Scott Margolin, Co-Chairman, The Partnership for Electrical Safety
Ready to be shocked? More than 500,000 Americans working on or near energized electrical equipment do not currently have protection from a deadly hazard, despite standards which have been in place for over 20 years. A new organization has been formed to directly address this longstanding issue, raise awareness, and get these people the protection they deserve: The Partnership for Electrical Safety (PES).
PES is a non-profit association dedicated to improving the health and safety of unprotected electrical workers across the U.S. by ensuring that every American working on or near energized electrical equipment is provided with the appropriate arc-rated clothing and PPE. Proper AR clothing and PPE allows those whose jobs place them in a potentially hazardous situation to comfortably perform their essential work and return home safely at the end of the day.
Electric arc flash is an electrical fireball that can reach temperatures up to four times hotter than the surface of the sun. This fireball can and does ignite flammable clothing and seriously burn exposed skin, causing catastrophic or fatal injury. As a result of being improperly outfitted, many American workers suffer serious burn injuries every year. This does not need to happen. Due to the nature of electrical work, arc-flash events will occur, but the fatal and catastrophic injuries are almost always caused by clothing ignition, not the arc-flash itself. The solution is simple – stop wearing fuel (clothing that can burn) and start wearing arc-rated clothing.
Electrical utility workers have been protected by AR clothing since 1994. But an arc flash doesn’t care who signs your paycheck, so this protection was extended to industrial electrical workers twenty years ago, when NFPA 70E first included arc flash. As a result, over a million more electrical workers have been provided protection from arc flash, dramatically reducing rates of serious injuries and fatalities. Despite this clear and compelling success, over half a million Americans continue to work energized without lifesaving PPE. This must stop, and The Partnership for Electrical Safety intends to ensure that all American electrical workers have access to and properly wear the appropriate arc-rated clothing and associated PPE.
The PES strongly believes that the PPE requirements of NFPA 70E: Standard for Electrical Safety in the Workplace provide the appropriate best practices to ensure worker safety and should be universally adopted for substantially all live or potentially live electrical work in the U.S. Two primary goals of NFPA 70E and the PES are 1) whenever possible, de-energize, and 2) when working energized, always wear arc-rated clothing appropriate to the hazard.
Arc Flash Hazard Analysis
Work de-energized whenever possible. NFPA 70E requires justification for energized work and allows it only if it is infeasible to de-energize. It also recognizes that some work must be performed energized; for instance, you cannot troubleshoot a commercial HVAC system while it is off.
70E 130.2(A)(2): Infeasibility permits energized work if it can be demonstrated that the task to be performed is infeasible in a de-energized state. Examples include diagnostics and testing that can only be performed while energized.
There is a big difference between inconvenient and infeasible; please be honest and accurate when making this important decision. If there is an incident, in addition to the ethical and moral implications, you’ll need to justify the position to family and friends of the injured worker, company leadership, investigators, and possibly attorneys.
The standard then requires risk assessment, even if you intend to work de-energized. That may sound odd at first, but there are energized work steps here: de-energize and confirm absence of voltage and reenergize and confirm presence of voltage. Here’s the language in 70E and take note of use of the word “shall,” which is proscriptive (required, not optional):
130.5 Arc Flash Risk Assessment
In general: arc flash risk assessment shall be performed:
- To identify arc flash hazards
- To estimate the likelihood of occurrence of injury or damage to healthy and the potential severity of injury or damage to health
- To determine if additional protective measures are required, including the use of Personal Protective Equipment (PPE)
If there is no risk of arc flash (a very high bar to clear except when working new construction not connected to the grid), AR clothing and other PPE are not required. If there is a risk of arc flash, you must document safety related work practices, arc flash boundary, incident energy at the working distance, and the PPE that people within the arc flash boundary shall use. Any equipment “likely” to require energized examination, adjustment, service or maintenance must be field marked with the appropriate label around arc flash risk, boundary, and PPE. It’s important to note that one cannot “sell liability” or eliminate the need for arc flash hazard analysis by farming out work to contractors. The host employer is responsible for informing the contractor or service company of the hazards and identifying them (Section 110.3(A)).
OSHA has already begun to take a much more proactive stance, beginning with COVID-19 and worker safety and extending into other top-ten violation areas, including electrical, later this year. While OSHA does not per se enforce NFPA 70E, they have been clear in both letters and citations that if you are compliant with 70E you are compliant with OSHA, and that 70E is a primary remediation source. The law, standards, science, and data are clear: arc-rated clothing and other PPE dramatically reduce both the incidence and severity of injury and save lives.
Do not work energized unless you truly have to and recognize and dress to the arc flash hazard 100% of the time when you must work energized. Stay tuned for further exploration of arc flash risk mitigation in coming issues.