5 MISTAKES SAFETY PROFESSIONALS MAKE ON NFPA 70E

From the Desk of Daryn Lewellyn Dear Safety Professional: Thank you for taking the time to read this informative document. Your efforts show your diligence in adhering to your mission as a safety professional, and I am convinced the time you invest to read this report will be well worth it. There is much confusion about regulatory compliance in regards to electrical hazards. This is caused by the National Fire Protection Associations standard 70E - not the document itself, but rather its place in the overall compliance picture. Many safety managers have heard about the standard, but are waiting for a decisive regulatory move from a body such as OSHA before learning more. Others have a better appreciation for 70Es importance, but have a desire to know more about how it applies at their facility. If youre reading this report, you probably fall into one of these two groups. What you need to understand is that NFPA 70E is now the consensus standard for electrically safe work practices. Applying the recommendations of the standard can be a daunting task. For example, the primary message of NFPA 70E is to de-energize live electrical parts prior to working on them, which has prompted some facilities to implement "no live work" policies. That alone will create a contradiction when applying lockout/tagout procedures. Successful implementation of 70E can only be achieved with a facility-specific mindset; what 70E may spell out in letters you may need to implement in spirit, as well see. This report uncovers five of the most common errors in judgment safety professionals make when they handle 70E. The information herein is drawn from the experiences of my business interactions with clients of virtually every size, industry and location, and decades of my own personal experience as an electrician and safety instructor. It is not a complete list. Just as 70E does not provide 100% of the answers youll need to keep your people safe from electrical arc and shock, this report cannot catalog every myth and misconception regarding 70E weve encountered over the years. There simply isnt enough space and you dont have the time. What we can do is equip you to better understand 70E and the more common pitfalls many encounter when it comes to this standard. As well see, these mistakes are made both from a philosophical and application standpoint. Both are harmful and can cost lives. Thats not over-reaching for effect: 70E is a wonderful tool that has and will continue to save lives, and the way we approach it must reflect this. Thank you again for your correspondence with Lewellyn Technology. Please also review the other materials weve included with this report to learn more about our company, and dont hesitate to contact us. We look forward to hearing from you. Best Regards,

Daryn Lewellyn President/Founder Lewellyn Technology

www.Lewellyn.com | 800.242.6673 | PO Box 618, Linton, Indiana 47441 | Copyright Lewellyn Technology 2012

M MISTAKE # IGNOR #1: RING 70ES S IMPORT TANCE ry month Lew wellyn Tech hnology is fo ortunate to conduct c sem minars on ele ectrical safet ty and meet hundreds o of Ever peop ple who are e trying to do d the right thing and protect p their r employees s from elect trical hazard ds. Yet these e meet tings have se erved to point up just how h much sa afety people e are confuse ed when it comes c to 70 0E. The most common questio on concerni ing 70E is, "Is " it the law w?" Many ot thers state definitively d t that since 70E is not an n OSH HA requirem ment, they ar re not implem menting it at t their facilit ty. Ther re is a three e-part answe er to these questions: NFPA N 70E is s not an OS SHA require ement. It is not the law w. And neither of these t facts matter. m at does mat tter is this: OSHA curr rently requir res employe ers to prote ect their em mployees fro om electrica al Wha hazards, includin ng shock and d arc flash. Some S of OS SHAs own words w on th his topic are e instructive. There is o of cour rse the Gen neral Duty Clause C which h serves as a broad mi ission statem ment for an nyone in the e business o of safet ty, but consider also OS SHAs words s on Persona al Protective e Equipment t (PPE): "Emp ployees wor rking in areas where there ar re potential electrical hazards sha all be provided with, and a shall us se, electrica al protective e equip pment that is appropriate for the sp pecific parts of the body y." (29 CFR 1910.335(a) )) So we find d that OSHA A requ uires employ yers to prot tect employ yees from "r recognized hazards" h (Ge eneral Duty y Clause) an nd that steps must t be taken specifically to address s electrical hazards (29 9 CFR 1910 0.335 (a)). Among the e recognized d elect trical hazard ds present in n the workp place are arc c flash and shock. To su ummarize: OSHA O curren ntly requires your r facility to protect p empl loyees from arc flash and shock. How wever, OSHA regulations themselv ves do not provide enough detaile ed informat tion to acco omplish this s. NFPA A 70E is cr rucial becau use it provid des a bridge e between OSHAs O req quirement to protect against a these e dang gers and actual complian nce with tha at rule. OSH HA itself def fers to 70E in a Standard Interpret tation Letter dated Novembe er 14, 2006: "OSHA rec commends that t employe ers consult consensus standards s su uch as NFPA A 70E-2004 to ide entify safety measures that t can be used to co omply with or o suppleme ent the requ uirements o of OSH HAs standar rds for preve enting or pro otecting agai inst arc flash h hazards." HA Director r David Wall lis, in an inte erview with IEEE, had th his to say ab bout OSHA compliance: : "It certainly y OSH seem ms to me th hat if Im an employer, and I want to comply with a gene eral requirement for pr rotecting my y employees from electric sho ock, that the e first place Im going to look is NFP PA 70E." se announcin ng the citatio on for unsaf fe work prac ctices by a Denver D elect tric company y following a In a news releas s accident t, OSHA Are ea Director Herb Gibso on said, "This s accident co ould have be een avoided by following g job site reco ognized safe practices for r working ar round electr rical hazards." (March 23 3, 2006.) Time e and again, OSHA defe ers to NFPA A 70E as a "h how to" guid de to OSHA A compliance e. In the abo ove examples and countless ot thers, top ag gency perso onnel acknow wledge that when it com mes to keeping employe ees safe from m elect trical hazard ds, OSHA regulations do o not fully sp pell out OSH HA requirem ments. r whether NFPA N 70E is the law is outdated o and d misguided at best. The e question yo ou should be e The debate over askin ng about 70E is not whether it is the t law, but rather, if your compan ny is not usi ing 70E to guard g against elect trical hazard ds, what is it t using? If yo our electrica al safety train ning does no ot include th he procedur res explained d in 70 0E, what does it include e? Failing to recognize 70Es 7 place in the area of o complianc ce is a comm mon mistake e that prevents em mployers fro om implemen nting the con nsensus best t practice for keeping th heir employe ees safe from m elect trical hazard ds.

www.Lewellyn n.com | 800.2 242.6673 | PO O Box 618, Lint ton, Indiana 47 7441 | Copyright Lewelly yn Technology 2012

M MISTAKE # THEY VALUE #2: V CO OMPLIANCE OVER SAFETY re once was s a suburban n doctor wh hose practice e served a seemingly s ho omogenous group: youn ng, educated d, Ther "Typ pe A" profe essionals wh ho commute ed to the city c for their white-col llar jobs at high-profile e employers s. Incre easingly, this s doctors patients p beg gan to comp plain of a si imilar sympt tom: chroni ic headaches. The wellmean ning doctor, already ov verworked due d to a double patient t load and now n faced with w a budding epidemic c, bega an to look fo or the first similarity s he could find among a the headache h suf fferers. "Aha a!" he exclaim med with no o small amount of f satisfaction. "Its their stressful s lifestyle! These e people nee ed to learn to t slow dow wn." Without furth her examinat tion or evalu uation, he in nstructed each one of hi is patients who w had com me to him co omplaining o of head daches to tak ke a vacatio on to relieve e stress. Tha at would und doubtedly ta ake care of the t problem m, he assured d them m. We chuckle at this fiction nal account, , yet many managers exhibit the same kind d of careles ssness when n deve eloping their r electrical sa afety progra ams. Instead of focusing on safety, i.e e. the avoida ance of emp ployee injury y, many y are focuse ed on compliance, i.e. th he avoidance e of regulato ory action ta aken against them. To pu ut it another way, compliance e-first is a mindset that asks, "W What do I need to do o to stay safe in the eyes of the e gove ernment?" while w a safety y-first mindset frames th he issue mor re simply: "W What do I need n to do to t stay safe?" While there ma ay appear to be only six x words diff ference betw ween them, the implicat tion of that difference is farre eaching and potentially p deadly. d The problem is that too often o compliance-based safety prog grams apply a rigid set of guideline es to unique e situa ations that th he well-meaning creator rs of those guidelines g co ould not fore esee. A perfe ect example e is the set o of table es found in NFPA N 70E di irecting PPE usage, whic ch we will ex xplore in the e next sectio on. escription may m have bee en spot on in n some case es, but by ap pplying a blan nket diagnos sis to specific c The doctors pre patie ents, the doc ctor may be e overlooking a potentia ally deadly co ondition. His s patients were w probabl ly more than n willin ng to accept t a vacation as opposed d to a more intensive fo orm of treat tment, but that is only because b they y have e put their trust in their r medical ca aregiver. His desire to clear c out som me of the patient backlo og may have e left his patients open to worsening he ealth conditions and thu us the need for more appointment a ts and office e e, and his pra actice open to t a lawsuit. time And that may be e the most ironic aspect t of a policy y that values compliance over safety y: It likely will compound d the problems p it is intended to avoid. As s well see, when w the go oal is simply avoidance of o regulatory y action from m OSH HA or another body, saf fety can be compromise c d and people can be injured. In that t case there well may be e an OSHA O citatio on on the ho orizon, but if i the inciden nt is serious s enough, th he check for that citation will be the e smallest check you y write. Le egal bills, cos st of downtime, replaced d equipment t, employee injury rehab bilitation - all will dwarf d the co ost of that dreaded d citat tion penalty in short order. Compli iance-first is a shortsight ted goal tha at in th he end may do d more har rm than good. Safet ty at your facility fa canno ot be arbitra ated by peo ople who ha ave never walked w the floor at your r site. When n mana agers adopt policies in which w safety is valued ov ver complian nce, the deci isions about t what is safe e and what is not are a taken ou ut of the han nds of these at-large arb biters and pla aced back in nto the hand ds of the peo ople who are e responsible for seeing their r fellow emp ployees go home h from their t jobs sa afely. When n this happen ns, thorough h yses are co onducted of f the hazar rds specific to the fac cility, and recommenda r ations to fix them are e analy imple emented. Plans are put t in place to o change the e safety cultu ure, which may m be the most difficu ult and timecons suming aspe ect of the entire e policy y. There are e many dec cisions that will need to t be made e when your company begins to impleme ent 70E: who o will do th he training, who w will pro ovide the PP PE, how will we mitigate e hese decisio ons are made e with the ov verall goal of o achieving safety, s comp pliance hazards, etc. If th will take t care of itself.

www.Lewellyn n.com | 800.2 242.6673 | PO O Box 618, Lint ton, Indiana 47 7441 | Copyright Lewelly yn Technology 2012

M MISTAKE # THEY RELY #3: R ON THE NFPA A 70E TAB BLES TO SEL LECT PPE E The primary me ethod of pro otecting emp ployees from m arc flash as a spelled out in 70E is de-energizing live parts prior r to workin ng on or near n them using u prope er lockout-ta agout proce edures. This s limits the e employees expo osure to electrical hazar rds during th he shutdown n and verific cation proce ess. Many be elieve they dont d have to o worr ry about ar rc flash beca ause they have h institut ted a "no li ive work" policy p at the eir facility. Because the e employee is still l exposed during shutdo own and ve erification, th his policy do oes nothing to remove the need to o prot tect against arc a flash. Until you have verified that t the circuit is de-energi ized, it must t be treated as energized d and the t appropr riate Persona al Protective e Equipment (PPE) must be used to protect agai inst arc flash h. NFPA A 70E describes two methods m of doing that: a thorough arc flash ha azard analys sis in which dangers are e ident tified and recommenda r ations are made m to mit tigate them, and a set of tables to t determin ne what PPE E personnel should d wear when performing electrical work. w Manag gers with a compliancec only mindse et will merely y hire someone to o look at th he PPE table es found in NFPA 70E, prescribe the t proper PPE according to those e table es, and call it i a day. The e tables may y be a good place to be egin the pro ocess of pro otecting again nst electrica al hazards, but will leave you woefully w short if they are e the only le ength to whic ch you go to o keep your people safe. - and voltag ge-specific se ections. In each e section n The tables are task-based and divided into eight equipmentseveral tasks ar re listed tha at might be performed on that pie ece of equip pment. For example, in the section n label led, "600V Class C Motor Control Ce enters (MCC Cs)," one of the ten task ks listed for that piece of o equipment is, "W Work on en nergized part ts, including voltage test ting." The ta able says tha at task on th hat piece of equipment e is a Ha azard Risk Category C 2*. A worker could c then lo ook at a sep parate chart specifying th he PPE need ded to satisfy y a Ca ategory 2 rat ting. ough, but us sing a tables-only approach to pro otection fro om electrica al This procedure may seem simple eno hazards overloo oks the critic cal flaw in the t tables creation: The e authors have never visited v your facility. As a result, there are e enormous s gaps in the e protective e qualities of f the tables. . A task you u perform or o a piece o of equip pment you use may not t be covered in the tab bles. A piece e of equipme ent may hav ve a risk cate egory higher than Category 4, 4 for which the tables make m no reco ommendatio ons. And mo ost glaringly, the tables are a based on n edetermined d available sh hort circuit current c and clearing tim me. Your facility may have e variances from f either a pre of th hese, which will w introduc ce huge inaccuracies in the t selection n of PPE. , these short tcomings can n produce a dangerous environment for employ yees working on or near Needless to say, trical equipm ment. Yet, th he employer r who simply y uses tables s to assess electrical e haz zards may well appear to o elect be in n compliance e by virtue of o the labels affixed neatly to their electrical panels. Rem member the example of the doctor r who tells every patien nt complaining of chron nic headaches to take a vacat tion? While e he may be e correct in n a handful of cases, he h also could be misdia agnosing pot tentially life ethrea atening problems with such a blanket prescr ription. Likew wise, the ta ables are a great tool in a limited d number of situat tions, but if you want to o more accu urately protect your em mployees you u must have e an arc flash h hazard analysis performed p at t your facilit ty. With h that said, allow me to o shade the discussion on o this topic: If your co ompany is doing d nothing to protect employees from m electrical hazards h toda ay, tomorrow start usin ng the tables s. They are not perfect, , but they a at least t provide so ome measur re of protec ction. Use th he tables un ntil you can have a tho orough arc flash f analysis perfo ormed at yo our facility, with w recomm mendations fo or mitigating g hazards.

www.Lewellyn n.com | 800.2 242.6673 | PO O Box 618, Lint ton, Indiana 47 7441 | Copyright Lewelly yn Technology 2012

M MISTAKE # THEY CUT #4: C COR RNERS IN AN A ARC FL LASH ANA ALYSIS Beca ause the tab bles provide ed in NFPA A 70E prov vide only a starting po oint for tho orough elect trical hazard d prot tection, the best way to o keep emplo oyees safe is s through an n arc flash analysis. a Unfo ortunately, this t can be a daun nting task fo or a variety y of reasons s. The different pricing g options, wide w range of services included by y different compan nies in the analysis, and generally sim milar appear rance of com mpanies that perform the e studies can n cause safety man nagers to cu ut corners on o the study y. Because th he overall an nalysis is the e best way to t keep your peop ple safe, this is a mistake e you cannot t afford to make. m The publication of 70E and its role in electrical sa afety at the workplace has h prompte ed a growin ng awareness among employe ers of the potential p da angers that exist at th heir facilities s. It also ha as produced d a crop o of s ov vernight wit th the prom mise to help employers mitigate those hazards s. companies that sprang up seemingly Simp ply type "Arc c Flash" into o a Google_ _ search and d youll find pages of companies wit th a whiz-ba ang Web site e prom mising to solve all your compliance c p problems. As you y might ha ave guessed, many of these compan nies are run by opportunists who se ee compliance confusion n stem mming from 70E as their latest cash h cow. Other businesse es are reput table, thoro ough venture es that value e safet ty over com mpliance. The ese firms tak ke arc flash analyses ex xtremely ser riously becau use they und derstand the e goal of the study y is first and foremost to o keep employees safe, not put up a charade of f compliance e to collect a chec ck. re are certai in things an arc flash ana alysis must include to en nsure it is worth w the eff fort and reso ources. First t, Ther the company c co onducting the analysis must m obtain accurate, up p-to-date inf formation on o the facilit tys electrica al syste em by actual lly visiting th he facility. Th his is absolut tely critical, as often dra awings or blueprints of a system wil ll beco ome dangero ously outdated with even n slight reno ovations or additions a to the physical l building. Next t, the data collected c in phase p one is s utilized to evaluate the e power syst tem using NFPA N 70E and IEEE 1584 4. It is imperative this t is perfor rmed by a lic censed Profe essional Eng gineer using highly sophis sticated soft tware. There e are look-alikes l o there who claim to be using sim out milar equipm ment they ob btained for free f - they are a walking a dang gerous line between b recklessness and a willful ig gnorance. The T calculatio ons made by b the engin neer and the e softw ware will sho ow where in n your facility y the hazard ds exist. It is unwise to take t chances s with such information. t comes one e of the mo ost crucial el lements of the t study: re ecommendat tions for mitigating the hazards tha at Next exist t. Many employers hold off on th his element for fear of f a glorified sales pitch h or because of fear o of exor rbitant cost. However, most adjust tments to el liminate or greatly redu uce hazards can be performed with h little e or no cost t at all - re eplacing fuse es or adjust ting circuit breakers. b More expensive and time-consuming g mod difications inc clude breake er replaceme ent or having entire panels upgraded d. Follo owing this phase, there should be collaboration n on an "elec ctrically safe e work pract tices" policy y and training g to im mplement it. . This may be b the most crucial step p of all - the training in which w emplo oyees are eq quipped with h know wledge of ex xisting dangers and how w to stay sa afe is the glu ue that hold ds the entire e analysis to ogether. It is critic cal to choos se the correc ct trainer who w has been n there before, and can speak with passion p and authority on n the topic t of elec ctrical safety y. It helps if he has scars s. This last phase p is so crucial c that missing m the mark m on it is anot ther critical error e safety professiona als make on 70E.

www.Lewellyn n.com | 800.2 242.6673 | PO O Box 618, Lint ton, Indiana 47 7441 | Copyright Lewelly yn Technology 2012

M MISTAKE # THEY FAIL #5: F TO PLAN P FOR R THE CULTURE CHANGE C

It wo ould work be est if safety managers m we ere able to cut c a check to install cult ture change at a their facilit ties. It would d be ev ven better if f you could download d it from f the Inte ernet for fre ee. It would avoid a the pai instaking time and energy y this endeavor e will undoubted dly cause. Be certain: Cul lture change is without question q the most impor rtant, difficult t, time-consuming aspect a of 70E E implementa ation. Many safety s manag gers fail to pla an for it prop perly. Safet ty managers may be tem mpted to cha alk up the dif fficulty in im mplementing any a new pro ogram to a simple s "cant tteach h-an-old-dog g-new-tricks" mentality common in many m workpl laces. While it is true th he more exp perienced se et may pose proble ems in institu uting culture change beca ause of rigid habits built over years on o the job, th hey also hold d the key k to succes ssfully implem menting 70E. The keys ar re inclusion and a ownershi ip. At th he risk of lib beral stereoty yping, most maintenance m department ts have a sim milar breakdo own. If there are ten who o are technically t "q qualified" to work on ele ectrical equip pment, usually there are at least a co ouple who are a not. They y may have been tr rained impro operly, may have h lost focu us - whateve er the reason n, they are th he least-skille ed employees you have. h The largest set in n a departme ent are the eight e or so who w are qual lified, highly skilled profe essionals. The ey handle the e bulk of the work k. They are so olid, well-rou unded, and ha ave potential l to become truly great at a what they do. a truly gre eat workers everyone lo ooks up to an nd admires. They are the first to be e called when n The top couple are ething goes haywire, and d have a we ealth of experience from m which to draw in eve ery situation. Sometimes s, some howe ever, these can c be the em mployees wh ho become entrenched e in n their ways and make in nstituting cult ture change a challenge. The key is to giv ve these top p employees inside know wledge of the e changes yo ou plan to make m and allo ow for open n, hone est feedback before pres senting it to the rest of the group. Make M it look k like their id dea. For exa ample, if your prog gram will req quire usage of o PPE where e none was required r befo ore, allow yo our top personnel to sele ect the attire e or make m other decisions d related to imp plementation n. Nothing will w torpedo culture chan nge more quickly than a coup ple of key em mployees who o yield influen nce over the e newer set balking b at the e program. re are many decisions to o make when n you decide e to impleme ent 70E, and when it com mes to the most m critical Ther cultu ure change - it will be helpful to allow w these influencers to sho ow ownership p of the prog gram by inclu uding them in n the decision-mak king process s. What PPE E to wear, who w should provide it, who should d provide training, wha at pment modif fications to make m - all are decisions that t should include the in nput of the people p impac cted by them m equip most t. ement of tra aining your employees e o new proc on cedures rela ated to 70E should be taken t just as Similarly, the ele ously as any other aspect t of the stan ndards imple ementation and probab bly more so. . The trainin ng provider is serio respo onsible in a large way for r selling the programs p im mportance, ed ducating your workers, and making th hem better a at what t they do. Co onsequently, the trainer must m be able e to relate to o your worke ers. He or sh he must have e worn a too ol belt at one point in their care eer. They mu ust be as passionate abou ut improving workplace safety s and performance as eacher at a tent t revival meeting. m And d it helps if they t have sc cars eviden nce of their own o persona al experience e a pre with electrical accidents and the t significan nce of staying g safe. Whil le all the elements conta ained in NFPA A 70E are cr ritical, none are more so o than the tra aining and cu ulture change e required to imp plement a new n safety program. A company could c make all the correct decisio ons on PPE E, locko out/tagout, arc a flash analysis, etc., but if the employees who work on the e floor and with w the equipment every y day do d not buy in n to the prog gram because they are im mproperly trained, the be est safety pro ogram in the world wont mean n a thing. As s said before, make safety y the numbe er one priori ity for impro oving your workplace, w an nd allow it to o guide e you in the training dec cisions that need n to be made, m and yo oull avoid th his dangerou us mistake, and the other comm mon errors weve w examined.
www.Lewellyn n.com | 800.2 242.6673 | PO O Box 618, Lint ton, Indiana 47 7441 | Copyright Lewelly yn Technology 2012