Electrical Safety: Safety Management and Organizational Structure (part 1)

INTRODUCTION

An electrical safety program is effective only if management makes a strong commitment to support it. This section develops some of the key management concepts and procedures that must be present for a safety program to work. Of course, electrical safety is only part of an overall safety program; consequently, much of the material in this section is applicable to the entire safety effort.

The procedures introduced in this section should be applicable to all types of electrical installations. However, the effectiveness of any specific program must be determined by ongoing evaluations.

Safety organizations should be responsible to the very highest management levels and generally should not report to operations. Safety-related decisions should not be made by personnel with direct, bottom-line responsibility.

Additionally, the decisions made by legal counsel should be closely evaluated in terms of their effect on personnel safety. Many well-meaning attorneys and/or senior-level man agers are required to make decisions that will maximize shareholder returns and/or limit corporate liabilities. Such decisions are, unfortunately, not always consistent with long term worker safety.

Problems also may be introduced by labor organizations in their attempt to secure the best overall package for their members. Care should be exercised to avoid using safety as a "bargaining chip." This caution applies to labor and management.

CHANGING THE SAFETY CULTURE

One of the biggest roadblocks to improved electrical safety is culture. Worker behavior is often controlled by the local culture in terms of attitudes, procedures, and the use of safety equipment. Since most of us rely on anecdotal experiences in our lives, we often make inaccurate assumptions and do things that put us in harm's way.

Electrical safety regulatory and standards groups have tried especially hard over the past 20 years to change wrong-headed thinking and inaccurate and dangerous assumptions such as the following:

• It's only 120 volts. It can't hurt you.

• These leather gloves provide me with plenty of insulation to work on the 240-volt circuit.

• I'll just ground this by wrapping this chain around the 480-volt bus. (This practice was once so common that even in the 21st century safety grounds are often referred to as grounding chains.)

• As long as I keep one hand in my pocket, I can't get shocked.

• I won't ever be exposed to an electrical blast-I keep the doors to the switchgear firmly latched.

Although there is still a long way to go and a lot of work to do, we have made great strides in changing the electrical safety culture. The following paragraphs explain.

An article titled "Occupational electrical injury and Fatality Trends and Statistics: 1992-2007," written by Brent C. Brenner in May 2009 and published in the IAEI (international Association of electrical inspectors) Magazine, stated that since the creation of the U.S. Department of Labor Occupational Safety and Health Administration (OSHA), overall work place fatalities have been cut by more than 60 percent and occupational injury and illness rates have declined by 40 percent. This decline occurred during an era of growth in which the total number of workers more than doubled. By focusing on the industry wide trends in electrically related fatalities and injuries, we can confirm that efforts to create a "culture of safety" are, in fact, beginning to have an impact. The numbers studied demonstrated substantially fewer deaths and injuries in 2007 than were experienced 15 years earlier in 1992.

In 1994, there were 348 electrically related fatalities and 6018 injuries. In contrast, in 2007, there were a total of 212 electrically related fatalities and 2540 injuries reported. It is important to note, however, even with the overall decline, fatality rates in certain industries remained static or had risen over the five years between 2003 and 2007. The electrical Safety Foundation international (ESFI) has found that worker contact with electric current in some shape or form was responsible for 1213 fatal workplace accidents during this period and 13,150 workers were so severely injured from electrical contacts that their injuries required time off from work.

Brenner stated in his article that contact with overhead conductors accounted for 43 percent of all occupational electrical fatalities between 2003 and 2007, and the second leading category of electrical fatalities involved workers coming in contact with wiring, transformers, or other electrical components. This is the type of accident that occurs more often to employees whose jobs routinely involve working with electrical components such as an electrician or contractor. This category accounted for 28 percent of electrical fatalities and 37 percent of nonfatal electrical accidents. The third leading category of electrical fatalities involved workers coming in contact with electric current from machines, tools, appliances, or light fixtures. This type of accident occurs more often to workers whose job duties include mechanical and electrical maintenance. Accidental electrocution due to con tact with tools and apparatus whose grounding conductors were faulty or missing is included in this category. These accidents accounted for 18 percent of all electrical fatalities and 35 percent of nonfatal electrical accidents.

Historically, the construction industry has had the greatest number of electrical fatalities.

Between 2003 and 2007, the construction industry, with a workforce numbering 9.5 million workers in 2007, accounted for 52 percent of the occupational electrical fatalities. Electricians sustained 47 percent of the electrical fatalities in construction followed by laborers at 23 percent. Painters, roofers, and carpenters suffered 6 percent in each occupation. During the study period from 2003 to 2007, the electrical burn rate per 100,000 workers in the construction industry hovered between 0.5 and 1.0. Construction was one of only two industries, along with the utility industry, in which the number of nonfatal electrical burn injuries exceeded the number of electrical shock injuries. There were 2390 electrical burn injuries in construction and 1710 electrical shock injuries.

These statistics demonstrate that we have made progress, but there is still a lot of room for improvement. The only way to improve these grim statistics is by creating a change in the electrical safety culture. This can only happen by changing the way employees think about their personal safety. Personal safety is exactly what the term implies: the workers exposed to electrical hazards must take personal responsibility for their own health and welfare. No matter how many rules are in place, how much personal protective equipment is supplied, or how much information is available for an individual worker's use, individual workers are the only ones in a position to make good judgments that will keep them safe.

Common sense coupled with a thorough understanding of basic fundamentals of electricity, safety rules, federal and state regulations, safety practices, and up-to-date procedures will increase the worker's level of safety awareness.

Working together, owners, managers, and electrical workers can create an environment in each individual workplace that will incubate and nurture positive changes in the electrical safety culture.

ELECTRICAL SAFETY PROGRAM STRUCTURE

FIG. 1 is a suggested design for the overall structure of a company electrical safety program. Of course, such a structure must be integrated into the overall safety program; however, the unique needs of the electrical safety program should be included in the design in a manner similar to the one shown.

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FIG. 1 The electrical safety program structure.

Health & Safety Department

The Company Electrical Safety Team Management Legal Company Safety Policy Company Safety Procedures Accidents/Near Misses Development/Evaluation Needs Assessment

Safety Audits

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Each of the various elements of the design is described in the following sections.

ELECTRICAL SAFETY PROGRAM DEVELOPMENT

An electrical safety program is composed of a variety of procedures, techniques, rules, and methods. Each of these individual items must be developed independently; the sum of them then adds up to the overall safety program. The development of an entire program becomes the accumulation of all the individual procedures.

This does not mean that the development of a safety program is a hodgepodge effort. On the contrary, the whole procedure should be viewed as an engineering design problem. The program should be put together by a corporate electrical safety team composed of management, safety, and technical personnel.

Some companies take regulatory and consensus standards such as the OSHA electrical Safety-related Work Practices rule and the NFPA 70e and apply them almost verbatim for their safety policies, procedures, and/or rules. This is a very poor practice. Even the NFPA 70e standard should be looked at only as a set of minimum requirements. In addition to regulatory requirements, company policies and procedures must include specific local requirements and must be developed in a way that is consistent with the facility culture.

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Table 1 recommended electrical Safety Team Members

[ electrical workers

Health and safety professionals

Management

Legal representation

]

[ An electrical worker should serve as the chairperson of the team. In addition to the chairperson, sufficient members should be included from the workforce to ensure that the workers have a significant say in their overall safety program. Working supervisors should be eligible for these positions; however, supervision should never dominate the team.

At least one health and safety professional should be included on the team to advise and assist in the areas in which his or her expertise applies.

A member of management should be present as an adviser. This person can direct the team with respect to company policies to avoid the team conflicting with company directives. The management representative should be as high a level as possible. The management representative should always be willing to consider modification of conflicting company policies in the interest of improved safety.

Company counsel should be represented on the team; however, they should be there strictly in an advisory capacity.

]

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Company Electrical Safety Team

Introduction. One of the best overall safety concepts of the last part of the 20th century was that of the worker team. Nowhere is the team of more use than in the safety arena. The following paragraphs describe the concept of the electrical safety team and provide enough information to serve as a template for the setup of such a body.

Note that the company health and safety department (HSD) has the ultimate responsibility for the safety program. The HSD should work closely with the team and review all procedures and policies developed by the electrical safety team. As described in the following, the HSD should have a representative on the team.

Structure. Generally, the safety team should include the following representatives/ members:

Responsibilities. The company electrical safety team (CEST) should have the following responsibilities and authorities:

• The CeST should have overall responsibility for the development, implementation, evaluation, and modification of the company electrical safety procedures. Either directly or through delegation, the CeST should develop the entire program, working closely with the health and safety professionals.

• The degree of authority vested in the CeST must be a matter of individual company policy. Generally, the CeST should have the maximum authority allowable under existing company structure.

• if the company has multiple locations, the CeST should appoint or sponsor elections for employee electrical safety teams (eeSTs) at each site. The local teams will participate in local accident reviews, evaluate procedures and determine the best way to apply them locally, counsel employees, and implement and plan safety meetings.

• The CeST should have representation at the management level for the purpose of participating in the development of the company safety policy.

Employee Electrical Safety Teams. Employee electrical safety teams should be put in place to perform the actual fieldwork and legwork required by the CeST. The EEST will participate in accident investigation, program development, and any other activities deemed necessary. Some companies appoint permanent employee electrical safety teams as part of their ongoing corporate structure.

Company Safety Policy

All safety programs should be underwritten by a company and/or departmental safety policy. Although specific policy statements must vary from industry to industry, all policies should contain the following key statements:

1. The company is committed to safe work practices.

2. At a minimum, all company safety policies and procedures shall comply with applicable federal, state, and local standards as well as recognized consensus standards.

3. Safety is the premier consideration in performing work.

4. Employees will be required to follow all company safety procedures.

5. If a job cannot be safely done, it need not be done.

6. Each individual employee is uniquely responsible for his or her own personal safety.

7. The cooperation of all personnel will be required to sustain the safety program.

Assessing the Need

The development or revision of an electrical safety program should begin with an evaluation of any existing programs. This initial survey should closely examine and catalog the number and types of electrical accidents. Investigators should also be creative in their analysis. That is, they should identify potential hazards as well as demonstrated ones. One of the most effective ways to catalog safety hazards is to perform a safety audit. Safety audits are discussed later in this section.

Problems and Solutions

Based on the results of the needs assessment, accidents and potential problem areas should be cataloged into cause categories. The specific categories selected should be chosen to fit the industry. Good starting points are the seven categories used by the Occupational Safety and Health Administration in the development of the Safety-related Work Practices rule.

These categories, illustrated in Table 2, can be used for most electrical accidents. The specific installation should develop additional categories or subcategories as required so that very few accidents fall into category 7.

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Table 2 Categories to Classify Accidents or Potential Accidents

1. Use of equipment or material too close to exposed energized lines

a. Vehicles (e.g., cranes and dump trucks)

b. Other mechanical equipment (e.g., augers and derricks)

c. Tools and materials (e.g., ladders and tree limbs)

2. Failure to use electrical protective equipment

3. Assuming an unsafe position

4. Failure to de-energize (and lockout-tagout) equipment

5. Use of visibly defective electric equipment

6. Blind reaching, drilling, digging, etc.

7. No unsafe work practice or not enough information to classify

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TABLE 3 Example of Fuse Removal Safety Procedure Development

[ Need assessment

Problem(s)

Solutions

Implementation

]

[

In the past five years, 15 employees have been shocked while removing and/or replacing low-voltage cartridge fuses. Five of the injuries were extremely serious. No deaths have occurred.

Review of the problems indicates that employees must, from time to time, work on such circuits when they are energized. Further investigation shows that employees are using channel lock type pliers to remove the fuses.

Employees are not using rubber insulating gloves during such "hot" work.

To resolve this problem, employees will be supplied with insulated tools that are specifically designed for the removal and replacement of fuses.

Employees are already supplied with rubber insulating gloves.

A procedure is added to the employee safety procedures manual, which specifies the following:

When removing or replacing fuses, the bus that feeds them shall first be de-energized unless doing so introduces additional hazard or unless de-energizing requires a major plant outage.* Removing energized fuses is classified as hot work. Only qualified, trained personnel shall be allowed to remove and replace energized fuses.

Low-voltage, cartridge type fuses shall be removed using only approved, insulated fuse pullers.

Employees shall wear at least the minimum required safety equipment when removing or replacing energized low-voltage, cartridge type fuses.

Minimum personnel protective equipment required to remove and replace energized low-voltage, cartridge safety type fuses shall include hard hat, safety glasses or goggles, long pants and long-sleeve shirt, leather safety shoes with rubber soles, and rubber electrical insulating gloves with leather protectors approved for the voltage level being worked on.

The new procedure should be introduced at an employee safety training meeting. The new procedure must be demonstrated and employees must demonstrate competency to a management representative before being considered qualified to perform this energized work procedure.

]

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TABLE 4 Example of Flash Suit Safety Procedure Development

[ Need assessment

Problem(s)

Solutions

Implementation

]

[

Companies of similar size and business, with comparably sized and arranged electrical systems, have had problems with severe flash injuries. These same companies have implemented flash suit use during certain phases of their operations and have exhibited a marked decrease in the number of injuries.

Employees must, from time to time, perform open-door circuit breaker switching, remove motor starters from cubicles, and operate open-air disconnect switches. This exposes them to more than a normal electrical arc hazard.

To resolve this problem, the company will supply and require the use of flame-retardant flash suits.

A procedure is added to the employee safety procedures manual that specifies that employees shall be required to wear flame-retardant flash suits when performing open-door switching, motor starter removal or installation, or open-air switch operation. This requirement applies to all medium-voltage circuits and all low-voltage circuits with ampacities in excess of 100 A. This requirement is in addition to other safety equipment including hard hat, eye protection, and rubber insulating gloves with leather protectors.

The new procedure should be introduced at an employee safety training meeting. This new procedure must be demonstrated and employees must demonstrate competency to a management representative before being considered qualified to perform this energized work procedure.

]

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Table 5 example of recognition of exposed Live Parts Procedure Development

[need assessment

Problem(s)

Solutions implementation

]

[

An employee was working in a 480-V cabinet. His supervisor had previously told him that the cabinet was de-energized. The employee had looked at the cabinet and had measured the obvious energized locations.

They were dead.

There were exposed fasteners in the front of the cabinet that were not de-energized. They were not obvious and the employee missed them. The employee believed his supervisor and did not inspect the cabinet closely enough. The employee did not perform a thorough prework inspection to check for energized parts. He made several assumptions.

Employees must be retrained to closely inspect for exposed energized parts.

At a safety meeting, the entire incident was discussed and the problem brought to the forefront. All employees were reminded to inspect and check for energized parts no matter how certain they are that the system is safe.

A training program was implemented in which the various specific pieces of equipment are identified and employees learn where all of the possible exposed parts are located. A formal procedure was added to require that employees carefully inspect equipment before they work on it.

]

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Table 6 example of Voltage Measurement Procedure Development

[

Need assessment

Problem(s)

Solutions implementation

]

[

In addition to the problem discussed in the previous example ( Table 5), other employees have been observed performing voltage measurements incorrectly.

OSHA and other regulations require that voltage measurements must be made prior to working on a piece of de-energized equipment. All qualified electrical workers must be thoroughly trained in the proper and safe methods of voltage measurement.

Employees are to be retrained in the proper methods of voltage measurement.

The correct methods of voltage measurement were discussed and reinforced in employee safety meetings. Specific, hands-on training programs were implemented and all employees were tested to make certain that they were thoroughly familiar with the procedures.

Additionally, the methods of selecting and inspecting measuring instruments were reinforced.

]

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Identification of the safety problems will inevitably lead to solution concepts. These solutions should take the form of specific plans and programs that can be incorporated in the new or existing electrical safety program.

Program Implementation

After the analysis phase, the solutions can be integrated into the facility's safety pro gram. The method used here will depend upon the facility; however, a reasonable starting point would be the development of an energy control program similar to that described in Section 4.

Examples

The following examples (Tables 3 through 6) illustrate the steps just outlined. These examples are drawn from actual industry experiences and illustrate the specific kinds of problems that workers may face every day.

Electric Shock While Replacing Low-Voltage Fuses. Assume that your electrical safety audit has identified several instances in which employees were shocked during the removal and/or installation of 120-V fuses. Table 3 shows the problem, solution, and implementation required to provide a safer work environment.

Protection for Arc injury during Switching Operations. Not all safety procedures are developed based on local facility experience. In this example, we assume that the local safety personnel have reviewed other industrial safety programs with respect to flash protection. They have discovered that other companies have experienced severe injuries during routine switching and racking operations. Furthermore, they discover that other companies have implemented successful programs that involve the use of flash suits. The number of flash-related injuries has dropped at these other companies. Table 4 was developed based on this analysis.

Recognizing Exposed Energized Parts. Unfortunately, many procedures are developed and modified based on an accident or injury. The example shown in Table 5 is one such instance. In this example, the employee was qualified and trained; he simply made a mistake.

Despite this, a significant amount of effort must go into the continuous retraining of personnel.

Voltage Measurement. OSHA states that one of the basic requirements for workers to be considered electrically qualified is that they shall possess the ability to discern what is energized and/or de-energized. This requirement means electrical workers must be able to examine the construction of the electrical system and determine the maximum voltage that could be present by looking at the construction, insulation, and conductor spacing. Once this is determined, workers can then know what type and class of measuring device they must use to measure for voltage. OSHA mandates that all voltage measurements be a three-step process-test the tester to make sure it is operable, measure the circuit or equipment being verified as de-energized, and retest the tester to make sure the instrument is still operable and a valid measurement has been obtained. On three-phase systems, measuring the equipment being verified requires three phase-to-ground measurements and three phase-to-phase measurements. Table 6 is an example of voltage measurement procedure development.

Company Safety Procedures

The actual development and structure of company electrical safety procedures are specific to each company. The methods and formats described in Chaps. 3 and 4 of this handbook should be referred to as a basis.

Also, the OSHA procedures have suggestions and formats for such plans.

Results Assessment

Few, if any, procedures will endure forever without modification. Personnel replacements, equipment changes, enhanced operating experience, and new safety innovations will require that any safety program be periodically reviewed and updated. The following criteria should be used to evaluate the need to revise an existing safety procedure:

1. Accidents and near misses

2. employee suggestions

3. employee electrical safety committee recommendations (see next section)

4. Changes in regulatory or consensus standards

cont. to part 2 >>