About one-half of all electrical injuries and fatalities happen to people engaged in construction activities. (This information is from the Federal Register, “Rules and Regulations.” Vol. 55, No. 151, Monday, August 6, 1990, p 31986. (Preamble to 29 CFR Part 1910, Subpart S, Electrical Safety-Related Work Practices; Final Rule) Washington, DC: U.S. Department of Labor, Occupational Safety and Health Administration. Exposure to employees in the construction industry is identical to exposure in general industry. Electrical hazard exposure is identical to a construction industry employee who is withdrawing a power circuit breaker from a compartment or a general industry employee performing the same task.
General industry tasks are usually associated with operating, maintaining and repairing equipment. Construction industry tasks are usually associated with installing, energizing and checking out new equipment. Tasks commonly executed in these two industrial segments appear to be significantly different. Most people think that general industry tasks are executed while equipment is energized, whereas construction industry tasks are done on de-energized equipment. Consensus standards and regulations normally attempt to address unique industrial requirements.
Analyzing the injuries and the hazards
An analysis of injuries that occur within the two industrial segments suggests that although the type of tasks may be different, employees in each industrial segment are exposed to identical hazards. The mechanics of the task may not be the same, but both the type and degree of exposure are identical. The results of the hazard exposure also seem to be identical. Employees are injured when they are struck by flying parts and pieces, burned when an arc flash occurs and electrocuted if they contact an exposed energized conductor.
No difference can be determined between a general industry employee who is injured when he or she removes a starter unit for repair and a construction industry employee who is injured when he or she removes a starter unit to install a larger starter. A general industry employee who is electrocuted when troubleshooting a malfunctioning starter unit is no different than a construction industry employee who is electrocuted while connecting a cable for new monitoring equipment. The results are identical, as death plays no favorites.
Both employers and employees should be familiar with all hazards associated with electrical energy. As understanding of hazards increases, an employer or employee is better prepared to analyze how employees are exposed to the hazards. As the ability to analyze how an employee is exposed to a hazard increases, the employer’s ability to select an effective work practice also increases. Procedures are put in place that are more responsive and applicable to the work process.
Electrical injuries and fatalities can be reduced when the following thought sequence is in place:
These steps are sequential. A work practice can only follow analysis. If one step in the sequence is inadequate, then all of the following steps will be inadequate. If the plan or procedure is inadequate, a greater chance exists for an electrical injury.
On-site experience plays a key role
The real difference between work performed by construction employees and that performed by general industry employees seems to be the length of experience of each employee at that site. They tend to have less experience at a particular site. Construction employees tend to be temporary, while general industry employees tend to have more experience at the particular site. A general industry employee is probably more familiar with arrangement of particular circuits and specific equipment on the site than a construction employee. These facts seem to have a significant bearing on employee training needs. Short-term employees are generally less familiar with the general industry procedural requirements in place at the site.
The issue, then, tends to be related to owner and contractor instead of general industry and construction. Sometimes, the responsibilities of the general industry employer and the contract employer are not clearly defined. Contractor employers are in the business of supplying a service to an owner or to a general contractor. The contractor believes that the owner or general contractor expects electrical work to be performed without interfering with production or other activities. The employees may feel pressured by the contractor to accept exposure to electrical hazards. In most instances, no attempt is made to develop the necessary understanding of the hazard exposure. Sometimes, the owner or general contractor takes a “hands off” approach to electrical contracting employees.
Consensus standards are moving to better define requirements that will afford protection to any employee who is exposed to an electrical hazard. While regulatory action tends to remain divided by industry segment, consensus standards are beginning to increase focus on exposure to electrical hazards.
NFPA 70E proposal introduces change
The NFPA 70E technical committee received one proposal (NFPA 70E: Standard for Electrical Safety Requirements for Employee Workplaces) for inclusion in the 2003 edition of the standard attempts to define the relationships and responsibilities for personnel safety on multi-employer work sites. In this proposal, a requirement is defined for each employer to inform the other(s) of existing hazards to which an employee is likely to be exposed. The requirement indicates that each employer must inform the other(s) about procedure requirements in addition to the degree of the potential hazards. The proposal requires a meeting (with documentation) to discuss electrical hazards, procedures, evacuation requirements and protective equipment requirements.
The proposal requires that procedural requirements of each employer are to be coordinated with those of the other employer(s). The on-site employer and the off-site employer(s) must ensure that employees understand the requirements of the other employers. Both on-site (owner or general contractor) and off-site employers are required to review the work to ensure that the coordinated procedures are followed. The bottom line of the proposal is that both the on-site and the off-site employers have responsibility for the safe execution of the work, regardless of the industrial segment.
Who says work must be done on energized systems?
In most cases, employees who perform a service want to provide it so that their work does not interfere with ongoing production, regardless of whether the employee is short or long term. Of course, production supervisors and managers are in favor of that non-interference. These facts exert pressure for electrical employees to avoid shutting down equipment. Wanting to be viewed as a “can do” employee, he or she frequently accepts exposure without questioning if the exposure is really necessary. It is possible to perform electrical work on an energized system while it is energized, but the risk of injury is greatly amplified.
Experience has shown that if a production supervisor or manager really thinks about the significant risk of injury, the equipment can be de-energized without significantly impairing product output. If all sources of electrical energy are removed, the risk of injury from electrical energy goes to zero. Of course, potential injury from other sources of energy might remain, but no risk of electrical injury exists.
Consensus standards are moving toward requiring a signature on a document to indicate the necessity of accepting the increased risk. Experience has shown that when supervisors or managers put their signatures on a document, they recognize the higher degree of risk. The number of instances where the task must be accomplished while energized suddenly is drastically reduced. The document and signature have no direct bearing on the legal or moral responsibility of the supervisor or manager. The legal and moral responsibilities exist, regardless of the document. However, the act of placing his or her signature on the document causes the manager to think about the result of accepting the increased risk. The manager may be able to find a way to de-energize the circuit and shut down the equipment.
As proposed for the next edition of NFPA 70E, an “Energized Electrical Work Permit” will be required for work where exposure exists to “live parts” that are not placed into an electrically safe work condition. The proposal does include an exception for repetitive work tasks that are performed by a qualified person and require on circuits that must be energized. EC
The JONESES of Electrical Safety Consulting Services Inc., can be reached at 919.557.7711 or firstname.lastname@example.org.