Electrical Safety training can be difficult to implement.
Complex rules from OSHA and NFPA 70E have to be incorporated into even more complex workplace roles and responsibilities (job descriptions). The aim of this short article is to simplify these requirements in an easy-to-digest manner.
This is aimed at persons new to electrical safety.
OSHA should be the first port of call
More specifically, look at 1910 Subpart S – Electrical. These rules focus on industrial (stamping, vehicle manufacturing, airports, food processing, packaging, general manufacturing, hospitals, etc.) and light commercial operations (administration buildings, warehouses, hotels, entertainment areas, etc.). Utilities and residential are largely excluded from the rule set.
Look at the Who, What, Where, When and Why
Before delving into training, take a step back and think about the following:
- Who is at risk, and when are they at risk of injury from the shock and arc flash hazard?
- When should training be done?
- Where is risk of injury greatest?
- What kind of electrical safety training do my workers need?
- Why would I want to provide training?
WHO is at risk?
Anyone who may interact with energized electrical equipment (e.g., switching a disconnect or breaker, performing maintenance work close to energized parts, troubleshooting, testing, installing, decommissioning, measuring, etc.).
OSHA 1910.332(c) provides a list of who should be trained. We recommend that you start with electrical engineers, electricians, electrical technicians, then move onto training maintenance, operations. Don’t forget management. If getting started or budgeting is a problem, or if support is lacking, try reading up on “Get the Boss on Board”.
WHEN should training be done?
Training should be performed once every three years in order to align with the major changes in NFPA 70E. Annual refresher training and the on-the-job coaching should supplement the three yearly cycles.
WHERE is risk of injury greatest?
OSHA uses the language “close enough to energized parts”. This means that the risk of injury is influenced by proximity.
OSHA does not allow unprotected workers to be closer than one foot (12 inches) from an energized part at low voltage (< 600V). NFPA 70E states that the risk of shock is still present at 3’6” (42 inches) and that the risk of burn injury should be quantified and could be (and in certain cases will be) greater than 42”.
WHAT kind of electrical safety training do my workers need?
Training varies based on risk exposure. Electrical engineers, electrical technicians, and electricians have the highest exposure rates. Their training should be a comprehensive NFPA 70E class that covers the relevant parts of OSHA (1910 Subpart S for work practices and 1910 Subpart I for Personal Protective Equipment).
Operators and mechanics will require a basic class that makes the workers aware of their responsibilities and safety limits (i.e., tasks they are allowed to perform and tasks that are prohibited). They should also understand the hazards and be able to interpret the safety signs and warnings.
WHY would I want to provide training?
OSHA may issue citations or possibly close down operations until safety concerns are addressed. Training the workforce shows the employer’s commitment to the workers’ success. Finally, safety risks transcend worker injury and can easily spill into business risk due to reputation (brand) damage and insurance premium adjustments.
Bringing it all together
To take advantage of a great resource based on the Plan, Do, Check, Act model (Deming model, Ishikawa examples), refer to the e-Hazard Safety Cycle™.
Here is a very high level summary of the steps:
Training is by far the quickest return on investment since it is cheap, requires little time away from work, and most importantly, provides all the information required to make the next big decisions. Students leave with an idea of what PPE they would need for shock protection and arc flash.
The second stage should be an estimation of the arc flash incident energy (arc flash engineering study). This will quantify the need for higher rated arc protection and provide labels on equipment so that workers can easily identify high energy (higher risk) types of equipment.
Establish work practices by developing a Written Electrical Safety Program. Hugh Hoagland provides a guideline on the typical contents of a written program. Read Electrical Safety Program by Hugh Hoagland.
After a defined period, typically after the roll out of PPE and appointment of qualified persons, perform a high level electrical safety audit. This may be performed in-house, or you can partner with an expert. We generally recommend that companies self-audit different areas and involve our team once every three to six years to provide the third party audit.
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What is the industry consensus for PPE requirements for workers that may pass through an electrical switchgear room or such areas with energized electrical enclosures, where no active work is going on, thus presenting no shock hazard or elevated arc flash risk? NFPA 70E references house keeping practices not requiring an EEWP with the associated caveats, nothing really states arc rated day wear requirements for non electrical workers that pass by energized electrical enclosures during the performance of their duties
Timothy, I have had this question arise often in industrial and utility settings. The answer varies from site owner to site owner. I have seen companies allow anyone to walk through these areas, even with nylon or polyester fabric, and I’ve seen the other extreme of allowing no one into the room, even just to pass through, without a minimum of, for example, 8 calories per square centimeter arc-rated PPE. The answer that you find in NFPA 70E would be found in Table 130.5(C), where the user is instructed to estimate the likelihood of an arc flash incident. This, of course, is assuming all equipment is properly grounded and bonded, thus presenting no shock hazard by just walking through the room. In the case you presented, no active work is being performed to increase the risk of an arcing event. However, we must look fully at Table 130.5(C) and its intent. An asterisk appears on the top right side of the table, adjacent to the words “Likelihood of Occurrence.” This asterisks is found on the next page, and defines the two components of risk as (1) likelihood of occurrence, and (2) severity of injury or damage to health IF an event does occur.
This is where the concept of Best Practice must fall upon the site ownership/employer and electrical safety policies. If I owned an electrical room that had 38 cal/cm2 panels, I would certainly not allow melting fabric to be worn in that room, even by a passer-by. I am a big believer in daily-wear arc flash clothing, or at a minimum, natural fabric clothing in these circumstances. It is amazing to watch how quickly melting fabric ignites during arc testing, but I cannot say it “violates” a standard if someone is allowed into an electrical room dressed like this while performing non-electrical tasks. One could argue, however, that a subsequent injury or fatality, one that could have been prevented by requiring a minimum PPE level to enter such rooms, could violate OSHA’s General Duty clause to protect workers from all known hazards.
You would get 30 differing opinions from 30 so-called experts in this area, and ultimately the responsibility, as always, lies at the feet of the employer. Due diligence is the best approach, and that involves a proper hazard analysis and a follow-up risk analysis when making these decisions.