Electrical safety is as much an individual responsibility as it is an organizational responsibility. Employers (contractors) are required to provide a safe workplace for workers, and qualified workers must know how to recognize and avoid electrical hazards to keep them safe. Everyone can agree that workers should be able to return home from a day's work in the same healthy condition in which they left for work that day. This requires following safety rules and applying best practices in the field. While the employer (contractors) should have a safety program and policies for the workers, workers must be diligent enough to differentiate between bad practices that place them at risk of injury and even death. It's important to review the basic requirements for locking out electrical energy, so work can be performed in an electrically safe condition. When a life is on the line, effective lockout/tag-out procedures must be implemented.
Shut the power off
The Occupational Safety and Health Administration (OSHA) regulations require electrical equipment and circuits to be worked on only when placed in an electrically safe work condition. Subpart K in CFR 29 OSHA 1926 provides clear requirements about this concept. This is the general rule which means this is how electrical work should be performed by workers most of the time. Ask yourself this question. How safe is my work environment, or if you’re an employer, how safe are my workers and are they following the OSHA requirements? Electrical equipment and circuits should not be worked on while energized. This is a risk to workers and violates OSHA rules. NFPA 70E provides standardized guidance for electrical worker safety and reiterates the same concepts of not working on electrical circuits while they are energized. These clear requirements that have been in place for years, yet statistics indicate that more and more workers are sustaining injuries and even dying from violating this general rule. Why? Is it because they are unqualified? Is it because that is the common practice they know and understand? Or is it because they have no fear or respect for the power of electricity? Is it a lack of training? Perhaps it is a combination of the above. Something is definitely inadequate with the current practices employed by many electrical workers. It is as if cultural practices used for years have to be changed or should we say improved upon. The culture of the electrical workforce in this country is strong and with much pride, however, there is documented need for improvement in the area of electrical safety. Always shut the power off then work. When in doubt, shut the power off. There are no heroes except the ones that return home to their families because they follow established safety policies and procedures in their daily work.
Equipment disconnect rules in the NEC
The National Electrical Code (NEC) has general requirements for installing disconnects within sight from motors, driven machinery, and other equipment. The term within sigh from, in sight, or insight from is described as visible and not more than 50 ft from the equipment.
When the disconnecting means for equipment is located in accordance with the general NEC rule, the workers have the ability to monitor the disconnecting means while work is being performed. Locating disconnect out of sight from the equipment is typically only allowed by exception and there has to be a reason of impracticability or the disconnecting means introduces additional hazards. In any event, The NEC is an installation Code and includes requirements that work hand-in-hand with the requirements in NFPA 70E Standard for Electrical Safety in the Workplace.
Each of these standards has basic requirements in common. In fact, OSHA finds an electrical lockout/tag-out (LOTO) program using the procedures in 1910.147 compliant with 1910.333 so long as the procedures include the following:
1) A qualified person ensuring tests are performed to verify the circuit is de-energized and cannot be inadvertently energized or energized by induced voltage or backfeed
2) If a tag alone is used, an additional safety measure is used that includes the removal of an isolating circuit element, blocking of a controlling switch or opening of an extra disconnecting device
A simple individual LOTO is used by a qualified person when the disconnecting means remains visible to that person during the work and the work does not extend beyond one shift. A simple LOTO procedure can be used when qualified person(s) are working on one set of conductors or circuit parts. Each person must have control over his or her lockout.
Simple lockout and tag-out process
There are several basic steps in a simple lockout/tag-out process as follows:
• Review the company written LOTO plan.
• Identify all energy sources including stored energy.
• Locate all disconnecting means and identify procedures to release stored energy.
• Determine the means for verifying disconnection.
• Identify all workers who may be affected or exposed by the LOTO.
• Ensure that all employees are trained to the degree necessary to execute their responsibilities as related to the LOTO procedure.
• Identify the appropriate voltage detector that will be used.
• Develop procedures for verifying operability of the voltage detector and determine appropriate procedure.
• Determine the need for any protective safety grounding.
• Develop the procedures for controlling energy.
• Coordinate electrical LOTO procedures with other means of hazardous energy control.
Employees should be trained on the requirements of lockout/tag-out plans provided in the employer’s overall safety program. The first step in the process requires affected employees to become familiar with the all energy sources and identify them and their associated means of disconnect. The next step is to disconnect the power by opening the switch or circuit breaker. This typically involves use of an accurate single-line diagram and depending On accurate panel indexes identification for the circuits. Experience has shown that often times the circuit identification on panelboards and switchboards is not accurate. It is supposed to meet the requirements in NEC 408.4. Once the disconnecting means is placed in the open position, it is important to verify that the blades are open if possible. The next step is to apply a lock to the switch or circuit breaker assuring it will remain in the open position. The lock and tag should be applied to the switch giving others an indication that there is a worker on the other end of the line. The next step is to verify that the power has been disconnected. This is referred to in NFPA 70E as verification of the absence of voltage. This is done using an appropriate voltage detector. NFPA 70E has recently been revised to address voltage detection processes. Section 110.6(D)(1)(e) of NFPA 70E-2009 requires workers to be trained in the use of voltage detectors and understand the readings and settings of such equipment. The specifics about the training are not provided in 70E, nor are the organizations that are qualified for providing the training. Another important part of verifying the circuit is de-energized is to do so while wearing the appropriate level of personal protective equipment (PPE) while doing so. It may also be necessary to apply protective safety grounding to the circuit or equipment involved as an added safety provision. This also helps bleed off any stored energy such as capacitance or static charges. Once the circuit and equipment is known to be in the de-energized state, safe work can begin. The National Electrical Contractors Association (NECA) has recently developed a new effective guide for electrical contractors and workers that includes step-by-step guidelines of effective lockout/tag-out operations. Additional information about NECA Lockout/Tag-out Guide is provided at www.necanet.org.
Complex lockout and tag-out rules
Complex lockout/tag-out (LOTO) rules are beyond the scope of this article. Readers should be aware that are in complex lockout/tag-out operations, there are multiple individuals involved. A complex LOTO must be used when there are multiple elements involved such as multiple crews, energy sources, or locations. In the complex LOTO procedure, a qualified person is appointed responsibility for the procedure. This person must account for all energy sources and all persons working on the job. A written plan is needed for execution of the complex LOTO operation and procedure. Complex lockout/tagout procedures are thoroughly reviewed in NECA’s new Lockout/Tag-out Guide.
Establishing an electrically safe work condition
In situations of applying electrical lockout/tag-out processes for NEC installations, NFPA 70E is used as the guideline (standard). A key observation is that consensus standards can sometimes be relevant to a general duty clause citation in the sense that they may be used as evidence of hazard recognition and the availability of feasible means of abatement. The requirements in NFPA 70E call for live parts to be placed in an “electrically safe work condition” before employees can work on or near them. An electrically safe work condition is defined as “A state in which an energized conductor or circuit part has been disconnected from the energized parts, locked/tagged in accordance with established standards, tested to ensure the absence of voltage and grounded if determined necessary.” All electrical contractors and workers should become familiar with NFPA 70E and the applicable OSHA regulations to ensure the safety of their employees.
Safety policies and procedures
Electrical contractors (employers) must decide how to meet the level of protection required. This is common in OSHA standards as the responsibility for compliance is left with the employer to determine compliance procedures. When a compliance inspection is conducted, OSHA may defer to consensus standards to compare the effectiveness of the employers’ procedures with industry accepted practice. Employers and employees share in the responsibility of adhering to OSHA rules. This is a combined effort.
Electrical contractors (employers) are required to have and implement a safety program for the workers. This program should include procedures and policies on establishing and maintaining a safe workplace for the employees. The employees should be trained to adhere to the rules and policies established in the safety program. The definition of qualified person emphasizes requirements for training and skills that enable workers to recognize and avoid any hazards involved with the work they perform on a daily basis. Being trained in the proper application of lockout and tag-out processes is an important step in the right direction. A good practice employer’s could incorporate is to establish a policy that all workers carry acceptable lockout devices and tag-out devices and be trained on their use. Compliance with safety programs and procedures necessitates workers (employees) applying best practices in the field.
The need for training contractors and workers
Communication and education are the keys along with training, training, and more training. Employers (contractors) also need to be trained as to the correct safety-related work practices for the employees. They have responsibilities to protect their employees by implementing an electrical safety program. The best approach to electrical safety is being proactive rather than reactive. Including electrical safety at the bidding and project start up phase is far more effective that treating safety as an afterthought. It is fairly common for employers to react to an event (injury or death or an employee) after the fact. By then it is too late for the employee, the family, and the business. So it is evident what the best approach should be. How can contractors implement effective safety programs for their employees and still remain competitive? It is not easy, but it is the right thing to do. Anything less is running risk. Risk management groups are constantly advising employers about the best practices and the laws to ensure they are benefitting from the best insurance rates possible. Contractors that ore on the receiving end of safety violation notices and fines are usually paying much more in insurance premiums. It is best to be proactive when it comes to electrical safety in the workplace.
The impact of violating safety rules
When safety rules are violated and there is an injury or death which of the following is impacted: the employer, the employee, or the families? The answer is all of the above. Electrical safety for employees is as much an individual responsibility as it is for employers. Workers have to be trained to make the right decisions involving the own safety in the field. Here is something for workers to consider the next time they have doubt about safety requirements or are taking risks. What would the family want them to do? If the family knew the safety rules that the employee should follow, they would expect that their family member (the worker) would follow them, not violate them. Another way to look at this is for contractors to substitute a family member for their employee. Would they put a family member in harms way? This author believes not.
Yet, as an industry, there seems to be so much complacency about safety in the workplace. It is as if workers take an “it won’t happen to me” approach. This needs to change. The approach to electrical safety should be one that reduces risk and hazards for workers. Everyone benefits from this approach; contractors and workers alike.
Work on electrical circuits or equipment should generally always be performed in an electrically safe work condition. NFPA 70E outlines how to establish an electrically safe work condition. Only when it is infeasible or introduces additional hazards should work be perform while circuits and equipment are energized. Examples include, but are not limited to, a troubleshooting operation or procedure or a power for critical operations facility. Locking and tagging out of de-energized circuits protects lives that are working on the line. Employers (contractors) should include lockout/tag-out policies in their overall safety program. The key to keeping workers safe and avoiding injuries and safety violations is communication and effective safety training. This article provides readers with the basics of achieving electrically safe work conditions through proper application of lockout and tag-out (LOTO) procedures. When locks and tags are applied to the disconnecting means of a circuit or equipment, safe work conditions are established for those working on the line. A life is on the line and it is safe because of compliance with established effective safety policies and procedures. Safety first, always!
JOHNSTON is NECA's executive director of standards and safety. He is former director of education, codes and standards for IAEI; a member of the IBEW; and an active member of the NFPA Electrical Section, Education Section and the UL Electrical Council. Reach him at firstname.lastname@example.org.