Implementing and Managing Electrical Safety Programs

Donny Snyder Vice President Martin Technical, Inc donnys@martechnical.com 866-234-6890 Ext. #2

1. Audits 70E, NEC, 70B 2. Written Policy 3. Arc Flash Risk Assessment PPE 4. Qualified Person Program 5. Electrical Safety & Skills Training 6. Maintenance Procedures Software 7. Program Management Change Management Near Miss Investigation Preventive & Predictive Maint

4 Agenda Codes and Standards Burden of Proof Electrical Safety Programs Audit Written Policy Arc Flash Risk Assessment Qualified Person Program Electrical Safety and Skills Training Maintenance Procedures Program Management Implementation Common Challenges & Solutions

5 Code / Law Hierarchy Company Policy State OSH OSHA 1910 Federal Law NFPA 70E NFPA NEC IEEE 1584 How & When to comply with Electrical Safety Work Practices Equipment Installation Requirements Calculation Standards for conducting an Analysis Also publishes National Electrical Safety Code which is similar to 70E, but not as widely known Standards about product criteria that is often cited in electrical codes

6 NFPA 70E Standard for Electrical Safety in the Workplace Written by NFPA at the request of OSHA to provide the prescriptive for compliance with Subpart S Is the Electrical Safety Standard for employees who install, maintain or repair electrical systems and equipment 2015 Edition is the current edition & the next edition will be published in 2018

7 In several instances OSHA has been asked for a formal interpretation as to its relationship with the 70E Standard. The OSHA response is: Industry consensus standards, such as NFPA 70E, can be used by employers as guides to making the assessments and equipment selections required by the standard. Similarly, in OSHA enforcement actions, they can be used as evidence of whether the employer acted reasonably. OSHA tells you WHAT to do.nfpa 70E tells you HOW to do it

8 Burden of Proof Section 5. Duties (a) Each employer -- (1) shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees; (2) shall comply with occupational safety and health standards promulgated under this Act. (b) Each employee shall comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to this Act which are applicable to his own actions and conduct.

9 Employer vs. Employee Responsibilities EMPLOYER Identify Hazards Eliminate or Mitigate Hazards Provide PPE for Hazards Train Employees on Hazards Create/Document/Train Process and Procedure for tasks involving Hazards Address Employee concerns with Hazards and Work Tasks EMPLOYEE Follow Documented Process and Procedures Notify Employer of unidentified Hazards or Procedures that are incorrect. Wear PPE Follow Training

11 Electrical Safety Audit NFPA 70E 110.1 (I) Electrical Safety Auditing. (1) Electrical Safety Program. The electrical safety program shall be audited to verify the principles and procedures of the electrical safety program are in compliance with this standard. The frequency of the audit shall not exceed 3 years. (2) Field Work. Field work shall be audited to verify the requirements contained in the procedures of the electrical safety program are being followed. (3) Documentation. The audit shall be documented. Audits should cover all aspects of your safety program including electrical equipment.

12 National Electrical Code Equipment Installation & Maintenance Updated Every 3 Years (current 2017 version) For Electrical Safety not design / efficiency Equipment that is not installed or maintained properly can cause an electrical hazard. When modifying old equipment, it must be brought up to new code. If you don t touch old equipment, it is grandfathered in as compliant.

13 GROUP QUESTION Why do you think there are minimum requirements for work space?

14 Maintenance Equipment Installation & Maintenance OSHA & NFPA require that the equipment be maintained per manufacturer guidelines.but this often gets ignored. Relay & Breaker Testing, cleaning off oil & dust. Makes equipment more efficient / saves $$$ Resolves small problems before they become big ones. GROUP QUESTION: How often shall Ground Fault Interrupter Circuits be tested according to Manufacturer s and thereby by law? Monthly! Raise your hand if you are not compliant.

15 Electrical Drawings Electrical Workers should be referencing electrical drawings for design / safety. Many companies file theirs away afterinitial build good companies do the following: Drawing Management Drawings are readily available to employees Electrical Rooms? Electronic Versions by Computer or Tablet? Employees are trained to read the drawings Drawings are updated at electrical equipment changes

16 Electrical Studies Arc Flash Most expensive part of electrical safety programs Most complex to understand Normally requires specialized engineer from outside Short Circuit & Protective Coordination Studies Makes sure your equipment is Properly rated to handle the electrical current Protective devices trip and in the right order Normally done with arc flash study

17 Contractors NFPA 70E 110.3 Host and Contractor Employer s Responsibilities All parties have responsibilities. This section is divided into two parts, A and B: (A) Host Employer Responsibilities (1) The host employer shall inform contract employers of: a. Known electrical hazards related to the contract employer s work that might not be recognized by the contract employer or its employees b. Information about the employer s installation that the contract employer needs to make the assessments required by Chapter 1

18 Contractors (2) The host employer shall report observed contract-employerrelated violations of this standard to the contract employer. (B) Contract Employer Responsibilities. (1) To ensure that each employee is instructed in the hazards communicated to the contract employer by the host employer. This instruction is in addition to the basic required training (2) Ensure that each employee follows the work practices required by this standard and safety-related work rules required by the host employer

19 Contractors (3) Must advise the host employer of: 1. Any unique hazards presented by contract employer s work 2. Hazards identified during the contract employer s work that the host employer did not mention, and 3. The measures taken to correct any violations reported to him by the host employer; as required by previous paragraph (D) Documentation. There shall be a documented meeting between the host employer and the contract employer.

21 Written Electrical Safety Policy Provides Guidelines and Specific Details One size doesn t fit all should be customized to your: Equipment Tasks Performed Level of Hazards & Risks at the plant Skill Set of Employees & Risk Tolerance of Employer Examples: What equipment can they work on and when should they call an electrical contractor? Do you have hazardous areas like battery rooms, dust, gases that need special consideration? Who is in charge of purchasing and managing the testing of the PPE? Careful what you write!!! OSHA will measure you against your own policy, so don t include things you aren t going to do or you will be in violation!

22 Written Electrical Safety Policy Areas to Address: Some are Required, Some are Optional FUNDAMENTALS Purpose Scope Principles Definitions Responsibilities Regulations, Codes, and Standards QUALIFICATION Training Requirements Qualified Persons Program Non-Qualified Persons Contractors, Vendors, and Suppliers DESIGN and INSTALLATION Design Considerations / Options IDENTIFICATION & LABELING Equipment ID Labels ID Scheme Warning Labels DRAWINGS / REPORTS / TESTING Electrical Drawing Management Classified Areas Arc Flash Audits Infrared Equipment Testing Relay Breaker GFCI

23 Written Electrical Safety Policy EQUIPMENT Test Equipment Portable Electrical Equipment Hand Tools Extension Cord Use SAFETY WORK PRACTICES Job Planning Hazardous Locations Electrically Safe Work Condition Temporary Grounding Energized Electrical Work Permit Risk Assessment Lockout / Tagout Interlocks Electrical First Aid PPE & TOOLS PPE Requirements & Use Insulated Tools Requirements & Use CHECKLISTS / FORMS Electrical Work Permit Job Planning Checklist

25 Arc Flash An Arc Flash is an electrical explosion due to a fault condition or short circuit when either a phase to ground or phase to phase conductor is connected and current flows through the air. Arc flashes cause electrical equipment to explode, resulting in an arc-plasma fireball. It strikes without warning The strike is lightning quick The energy released by the arc is function of; System Voltage Magnitude of the current Duration of the arc = time (big factor)

26 Arc Flash: Law? Compliance? TECHNICALLY..NO, MAYBE and YES! How you protect workers is left up to each employer, which is why you won t see shall perform an arc flash analysis in OSHA code. You have options.but they aren t used very often. Alternatives to Arc Flash Risk Assessments Use of robotics to do some electrical tasks Limited to few applications & expensive Real time indicators on panels providing PPE requirements Expensive NFPA 70E Tables Requires electrical engineering calculations first and if you are going to do this, it s the same cost as doing an arc flash analysis May be going away in next code cycle

27 Arc Flash: Law? Compliance? TECHNICALLY..NO, MAYBE and YES! Identifying Electrical Hazards & the PPE to protect workers is required, including from arc flash. OSHA letters of interpretation state that performing arc flash is one way to protect workers OSHA fines companies if there is not a protective program in place for protection against arc flash Arc Flash warning labels with protection information is required by NEC as of 2017 version. All states have adopted NEC as their code, so this is a law as soon as your state adopts the 2017 version. 1910.269 Power Generation electrical safety 2015 update now has specific language about conducting arc flash (incident energy analysis) In short.you have options on how to comply, but arc flash analysis is what 99.9% of companies choose.

28 Arc Flash - Ignoring OSHA Enforces arc flash labeling Cives Steel Company Citation (Page 11) 7.6.12 Interstate Electrical Services 6.6.12 US Postal Service 7.12.10 O'Connell Electric Fines 11.16.09 Worker injury or death with no / wrong PPE or warnings Negligence / Willful Violation If you know about a hazard and choose not to protect workers, it may be negligent Business owners and managers are now being personally responsible, which has resulted in fines and jail time. Third Party Lawyers Too expensive is not a defense that will work Multi-million dollar lawsuits

29 Arc Flash: Responsibility It s not been clear in writing until recently NFPA 70E 130.5 (D) New in 2015 The owner of the electrical equipment shall be responsible for the documentation, installation and maintenance of the field, marked labels. This includes the methods for calculating the data that is on the labels (conducting the arc flash analysis).

30 Arc Flash Labels Arc Flash Labels are required to have the following: 1. Nominal System Voltage 2. Arc Flash Boundary 3. At least one of the following Available Incident Energy and Corresponding working distance, or arc flash PPE category from Table 130.7 (C)(15) (A), but not both Minimum arc rating of clothing Specific level of PPE Does this label meet compliance?

31 Wearing PPE Working Safe! PPE is the last line of defense in the Risk Control Hierarchy, not the first!

32 Arc Flash PPE Wearing the proper PPE is designed to limit the worker to 2 nd degree burns or curable burns. PPE protects form Shock & Burn Workers can still get injured in an arc flash if wearing the proper PPE The air blast can throw workers, resulting in serious injury or death Greater than Category 4 has no PPE that will protect the worker from the blast.

33 GROUP QUESTION Do you need to wear PPE while de-energizing equipment and performing lockout?

34 Electrical Safe Work Practices Includes things like: Risk Assessment Job Briefings De-energization of equipment Lockout of equipment Testing for voltage Using Proper Tools Identifying & Setting up Boundaries Energized Work Permit Should be documented in your written policy Requires training Part of Qualified Person annual observation

36 Qualified Person OSHA 1910.399 Subpart S and NFPA 70E 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. Qualification is specific to Task & Equipment not a title Person may be Qualified for one task or equipment, but not the other. Person in training is a Qualified Person if working under the direct supervision of another Qualified Person Annual Review & Documentation by another Qualified Person

37 Qualified Person Only Qualified Persons May Work on Electrical Equipment >50 volts (unless already proven de-energized by another Qualified Person) Qualified Person: Safety Training Demonstration of Skills & Knowledge related to equipment & tasks At least annual review of Qualified Persons OSHA leaves it up to the employer to determine: Program Requirements for Qualified Persons How to determine & document demonstration of skills & knowledge

38 Qualified Persons? These may not be Qualified Persons.

39 GROUP QUESTION Who Determines Whom is Qualified? 1. The Authority Having Jurisdiction. 2. OSHA. 3. Workman s Compensation Insurance. 4. The employer.

41 Electrical Safety Training Safety Training Qualified Persons Employees must be trained: Recognize & avoid specific hazards associated with electrical energy Provide protection from the electrical hazards associated with their respective job or task assignments. To identify and understand the relationship between electrical hazards and potential injury Creating an electrically safe work environment Selection of proper tools & PPE Emergency Procedures / First Responder Degree: Up to employer / based on risks & skill sets

42 Safety Training Qualified Persons Frequency: OSHA up to employer & with equipment changes & deviations NFPA 70E - 3 yrs & with equipment changes & deviations Electrical Safety Training Method: Live / classroom or on-the-job Online / Video.nope! Many companies do not provide proper training If the training does not include things like how to use meters to create a safe work environment or shock release methods it is awareness training only and does not meet requirements.

43 Electrical Skills Training Employees must have the skills of the operation of the equipment to perform their task safely Proper training improves efficiency and downtime Common areas of Electrical Skills Training Reading Electrical Schematics Basic Electricity Electrical Troubleshooting Motors & Motor Controls PLCs VFDs Solar Maintenance Standby Power & Generators Grounding & Bonding

45 Maintenance Procedures Types of Procedures and Related Assessments Lockout Tagout Procedures JSA/JHA Documented Work Process Ballast Change Wiring Motors Install Disconnect

47 Change Management Electrical System Changes Establish a process and lead for managing change Changes may include Electrical One Lines Arc Flash Study Updates Expensive if you don t manage this! Labels on Electrical Panels Keeping New OEM Manuals Updating Training with New Equipment

48 Change Management Tools & Practices Software CMMS, Work Orders, Document, Tracking Near Miss Investigations Preventive and Predictive Maintenance (PM s)

49 Implementation 1. Identify Champion(s) 2. Perform an Audit of Your Current Program 3. Prioritize Fixing the Gaps by Hazard Risk Assessment 4. Plan & Budget for Highest Priorities 5. Develop a Written Electrical Safety Policy 6. Develop a Qualified Person Program 7. Perform Training to Standards, Your Program & Gaps 8. Conduct Required Studies, Testing & Maintenance 9. Periodic Audits on Program, Workers & Equipment

50 Common Challenges 1. IT S HARD TO UNDERSTAND & COMPLY!! You can t see it, smell it or hear it.it s invisible! Solutions Too much detail for Safety Managers to handle: Must know electrical theory, equipment and installation NEC 875 pages 70E 104 pages 70B 227 pages OSHA Includes equipment choice, installation & maintenance 70E & NEC Codes Change every 3 years Equipment changing Solar, PLCs, Robotics. You re here that s the first step! Understand what you don t understand and fill in the gaps

51 Common Challenges 2. TIME CONSUMING & EXPENSIVE Some projects can take years if done internally, or months with outsourcing Electrical systems frequently change.so it s a never ending process Arc Flash Risk Assessments & PPE can be expensive Getting equipment to code can be expensive Solutions Prioritize in small, manageable chunks. Create an annual budget. Mix internal implementation & outsourced to maximize speed and $

52 Common Challenges 2. TIME CONSUMING & EXPENSIVE Solutions Sell in Safety If there is an accident, this will always be more than the cost of investing in safety. Electrical Accidents are often very traumatic injuries / deadly and require replacing expensive equipment. Down time if you don t have electrical..

53 Common Challenges 3. LACK OF AN ELECTRICAL SAFETY CHAMPION Who s driving the program? MAINTENANCE? SAFETY? Who s is keeping up with codes? Who s do you go to answer questions? Who s managing the PPE purchases? Solutions Identify a champion & provide proper tools & training for success Outsourced electrical safety leadership quarterly meetings

54 Common Challenges 4. FEAR (and reality) OF INCOMPETENCE Employees afraid to ask for help / pretend they know it all Many do have skill or knowledge gaps because they only have on-the-job training Fear of reporting problems / being punished Solutions Encourage / Celebrate near miss reporting Create anonymous question box for maintenance Encourage continuing education programs for electrical workers

55 Common Challenges 5. Overlooking NEC Compliance NEC is not for Electrical Design but for Safety! Electrical Safety Work Practices assume: Equipment meets the scope of the application Equipment was properly installed Equipment was properly maintained Safety Manager or Maintenance Manager often don t have knowledge of NEC Electrical Engineers often build for efficiency and cost, not safety, so it can get missed.

56 Common Challenges 5. Overlooking NEC Compliance Solutions Assign NEC Champion to learn how to use the code As part of work order completion / signoff, installed or modified equipment should be checked for approval by NEC Champion

57 Common Challenges 6. Program on Paper Only Solutions Written Policies that nobody knows exist Electrical Safety Labels but don t use them PPE but not using them Generic Training - not specific to needs Assign a Champion Build an Electrical Safety Culture Train Workers on Requirements & Expectations Enforce the Policies & Requirements Periodic Inspections of Worker

58 Common Challenges 7. The Old Guard Solutions Passing along old methods & information Hasn t been injured so must be working safe? Reluctance to Change Assign a Champion Sell in change management to team Continued Education new standards

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