Safety Leader

Hierarchy of Needs: Electrically Safe Work Conditions and Risk-Control Methods

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In the 2018 edition of NFPA 70E, a new Section 105.4, “Priority,” was added to clearly state hazard elimination is the first priority in implementing safety-related work practices. The informational note (IN) following this section reminds the user that elimination is the first risk-control method identified in 110.1(H)(3), “Hierarchy of Risk Control Methods.” Also, in 2018, the hierarchy of risk control was relocated from an IN into positive text in the required risk-assessment procedure [see 110.1(H)] included in the employer’s electrical safety program. These revisions put the hierarchy of risk-control methods on the front burner. 

It is imperative to understand that these methods control risk; they do not control hazards. When a hazard exists, a risk assessment must be performed. A risk assessment identifies hazards, estimates the likelihood of injury occurrence or damage to health, estimates the potential severity of injury or damage to health, and determines if protective measures are required. 

For example, consider the following task involving justified energized work. Remove the dead front, drill hole, punch hole, install connector, enter a conduit, pull conductors and terminate conductors on a circuit breaker in an energized 800-amp MLO panelboard supplied at 480/277 volts. Significant hazards associated with this task include shock, arc flash and arc blast. 

However, when an electrically safe work condition (ESWC) is properly achieved and maintained, the hazard is eliminated for the period of time that the ESWC is maintained. An ESWC is a state in which an electrical conductor or circuit part has been (1) disconnected from energized parts, (2) locked/tagged in accordance with established standards (this is the employer’s written LOTO program and prescriptive steps for LOTO), (3) tested to verify the absence of voltage, and, if necessary, (4) temporarily grounded for personnel protection.

It must be understood that NFPA 70E, Standard for Electrical Safety in the Workplace, addresses only electrical hazards, and the stated purpose of the standard in 90.1 is to provide a practical, safe working area for employees relative to the hazards arising from the use of electricity. It is practical to eliminate electrical hazards through the creation of an ESWC. 

In the 2018 edition of NFPA 70E, requirements were followed by INs that referenced safety management standards that can be found in multiple locations. In the 2021 edition, all references in INs to safety management standards following requirements have been deleted. 

NFPA 70E is not a safety management standard. These safety management standards deal with every hazard imaginable, and, in those standards, they consider elimination as the permanent removal of the hazard. This means all hours of every day. 

How do we design, install and maintain an electrical distribution system without a source of voltage? NFPA 70E does not apply to equipment that does not contain an electrical hazard. The concept of complete elimination in safety management standards functions very well in many work environments and associated hazards, but it does not work within the scope of NFPA 70E. 

Confusion arose when a few individuals were writing articles and providing presentations to electrical contractors, engineers and others telling them in no uncertain terms that eliminating electrical hazards is never achievable in an electrical distribution system. That is completely inaccurate. When an ESWC is achieved and maintained, the hazard is eliminated. 

The NFPA 70E technical committee addressed this misconception by adding an IN in the 2021 revision cycle that follows the definition of ESWC. This note says: “An electrically safe work condition is not a procedure, it is a state wherein all hazardous electrical conductors or circuit parts to which a worker might be exposed are maintained in a de-energized state for the purpose of temporarily eliminating electrical hazards for the period of time for which the state is maintained.”

The creation of an ESWC is energized work, and it involves exposure to potential hazards. See 120.2(A) that clarifies electrical conductors and circuit parts are not considered to be in an electrically safe working condition until all of the requirements of Article 120 have been met. This requirement further mandates that safe work practices applicable to the circuit voltage and energy level be used in accordance with Article 130 until such time  both electrical conductors and circuit parts are in an ESWC.

About the Author

Jim Dollard

Code Columnist

Jim Dollard is the safety coordinator for IBEW Local 98 in Philadelphia. He is a member of the NEC Correlating Committee, NEC CMP-10, NEC CMP-13, NFPA 70E, NFPA 90A/B and the UL Electrical Council. He can be reached at codefaqs@gmail.com.

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