OSHA Arc Flash Update and the Myth of De-Energized Work
By Scott Margolin, Contributor
The Partnership for Electrical Safety (PES) has been working with OSHA to understand NFPA 70E compliance rates and the resultant frequency and consequences of arc flash among commercial and industrial electricians in the United States. We’ve written in this space about the bipartisan letters from the House and Senate urging OSHA action on arc flash, as well as direct (albeit virtual) engagement with OSHA. I am delighted to report that PES was recently joined by senior safety leadership of the IBEW and Electrical Training Alliance for a meeting with OSHA, during which we received very positive feedback.
We are in alignment on the basic facts:
- Half or more of all commercial and industrial electrical workers in the U.S. (500,000 or more) still do not have arc flash PPE despite a standard (70E) that has addressed arc flash for over twenty years.
- The consequences of this lack of compliance are dozens of catastrophic injuries and fatalities every year.
- These injuries would be eliminated or dramatically reduced by arc rated clothing and other PPE.
- Action is justified and required to reduce injuries and save lives.
We applaud OSHA for recognizing the huge gap in protection and engaging with the industry to resolve it, and we’re optimistic that updated guidance will be forthcoming in 2022. We expect this guidance to address the myth and close the loophole that has been largely responsible for the lack of protection for hundreds of thousands of commercial and industrial electrical workers: “we don’t work energized.”
The De-Energized Myth
When the subject of arc flash PPE arises at seminars, training, trade shows, safety caucuses, or other venues, the primary reason cited for failure to provide arc rated clothing and other PPE is, as noted above, “we don’t work energized.” Sadly, many arc flash injuries occur as a direct result of a conviction that the work is de-energized, and the resultant lack of PPE. Obviously, if there was an arc the circuit was NOT de-energized. Arc rated clothing and other PPE such as hard hats, face shields, rubber insulating gloves and leather keepers can and do protect the wearer from burns…but flammable clothing is literally fuel for the fire. The logic is simple: don’t wear fuel. Here’s why.
The vast majority of fatal and catastrophic injuries in arc flash are not caused by the arc itself, but by the arc igniting flammable clothing. Arcs are extraordinarily hot, but also very, very brief and highly directional. This means that in most cases, less (and often much less) than half of the body is exposed to the arc energy. But if your clothing ignites, the hazard now lasts 5-10 seconds or more, rather than 1/10th of a second, and covers far more of your body (clothing covers about 88% of your skin). And since heat rises, once your clothing ignites you are very likely to inhale fire and superheated gasses, as well as suffer facial burns. The result of wearing fuel is thus much greater TBSA (Total Body Surface Area) of burn injury as well as greater severity (2nd and 3rd degree burns), in addition to the potential for respiratory issues. TBSA over 20% runs a high risk of shock, which can be fatal in and of itself. TBSA over 50% runs a much higher risk of fatality due to infection, as well as less desirable quality of life for those who do survive.
There are three key safety measures:
- Don’t work energized if you don’t have to.
- If you do work energized, recognize the hazard and don’t wear fuel.
- Ensure that your arc rated clothing and other PPE is rated to protect against the level of incident energy projected for that equipment.
Is it Really De-energized?
Even those who strive to only work de-energized rarely achieve that goal; very little of what is called de-energized work actually is, from either a standards or a practical/PPE perspective. There are two primary reasons. A misunderstanding of what “de-energized” means, and that some of the most common energized work is infeasible to perform de-energized such as “…testing of electric circuits that can only be performed with the circuit energized.”
Unless you’re pulling wire in new construction that is not connected to the grid and has no temporary power, chances are very high that the work is energized. NFPA 70E requires energized electrical conductors and circuit parts operating at voltages equal to or greater than 50 volts shall be put into an electrically safe work condition (ESWC) before an employee performs work. Think about the process for establishing ESWC: “electrical conductor or circuit part has been disconnected from energized parts (de-energized), locked/tagged in accordance with established standards, tested to verify the absence of voltage, and, if necessary, temporarily grounded for personnel protection.” Disconnection is energized work, and so is testing for absence of voltage. When the task is completed and it’s time to reverse the process, both reconnecting and testing for presence of voltage are energized work as well. So at least four major steps in almost every ESWC process ARE energized work. Workers need to routinely be protected from electric shock and arc flash as these energized tasks are performed.
It’s clear to PES and to OSHA that some significant portions of most electrical tasks qualify as energized work. It’s also clear that far too many people either misunderstand both the standards and the hazards, or have chosen to ignore them, resulting in a serious injury/fatality rate of about one person each week in the United States. These tragedies are compounded by how easily they are avoided. Establish an electrically safe work condition whenever possible, and wear arc rated clothing as daily wear. If the energized work truly is infrequent (less than once a week or so, including de-energizing tasks) another option is to obtain and enforce 100% donning of arc rated coveralls and other PPE over standard cotton clothing. This task-based option was common 5-10 years ago but has become significantly less popular recently. The two primary drivers of this migration from task to daily wear are the liability and accident rate with task based (when it is not worn) and the evolution of arc rated daily wear, which is now much lighter, more comfortable, and more stylish.
Scott Margolin is Co-Chairman, The Partnership for Electrical Safety. For more information or to participate in the effort, visit www.partnershipforelectricalsafety.org.