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Justified Energized Work: More than just shock/arc flash risk assessments and PPE

By Jim Dollard | Feb 15, 2024
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Employers invest time and money developing and implementing electrical safety programs, training employees and purchasing personal protective equipment.

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Employers invest time and money developing and implementing electrical safety programs, training employees and purchasing personal protective equipment (PPE). However, it is quite common for trained employees to go into autopilot mode with less than adequate risk assessments. 

They may perform shock and arc flash risk assessments, with no consideration given to other NFPA 70E requirements necessary for a comprehensive risk assessment. In many cases, these risk assessments miss additional risk control methods that can be implemented with other necessary protective equipment and other precautions for personnel activities. 

There are multiple reasons that contribute to this potential shortcoming, including, but not limited to, inadequate training and documentation of shock and arc flash risk assessments, lack of comprehensive auditing, complacency, job site conditions, job pressures and human behavior. 

Risk Assessments

Where the employer determines that justified energized work must be performed, their written electrical safety program should mandate the minimum required risk assessment outlined in 110.3(H)(1): (1) identify hazards, (2) assess risks and (3) implement risk control according to the hierarchy of risk control methods. In many cases, the risk assessment determines that the only risk control method to be applied is list item 110.3(H)(3)(6), PPE, and list items (1) through (5) are ignored. 

Obviously, a determination has been made to perform justified energized work because the electrical hazard cannot be eliminated, so substitution is not possible. However, there are more risk control methods to consider. In addition to PPE, each risk assessment must consider the implementation of engineering controls, awareness and administrative controls. 

Employees must be trained to consider and identify engineering controls that can be implemented during justified energized work. This includes, but is not limited to, arc energy reduction methods required by the National Electrical Code in sections 240.67 and 240.87. 

When applying requirements in Article 130, Work Involving Electrical Hazards, the scope in 130.1 very clearly requires that all Article 130 requirements apply without regard to the arc flash risk assessment method (incident energy analysis or arc flash PPE category method) used. This requirement is intended to drive employers and employees to observe all requirements in Article 130. It is possible to see errors in the selection and use of PPE and other protective equipment (130.7), including rubber insulating equipment or gloves that do not meet requirements for periodic electrical testing. 

Another requirement often overlooked is using barriers when employees will work within the restricted approach boundary (RAB) where exposed energized electrical conductors or circuit parts are operating at 50V or more. This requirement is to prevent unintentional contact while an employee is working within the RAB. See 130.7(D)(2) for barrier requirements. 

Other precautions for personnel activities in Section 130.8 must also be included in all risk assessments. It is imperative that during “error likely” tasks, such as repetitive justified energized work, employees remain alert and aware of the electrical hazards encountered. Impairment is often overlooked; it can occur due to fatigue, illness or other reasons that can prevent an individual from being focused on tasks that involve electrical hazards. 

Each employee must be trained to recognize changes in job scope that introduce additional hazards not part of the original plan. Blind reaching is never permitted, and many tasks require additional lighting, which is easily achieved with battery-operated lighting stands. Conductive articles such as rings and jewelry must never be worn inside the RAB or where they present an electrical contact hazard. Each task that involves conductive materials, tools or equipment must be carefully planned to prevent unintentional contact with energized electrical conductors or circuit parts. Justified energized work in confined or enclosed spaces such as maintenance holes presents additional challenges, and the risk assessment will likely identify protective shields and barriers or insulating materials as needed. 

Where adequate maintenance is not performed or other issues provide evidence that equipment could fail, this must be addressed in the risk assessments. Where electrical conductors and circuit parts are to be de-energized to cut, remove, reroute or otherwise work on them and the conductor terminations (source) are not within sight from the task location, 130.12 requires additional steps to verify absence of voltage or to positively identify the electrical conductors or circuit parts to be worked on.

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About The Author

DOLLARD is retired safety coordinator for IBEW Local 98 in Philadelphia. He is a past member of the NEC Correlating Committee, CMP-10, CMP-13, CMP-15, NFPA 90A/B and NFPA 855. Jim continues to serve on NFPA 70E and as a UL Electrical Council member. Reach him at [email protected].

 

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