It is imperative that users of NFPA 70E understand the defined terms “risk” and “risk assessment.” Risk is simply the combination of the likelihood of injury plus the potential severity of injury. For example, a task with a low likelihood of injury and a low potential of severity results in a low level of risk, and a task with a low likelihood of injury and high potential of severity results in a high level of risk. 

As defined in the standard, a risk assessment is a four-step process. This definition applies everywhere at home and on the job site, and it applies to all hazards. 

How to do a risk assessment

The first step is to identify a hazard. Second, estimate the likelihood of an injury occurring. This means we must consider the task to be performed in the presence or area of the hazard identified and determine if we could be injured by that hazard while performing the task. Third, estimate the potential severity of injury, which could range from one not requiring medical attention to a possible fatality. The fourth step is to determine if protective measures are required. Where the standard requires the user to determine additional protective measures, they must be selected and implemented according to the hierarchy of risk controls identified in Section 110.3(H)(3). 

NFPA 70E requires employers to implement and document an overall electrical safety program (ESP) that directs activity applicable to the risk associated with any electrical hazards encountered. The ESP is required to include a general risk assessment procedure [see Section 110.3(H)], which outlines the following process to be used before work is started: (1) it must contain the required elements, including identification of hazards, assessment of risks and implementation of risk control according to the hierarchy of risk control methods in 110.3(H)(3), and (2) address the potential for human error. 

Specific risk assessment requirements exist in sections 130.4, Electric Shock Risk Assessment, and 130.5, Arc Flash Risk Assessment. Employers should have a policy and procedure for documenting all arc flash and electric shock risk assessments as required in the standard. It can be a paper document or in an app such as the NECA Safety Meeting App, which contains multiple electronic documents that NFPA 70E requires to be documented and audited. 

It is extremely important to note that testing for the absence of voltage is considered energized work. This requires documented risk assessments to determine the necessary arc flash/electric shock PPE and applicable boundaries to test for the absence of voltage. 

In discussions with users of this standard, many have stated they do not need to document their risk assessments because they always create and maintain an electrically safe work condition (ESWC). That is incorrect. All required risk assessments must be documented as required. This documentation is a critical part of the employer’s required auditing of their safety program. Only through a review of energized electrical work permits and risk assessments can the employer determine if employee work practices are being implemented properly as required in Section 110.3(L)(2), the work practices audit.

Arc flash and electric shock risk assessment requirements contain multiple subdivisions that mandate a comprehensive assessment. In general, the standard user must identify when/where arc flash and electric shock hazards exist, estimate likelihood and potential severity, determine if additional protective measures are required, documentation, boundaries established, permitted risk assessment methods and labeling where mandated by installation codes such as National Electrical Code Section 110.16 or where desired by the equipment owner. 

Risk assessments in NFPA 70E exist to achieve the stated purpose of the standard, which is to provide a practical safe working area for employees relative to the hazards arising from the use of electricity. Where additional protective measures are required for tasks (justified energized work) identified in the exceptions following Section 110.2(B), 130.4(C) and 130.5(C) require the standard user select and implement risk control methods in the order provided in 110.3(H)(3). 

Additionally, the employer’s general rule as seen in the ESWC policy [110.2(A)] requires hazard elimination to be the first priority in the implementation of safety-related work practices. However, the standard recognizes the need to perform justified energized work in limited situations. Performing diagnostics and testing, such as startup or troubleshooting, is a very common task identified as justified energized work (see 110.2(B) Exception No. 3) because the task to be performed is not possible in a de-energized state. 

In this scenario, the first risk control method (elimination of the hazard through the creation of an ESWC) is not possible. The task cannot be performed on de-energized equipment. This is where many standard users look only to the last and least effective risk control method of arc flash and electric shock PPE. It is imperative to apply more than one of the risk control methods in Section 110.3(H)(3) where possible. For example, in addition to PPE, an arc energy reduction maintenance switch can be engaged to reduce the clearing time in the event of a fault, significantly reducing the potential arc flash energy at the point of work.

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