as to the expectations to be seen by the assessors. The inconsistency seemed to revolve around anything that would require a decision based on any subjective criteria. The workers overwhelmingly would comply with what they were asked to do by their employer. The gap was in many cases the lack of specificity in the employer’s electrical safety program. The clear solution then is less subjectivity and more objective criteria in their employer’s documentation. It has been suggested skilled employees perhaps make great technical advisers but at times poor safety mentors.
A new area of data collected for 2014 included assessing contractors whose primary job was not primarily electrical in nature. These companies have highly technical and in some cases proprietary equipment that requires their workers to interact with electrical cords, cables and connections. How well do these employers recognize and understand their responsibilities to worker safety from the electrical hazards? What processes are in place to direct all activities around these hazards? Three very large international companies were assessed based upon NFPA 2015 recommendations that apply to their activities. All had extensive written policies but gaps were noted in training, monitoring and defining energized work.
• Non-electrical company 1: 67%
• Non-electrical company 2: 60%
• Non-electrical company 3: 62%
Of note and to preface the subject of this paper is the high scores achieved on the workflow assessments where written procedures were in place. These workers would seek out and follow written procedures without hesitation but when left to what seemed repetitive and mundane tasks such as inspecting their PPE written procedures were neither sought nor used. In their defense such procedures often did not exist or were not in a form easily understood so these workers would revert to either their experience or the perceived importance of the task. Some action points for the employers based on 2013 data was for each to produce detailed written procedures, train the workers with documented demonstration of proficiency and produce short videos on the topics surrounding their expected work tasks for quick reference from the field through QR code link or accessing the company website during the pre-work preparation.
The foundation then as supported by the collected data is that workers will follow written guidelines with greater compliance than ones that are verbal or assumed. This pattern was identical whether the worker was performing construction tasks ending in energized commissioning and set up or whether their primary duties were on or near energized circuits with every assignment.
Companies and workers alike are seeking a prescriptive guide, a tell-all chart to help them survive. Most look to NFPA 70E for that guidance.
II. HAZARD ANALYSIS
Techniques to analyze the presence and level of electrical hazards have greatly evolved in recent years. Shock hazard analysis has basically been the same since the days of Edison, Tesla and Westinghouse. The higher the number associated with the voltage the higher the potential electrical hazard and greater the injury. In most cases the body has a fairly constant resistance during the time of contact and thus as voltage increases so too does the amount of current that can potentially flow. For this reason OSHA mandates a minimum value of voltage that could do physical harm under vastly varying conditions. Any exposed voltage 50 volts and above must be met with appropriate work practices and personal protective equipment, or PPE. Still today the perception is that low voltage, those levels 600 volts and below, in the mind of many employer’s and worker’s alike are an acceptable hazard and may be met with differing performance techniques as those over 600 volts. A reading of the preamble to OSHA’s recently released final rules for overhead line work (aka the utility rules) is most revealing in this regard. (4). Although the work rules are different above and below 600 volts for obvious reasons, the hazard of injury or death remains the same. Risk then is factored into the equation to settle on acceptable safe work practices and PPE. OSHA and other governing bodies are very clear that hazards must be managed. Risk can be assessed based on certain circuit and equipment conditions but should a worker be injured or killed based on an assumption of controlling rather than eliminating the hazard, an employer has much to explain. Arc flash analysis is a much more difficult animal to tame. The variations of when, where and how it develops, is allowed to grow and how a worker may encounter this electrical hazard makes it a very hard target to hit indeed. Recent tests and studies done by groups such as the IEEE arc flash task force and others have given us a much clearer idea of what happens in that split second of time. The mystery still remains as to means to achieve an exact science in this analysis. Without such clarity and consistency, the analysis techniques available give a worker a good idea of how bad it could be but in fact rarely is. Their experience has taught them based on observing or surviving past arc incidents that worst-case scenarios often do not occur, at least to them. It is in those times where the rare high energy does reach the worker that consistent application of employer-approved procedures and PPE are their only means of survival.
The hope is that incident energy analysis, or calculated caloric values, gives the worker that worst-case scenario. In many cases this is achieved. Unfortunately the field worker factors the calculated value into a highly secretive matrix within his own mind and determines that such an event is unlikely to occur and even if it did, there are other factors to consider which will provide them adequate protection. Factors such as enclosures with secure covers, angle of approach, open-air tasks where the energy dissipates 3-dimentionally and little if any is apt to reach where they may be standing during the task performance. The good thing is in many cases the worker wins that risky gamble. The bad thing is this personal analysis technique is emblazoned within his culture. And it is this culture he passes on to others.
It appears the NFPA 70E committee recognized this behavior and began producing a hazard/risk table based on common tasks and circuit parameters to help modify this inevitable evolution towards convenient and comfortable work practices. To be conservative and not under protect the workers many tasks seem and in fact may be an overprotection from the somewhat known hazard and their perceived risk during task performance.
Because both analysis methods are done without a worker’s input or buy-in, acceptance at face value has been slow. In some cases the analysis conclusion has been so grossly modified that the affect has been the opposite of the good results expected.
Comments such as, “There is a door on the equipment” or “I’m 10’ away using a hot stick therefore the hazard is much less” are common misstatements encountered. The hazard in all cases remains the same given any state of the equipment or worker position. What has changed is the risk, or better stated the likelihood of an incident occurring and an ensuing injury due to diminished exposure as a result of the equipment condition or distance. What then is the issue if all that is seemingly being argued is semantics? The real issue is the inconsistency of application of such techniques and greater still the inability to quantify the affect and provide the worker with clear understanding of the limitations of his/her protective means.
III. RISK ANALYSIS
Risk analysis takes into account more than just the hazard that may exist. Factors such as frequency of performing the task, consequence of an incident, and likelihood of an event even occurring are some of the variables that are considered. NFPA 70E provides a thorough guide and flow chart when considering risk factors in Annex F of the 2015 edition (5). Before we dissect that process and consider a worker’s understanding and probable response to this complex process we must first consider this precaution. Using risk based analysis to provide worker safety, as a trump card over the hazard that exists is at best risky business. It should always be a first choice to de-energize all circuits, conductors and parts as a matter of expected company policy. Exceptions to this rule should be few and far between. Unfortunately then enters the workers often-misguided perception of risk and hazard. Very clear, concise and consistently enforced rules about “live work” must be a key component of every company electrical safety policy.
In the heat of the battle, when time or budget is of the essence, workers need concise easy to use and readily accessible tools within their reach. Even more so when the workday is more relaxed to keep them focused on the goal. Annex F of NFPA 70E is not such a tool. Although its techniques are well proven the procedure is much too cumbersome for field use in the form presented in 70E. This is not a criticism of the 70E recommendation but rather a reminder that an employer must interpret the regulation as it applies to his workforce and present it in a format that it can be easily used. NFPA 70E is written to the employer for the benefit and safety of their employees. From this well established risk analysis process the employer must develop easy to use application tools, which are relevant to their work task, easily understood by all workers under their direction and applicable to varying system conditions. These tools must also include a “what if nothing fits” deviation section detailing a process and personnel to consult to determine the corrective action.
Since the earliest development and inclusion of Hazard Risk Category tables in NFPA 70E each cycle has seen an evolution towards becoming that useful field tool. What seems to have been grossly misunderstood by most field hands is the fact these tables were only meant to be a part of the overall analysis process and not the whole in and of itself. The greatly revised tables in 2015 NFPA 70E can in the opinion of this author place an unwarranted focus on subjective risk based actions which inevitably can be misapplied if continued to be used alone.
In defense of the 70E committee’s decisions on revisions, employers must understand that the NFPA 70E is a voluntary guide to achieve electrical safety in the workplace. Albeit the gold standard for such achievement and a recognized how-to guide for OSHA compliance, it cannot be dissected and applied in selective pieces if this goal is to be met. Employers likely understand this mandate while field workers are just as likely not to understand. Workers are conditioned to chose a tool for a specific task and leave the other tools in the box until they are needed. When applying the Hazard Risk Category tables the same mindset often emerges. The HRC tables are a tool often used in the field without all of its pieces in place. Through countless training sessions and field assessments of workers it has become very clear they easily become tunnel visioned in the analysis process. Comments such as, “Well, the tables say this” without considering equipment condition or “Surely if the door is intact none of this applies” are all too common responses to why a decision and action were made. It is in those statements that their convenient and comfortable culture is unmasked.
A qualified electrical worker in today’s workforce must be well trained in 3 specific areas to survive.
• Construction (NEC – NFPA 70/NETA-ATS)
• Maintenance (NFPA 70B/NETA-MTS)
• Safety (NFPA 70E/Company Electrical Safety Program)
Application of the tables in NFPA 70E is based on a worker being able to determine the condition of the equipment and system upon which he intends to do work. Determining signs of impending failure and conditions under which normal operation can continue (6) (7) is just as critical as recognizing when the intended work task will cause them to “interact with equipment is such a way as to cause an electrical arc flash” (8) Unfortunately neither is an exact science. Any subjectivity, which can be utilized in the safety process, must be met head on with easy to use objective and measurable processes provided by their employer.
Three distinct areas should be considered for the employer’s version of a Task Risk Analysis Matrix Tool.
1. Task Planning:
2. Task Preparation:
3. Task Performance:
Such processes must include easy to use and applied objective criteria in a matrix of task preparation and task performance guidelines including appropriate selection, inspection and use of personal protective equipment. They must be clear, concise and coached to have a consistently expected safe result.
IV. CONCLUSION
Employers are tasked with ensuring workplace safety of all that may enter their plant or work site. It is their general and expected duty to provide effective processes to ensure this goal. Where the electrical hazards are encountered, employers are to direct all activities appropriate for the hazard, voltage, energy level and circuit conditions. (8) The employer must establish clear guidelines in their electrical safety program in at least 3 areas to be in compliance. First policies must be written detailing when and under what conditions energized electrical encounters may occur. Secondly procedures on how that encounter is to take place must be developed that are both relevant and applicable in all situations. Where a situation occurs outside of the expected norm, a procedure guiding the worker in developing a work plan must be considered. In combination with procedures, the electrical safety program must detail what PPE is to be utilized when a worker is following the established procedures. In this way, nothing is left to chance and a worker’s tendency to minimize the hazard and underestimate the risk is greatly reduced.
To overcome the natural tendencies of worker’s approaching assignments based on some internal conditioning of convenience, comfort and consent each employer must then develop their own version of task hazard and risk tables detailing worker actions to any given work assignment. These tables can then be used in the overall analysis process as tools to achieve the safe outcome expected. Employer specific tables should include at least the following items.
• Task to be performed o Reference existing SOP or
o Process to develop work plan where none exists
• Circuit conditions under which the task can be performed
• Equipment condition indicators under which the task can be performed
• Worker training required before performing the task
• Minimum number of workers required based upon specific conditions
• Tools and Equipment needed
• PPE to be used
o Select
o Inspect
o Maintain/Store
• Emergency Action Plan (what to do and who will do it if everything falls apart)
Where NFPA 70E Hazard Risk Category tables were only intended to satisfy one aspect of the analysis process worker’s understood them to be much more encompassing. Unfortunately this has led to misapplication and possible incidents and injury. Electrical worker’s whose tasks are primarily maintenance tasks routinely encounter energized equipment and therefore are more accepting of analysis tools in the work preparation process. When workers only occasionally encounter energized hazards, such as with construction workers who in the build timeline now enter the scope of set up and commissioning, these clear directions are even more critical. Without these guidelines, worker’s whose primary tasks are constructing the electrical systems and only occasionally encounter energized equipment are less likely to be immediately aware of the hazards and appropriately apply expected safe work practices. Clear concise tools assist the employer to consistently achieve compliance to NFPA 70E and their electrical safety program from both sectors with successful results. Most importantly, detailed, relevant and applicable written tools such as are suggested in this presentation will result in a consistently safer work place. Awareness levels of all employees are raised to a much higher plane when especially the electrical workers who are recognized as the masters of subduing all things electrical are witnessed to be in compliance to their employer’s safe work practice mandates in every regard. By their example, a safer electrical workplace culture is realized by all.
V. REFERENCES
(1) 2015 NFPA 70E, Article 130, pages 70E-23 – 70E-43
(2) 2015 NFPA 70E, 110.2 (D)(1)(f), page 70E-17
(3) Moving from Training to Compliance, Practical methodology to monitor worker compliance to electrical safe work practices, Paper No. ESW 2014-33, Robert S. LeRoy and Tim McCoy, 978-1-4799-2098-3/14/$31.00 ©2013 IEEE
(4) OSHA final rule 29 CFR Parts 1910 and 1926, preamble pages20416 through 20420 and 20479
(5) 2015 NFPA 70E, Annex F, pages 70E-29 through 70E-80
(6) 2015 NFPA 70E, 130.6 (K), page 70E-29
(7) 2015 NFPA 70E, 130.2 (A)(4), page 70E-24
(8) 2015 NFPA 70E, 130.2 (2), page 70E-24
(9) 2015 NFPA 70E, 110.1 (A), page 70E - 15
978-1-4799-4782-9/15/$31.00 ©2015 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 43 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 400 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 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: Robert S LeRoy
Cell: 1 863.944.3369
rleroy01@gmail.com
http://www.linkedin.com/pub/robert-s-leroy/45/350/230 www.robertsleroy.net
www.wesstraining.com www.leeinc.org
One thing seems certain. When left up to employee decision alone, skilled and qualified workers tend to default to what is convenient or comfortable or what they have always done and this may likely not be the recognized safest best practice. This is extremely important in the construction industry where employees continually move from the relative safety of a deenergized installation to the dangerous arena of energized setup, commissioning or maintenance.
Electrical safety programs must contain detailed policies where working around energized systems is encountered. Where this is not possible objective and measurable matrixes must be established guiding the worker to make the appropriate decisions in the field. This paper will examine the additional processes and training required for employees to conduct the electrical task risk assessments intended by their employer and the procedural tools that may be required.
Index Terms – hazard analysis, risk assessment, behavioral safety, NFPA 70E, arc flash safety, shock safety, OSHA, best practices, electrical safety program, monitoring electrical safe work practices
I. INTRODUCTION
A skilled workforce is essential to attaining safety in the workplace. Much time, effort and budget is expended in developing such a team and the returns on those expenditures are quickly realized with equipment efficiency, longevity and many years of safe operation. Unfortunately, technically competent workers do not always follow the safest of work practices. An employer must have a detailed, written electrical safety program that directs all activities within their facility where any worker interacts with electrical equipment or systems. Through the years technically competent workers develop habits that serve them and their employer well by completing work tasks often under budget, in less than the expected time and decreased downtime to plant production. These workers are rewarded for providing such a value added service to their employer, re-enforcing the behaviors that likely are not the safest or follow the best practices now widely accepted based on industry standards and expectations. They are recognized and rewarded for these successes until the unimaginable takes place, an incident resulting in personal injury or death to themselves or others. Many safety minded supervisors and health and safety officers lament, “We didn’t see that coming”, when asked to immediately comment on the event.
When a deeper look is taken at the steps that unfolded to end with this undesirable event common themes emerge. Had there been processes in place to discover these themes on an ongoing basis, the event likely would not have occurred.
All competent, skilled, trained electrical workers have at least three common traits they have developed throughout their career. Regardless of age and length of service each tend to demonstrate consistent behaviors. These workers have developed an internal work culture that is convenient, comfortable and operates under the employer’s consent. A behavior of convenience is achieved as the environment, personal fatigue or perceived emergency of the task drives the work practices that are chosen. Without clear guidelines to follow, these workers are able to mask these behaviors unless constant supervision is supplied. The comfortable attitude is shown in a worker who expresses they have done this so many times they can do it in their sleep. Often the assignment of work tasks takes this in to consideration, especially when a supervisor has other more pressing issues at hand. Workers definitely need to be confident in whatever task they are assigned. Confidence comes from thorough knowledge of the equipment, installation, process and task. Over-confidence quickly leads to taking shortcuts whose path leads directly to a demonstration of convenience and comfort.
The third skilled worker behavior is the one most likely to be overlooked yet controls the inevitability of the other two. This is the one most easily detected but least likely to be changed unless processes are put in place to uncover and root it out at its deepest depth. Consent to perform tasks where convenience or comfort drive the work practices is given by default where there is an absence of clear, concise and consistent expectation. In other words, if we their supervisors, managers or employers do not tell them otherwise, silence is all the affirmation they need. It is often said that silence is deafening. In this arena of silence the mind is left to wander into paths unknown, which often leads to a destination not at all intended. The lack of audible sounds is often used as a definition for silence. A lack of written guidelines and expectations can also be a form of employer silence achieving the same end. Creativity and innovation in the workforce is essential to world-class global success. Creativity and innovation left to run free within a culture where not guided or controlled can be more deadly than simply dangerous. It is easy then to understand why the NFPA 70E committee placed expectations on the employer to discover and remedy these work behaviors within their workforce.
“The employer shall determine, through regular supervision or through inspections conducted on at least an annual basis, that each employee is complying with the safety-related work practices required by this standard.” (2)
At the 2014 IEEE-IAS ESW conference held Feb, 2014 in San Diego, Ca, several papers were presented exploring the role of employee behaviors in ensuring safety and compliance to accepted safe work practices. One such paper explored the methodology to monitor worker compliance to a host employer’s electrical safe work practices.(3) This presentation and paper detailed an ongoing assessment program with a large host employer and several contract electrical employers and their employees. The data presented was both eyeopening and disturbing in shedding light on training retention and understanding of their employer’s safe work practices after many months had passed since the training had been received. What was most enlightening was the consistency in which the workforce had developed their misunderstanding and thus non-compliance to basic selection and inspection processes with PPE and workflow.
As a foundation to the premise suggested in this presentation a quick review of the data collected, conclusions drawn from the referenced paper and an update to more recent 2014 data is essential.
Data in 2013 was gathered against a procedural standard from both the employers and their workers performing both electrical construction or maintenance activities. The employer’s were objectively measured for compliance to the mandates detailed in 2012 NFPA 70E, Article 110. Their workers were assessed based on their understanding and expectations as given to them by their employers in several key work practice areas.
• Selection of a pre-approved work plan (SOP)
• Applicability of the selected SOP based on work site, equipment and worker conditions (JHA/JSA analysis techniques)
• Using employer provided processes to develop a work plan where no SOP exists
• Recognizing the difference between “energized or de-energized” conditions
• Appropriate selection, inspection, use, maintenance and storage of PPE
The employers are responsible to ensure hazards are both recognized and controlled to ensure worker safety. It is their responsibility to provide worker protection in the form of policies, or work procedures performed while using appropriate PPE. Monitoring processes and personnel must be in place per 2015 NFPA 70E to ensure worker understanding and compliance.
These employers received scores ranging from a low of 42% for contract employers to a high of 90% for the host employer indicating a workplace culture more or less compliant to NFPA 70E expectations. Once their workplace culture was discovered, action plans could then be put in place to remediate any deficiency.
Data was assembled for 2013 and 2014 comparing large electrical contractors (>100 electrical workers), small electrical contractors (<100 electrical workers) and manufacturer’s whose technicians perform only electrical troubleshooting and repairs on their own equipment.
• Large Electrical Contractor
o 2013 – 76% o 2014 – 92%
• Small Electrical Contractor
o 2013 – 48% o 2014 – 82%
• Manufacturer with electrical technicians
o 2013 – 42% o 2014 – 46%
Fig 1. Comparison 2013 to 2014 Company Data
Objective task performance landmarks based upon standards, industry recommended practices and the employer’s electrical safety program where detailed in assessment procedures given their workers. Each landmark was assigned a weighted numeric value based on its importance. As a pre-requisite to the worker’s assessments they were to have received training on the aspects of each assessment by either their employer or a third party approved by their employer. Once an expected skill or knowledge indicator was either seen or heard with a correct response, the worker was given the points associated with it.
Worker assessment scores ranged from the low 40 percentile to 100% in some cases. Typically workers scored much higher on workflow assessments, i.e. using company JHA/JSA and SOP processes than was achieved for assessments dealing with PPE, tools and equipment. These low scores were attributed to a lack of knowledge and the subject absent in employer training curriculum in most cases. In other cases it was apparent, often from responses given, that the workers had developed a work ethic where in their comfort and convenience the new protective measures did not easily fit. By establishing a work culture of both awareness and higher expectation using this assessment process these low scores have greatly increased in 2014. Typical recent scores range from a low in the 64 percentile to most achieving 85% or greater. The recommendations of NFPA 70E concerning employer supervision and safe work practice auditing have shown great success in improving awareness, understanding and compliance.
Data was assembled for 2013 and 2014 comparing large electrical contractor workers (>100 electrical workers), small electrical contractor workers (<100 electrical workers) and manufacturer’s technicians performing electrical troubleshooting and repairs on their own equipment.
• Large Electrical Contractor
o 2013 – 70% o 2014 – 91.5
• Small Electrical Contractor
o 2013 – 65% o 2014 – 90%
• Manufacturer with electrical technicians
o 2013 – 40% o 2014 – 64%
Fig 2. Comparison 2013 to 2014 Worker Data
The gains from 2013 to 2014 were significant and almost cause for celebration until two things were considered. Any misunderstanding of requirements or deficiency in skills performance less than 100% leaves open the door for incidents to occur. Most alarming upon deeper analysis of the data was that of the several hundred worker’s assessed during 2014, over 60% of the electrical workers could not consistently recognize when their task at hand had crossed the line into an “energized work task” requiring the need for greater permission and protection. Workers were demonstrating appropriate skills performance as the word got around the crews as to the expectations to be seen by the assessors. The inconsistency seemed to revolve around anything that would require a decision based on any subjective criteria. The workers overwhelmingly would comply with what they were asked to do by their employer. The gap was in many cases the lack of specificity in the employer’s electrical safety program. The clear solution then is less subjectivity and more objective criteria in their employer’s documentation. It has been suggested skilled employees perhaps make great technical advisers but at times poor safety mentors.
A new area of data collected for 2014 included assessing contractors whose primary job was not primarily electrical in nature. These companies have highly technical and in some cases proprietary equipment that requires their workers to interact with electrical cords, cables and connections. How well do these employers recognize and understand their responsibilities to worker safety from the electrical hazards? What processes are in place to direct all activities around these hazards? Three very large international companies were assessed based upon NFPA 2015 recommendations that apply to their activities. All had extensive written policies but gaps were noted in training, monitoring and defining energized work.
• Non-electrical company 1: 67%
• Non-electrical company 2: 60%
• Non-electrical company 3: 62%
Of note and to preface the subject of this paper is the high scores achieved on the workflow assessments where written procedures were in place. These workers would seek out and follow written procedures without hesitation but when left to what seemed repetitive and mundane tasks such as inspecting their PPE written procedures were neither sought nor used. In their defense such procedures often did not exist or were not in a form easily understood so these workers would revert to either their experience or the perceived importance of the task. Some action points for the employers based on 2013 data was for each to produce detailed written procedures, train the workers with documented demonstration of proficiency and produce short videos on the topics surrounding their expected work tasks for quick reference from the field through QR code link or accessing the company website during the pre-work preparation.
The foundation then as supported by the collected data is that workers will follow written guidelines with greater compliance than ones that are verbal or assumed. This pattern was identical whether the worker was performing construction tasks ending in energized commissioning and set up or whether their primary duties were on or near energized circuits with every assignment.
Companies and workers alike are seeking a prescriptive guide, a tell-all chart to help them survive. Most look to NFPA 70E for that guidance.
II. HAZARD ANALYSIS
Techniques to analyze the presence and level of electrical hazards have greatly evolved in recent years. Shock hazard analysis has basically been the same since the days of Edison, Tesla and Westinghouse. The higher the number associated with the voltage the higher the potential electrical hazard and greater the injury. In most cases the body has a fairly constant resistance during the time of contact and thus as voltage increases so too does the amount of current that can potentially flow. For this reason OSHA mandates a minimum value of voltage that could do physical harm under vastly varying conditions. Any exposed voltage 50 volts and above must be met with appropriate work practices and personal protective equipment, or PPE. Still today the perception is that low voltage, those levels 600 volts and below, in the mind of many employer’s and worker’s alike are an acceptable hazard and may be met with differing performance techniques as those over 600 volts. A reading of the preamble to OSHA’s recently released final rules for overhead line work (aka the utility rules) is most revealing in this regard. (4). Although the work rules are different above and below 600 volts for obvious reasons, the hazard of injury or death remains the same. Risk then is factored into the equation to settle on acceptable safe work practices and PPE. OSHA and other governing bodies are very clear that hazards must be managed. Risk can be assessed based on certain circuit and equipment conditions but should a worker be injured or killed based on an assumption of controlling rather than eliminating the hazard, an employer has much to explain. Arc flash analysis is a much more difficult animal to tame. The variations of when, where and how it develops, is allowed to grow and how a worker may encounter this electrical hazard makes it a very hard target to hit indeed. Recent tests and studies done by groups such as the IEEE arc flash task force and others have given us a much clearer idea of what happens in that split second of time. The mystery still remains as to means to achieve an exact science in this analysis. Without such clarity and consistency, the analysis techniques available give a worker a good idea of how bad it could be but in fact rarely is. Their experience has taught them based on observing or surviving past arc incidents that worst-case scenarios often do not occur, at least to them. It is in those times where the rare high energy does reach the worker that consistent application of employer-approved procedures and PPE are their only means of survival.
The hope is that incident energy analysis, or calculated caloric values, gives the worker that worst-case scenario. In many cases this is achieved. Unfortunately the field worker factors the calculated value into a highly secretive matrix within his own mind and determines that such an event is unlikely to occur and even if it did, there are other factors to consider which will provide them adequate protection. Factors such as enclosures with secure covers, angle of approach, open-air tasks where the energy dissipates 3-dimentionally and little if any is apt to reach where they may be standing during the task performance. The good thing is in many cases the worker wins that risky gamble. The bad thing is this personal analysis technique is emblazoned within his culture. And it is this culture he passes on to others.
It appears the NFPA 70E committee recognized this behavior and began producing a hazard/risk table based on common tasks and circuit parameters to help modify this inevitable evolution towards convenient and comfortable work practices. To be conservative and not under protect the workers many tasks seem and in fact may be an overprotection from the somewhat known hazard and their perceived risk during task performance.
Because both analysis methods are done without a worker’s input or buy-in, acceptance at face value has been slow. In some cases the analysis conclusion has been so grossly modified that the affect has been the opposite of the good results expected.
Comments such as, “There is a door on the equipment” or “I’m 10’ away using a hot stick therefore the hazard is much less” are common misstatements encountered. The hazard in all cases remains the same given any state of the equipment or worker position. What has changed is the risk, or better stated the likelihood of an incident occurring and an ensuing injury due to diminished exposure as a result of the equipment condition or distance. What then is the issue if all that is seemingly being argued is semantics? The real issue is the inconsistency of application of such techniques and greater still the inability to quantify the affect and provide the worker with clear understanding of the limitations of his/her protective means.
III. RISK ANALYSIS
Risk analysis takes into account more than just the hazard that may exist. Factors such as frequency of performing the task, consequence of an incident, and likelihood of an event even occurring are some of the variables that are considered. NFPA 70E provides a thorough guide and flow chart when considering risk factors in Annex F of the 2015 edition (5). Before we dissect that process and consider a worker’s understanding and probable response to this complex process we must first consider this precaution. Using risk based analysis to provide worker safety, as a trump card over the hazard that exists is at best risky business. It should always be a first choice to de-energize all circuits, conductors and parts as a matter of expected company policy. Exceptions to this rule should be few and far between. Unfortunately then enters the workers often-misguided perception of risk and hazard. Very clear, concise and consistently enforced rules about “live work” must be a key component of every company electrical safety policy.
In the heat of the battle, when time or budget is of the essence, workers need concise easy to use and readily accessible tools within their reach. Even more so when the workday is more relaxed to keep them focused on the goal. Annex F of NFPA 70E is not such a tool. Although its techniques are well proven the procedure is much too cumbersome for field use in the form presented in 70E. This is not a criticism of the 70E recommendation but rather a reminder that an employer must interpret the regulation as it applies to his workforce and present it in a format that it can be easily used. NFPA 70E is written to the employer for the benefit and safety of their employees. From this well established risk analysis process the employer must develop easy to use application tools, which are relevant to their work task, easily understood by all workers under their direction and applicable to varying system conditions. These tools must also include a “what if nothing fits” deviation section detailing a process and personnel to consult to determine the corrective action.
Since the earliest development and inclusion of Hazard Risk Category tables in NFPA 70E each cycle has seen an evolution towards becoming that useful field tool. What seems to have been grossly misunderstood by most field hands is the fact these tables were only meant to be a part of the overall analysis process and not the whole in and of itself. The greatly revised tables in 2015 NFPA 70E can in the opinion of this author place an unwarranted focus on subjective risk based actions which inevitably can be misapplied if continued to be used alone.
In defense of the 70E committee’s decisions on revisions, employers must understand that the NFPA 70E is a voluntary guide to achieve electrical safety in the workplace. Albeit the gold standard for such achievement and a recognized how-to guide for OSHA compliance, it cannot be dissected and applied in selective pieces if this goal is to be met. Employers likely understand this mandate while field workers are just as likely not to understand. Workers are conditioned to chose a tool for a specific task and leave the other tools in the box until they are needed. When applying the Hazard Risk Category tables the same mindset often emerges. The HRC tables are a tool often used in the field without all of its pieces in place. Through countless training sessions and field assessments of workers it has become very clear they easily become tunnel visioned in the analysis process. Comments such as, “Well, the tables say this” without considering equipment condition or “Surely if the door is intact none of this applies” are all too common responses to why a decision and action were made. It is in those statements that their convenient and comfortable culture is unmasked.
A qualified electrical worker in today’s workforce must be well trained in 3 specific areas to survive.
• Construction (NEC – NFPA 70/NETA-ATS)
• Maintenance (NFPA 70B/NETA-MTS)
• Safety (NFPA 70E/Company Electrical Safety Program)
Application of the tables in NFPA 70E is based on a worker being able to determine the condition of the equipment and system upon which he intends to do work. Determining signs of impending failure and conditions under which normal operation can continue (6) (7) is just as critical as recognizing when the intended work task will cause them to “interact with equipment is such a way as to cause an electrical arc flash” (8) Unfortunately neither is an exact science. Any subjectivity, which can be utilized in the safety process, must be met head on with easy to use objective and measurable processes provided by their employer.
Three distinct areas should be considered for the employer’s version of a Task Risk Analysis Matrix Tool.
1. Task Planning:
2. Task Preparation:
3. Task Performance:
Such processes must include easy to use and applied objective criteria in a matrix of task preparation and task performance guidelines including appropriate selection, inspection and use of personal protective equipment. They must be clear, concise and coached to have a consistently expected safe result.
IV. CONCLUSION
Employers are tasked with ensuring workplace safety of all that may enter their plant or work site. It is their general and expected duty to provide effective processes to ensure this goal. Where the electrical hazards are encountered, employers are to direct all activities appropriate for the hazard, voltage, energy level and circuit conditions. (8) The employer must establish clear guidelines in their electrical safety program in at least 3 areas to be in compliance. First policies must be written detailing when and under what conditions energized electrical encounters may occur. Secondly procedures on how that encounter is to take place must be developed that are both relevant and applicable in all situations. Where a situation occurs outside of the expected norm, a procedure guiding the worker in developing a work plan must be considered. In combination with procedures, the electrical safety program must detail what PPE is to be utilized when a worker is following the established procedures. In this way, nothing is left to chance and a worker’s tendency to minimize the hazard and underestimate the risk is greatly reduced.
To overcome the natural tendencies of worker’s approaching assignments based on some internal conditioning of convenience, comfort and consent each employer must then develop their own version of task hazard and risk tables detailing worker actions to any given work assignment. These tables can then be used in the overall analysis process as tools to achieve the safe outcome expected. Employer specific tables should include at least the following items.
• Task to be performed o Reference existing SOP or
o Process to develop work plan where none exists
• Circuit conditions under which the task can be performed
• Equipment condition indicators under which the task can be performed
• Worker training required before performing the task
• Minimum number of workers required based upon specific conditions
• Tools and Equipment needed
• PPE to be used
o Select
o Inspect
o Maintain/Store
• Emergency Action Plan (what to do and who will do it if everything falls apart)
Where NFPA 70E Hazard Risk Category tables were only intended to satisfy one aspect of the analysis process worker’s understood them to be much more encompassing. Unfortunately this has led to misapplication and possible incidents and injury. Electrical worker’s whose tasks are primarily maintenance tasks routinely encounter energized equipment and therefore are more accepting of analysis tools in the work preparation process. When workers only occasionally encounter energized hazards, such as with construction workers who in the build timeline now enter the scope of set up and commissioning, these clear directions are even more critical. Without these guidelines, worker’s whose primary tasks are constructing the electrical systems and only occasionally encounter energized equipment are less likely to be immediately aware of the hazards and appropriately apply expected safe work practices. Clear concise tools assist the employer to consistently achieve compliance to NFPA 70E and their electrical safety program from both sectors with successful results. Most importantly, detailed, relevant and applicable written tools such as are suggested in this presentation will result in a consistently safer work place. Awareness levels of all employees are raised to a much higher plane when especially the electrical workers who are recognized as the masters of subduing all things electrical are witnessed to be in compliance to their employer’s safe work practice mandates in every regard. By their example, a safer electrical workplace culture is realized by all.
V. REFERENCES
(1) 2015 NFPA 70E, Article 130, pages 70E-23 – 70E-43
(2) 2015 NFPA 70E, 110.2 (D)(1)(f), page 70E-17
(3) Moving from Training to Compliance, Practical methodology to monitor worker compliance to electrical safe work practices, Paper No. ESW 2014-33, Robert S. LeRoy and Tim McCoy, 978-1-4799-2098-3/14/$31.00 ©2013 IEEE
(4) OSHA final rule 29 CFR Parts 1910 and 1926, preamble pages20416 through 20420 and 20479
(5) 2015 NFPA 70E, Annex F, pages 70E-29 through 70E-80
(6) 2015 NFPA 70E, 130.6 (K), page 70E-29
(7) 2015 NFPA 70E, 130.2 (A)(4), page 70E-24
(8) 2015 NFPA 70E, 130.2 (2), page 70E-24
(9) 2015 NFPA 70E, 110.1 (A), page 70E - 15
978-1-4799-4782-9/15/$31.00 ©2015 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 43 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 400 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 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: Robert S LeRoy
Cell: 1 863.944.3369
rleroy01@gmail.com
http://www.linkedin.com/pub/robert-s-leroy/45/350/230 www.robertsleroy.net
www.wesstraining.com www.leeinc.org
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