Five steps to improve your electrical safety program
OSHA recommends ways to make your electrical safety program better
BY H. LANDIS “LANNY” FLOYD, PE, CSP, CESCP | MAY 13, 2020
Drawing from the U.S. Bureau of Labor Statistics data, Electrical Safety Foundation International (ESFI) has updated occupational electrical injury and fatality statistics to include 2018 performance. The ESFI report shows that the trend in electrical fatalities has been essentially flat for the past 10 years, although the trend in nonfatal lost-time injuries continues downward. In 2018, there were 160 fatalities from exposure to electrical energy, an 18% increase over 2017 and the highest number of fatalities since 2011. There was a record low of nonfatal lost-time electrical injuries in 2018: 1,560, a 29% decrease over 2017.
The phenomena of a flat trend in fatal injuries at the same time as a continuing downward trend in nonfatal injuries is not unique to electrical injuries and fatalities. It is a general characteristic of all hazards in the workplace that have a credible potential to cause long term disabling or fatal injuries. The disconnect between the trends in fatal and nonfatal injuries has had the attention of safety management experts for nearly two decades. While the long-term trend in occupational injuries and fatalities in the U.S. has been downward, other countries have demonstrated progress significantly better than the U.S.
A recent study shows the occupational fatality rate in the U.S. is nearly four times higher than that in the United Kingdom. In response to the flattened trend in occupational fatalities, federal agencies at the forefront in workplace safety have taken steps to enable employers and workers to identify gaps better and improve the effectiveness of workplace safety programs. In 2006, the National Institute for Occupational Safety and Health launched the Prevention through Design (PtD) national initiative to emphasize engineering design opportunities in facilities, equipment, tools and processes to complement safe work practices and personal protective equipment in reducing the risk of injury. More recently, in 2016, OSHA created and continues to add resources to support its efforts in promoting recommended practices for safety and health programs.
Electrical safety program implications
Employers should benchmark their electrical safety programs against the core elements of effective safety management outlined in industry standards such as ANSI Z10 and ISO 45001. Widely considered one of the most prominent standards regarding workplace electrical safety in the United States, NFPA 70E: Standard for Electrical Safety in the Workplace provides safe work practices and other administrative controls aimed at reducing the risk of exposure to hazardous electrical energy. The standard acknowledges that safe work practices and administrative controls comprise a part of an electrical safety program and reference safety management standards as resources to aid employers in addressing the essential elements of an effective electrical safety program not addressed in NFPA 70E.
Effective application of safety management systems standards typically requires having safety professionals competent in the standards. Many small businesses do not have the resources to have this competency in-house, and the task of understanding and implementing safety management systems standards can be overwhelming. To aid small companies and other organizations lacking the resources needed to implement safety management systems standards, OSHA has published guidelines to assist employers in core elements of safety management proven essential for effective and robust safety programs (see Figure 1). These core elements are interrelated and are best viewed as part of an integrated system.
Actions taken under one core element will likely affect actions needed under one or more other elements. A library of resources, summarized in Figure 2, was developed specially for use by small organizations. For electrical safety, this means any organization can now have easy access to resources to address the gaps in an electrical safety program not included in NFPA 70E. One of the resources is the OSHA Crosswalk of Voluntary Standards and Guidelines, which shows how the core elements in OSHA Recommended Practices for Safety and Health Programs are aligned with safety management systems standards and leading organizations in occupational safety. Figure 3 shows only a portion of the Crosswalk, showing how the core element Management Leadership is aligned with voluntary standards and guidelines.
Five key steps to improve your electrical safety program, based on the OSHA recommendations, are discussed in this article.
1. Enable management leadership. Management provides the leadership, vision and resources needed to implement an effective electrical safety program. Top management should demonstrate its commitment to continuous improvement in electrical safety, communicate that commitment to workers and set program expectations and responsibilities. Managers at all levels should make electrical safety a core organizational value, establish safety and health goals and objectives, provide adequate resources and support for the program and set a good example by demonstrating a commitment to eliminating hazards, reducing risks, protecting workers and continuously improving workplace electrical safety.
Some examples of visible leadership include establishing a written policy describing the organization’s commitment to electrical safety, communicate the policy to all workers and stakeholders, including contractors, suppliers, visitors, providing the resources needed to implement the electrical safety and program, integrating electrical safety into planning and budgeting processes and aligning budgets with program needs.
2. Empower worker participation. Workers should be involved in all aspects of the program — including setting goals, identifying and reporting hazards, investigating incidents and tracking progress. By encouraging workers to participate in the program, management signals that it values their input into electrical safety decisions. Workers are often best positioned to identify electrical safety concerns and program shortcomings, such as emerging workplace hazards, unsafe conditions, close calls/near misses and actual incidents. By encouraging reporting and following up promptly on all reports, employers can address issues before someone gets hurt. Including worker input at every step of program design and implementation improves the ability to identify the presence and causes of workplace hazards, creates a sense of program ownership among workers, enhances their understanding of how the program works and helps sustain the program over time. Opportunities to engage workers span all aspects of the program, including setting goals, identifying and reporting hazards, identifying safe work practices, developing safety procedures, participating in incident investigations, training electrical and non-electrical workers, leading safety audits and program evaluation. Workers must feel that their input is welcome, and their voices will be heard. Differences in language, education or skill levels in the workplace must be considered.
We live in an electrical world, and all workers have some exposure to electrical hazards. For office workers, exposure may be limited to appliances, cords, outlets and power strips. For construction laborers, exposure includes extension cords, power tools and overhead and underground powerlines. Overhead lines are a concern as unintentional contact with mobile equipment, scaffolds, ladders and conducive materials is a leading cause of fatality for construction workers. A key question to ask: Is our electrical safety program applied to workers whose job expectations include working on or near energized circuits and equipment, or is it applied to all workers who may have exposure to electrical hazards? The electrical safety program should include all workers, with details of the program tailored to hazards and risk in specific work environments.
3. Build competency. A common root cause of workplace electrical injuries is the failure to identify or recognize hazards that are present, or that could have been anticipated. Unrecognized hazards or underestimation of risk can lead to unintentional acceptance of risk. A critical element of any effective electrical safety program is a proactive, ongoing process to identify and assess such hazards. Hazards can be introduced over time as work areas, and processes change, equipment or tools are damaged, cords become worn, maintenance is neglected or housekeeping practices decline. Setting aside time to inspect the workplace for electrical hazards regularly can help identify shortcomings so that they can be addressed before an incident occurs. For each hazard exposure identified, you should determine the severity and likelihood of incidents that could result and use this information to prioritize corrective actions. Some hazards, such as damaged cords or missing covers, should be fixed as they are found. Fixing hazards on the spot emphasizes the importance of electrical safety and takes advantage of a safety leadership opportunity.
You should include all areas and activities in these inspections, such as storage and warehousing, facility and equipment maintenance, purchasing and office functions and the activities of onsite contractors, subcontractors, temporary employees and visitors. Checklists that highlight things to look for are helpful. Checklists can be developed for major categories such as work environment, equipment operation, equipment maintenance, work practices and work organization.
Workplace electrical incidents, including injuries, close calls/near misses, and equipment failures can provide a clear indication of where hazards exist. By thoroughly investigating incidents and reports, hazards that are likely to cause future harm are identified. The purpose of an investigation must always be to identify the root and contributing causes to identify every opportunity to prevent future occurrences. Having a plan and procedure for conducting incident investigations can enable investigations to begin immediately when an incident occurs. The investigation plan should cover who should be involved, what skills need to available, and what training members of the investigation team need.
Where hazards are identified, controls should be selected according to a hierarchy that uses engineering solutions first, followed by safe work practices and other administrative controls and finally, personal protective equipment (PPE). Employers should select the controls that are the most feasible, effective, and permanent. New technologies may have the potential to be more protective, more reliable or less costly. Whenever possible, select equipment, machinery and materials that are inherently safer based on PtD principles. Apply PtD when making your facility, equipment or product design decisions. For more information, see the link to the NIOSH PtD initiative.
It is crucial to ensure that selected controls are implemented, interim protection is provided, progress is tracked and the effectiveness of controls is verified. Evaluate control measures to determine if they are effective or need to be modified. Involve workers in the evaluation of the controls. If controls are not adequate, identify, select and implement further control measures that provide adequate protection. For example, after establishing an electrically safe work condition, hazardous energy may still exist at the boundary of the safe working zone, such as on the line side of isolation devices, in adjacent compartments of motor control centers or switchgear, behind shutters in drawout circuit breaker cells and behind doors and covers that could be opened. Risk control planning should take into consideration how miscommunications, distractions or misunderstandings could lead to failure of the implemented controls to prevent exposure or injury. By asking, “How could this control fail?” additional engineering or administrative controls may be warranted to control the remaining risk. It is usually the case that no single method fully protects workers, requiring a combination of controls or multiple layers of protection is almost always appropriate.
4. Assess education and training needs. Education and training are essential tools for informing workers and managers about electrical hazards and controls, and for understanding the electrical safety program so that everyone can contribute to its development and implementation. Managers, supervisors and workers need to understand the program’s structure, plans and procedures. Having this knowledge ensures that everyone can fully participate in developing, implementing and improving the program.
Additional training may be needed depending on the roles assigned in the program. For example, employers, managers and supervisors may need specific training to ensure they can fulfill their roles in providing leadership, direction and resources for the electrical safety program. Workers assigned specific roles in the program (e.g., incident investigation team members) may need the training to ensure their full participation in those functions. Employers, managers and supervisors are responsible for workers’ safety, yet sometimes have little training on safety-related concepts and techniques such as risk assessment, the hierarchy of controls and PtD. They might benefit from specific training on these, and other topics will allow them to fulfill their leadership roles in the program better.
Worker training should be tailored to the specific hazards and risks associated with their job responsibilities. Office workers with exposure to cord-powered office equipment should have training appropriate for this risk. Workers using mobile equipment or handling long conductive materials need training on identifying and avoiding overhead powerlines. Electricians whose job expectations include working near energized equipment and components need hazard identification and risk control training specific for their exposure to hazardous energy.
Additional training may be needed when a change in facilities, equipment, processes, materials or work organization could increase hazards, and whenever a worker is assigned a new task. A formal process may be needed for determining the training needs of workers responsible for developing, implementing and maintaining the program.
Promoting awareness of home electrical safety is a way to engage everyone in the organization in thinking about electrical safety. Management, supervision and workers can apply home electrical safety tips in their personal lives. Topics can include ground fault circuit interrupters (GFCIs) and arc fault circuit interrupters (AFCIs), extension cords, electrically powered tools and appliances and overhead and underground utility powerlines. Home electrical safety education can provide a sound base for understanding and value for the electrical safety program at work. Electrical Safety Foundation International has an extensive library of home electrical safety awareness materials that can be downloaded at no cost.
5. Think continual improvement. Once an electrical safety program is established, it should be evaluated initially to verify it is being implemented as intended. After that, employers should periodically, and at least annually, step back and assess what is working and what is not, and whether the program is on track to achieve its goals. Whenever these assessments identify opportunities to improve the program, employers, managers and supervisors — in coordination with workers — should make adjustments and monitor how well the program performs as a result. Sharing the results of monitoring and evaluation within the workplace, and celebrating successes, will help drive further improvement.
The first step in monitoring is to define indicators that will help track performance and progress. Both lagging and leading indicators should be used. Lagging indicators track worker exposures and injuries that have already occurred. Leading indicators track how well various aspects of the program have been implemented and reflect steps taken to prevent incidents and injuries before they occur.
Electrical injuries comprise less than 0.2%, or less than 1 in 500, of all nonfatal occupational injuries. The relative infrequency of electrical injuries can create an illusion of having an effective electrical safety program. A rare serious electrical injury or fatality may be incorrectly viewed as a random event. Incidents and injuries that are low in frequency also can mean that a company or organization does not have enough internal data to be statistically meaningful. Due to the inherent low-frequency occurrence of electrical injuries, an individual or company may not recognize the potential for a fatal (high consequence) injury. The lack of, or a low number of, electrical injuries is not a valid indicator of the quality of the electrical safety program. Factors that may be better indicators of electrical safety program quality are leading indicators such as:
- Frequency and quality of electrical safety training for electrical workers, nonelectrical workers, line supervision, management and support personnel such as safety professionals, contractor administrators and training staff
- Frequency of field audits that examine the implementation of the organization’s electrical safety program
- Quality and frequency of management system audits focused on preventing exposure to electrical hazards
- Attention to inherently safer design in hardware selection and electrical system design in capital projects
- Discipline in maintaining maintenance programs for equipment and systems critical to electrical safety.
Initially and at least annually, management should evaluate the program to ensure it is operating as intended, is effective in controlling identified hazards and is making progress toward established electrical safety goals and objectives. The scope and frequency of program evaluations will vary depending on changes in your organization, OSHA regulations, industry standards and the scope, complexity and maturity of your electrical safety program. The evaluation should take into consideration whether changes in equipment, facilities, materials, key personnel or work practices trigger the need for changes in the program.
One size does not fit all
OSHA Recommended Practices for Safety and Health Programs should be tailored to the electrical safety program for your workplace. The core elements for successful safety management are common across all hazards and the recommended practices and supporting resources can be applied to any safety and health hazard in the workplace. By inserting “electrical safety program” wherever “safety and health program” appears in the tools and resources, you will see opportunities to improve visibility, support, engagement and robustness of your electrical safety program. Experimentation, evaluation and program modification are part of the process. You also may experience setbacks from time to time. What is important is you learn from setbacks, remain committed to finding out what works best for you and continue to seek leading edge methods.
Electrical injuries occur in all types of workplace settings, from manufacturing sites to hospitals and health care facilities, to offices, to construction and to service industries. The preventive approaches described in the OSHA recommended practices work equally well across all sectors of the economy, for all different kinds of hazards, in both mobile and fixed work environments; and for small, medium-sized and large organizations. Small employers may find that they can best accomplish the actions outlined in these recommended practices using informal communications and procedures. Larger employers, who have more complex work processes, may require a more formal and detailed program. They also may wish to integrate their electrical safety program with other programs they are using to manage assets, production, quality control and environmental protection or sustainability.
You can use the self-evaluation tools found on the OSHA Recommended Practices for Safety and Health Programs website to track your progress and assess how fully you have implemented each action item. Figure 4 is an example of one of the continual improvement tools available on the OSHA Recommended Practices website.
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