PPE: The Last Line of Defense, But the First Step in Protecting Workers
By: Mike Enright, Contributor
In the 20 years since the NFPA 70E standard (2000 edition) was revised to put much more of a focus on the arc flash hazard, many people and organizations have dedicated a significant amount of time to educate companies on how to comply with the new requirements and establish an effective electrical safety program to help keep their employees safe. In the 2018 edition of NFPA 70E edition, an electrical safety program is defined as “a documented system consisting of electrical safety principles, policies, procedures, and processes that directs activities appropriate for the risk associated with electrical hazards.”
Over the years, NFPA, IEEE, NSC, ASSP, and many other organizations have conducted thousands of educational training sessions on how to create a safer working environment for electricians. The statistics show that all of this excellent work has dramatically improved electrical safety and, as such, I’m sure their efforts have saved countless lives. Unfortunately, we still have a long way to go to ensure all electrical workers are properly protected. Clearly the best solution to keep workers safe is to eliminate electrical hazards entirely. However, in many industry applications, de-energizing the electrical system may not be practical, and in some cases, may result in an even greater safety hazard. In addition, even the task of verifying the absence of power requires use of PPE, as does frequent trouble-shooting requirements.
Protecting electrical personnel from electrical hazards is an evolutionary process and, unfortunately, there is no individual solution that will eliminate the arc flash hazard when working on energized equipment. There are, however, certain protections that are more effective than others. Added to the main text in the latest edition of NFPA 70E (2018), the hierarchy of controls begins at the source, starting with the protections considered to be immune to human error and moving to the controls that are often the most feasible at any facility. The six steps are as follows:
- Elimination: Removing the hazard entirely
- Substitution: Replacing a severe hazard with a less severe one
- Engineering Controls: Replacing equipment or changing the work environment to separate workers from a hazard
- Awareness: Educating workers on the hazards and providing information on making safe decisions
- Administrative Controls: Developing formal procedures and processes for working safely under anticipated conditions
- Personal Protective Equipment (PPE): Equipping workers with clothing and equipment designed to reduce risk and limit the severity of injuries.
The Importance of PPE
In addition to being the final step in the hierarchy of controls, electrical PPE is commonly referred to as the “last line of defense.” This is appropriate and it make sense, however, when it comes to protecting workers, the timeline on issuing PPE should be pulled in. While specific exposure details may have to wait for engineering studies to be completed, it isn’t difficult to issue PPE using the “Simplified Two-Category, Arc-Rated Clothing System” highlighted in informative Annex H in 70E. The main concern with using this method is that it could lead to “over-protection,” which could adversely impact the comfort and functionality of the PPE. Thankfully there are many options on the market that have largely taken this concern off the table. In fact, many companies have adopted their own “simplified one-category, arc-rated clothing system,” in which electricians are only issued one 40 cal kit to use when conducting tasks in all PPE categories from 1 to 4. This may seem irrational on the surface, but as you dig deeper it makes a lot of sense. After all, there are PPE CAT 4 arc flash suits (40 cal) on the market today that are similar in weight to legacy CAT 2 suits, and they’re arguably more comfortable and user friendly, not less.
I’m not suggesting that companies should implement a simplified PPE program to avoid or delay the other important items listed on the hierarchy of controls. Those are extremely important steps, and they need to be followed. However, if you ask electrical safety consultants that provide 70E compliance training throughout North America what percentage of electrical workers wear electrical PPE every time it’s required, you’ll be surprised by their answers. I’ve heard estimates ranging from 40-50% all the way down to 15-20%.
The point I’m trying to make is that companies should take action today to make sure each qualified worker has an electrical PPE kit. Yes, the upfront cost of electrical PPE can be higher than other types of PPE but electrical accidents, although infrequent, result in one of the most expensive injuries a worker could sustain. There have been many case studies conducted over the years highlighting all the costs involved with an electrical injury and it’s easy to see that just one serious injury or fatality would more than enough to pay for an electrical PPE program for decades. In addition, electrical PPE routinely lasts 5-10 years in the field so the cost per wear will be relatively inexpensive over time.
Do Your Research
One other very important point I would like to make is that if workers view wearing electrical PPE as a painful experience, they may not wear it, or wear it properly (especially when no one is looking). This could negatively impact compliance and, more importantly, worker safety. As mentioned above, this PPE will be in your system for a very long time so placing an order sight unseen or hitting the “easy button” and buying what you’ve always bought is NOT the best solution.
You also need to be careful searching options on the internet simply using the arc rating you need because you will see a wide variety of price points with performance and quality that is equally as varied. Therefore, companies should fully investigate the options that are on the market, talk with PPE company representatives to understand what meaningful benefits their PPE offers the actual wearer, seek testimonials from other companies in your field that have experience using their products and, last but definitely not least, conduct a comprehensive wear trial evaluation. It’s often recommended that the trial participant(s) be a person on your team that isn’t shy about sharing their feedback about the gear (both positive and negative). The feedback should be captured on wear trial evaluation forms so they can be summarized for all to see. While this sounds like a daunting task, suppliers typically take on most of the heavy lifting.
Obviously, all safety professionals want their workers to go home to their families in the same condition they were in when they came to work, and nobody plans to have an accident. While it’s important for companies to create, implement, and enforce an electrical safety program so workers know their roles & responsibilities, understand processes & procedures, and follow policies; providing electrical PPE that they will wear when required, and wear properly, is a huge step toward closing the large gap in electrical safety that still exists today.
Mike Enright is the President & CEO of Enespro. He has 27 years of experience in the electrical safety PPE industry and is committed to executing Enespro’s mission of improving the electrical PPE user experience through collaboration and continuous innovation to increase compliance and help make workers safer. www.enesproppe.com.
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