inside this dition electrical safetypdf.1105media.com/ohs/2016/ohs_1611edition.pdfeditors can be...

A Common Task Non-Electricians Do Covered by NFPA 70E: The Safest Way to Operate a Circuit Breaker, Disconnect, or Switch

You Saved My Life!

Arc-Rated, Flame-Resistant Clothing Care Electrical Safety

DITIONNOVEMBER 2016

INSIDE THIS DITION

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2 Occupational Health & Safety | NOVEMBER 2016 | www.ohsonline.com

R eading this, you are looking at the first digital special issue that Occupational

Health & Safety magazine has produced. This eDITION, as we’ve called this project inter-

nally, is our attempt to bring you a highly useful and timely one-topic product that you can use right away, share with your co-workers and other colleagues, and save in order to consult it for fu-ture reference.

We chose Electrical Safety as the focus of this special issue #1 and asked a blue-chip expert on this subject, e-Hazard’s Hugh Hoagland, to de-velop the articles to fill it. He and two of the com-pany’s partners, Bill Shinn and Al Havens, wrote most of them, and we’re indebted to all three of them for their time and effort that have allowed this project to turn out beautifully. Kudos also to Art Director Dale Chinn of 1105 Media Inc. for his design and production work to complete this special issue. Tyndale Company, Inc.’s Scott Mar-golin provided another excellent article.

The articles in this special issue offer a “soup to nuts” look at AR and flame-resistant clothing. The e-Hazard team and Margolin bring us up to date on care and maintenance of AR/FR fabrics, equipment labeling, employee training, barri-cades for marking shock and arc flash boundar-ies, electrical equipment testing, and the value of auditing for boosting workers’ safety compliance.

Two of OSHA’s Top Ten most-cited standards in fiscal year 2015 were electrical standards: 1910.305 Electrical, Wiring Methods and 1910.303 Electrical, General Requirements. And when the Bureau of Labor Statistics released its prelimi-nary data in September 2015 from the National Census of Fatal Occupational Injuries, it showed exposure to electricity was responsible for 9

percent of all fatal injuries involving contracted workers in 2014, and that the number of fatally injured electricians in 2014 increased by 14 cases to a total of 78. More than half of the contracted workers who died in 2014 were working in either construction or extraction industries when they

were fatally injured, BLS reported.Both the citation frequency and the fatality

data illustrate the necessity of having workers follow the recommendations and guidance you’ll find in these articles. Such as this advice taken from Hugh Hoagland’s article “Com-bine Training and Auditing for Great Results” (page 6):

1. Inspect/evaluate the electrical equipment for code compliance.

2. Maintain the electrical equipment’s insu-lation, enclosure integrity, and operational reli-ability: especially breakers and fuses.

3. Plan every job and document first-time procedures.

4. De-energize whenever possible.5. Anticipate unexpected events.6. Identify and minimize the hazard.7. Protect the worker from shock, arc, and

other hazards.8. Use the right tools and PPE for the job.9. Assess, audit, and document workers’ skills.10. Audit the principles of the applicable

standards.He urges safety managers to measure behav-

iors such as:1. De-energizing, lockout/tagout 2. Wearing of rubber insulating gloves3. Verification of meter and absence of voltage4. Wearing of basic arc-rated daily wear and

face protection5. Wearing flash suits for higher-level expo-

sures6. Use of insulated tools7. Testing of rubber insulating gloves, blan-

kets, and other insulated equipment

JERRY LAWS, EDITOROccupational Health & [email protected]

A Soup to Nuts Look at AR and FR Clothing

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REACHING THE STAFFEditors can be reached via e-mail, fax, telephone, or mail. A list of editors and contact information is at www.ohsonline.com.

Email: To e-mail any member of the staff please use the following form: [email protected].

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Both the citation frequency and the fatality data illustrate the necessity of having workers follow recommen-dations and guidance you’ll find in these articles.

FROM THE EDITOR DITION

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TABLE OF CONTENTS DITION

featuresFABRIC CARE

4 Arc-Rated, Flame-Resistant Clothing CareThe most critical thing for properly cleaning FR clothing is to follow the laundry instructions on the garment. Those instructions are the most important because the material manufacturer has the most experience with the fabrics. by Hugh Hoagland

AUDITING

8 Combine Training and Auditing for Great ResultsAuditing the right behaviors and thought processes can improve electrical safety compliance by 40 percent. by Hugh Hoagland

EQUIPMENT LABELING

10 Categories or Calories: How to Assess the Arc Flash Hazard ClearlyIf equipment has labels on it, that means an analysis was done and a person cannot use the tables. Simply stated, LABELS RULE! by Al Havens and Hugh Hoagland

TRAINING

12 Arc Flash Training: No Energized Electrical Permit Required in NFPA 70E for Common Safety TasksThe purpose of NFPA 70E permits is to prevent workers from doing energized work or management from requiring ener-gized work that is not necessary and justified. The energized work that doesn’t require a permit typically must be done energized, and the standard accepts this reality. by Bill Shinn and Hugh Hoagland

PROTECTION

14 Barricades in Shock and Arc Flash Boundaries vs. GuardingFor this article, we confirmed that you can no longer easily buy red barricade tape that has the “Keep Out” printed on it unless special ordered at about $45 per roll. The standard “Danger High Voltage” red barricade tape costs about $10 a roll. by Bill Shinn and Hugh Hoagland

PPE SELECTION

16 The Power of Choice in FR Clothing ProgramsHow to change your PPE culture. by Scott Margolin

EQUIPMENT TESTING

18 You Saved My Life!An old school practice saves a life. by Bill Shinn

WORKER SAFETY

20 A Common Task Non-Electricians Do Covered by NFPA 70E: The Safest Way to Operate a Circuit Breaker, Disconnect, or SwitchThe standard does not lay out specific procedures, but these are recommended by best practice and our accident investigation history. by Al Havens

departments2 From the Editor5, 7 Company Profiles22 Sponsors23 New Products

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TYNDALE COMPANY, INC.

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FABRIC CARE DITION

E lectrical workers work in some of the most challenging work conditions. From an electrician in Fort McMurray working in a tar sands plant to a lineman climbing poles on a Colorado mountain range, arc-rated flame resistant

clothing must be more than protective.In the past, electrical workers used cotton as the clothing of

choice. It was believed that even non-FR cotton would have less risk of increasing injury because it didn’t “melt into the skin.” This non-melting characteristic of cotton has been shown to have little or no value if cotton ignites. But the good news is that arc-rated clothing fabrics are coming on the scene faster than ever.

Flame-resistant and arc-rated garments began proliferating af-ter 1994, when electric utilities started using them to comply with OSHA 1910.269. In 1994, aramid products like Nomex, Kermel, and PBI/Kevlar were leaders, flame-resistant cotton materials like Indura were second, and modacrylic/cotton blends like FireWear were third. These materials require some specific care, but new materials have entered the competition that offer more wear life for less investment and better breathing and moisture manage-ment. Other materials that were dangerous if washed improperly are much less common and easier to weed out using the proper standards.

Twenty-two years ago, there were fewer than five fabric types that could have received arc ratings with today’s standards and in-adequate standards to determine the best ones. Last month, more than 30 fabrics were tested from more than 15 types of fabrics, from common work fabrics to chemical-resistant lab coat fabrics, full chemical suits, disposable materials, and even cleanroom and nuclear radiation protective fabrics.

Cleaning each requires getting the manufacturer’s care instruc-tions, and this will be somewhat different for each material.

The NFPA (National Fire Protection Association) Standard 70E-2015, Electrical Safety in the Workplace, recognizes electri-cal tasks as a hazard regardless of who is performing the task and requires some level of protective clothing for many tasks. Electri-cians, welders, operators, linemen, and other workers have been killed operating disconnects and performing other electrical tasks, so NFPA 70E requires flame-resistant clothing to provide protec-tion when there is an arc flash hazard greater than 1.2 cal/cm². Arc-rated (AR) meeting ASTM F1506 clothing always prevents ignition and in the vast majority of the cases eliminates fatalities and often all burn injuries.

Proper care of AR garments is an important part of an AR clothing program. For years, end users have successfully used

Arc-Rated, Flame-Resistant Clothing Care The most critical thing for properly cleaning FR clothing is to follow the laundry instructions on the garment. Those instructions are the most important because the material manufacturer has the most experience with the fabrics.BY HUGH HOAGLAND

E-HAZARD.CO

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CORPORATE PROFILE DITION

TOP-QUALITY AR FLAME RESISTANT CLOTHING IN CUSTOMIZED PROGRAMS

Tyndale delivers top-quality arc-rated flame resistant (AR) clothing in custom-ized managed apparel programs. Found-ed in 1981, Tyndale began specializing in AR clothing and became involved in the ASTM committees responsible for writing worker safety standards for arc flash protection early in the company’s history. From there, Tyndale began track-ing employee orders and offering ser-vices in addition to products. Today, as both a manufacturer and distributor, Tyn-dale offers the most comfortable, inno-vative mix of flame resistant garments in the industry. Our own Made in USA line plus relationships with the largest AR manufacturers offer an unprecedented selection, making Tyndale a one-stop shop to keep workers safe, comfortable, and compliant. Learn more at www.Tyn-daleUSA.com and blog.TyndaleUSA.com or call 800-356-3433.

• Direct purchase allowance or allotment programs

• Save as much as 50% compared to a uniform rental program!

• Drive satisfaction and compliance with employee-level garment choice

• Custom catalog with online ordering

• Home laundry care and maintenance resources

• In-house logo customization

• US-based customer service

• Certified woman-owned business (WBE)

• Quick-start options get workers in AR fast!

Tyndale Company, Inc. www.TyndaleUSA.com5050 Applebutter RoadPipersville, PA 18974

Tel: 800-356-3433

Contact Information

Shannon Nash, Sales Administrator

800-356-3433 extension 679

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FABRIC CARE DITION

both home and commercial laundering to clean their AR cloth-ing. The most critical thing for properly cleaning FR clothing is to follow the laundry instructions on the garment. Those instruc-tions are the most important because the material manufacturer has the most experience with the fabrics. Inspection of the gar-ments for proper cleaning by the end user/cleaner is also critical to maintaining garment integrity.

Fabric TypesFlame-Resistant Cotton has long been a staple of basic work clothing, but the FR cotton of yesterday and a few lowest-cost FR cottons of today may actually be dangerous, especially if laundered improperly. Though they may pass a low level vertical flame test, if they do not meet ASTM F1506 or NFPA 2112, they are not guaran-teed for the life of the garment and the FR may wash out in as little as 25 washings or less. These are less common in the U.S. market but do still exist in welding garments. Special care by the end user needs to be used when selecting and using FR cottons. If they meet the standards above, they should last for more than 25 washings, but a lifetime guarantee by a reputable company with a strong track record is critical. Better to choose something with compliance to 100 washings than to be sorry.

Check the garment label for an arc rating (http://www.arcwear.com), which is a good indication they are properly tested—but if you have no “life of garment” statement, you don’t know how long they will last.

FR Cotton/Nylon (commonly called 88/12 blends)—several materials on the market today meet the commonly cited >100 wash test requirement for flame resistance. Many of these blends have twice the wear life for about 20 percent more cost. This is a real savings to the end user in the long run if you choose FR cotton/nylon blends.

Aramid Materials—Nomex, Kermel, Kevlar, Twaron, Conex, PBI, and other aramids are great for flame resistance and arc rat-ings.These materials need little special care; just follow the com-mon recommendations in the Do’s and Don’ts below or the manu-facturer’s instructions for laundering and care.

Do’s and Don’tsDon’t

■ Use fabric softener on FR garments in the washer or fabric softener sheets in the dryer. (They may act as a fuel and weaken the fabric.)

■ Use chlorine bleach on FR garments. (They can destroy fab-ric integrity.) Some also recommend not to use peroxide bleach, either.

■ Wear garments that are grossly contaminated by oils, paints, solvents, or chemicals that leave a combustible residue on the fabric.

■ Apply insect repellents containing DEET to garments. (It can act as a fuel in larger amounts.)

■ Apply any chemicals directly to the FR garment, including spray starch.

Do■ Wash FR clothing separate from the home laundry to avoid

transferring contaminants or transferring non-FR fibers to the FR garment. This form of hydrocarbon loading may decrease protec-tive value of the garment in some cases. (No documented peer-reviewed study is currently available, but one company’s internal anecdotal research is commonly cited as reducing protection by about 3 percent when laundered with non-FR cotton clothing.)

■ Use warm water and a dry type detergent that does not con-tain bleach (liquid detergents may compromise effectiveness and while they should not be harmful, they are not as effective at clean-ing garments as powder type detergents in most cases).

■ Dry the garment on medium or low heat.■ Launder the garments when they become visibly contami-

nated with any grease, oil, hydraulic fluid, petroleum product, paint, or chemical.

■ Follow manufacturer’s washing instructions printed on the garment’s label.

Wool and wool blends are the most common material in the aluminum industry. These materials are secondary protection for potential metal splash or under primary garments and may be used for special applications flame resistance, especially when in the vicinity of molten aluminum or steel. The materials are much more comfortable than the garments of old but require special care. Laundering wool garments often recommends use of soap (unlike most flame-resistant garments) and drying in lower temperatures. See manufacturers’ recommendations.

Additional Guidance for Home LaunderingAdditional resources for home laundry guidance are ASTM F2757-

16, Standard Guide for Home Laundering Care and Maintenance of Flame, Thermal and Arc Resistant Clothing and NFPA 2113, Stan-dard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Short-Du-ration Thermal Exposures.

Many users choose an industrial launderer for convenience, ease of use, and peace of mind, but this isn’t always necessary. Some folks have been concerned that flame-resistant cotton fabrics’ flame resistance would “wash out” over time, but most of the best mate-rials don’t have this problem today. The U.S.-based fabrics have stood the test of time and extensive testing and there are no re-corded home laundry failures of AR garments.

ArcWear recently presented and has had accepted for ASTM publication “An Evaluation of Bleach on the Flame Resistant Prop-erties of a Common Flame Resistant Cotton Blended Fabric” by J. Kirby, S. Klausing, and H. Hoagland. This paper indicates that home laundering does not affect arc rating or flammability ap-preciably over as many as 200 washings as long as the recom-mendations above are followed. This testing was independently performed by our ISO 17025 accredited lab to study the effect of chlorine bleach, peroxide bleach, and fabric softener in soft water. Another study is planned for hard water to complete the picture, but the preliminary results support the basic assumptions of FR cotton manufacturers to limit chlorine bleach for certain.

Arc-rated garments are normally guaranteed for the life of the garment, and home laundering has been shown to be very effective in maintaining the integrity of the garments’ flame re-sistance and arc rating.

Before choosing home over industrial laundry, employers should consider National Institute for Occupational Safety and Health (NIOSH) recommendations on clothing soiled with haz-ardous chemicals at work. Clothing exposed to certain hazardous chemicals should be laundered by the employer or, if washed at home, it is recommended to launder it separately from the family wash.

Some companies choose industrial or on-site laundering to limit liability, and some chemicals are too hazardous to ever take home. The industrial hygiene department makes this determina-tion in most companies. But home laundering is more common than industrial laundering, so proper evaluation of the work site soils is critical, as well as employee training.

Hugh Hoagland is the owner of ArcWear.com and a partner, trainer, and consultant at e-Hazard.com.

Arc-rated garments are normally guaranteed for the life of the garment, and home laundering has been shown to be very effective in maintaining the integrity of the garments’ flame resistance and arc rating.

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www.ArcWear.com

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CORPORATE PROFILE DITION

DUPONT PROTECTION SOLUTIONS

For nearly 50 years, DuPont™ Nomex® fiber has set the global standard for fire protection. It’s been proven time and time again, not only in rigorous lab and field testing, but also in real-world sce-narios where lives are at stake.

Building on that heritage, we’ve en-gineered a breakthrough solution for multi-hazard protection—Nomex® MHP. Designed for electric arc and small mol-ten metal splash protection, Nomex® MHP also provides optimal moisture management for enhanced comfort. We’ve subjected Nomex® MHP to rigor-ous testing to ensure that it delivers what wearers want: comfort, durability and cost-effectiveness.

Nomex® MHP is rated for international standards, including NFPA 2112, NFPA 70E and EN ISO 11611. Protection, comfort and strength from a name you know and trust—that’s Nomex® MHP.

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AUDITING DITION

The Problem: Learning or Doing?I walked into the room to do electrical safety training like I have done thousands of times before and looked around the room. It was a Saturday; I was in my hometown. (We do training all over the world, but when I train at home, I can’t help but wonder if these guys are someone I know. Are they husbands or wives of friends? Do my kids go to school with them?)

Like so many times before, I walked into a company that had received an OSHA citation due to an employee complaint. So they decided to improve their safety program and become an OSHA VPP (Voluntary Protection Program) site. These programs began in California under Cal/OSHA in 1979, followed by federal OSHA in 1982. After years of experimenting, Fed OSHA offered the pro-gram to all employers in 1998. Basically, VPP sets performance-based criteria for a managed safety and health system. One of the current issues they are focusing on is electrical safety. Electrical incidents are the fourth-leading killer of employees, so it is an im-portant focus.

Interestingly enough, this site had been in the process for VPP for some time and just identified the electrical safety need after an OSHA consultation. The problem is the same I see everywhere, and it affects all safety.

Most companies trying to comply with safety standards start with PPE or a written program. PPE is important and should be put into place quickly, but from a program perspective, a company should follow more standardized approaches. The disadvantage of these standardized methods is they are theoretical and don’t get to the most “bang for the buck” quickly. Some companies have had employees die while they were commissioning arc flash studies.

Some common processes for building a safety program focus on hazards and programs, while others focus on behavior. Each of these has merits, but we must really do all of these things. A com-mon outline for developing a safety program is below:

1. Establish the priority and goal of safety.2. Create a safety program by:3. Hazard Identification

4. Hazard Evaluation5. Hazard Control.6. Educate management and supervision.7. Begin measuring safety as a part of job performance.8. Make safety, and planning for it, a job site priority.9. Make all employees responsible for, and accountable for,

safe behavior.The problem with most safety programs from an electrical

standpoint is that the safety departments often do not have the technical expertise in electrical safety. But electrical safety must be managed as part of an overall safety program because the electrical department rarely has safety management expertise.

OSHA has electrical safety requirements, but they are insuf-ficient to build an electrical safety program except in the case of electric utilities (29 CFR 1910.269). Most OSHA 10 Hour courses have an electrical safety component that tends to be very cursory. For an effective electrical safety program, companies must build the overall safety improvement process into the technical electri-cal safety program.

Consensus Standards to the RescueThe NFPA 70E committee recognized this and included two in-formational notes (IN), which are non-mandatory but encompass a whole range of changes in how electrical safety will be done in the future. These two notes are found in NFPA 70E since the 2009 standard. They simply state:

“Informational Note No. 1: Safety-related work practices such as verification of proper maintenance and installation, alerting tech-niques, auditing requirements, and training requirements provided in this standard are administrative controls and part of an overall electrical safety program.

Informational Note No. 2: ANSI/AIHA Z10, American National Standard for Occupational Health and Safety Management Systems, provides a framework for establishing a comprehensive electrical safety program as a component of an employer’s occupational safety and health program.”

They are simple but, reading the ANSI Z10-2012 standard, we

begin to understand what NFPA 70E committee members (some of the most electrical safety-conscious individuals in the world) are getting at. Note that, even though informational notes are non-mandatory, they often foreshadow upcoming moves by the committee—OSHA VPP normally includes requirements to use the Z10 standard.

Consider some of the requirements of ANSI Z10-2012:1. Requires a safety management system. This is a proactive,

standardized process for continuously ensuring and improving el-ement effectiveness.

2. Requires establishing policy and objectives that use an orga-nizational structure with systematic documented roles, responsi-bilities, processes, and resources to obtain objectives.

3. Emphasizes continuous improvement and systematic elimi-nation of root causes of deficiencies.

4. Requires management leadership and employee participa-tion.

5. Requires planning and ongoing review, assessment, and pri-oritization of objectives by implementation of plans and allocation of resources.

6. Implementation of the OH&S System, which includes the fol-lowing elements:

7. Hierarchy of Controls8. Design Review and Management of Change9. Procurement10. Contractors 11. Emergency Preparedness 12. Education, Training, and Awareness 13. Communication 14. Document and Record Control Process 15. Evaluation and Corrective Action16. Monitoring and Measurement17. Incident Investigation18. Audits19. Corrective and Preventive Actions20. Feedback to the Planning Process21. Management Review: Outcomes and Follow UpMany companies have their safety program operating in the

ANSI Z10 format to some extent, but they often place electrical safety under the engineering department, and only parts are actu-ally “owned” by safety. In order to get real compliance improve-ment, the safety process must infiltrate the electrical maintenance world. NFPA 70E and CSA Z462 are the U.S. and Canadian stan-dards for electrical safety. Implementing a strong consensus stan-

Combine Training and Auditing for Great Results Auditing the right behaviors and thought processes can improve electrical safety compliance by 40 percent.BY HUGH HOAGLAND

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AUDITING DITION

dard within a continuous improvement process framework will bump up the quality of any electrical safety program.

We recommend the following elements for an electrical safety program:

1. Inspect/evaluate the electrical equipment for code compliance.2. Maintain the electrical equipment’s insulation, enclosure in-

tegrity, and operational reliability: especially breakers and fuses.3. Plan every job and document first-time procedures.4. De-energize whenever possible.5. Anticipate unexpected events.6. Identify and minimize the hazard.7. Protect the worker from shock, arc, and other hazards.8. Use the right tools and PPE for the job.9. Assess, audit, and document workers’ skills.10. Audit the principles of the applicable standards.See NFPA 70E or CSA Z462.

How Do I Gain >40 Percent Compliance?Train. Training raises compliance by 10-50 percent, depending on the behaviors. The general study was on basic behaviors such as hard hats, etc.; electrical safety habits are new and often not as well known as basic safety.

Set goals and measure. You have to measure the right things. Measuring behaviors such as flash suit use might take years to de-velop baseline data, but measure behaviors such as:

1. De-energizing, lockout/tagout 2. Wearing of rubber insulating gloves3. Verification of meter and absence of voltage4. Wearing of basic arc-rated daily wear and face protection5. Wearing flash suits for higher-level exposures6. Use of insulated tools7. Testing of rubber insulating gloves, blankets, and other insu-

lated equipmentThis list isn’t inclusive, but these behaviors are easy to measure

and give big results. Most incidents involved no injury when the elements above are used.

Audit, audit, audit. We recommend a three-tiered auditing strategy.

■ Year One: Have an outside firm audit, giving you a frame-work for audit.

■ Year Two: Audit your own site as a safety person.■ Year Three: Have another safety person/electrical person

from within your company audit your site, and you audit their site (cross-pollination).

Start the process over again.This three-step approach to auditing will be more cost effec-

tive and get better results. Auditing is a learning tool. Outside firms and other people have different approaches, and you can learn and teach others about what you have learned or seen. Training is great, but it isn’t a “be all, end all.” When I say training here, I mean event training. High-impact training can get some results; it gets atten-tion and introduces concepts. Detailed technical training also is effective but goes over the heads of some workers and is no more successful in changing behavior than high-impact training.

Training increases compliance by about 10-40 percent, up to about 77 percent at the best. Training, auditing, and retraining take you over the top to much better compliance. People don’t do what you expect, they do what you inspect.

The chart above is based on the data in “The Effects of Train-ing, Goal Setting, and Knowledge of Results on Safe Behavior” by Reber, et al.1

In simple safety behavior like “horseplay,” Reber, et al. found the workforces studied were about 65 percent compliant (common in basic safety). Training alone improved compliance by about 12 percent. Measurement of clear goals and knowledge of results could improve compliance to about 95 percent. The baseline for electrical safety we have found is not this high, but statistically we use their argument as we continue our studies. The greatest results come from measuring and sharing the results. Again, people don’t do what you expect, they do what you inspect. Historically, electri-cal safety was only inspected by the journeyman or the manager of

that department; no one came in from the outside to audit electri-cal safety. If safety audits were done, little in the audit related to electrical safety, and almost nothing related to electrical safe work practices. That is changing.

How Do Auditing & Training Lead to Such Great Results?Goal setting and auditing help training get implemented. When you set goals and audit them, it helps identify failures in motiva-tion, systems (you can’t wear rubber insulating gloves if you don’t have them), and understanding (frequently with new behaviors, especially complex ones, people don’t fully understand the require-ments). Auditing basically becomes more training and helps clarify the behavioral goals and tweak the system so these objective goals can be met and have the desired effect of no injuries.

SummaryCompanies that want to operate safely must have systems that al-low for learning and evaluation of behavioral change. Training alone is not enough to reach compliance in most cases. Statistically, it has been shown that Training, Goal Setting, Auditing, and Com-munication of Results have been effective in increasing company compliance to safety standards. Implementing both training and auditing into your compliance toolbox will raise the bar in your company more than most methods.

Hugh Hoagland does arc flash testing and electrical safety train-ing. e-Hazard.com offers internal and external audit solutions for electrical safety. Hugh may be reached at [email protected]. His training video “7 Electrical Safety Habits” includes a free field audit spreadsheet to look at 40 behaviors supervisors can use to meet the field audit requirements of NFPA 70E and CSA Z462. Adapted from e-Hazard.com white paper, “Improving Electrical Safety Audits.” Used with Permission.

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Auditing is a learning tool. Outside firms and other people have different approaches, and you can learn and teach others about what you have learned or seen.

REFERENCES1. “The Effects of Training, Goal Setting, and Knowledge of Results on Safe Behavior: A Component Analysis,” by Robert A. Reber and Jerry A. Wallin, The Academy of Management Journal, Vol. 27, No. 3 (Sep., 1984), pp. 544-560

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EQUIPMENT LABELING DITION

E very day, electrical employees approach a piece of electri-cal equipment to do some work. Often they see a label like the one in Figure 1.

They read the information on the label. It is very clear that it is a warning label, indicating there is a safety hazard working on this equipment. One of the many questions they have to answer is, “What Personal Protection Equipment (PPE) do we need to use to work safely on this equipment?”

The label lists lots of information regarding arc flash incident energies and electrical shock hazards. The label lists an incident energy of 15 calories/ cm2 . This one also lists required PPE of PPE Category 3.

Since both the incident energy and a PPE Category are listed (not standard for NFPA 70E since 2009 but still allowed by IEEE 1584), what arc flash PPE do they need to wear? Based on this label there are two answers:

1. Wear arc rated clothing equal to or greater than the incident energy of 15 calories/ cm2 . If they are wearing 8 calories/cm2 as everyday wear, they may be able to increase their arc rated (AR) protection by layering other AR PPE, such as donning an AR cov-erall. Annex M in the 2015 edition of the National Fire Protection

Association’s (NFPA) Standard 70E for Safety in the Workplace® describes how people can approach layering AR PPE to increase the PPE protection.

2. Wear an AR flash suit rated a Category 3. The arc rating of a Category 3 flash suit is 25 calories/cm2. Unfortunately, most em-ployers do not have a Category 3 flash suit. They usually have a Category 4 flash suit, to substitute for a Category 3 situation, which has a rating of 40 calories/cm2.

The best practice is wearing AR PPE equal to or greater than the stated incident energy. Yet if that is the best practice, what is the reason labels can have both incident energy statements and Re-quired PPE in terms of PPE Categories? And when they do have both statements, to which should the electrical employees comply?

What the Current Edition of 70E® RequiresThe IEEE Std 1584-2002 Arc-Flash Hazard Calculator is part of the issue. While NFPA 70E has been updated several times since 2002, the IEEE 1584 standard used by most software companies for calculations still uses an outdated version of the category table that was originally used with both tables assessments and incident energy assessments. The 2015 edition of NFPA 70E® has specific requirements for arc flash labels and the PPE Categories are only used when the tables are used in the hazard assessment. Before, 8.1 cal/cm² calculated resulted in the CAD software for energy assess-ment requiring a HRC or PPE Category of 3, which resulted in a minimum protection level of 25 cal/cm².

Labels created based on prior editions of NFPA 70E® can have both the cal/cm2 and Hazard/Risk Category (HRC) listed. This la-bel was created prior to the 2015 70E® Edition, so that is probably the reason it has both. Proper assessment today would use the task and equipment tables to determine the PPE or do incident energy calculations and then use Annex H.3 to determine a PPE scheme to protect the worker, but the cal/cm² of the calculation would be the minimum protection, not an arbitrary HRC or PPE Category.

The 2015 edition of 70E® specifically states that either one can be listed on the label but not both. (See 2015 70E® Edition, Article 130.5(D), page 28.) What is the reason the current edi-tion of 70E® specifically states that both pieces of information

cannot be on the label?The current edition of 70E® makes it very clear that PPE Cat-

egories are developed based on the use of various tables in the 70E® Standard. These tables were constructed to be particularly conser-vative in listing the required PPE. Basically, if the arc flash analysis of a particular facility’s power distribution system used the tables to determine arc flash incident energy hazard, then the labels list the PPE Categories.

However, if the arc flash analysis of a particular facility’s power distribution system was determined by using mathematical analy-sis, such as commercially available software, the labels list the inci-dent energy at a particular working distance.

So the required PPE cannot be listed on the label both in a stated PPE Category and incident energy level because each listing is based on a separate analysis method yielding different results.

In other words, let’s use as an example of a person traveling be-tween two cities. Let’s say that public transportation is available as well as that person’s having a car, too. It doesn’t make sense for that person to purchase a ticket on public transportation and purchase gas and tolls, both, to travel between the two cities. That person chooses one or the other.

Similarly, when doing an arc flash analysis, use the tables to de-termine Categories or use mathematical analysis to determine inci-dent energy to choose PPE in a particular case, but do not do both.

If equipment has labels on it, that means an analysis was done and a person cannot use the tables. Simply stated, LABELS RULE!

So, when a label does have both listed, how does one choose which one to use? Based on the label in Figure 1 and using Annex M, it makes sense to choose PPE based on the incident energy and layering the PPE. It will take less clothing to have AR PPE at 15 calories/cm2 then using a Category 3 AR flash suit rated at 25 calo-ries/cm2. As stated above, most facilities use a Category 4 flash suit rated at 40 calories/cm2 to substitute for a Category 3 requirement. Obviously, wearing a Category 4 flash suit has its own challenges.

Even so, it is up to the employer to determine which value to use to choose the PPE. If the employer chooses to have their em-ployees choose Categories, then it is up to the employees to com-municate to the employers the option of used incident energy to determine the PPE.

Al Havens, formerly of the U.S. Navy and retired US Gypsum Corp, is a partner, trainer, and auditor at e-Hazard.com. Hugh Hoagland is the owner of ArcWear.com and a partner, trainer, and consultant at e-Hazard.com.

Categories or Calories: How to Assess the Arc Flash Hazard ClearlyIf equipment has labels on it, that means an analysis was done and a person cannot use the tables. Simply stated, LABELS RULE!BY AL HAVENS AND HUGH HOAGLAND

E-HAZARD.CO

M

Figure 1. Common arc flash equipment label

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TRAINING DITION

N FPA 70E has long waived the necessity of an energized work permit for such tasks as testing (voltage, current, phasing, infrared, and system tuning), circuit identifica-tion, and troubleshooting. In 2009, a fourth exemption

was added allowing persons to cross the Limited Approach Bound-ary (changed to Restricted Boundary in 2015) for visual inspection (130.2(B)), but some companies continue to require permits for many routine tasks. This is not prohibited by the standard.

In 2015, the permit requirements changed again to add an in-creased risk of arc flash hazard to permit requiring work and to change the shock boundary trigger for the permit to the Restricted Approach Boundary. Thermography was also added to the list of permitted activities, decreasing the times written permits are need-ed. Some companies do not understand that permit-exempt activi-ties such as thermography and voltage testing still require appro-priate PPE as defined in the standard’s tables or from the company risk assessment and all safe work practices must still be in place, trained on, and followed by workers exposed to shock or arc flash.

The change does, however, eliminate any need for unneces-sary paperwork in many areas. Companies may still choose to use a “hot work permit” or an energized electrical permit where conditions indicate. A common example of tasks that may be exempt from permit would be the need to look at a component to obtain a part number, but the most common is infrared in-spection of parts for system reliability. Whether an equipment door is opened to verify a component setting, a fuse size, or other common work task, a qualified, properly outfitted person may be exempt from a management signature permit for these common tasks under certain conditions.

Any time such inspections or any work is performed on ener-

gized equipment, whether a permit or written approval from man-agement is required or not, persons performing the task must be qualified and must understand the hazards involved. Therefore, the items listed in 130.1(B)(2) must be addressed for all tasks. These items include the equipment and circuits involved in a task; nec-essary safe work practices; mandatory PPE; the exposed energy sources; knowledge of and proper guarding/marking of the dis-tance of the electrical boundaries (arc flash or shock boundaries); and a job briefing.

Permit required or not, the person who performs such tasks must be fully aware of the increased hazards inherent to energized work and be qualified to work safely around those hazards.

The purpose of NFPA 70E permits is to prevent workers from doing energized work or management from requiring energized work that is not necessary and justified. The energized work that doesn’t require a permit typically must be done energized, and the standard accepts this reality.

Bill Shinn, a retired Alcoa Electrical Engineer, is a partner, trainer, and consultant with e-Hazard.com. Hugh Hoagland is the owner of ArcWear.com and a partner, trainer, and consultant at e-Hazard.com.

Arc Flash Training: No Energized Electrical Permit Required in NFPA 70E for Common Safety Tasks The purpose of NFPA 70E permits is to prevent workers from doing energized work or management from requiring energized work that is not necessary and justified. The energized work that doesn’t require a permit typically must be done energized, and the standard accepts this reality.BY BILL SHINN AND HUGH HOAGLAND

Some companies do not understand that permit-exempt activities still require appropriate PPE and all safe work practices must still be in place, trained on, and followed by workers exposed to shock or arc flash.

OSHA CITATION NEWS: SEPT. 14, 2016Alliance Ground International, LLCInspection site: O’Hare International Airport, ChicagoCitations issued: OSHA cited the company for two

willful, one repeated, five serious, and one other-than-serious violations on Sept. 8, 2016.

Proposed penalties: $338,881Investigation findings: OSHA announced that the

company, cited three times since 2014, violated pow-ered industrial vehicle and electrical safety standards. It is a cargo-handling company that employs forklift operators who transport goods from international airline carriers such as Amerijet, Delta, Finnair, and Virgin.

“Simply securing these portable fuel containers with clamps provided by the manufacturer will prevent workers from being exposed to containers jarring loose, slipping, or rotating and potentially striking workers who transport goods around the clock at one the nation’s busiest airports,” said Angeline Loftus, area director of OSHA’s Chicago North office in Des Plaines. “Airport ter-minals are inherently dangerous working environments, and Alliance Ground International needs to re-evaluate its forklift operating procedures to ensure they are pro-tecting workers on the job.”

OSHA initiated the inspection based on a complaint and as part of its Regional Emphasis Program on Pow-ered Industrial Vehicles. Inspectors also found Alliance Ground International failed to:

■ Remove damaged forklifts from service■ Inspect forklifts on a shift-by-shift basis■ Use manufacturer-recommended parts when

repairing forklifts■ Maintain fully charged fire extinguishers■ Inspect fire extinguishers monthly■ Maintain electrical equipment to prevent employ-

ee exposure to open panels and exposed wiringhttps://www.dol.gov/sites/default/files/newsroom/

newsreleases/OSHA20161843.pdf

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PROTECTION DITION

D o you need to provide barricades to indicate the arc flash boundary when doing energized electrical work or trou-bleshooting? Many companies claim that they do not do “live” or energized work. This is a misunderstanding of

the terms.“Working on” energized parts in NFPA 70E is defined as touch-

ing those parts with body parts, tools, probes, or test equipment, regardless of the PPE worn. Diagnostic testing and making changes to the equipment while the power is on or until it has been “made safe” (called an “electrically safe work condition” in NFPA 70E) is energized work by definition. So energized work includes tighten-ing a connection and voltage testing and requires PPE and all the provisions to safeguard the electrical worker, surrounding workers, and the public.

One of the best means to safeguard surrounding workers or the public is to keep them outside of the arc flash boundary and the limited shock protection boundary. We recommend using “bar-ricades” such as tape, tape and cones, or other structures to warn and limit access to unqualified workers.

OSHA Subpart S considers “exposed energized parts” as a Dan-ger Hazard, not a Caution Hazard because they can cause serious injury or death, and this level of hazard requires greater precaution. Both OSHA and NFPA 70E recommend using ANSI Z535 to miti-gate for limiting access.

ANSI Z535, American National Standard Safety Tags and Bar-ricade Tapes (for Temporary Hazards), dictates how Danger, Cau-tion, and Warning signs are to be worded and designed. It does not cover barricades. OSHA does not define a barricade in 1910.399, so the NFPA 70E definition should be used. Barricades can be any-thing that limits access, but the NFPA 70E standard recommends using ANSI Z535, so use the ANSI Danger Level. NFPA 70E and OSHA 1910.335(b) state that signs shall be used to warn employees of electrical hazards that might endanger them. It goes on to state that barricades and/or attendants shall be used.

Any time a barricade is used, there has to be signage posted to indicate the level of hazard, what the hazard is, and what em-

ployee action is required.

Danger Level Marking RequirementsANSI Z535 has three requirements for Danger Level:

1. Use Red Tape that states the word Danger to indicate the haz-ard level clearly to the exposed worker. We recommend securing this tape in the primary language of the exposed worker (the unqualified worker in the area or the public, if they are exposed). Typically, in the United States this will be English or English and Spanish.

2. The Tape or signage (usually attached to the barricade) should state what the hazard is; we recommend “High Voltage” (not all hazards are “high” voltage, but this is designed for the pub-lic and the unqualified worker).

3. Clearly indicate what the unqualified person should do to remain safe (red tape typically indicates to Keep Out, but the actual verbiage can be used).

So if yellow barricading is used, it should not say “Caution,” as this indicates a lesser level of hazard. Signs should be conspicu-ously posted at the barricade that meet the requirements of OSHA 1910.145 and ANSI Z535 that say “Danger” in black lettering on a red background, “Electrical Hazard” or “High Voltage” or “Shock Hazard” and “Keep Out” or “Qualified Persons Only” in black let-tering on a white background. Using the tape removes the need for the signage and is easier to use in many cases.

When using barricade tape with the sign printed on the tape, the tape must be red to comply with the requirements that the Dan-ger signage be on a red background. Red tape by color indicates a Danger hazard as indicated in ANSI Z535. “Danger” should never be printed on a yellow tape and “Caution” should never be printed on a red tape. This is a straightforward method of complying with both the signage and barricading requirements, but other methods of barricading along with Danger signage may be acceptable.

For this article, we confirmed that you can no longer easily buy red barricade tape that has the “Keep Out” printed on it unless special ordered at about $45 per roll. The standard “Danger High Voltage” red barricade tape costs about $10 a roll. Several manu-

facturers were asked and indicated that they dropped the “Keep Out” because it was redundant, as the “red” means keep out.

Whatever the color or barricades or tape, the signage must meet the ANSI Z535 standard, but with the cost of the tape being so low, this is currently the best practice when work is not performed in a locked electrical room or substation or when workers in those zones could be expected to need warning to stay away from electri-cal work with an arc flash or shock hazard.

Bill Shinn, a retired Alcoa Electrical Engineer, is a partner, trainer, and consultant with e-Hazard.com. Hugh Hoagland is the owner of ArcWear.com and a partner, trainer, and consultant at e-Hazard.com.

Barricades in Shock and Arc Flash Boundaries vs. GuardingFor this article, we confirmed that you can no longer easily buy red barricade tape that has the “Keep Out” printed on it unless special ordered at about $45 per roll. The standard “Danger High Voltage” red barricade tape costs about $10 a roll.BY BILL SHINN AND HUGH HOAGLAND

2017 NESC AND 2017 NESC HANDBOOK, PREMIER EDITION NOW AVAILABLEIEEE and the IEEE Standards Association (IEEE-SA) announced in August 2016 that the 2017 National Electrical Safety Code® (NESC®) has been published and also the launch of the 2017 NESC Handbook, Premier Edition. It is a handbook that includes a representation of the code text, “making it the next-generation tool for professionals wanting to improve their understanding of the NESC,” according to IEEE’s announcement.

The 2017 NESC and the handbook may be purchased at the online IEEE Standards store.

The NESC, which is published every five years, is the authoritative code for ensuring the safety of persons and utility facilities during the installation, operation, and main-tenance of electric supply and communication facilities.

The announcement noted some of the important changes in the code “include revised requirements for substation impenetrable fences, required consideration of Aeolian vibration for conductors, changes to ac-commodate new industry insulator ratings, as well as revisions to the rules in Part 4 that align with changes made to 29 CFR by the Occupational Safety and Health Administration (OSHA).”

IEEE began offering a series of new educational online courses based on the NESC 2017 Edition this fall and announced it would introduce a mobile app for enhanced access to NESC’s content in the field.

Information on updates to the code can be found at http://standards.ieee.org/about/nesc/.

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PPE SELECTION DITION

P ersonal Protective Equipment (PPE) programs with low acceptance, low compliance, and high complaint levels tend to have a few commonalities; at the top of that list is when individual wearers have little or no choice in or

control over what they must wear. No one likes to be told what to do, much less how to do it; in fact, people are hardwired to react negatively to mandates, particularly when it comes to the clothing they wear—an area that significantly impacts daily life. Psychology tells us that from about 2 years of age on, humans reject, almost au-tomatically, dictates from others, as anyone who has had children or been around them knows all too well. The “Terrible Twos” is among the earliest manifestations of human autonomy.

Most parents very quickly learn that one of the simplest and most effective ways to defuse such an impasse is to offer options. Even when all of the options have a similar net effect, people prefer choice, because choice equals control and everyone likes to feel em-powered. This core tenet of the human psyche changes little if at all as we mature and remains a prime motivator of behavior through-out our lifetime (think about the cereal aisle as a kid or the beer aisle as an adult—hundreds of options). So is it any wonder that so many PPE uniform programs struggle with achieving and main-taining high levels of wearer compliance, much less satisfaction or even happiness? Perhaps unsurprisingly, these problems are most common in programs that do not include employee-level product choice—programs that dictate a single shirt and pant combination in a single fabric, weight, style, and color.

Critically, these “no-choice” programs can introduce many lay-ers of challenge:

■ Safety risks by workers not wearing the PPE at all, or not wearing it properly;

■ Compliance and financial risks by not maintaining it out of resentment;

■ Reduced productivity thanks to diminished morale; and■ High investment of management’s time administering,

fielding complaints, and solving problems for the FRC pro-gram—detracting from management’s core responsibilities and professional priorities.

The no-choice approach to PPE has its roots a decade or more

in the past, when 90 percent of the market was concentrated in garments made from just two or three fabrics and garment styles had a distinctly industrial feel . . . there simply wasn’t much choice.

However, there has been a tremendous innovation boom in fabric performance and garment styling, leading to flame-resistant and arc-rated fabric options and garment styles over the last 10 years. Today’s FR and AR PPE bears about as much resemblance to the offerings pre-2005 or 2006 as your smartphone today does to the phone you had back then. Quality is way up, FR durability and protection are a given in many domestic brands, weights are dropping, comfort is increasing, and styles now rival non-FR street wear. As a result, the hottest trend in FR PPE over the last few years is the movement from no-choice uniform programs into managed choice programs (often called “catalog” programs).

If your company requires a uniform image and fixed colors, don’t despair; you can still leverage the power of choice. There are literally dozens of fibers, fabrics, weights, garment styles, and brands available, even within a given requirement (such as a light blue button-up shirt paired with khaki pants). These differences will be virtually invisible to your customers but make a major dif-ference to your wearers.

The top five reasons cited by safety managers for moving to managed choice programs are improved compliance, comfort, ac-cess to future innovations, morale, and cost reduction. Let’s take a closer look at each of the issues.

Compliance Clothing has always been a key way people express themselves. It’s one thing to be told you must wear protective clothing; it’s another matter entirely to also be told you have no options from which to choose.

Consciously or subconsciously, people rebel against ultima-tums, even when they know a requirement is in their best interest, because a lack of control is disenfranchising. As a result, compli-ance is compromised—and the worker may fail to wear PPE or

wear it improperly, putting himself at risk and reducing the com-pany’s compliance. And workers who are forced to wear uncom-fortable PPE are not motivated to take good care of it. Conversely, it is highly empowering to offer control through choice or collabo-ration, even when all of those choices are PPE originally selected and approved by Safety. Compliance rates rise considerably when individual wearers are empowered with choice.

The Power of Choice in FR Clothing Programs How to change your PPE culture.BY SCOTT MARGOLIN

TYND

ALE COM

PANY, IN

C.

Compliance rates rise considerably when individual wearers are empowered with choice.

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PPE SELECTION DITION

ComfortEmpowerment is a powerful psychological motivator; comfort is an equally powerful physical one. Everyone wants to wear com-fortable clothing. Comfort is inherently subjective, differing from person to person and even day to day. Take a moment to observe the crowd next time you’re in a meeting or other gathering of more than 10 people. You’ll almost always find people in both short sleeves and long sleeves; natural fibers, synthetic fibers, and blends; knit pullovers and woven button ups; one, two, or three layers; and lighter and heavier fabrics, even though everyone dressed for the same weather and even though it is the same temperature and hu-midity across the whole room.

Given this facet of human nature, there’s simply no way for a no-choice program to make everyone, or even a majority of people, happy. These programs open the door to comfort com-plaints and the attendant non-compliant behavior. On the other hand, when workers are permitted to choose from among a rea-sonable array of styles, colors, weights, fabrics, and brands (all of which meet the protective needs of the company), complaints fall off dramatically, compliance rates skyrocket, and employees are incented to properly maintain PPE garments—increasing their serviceable life. People tend to take better care of things they want and feel ownership of than they do rental clothing given to them without their input.

Access to InnovationAnother negative with no-choice programs is the tendency to lock in on one fabric, color, and garment for at least a year and usually 3-5 years. This severely restricts your ability to leverage product and fabric innovation as it occurs. Most of these new products have been engineered to deliver more comfort or more style or more protection at the same weight or to bring highly favored brands into the FR market.

Because these are all properties wearers’ desire, it’s wise to cre-ate PPE programs that ensure you don’t have to wait months or even years to add products that increase wearer satisfaction. This factor is growing rapidly in importance as millennials, a genera-tion that is known for acute self-awareness, make up a growing percentage of the workforce. “Catalog” programs are designed to allow addition and subtraction of included garments, which allows real-time access to more comfortable, more stylish, or innovative garments as they become available.

MoraleImproved morale is a hybrid of the psychology of choice and the physical response to comfort discussed above, coupled with the self-image/satisfaction that comes with wearing popular, stylish brands instead of boxy, industrial-looking “work clothing.” Taken together, they are a powerful triumvirate motivating behavior.

“We dramatically changed our cost and we dramatically changed perception—from not only management but from our people,” said one health and safety manager who recently replaced a problematic no-choice program with a catalog choice program. “We stopped wasting money . . . [and] the biggest benefit to our employees was ownership.” By owning the clothing, employees could purchase what they wanted and were motivated to follow proper care and maintenance guidelines to maintain an appearance they could feel good about.

As in this case, attitudes toward FR and AR PPE often shift from negative to positive after choice is introduced, and there can even be a halo effect in which workers think more highly of their company as a whole. Simply put, people want their clothing to feel good, look good, and express themselves. Deliver all three, and you create happy people. Happy people wear their PPE, wear it prop-erly, take care of it . . . and happy wearers aren’t constantly com-plaining to management.

CostCatalog choice programs can reduce cost, often considerably, depending on what type of PPE program they replace. Product cost comparisons are relatively obvious and easy to compare, but there are a number of other, less obvious cost reductions cited by safety and procurement professionals who have lever-aged the power of choice.

Chief among them is increased efficiency in three areas:■ Dramatic reduction of management time spent handling

the program and fielding complaints;■ Increased work output as less time is spent on clothing is-

sues by wearers; and■ Increased service life of the garments as a result of better care.There are also interesting stories about improvements in care of

tools, vehicles, and other company property as well, as an indirect result of a happier, more empowered workforce.

At first blush it may be hard to credit PPE with the potential for such sweeping effects, either positive or negative, but when that PPE is clothing, it matters considerably. Put aside the protective function for a moment and consider that clothing is used all day, every day—more than hard hats, tools, safety glasses, or virtually any other company-supplied item.

Whether at work or at home, people want clothing that feels good, looks good, and expresses some individuality. Companies want their employees to be protected, compliant, and happy. No-choice programs generally achieve only one or two of these quali-ties, but catalog programs that offer choice can and do deliver on both sets of expectations. Choice, comfort, and style drive accep-tance and happiness, which drive strong compliance and safety rates and reduce complaints and costs.

It is possible to change your FR PPE culture and compliance rel-atively quickly, simply by taking advantage of the power of choice.

Scott Margolin is the Vice President of Technical Sales at Tyndale Company, Inc. (800-356-3433), an industry-leading manufacturer, distributor, and service provider of flame-resistant clothing since 1981. With more than 25 years of FR industry experience, Scott has traveled globally to share his research and learnings on flash fire, arc flash, and combustible dust hazards to improve worker safety and the fibers, fabrics, and garments that protect against these hazards. Visit www.TyndaleUSA.com or blog.TyndaleUSA.com for more infor-mation and to learn about how Tyndale is Proud to Protect workers across the country.

“We dramatically changed our cost and we dramatically changed perception—from not only management but from our people,” said one health and safety manager who recently replaced a problematic no-choice program with a catalog choice program. “We stopped wast-ing money . . . [and] the biggest benefit to our employees was ownership.” No-choice programs severely restrict your

ability to leverage product and fabric innovation as it occurs.

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A few years ago in Louisville, Ky., at an open-enrollment High Voltage Electrical Safety Class, I had the most sat-isfying comment made to me as an instructor.

During a class break, a student (I’ll call him George) approached me. I recognized him from a previous high-voltage class I had taught about two years earlier. He got my immediate attention when he said, “I want you to know that you saved my life.”

I responded with, “Well, tell me how that happened!”George proceeded to tell me that what saved his life was train-

ing on how to install a protective ground on a de-energized circuit and how to use the “fuzzing” technique as an additional step to the test for absence of nominal voltage with a proximity detector. On high voltage, reliable touch type detectors are not readily available, so OSHA requires that these voltages be grounded. Proximity de-tectors and the work area often make testing for absence of voltage challenging even for highly experienced workers.

Now, the fuzzing technique is one of those things that is now passed down from one generation to the next. I learned it in the late 1960s when I was an apprentice. Back then, fuzzing was a pri-mary technique for testing absence of voltage by the generation of electricians who preceded me. By the time I was an apprentice, proximity testers—usually in the form of a “glow stick”—had come along, and using a glow stick was the method I learned and used. (Note that OSHA no longer allows “fuzzing” as the primary check for absence of nominal voltage and requires that a properly rated tester be used. As a backup, I have always “fuzzed” each conductor even when a proximity tester had confirmed it was de-energized.)

To “fuzz” a conductor, slowly move your protective ground to-ward the de-energized conductor. If the conductor is still energized or becomes re-energized, when you get about 1 foot away from it, at 13.8 kV you will hear a sizzling noise. If you hear this, you back away with the ground and do further research as that conductor is still hot. That is the experience George had.

George is a field service technician for a major equipment com-pany, and he is required to work on equipment at the customers’ locations. On this day, he was preparing to service air compressors that required the de-energizing and grounding of a 13.8 kV switch-gear. After opening the main switch, George proceeded to use his

proximity tester to verify the absence of nominal voltage on the main bus, as required by OSHA 1910.269(n)(5).

I asked George, “Why didn’t your tester pick up the presence of voltage?”

He replied, “I did something you told us not to do in the class. I put the tester voltage range selector switch on the 240 volt setting for the before-and-after verification that the tester was working and verified it on 120 volts. I then used the 15 kV setting for the absence-of-voltage test, and it indicated no voltage. It turned out that the tester was defective on the 15 kV setting.”

I said, “George, that’s why I always insist you test the tester on the setting you are going to use it on.”

It turned out that a back feed was coming from another loca-tion in the plant, and by using the fuzzing technique rather than just slapping the protective ground on the circuit, it prevented an arc flash explosion; and that’s how, in George’s eyes, I saved his life. I’m sure George could have been injured had he just smacked the protective ground on the bus, and it was most satisfying to me as an instructor that I had been able to share a technique that helped to protect him.

Not All Tradition is BadWhile the standards are one of the best things we have today to in-struct workers on electrical safety, they do not preclude extra steps or practical knowledge in development of work practices. There are many “tricks of the trade” that have sound engineering principles in them that are yet to be put into standards.

“Fuzzing” in addition to testing could be one piece of knowl-edge that could save a life. Not all tradition is bad.

Use the new techniques and try to understand the old. They might be worth considering.

Bill Shinn, a retired Alcoa Electrical Engineer, is a partner, trainer, and consultant with e-Hazard.com.

You Saved My Life! An old school practice saves a life.BY BILL SHINN

E-HAZARD

.COM

CONTACTING E-HAZARD.COM3018 Eastpoint Parkway, Louisville, KY 40223

Office 502-716-7073 | Fax 502-371-6300

www.e-hazard.com

EQUIPMENT TESTING DITION

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WORKER SAFETY DITION

N ational Fire Protection Association’s (NFPA) 70E Stan-dard for Electrical Safety in the Workplace® states in Ar-ticle 100, Definitions, that an arc flash hazard may exist whenever a person is interacting with electrical equip-

ment in such a way as to cause an electric arc. One interaction that happens innumerable times in an industrial environment is oper-ating a circuit breaker, disconnect, or switch to either the ON or OFF condition. The important safety issue is: Does it happen in a safe manner or, since it is so routine, are people too casual about it?

While NFPA 70E in 2015 exempted normal operation with doors or covers on from PPE requirements, most fail to read the requirement that this only applies when the device meets the following criteria: It is properly installed according to the NEC (National Electrical Code), properly maintained (according to manufacturer’s instructions or NFPA 70B), and has no evidence of impending failure (historical or physical evidence). And so most companies still need to follow a best practice procedure for equipment operation.

This is especially important on 3 phase equipment and equipment >300V due to the increased risk and energy from an arc flash. The standard does not lay out specific procedures, but these are recommended by best practice and our accident investigation history.

There are six observable behaviors that a person needs to dem-onstrate when operating a circuit breaker, disconnect, or switch. These are:

1. Wear the proper Personal Protective Equipment (PPE) as mandated by the Occupational Safety and Health Administra-tion (OSHA) Code of Federal Regulation (CFR) 29, Paragraph 1910.335, NFPA 70E, and the equipment label, if provided—typically, at a minimum, glove and arm protection, depending on worker location and incident energy analysis and the arc flash boundary.

2. Stand outside of the “line of fire.” It does not matter which side, but testing shows that the typical “piano” hinges on equip-

A Common Task Non-Electricians Do Covered by NFPA 70E: The Safest Way to Operate a Circuit Breaker, Disconnect, or Switch The standard does not lay out specific procedures, but these are recommended by best practice and our accident investigation history.BY AL HAVENS

E-HAZARD.CO

M

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WORKER SAFETY DITION

ment doors do not provide sufficient structural strength to contain an arc blast. (Arc resistant electrical equipment, on the other hand, does provide sufficient structural strength. Arc re-sistant electrical equipment is indicated on the nameplate of the equipment.)

3. Turn the head away. The distance from the arc flash and the line of sight nature of the radiant portion of the heat from a blast make turning the face away much safer for the worker.

4. Close the eyes. Remember that safety glasses are required even under faceshields by OSHA, but closing the eyes can provide a little additional protection from a potential “flash” in-jury to the eye.

5. Take a deep breath and hold it while oper-ating the circuit breaker, disconnect, or switch to prevent hot gas burns to the lungs.

6. Do not reach over the front of the equip-ment. This can cause injury from the door if ejected.

There is a report that a person did five of the above behaviors when operating a circuit break-er. Unfortunately, an arc flash occurred. The per-son did not receive any harm to his body, PPE, or clothing. The one behavior he did not do is hold his breath. When the arc flash occurred, he, of course, then took a deep breath, involuntarily inhaling the heated smoke and gases that usually accompany an arc flash.

He had trouble breathing after the incident and was sent to the local hospital. He died three days later from lung failure due to the damage caused by inhaling the toxic and heated smoke and gases.

Who Is ‘Task Qualified’?Another issue here is that anyone who needs to operate a circuit breaker, disconnect, or switch has to be “Task Qualified.” NFPA 70E 110.2(D),

Employee Training, states, “A person can be considered qualified with respect to certain equipment and methods but still be unqualified for others.”

In addition, NFPA 70E® states the definition for a “Qualified Person” is, “One who has demon-strated skills and knowledge related to the con-struction and operation of electrical equipment and installations and has received safety training to identify and avoid the hazards involved.”

So, putting these two statements together, it is clear that persons who need to operate a circuit breaker, disconnect, or switch have to:

■ Demonstrate they have the knowledge to properly and safely operate a circuit breaker, dis-connect, or switch

■ Demonstrate they have the skills to prop-erly and safely operate a circuit breaker, discon-nect, or switch

■ Receive safety training to identify and avoid the hazards of operating a circuit breaker, disconnect, or switch

How does a person demonstrate their skills and knowledge? Obviously, by demonstrating and practicing the six listed activities above.

To whom does the person demonstrate those skills and activities? OSHA holds the employer responsible for determining who is Qualified and who is Task Qualified.

It is incumbent upon employers to be cer-tain that no one be permitted to operate a circuit breaker, disconnect, or switch in an industrial en-vironment until they demonstrate that they can do it safely.

Qualified really means something. Are your workers qualified to operate equipment?

Al Havens, formerly of the U.S. Navy and retired US Gypsum Corp, is a partner, trainer, and auditor at e-Hazard.com.

To whom does the person demonstrate those skills and activities? OSHA holds the employer responsible for determining who is Qualified and who is Task Qualified.

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OSHA CITATION NEWS: SEPT. 14, 2016Wayne Lumber and Mulch, Inc.Inspection site: 8630 Route 152, Wayne, W.Va.Citations issued: OSHA cited the company for three willful, nine repeat, 12 serious, and three other-than-serious viola-

tions on Sept. 2, 2016.Proposed penalties: $214,633Investigation findings: On April 13, 2016, OSHA conducted an inspection as a follow up to a March 2014 inspection.

Inspectors cited the employer for willful violations due to its failure to properly guard a chop saw and provide standard railing and handrails.

The agency issued repeat citations for the following violations:■ Lack of an effective hazard communication training plan■ Exposing employees to electrical hazards, inadequate machine guarding, lack of a conveyor or exhaust system to

remove combustible sawdust and shavings■ Failing to have lockout/tagout procedures in place to prevent accidental machine start-up or movement■ Allowing buildup of combustible materials■ Failing to provide leg protectionOSHA’s news release said it had cited Wayne Lumber and Mulch previously for the same violations during a 2014

inspection.The agency issued serious citations for:■ Exposing workers to crushing and rollover hazards while operating machinery without manufacturer-installed seat belts■ Failing to provide employees with protection from falls up to 10 feet above the ground■ Not providing proper eye, hand and flashback protection, and barriers and warning signs■ Allowing hazards in the area where mulch was stored■ Permitting operation of a chainsaw without a manufacturer-approved chain catch■ Failing to pressure test repaired acetylene and oxygen burning torches before use■ Allowing workers to use damaged welding cables■ Failing to ensure a moving vehicle was equipped with an audible warning signal■ Electrical equipment not used in accordance with included instructionsOSHA issued other-than-serious citations for failure to report an employee amputation injury to OSHA, provide edu-

cational training program for employees on firefighting and fire extinguisher use, or place a valve protection cap on an acetylene bottle.

“By all indications, Wayne Lumber and Mulch failed to take the violations we found in 2014 seriously. The fact that many of these hazards existed again—and the addition of nearly 30 new violations—tells us this employer is willing to jeopardize the safety of its workers. In 2015, an employee suffered a fingertip amputation due to lack of machine guard-ing. Without taking immediate action to ensure a safe workplace, more workers could be injured or worse,” said Prentice Cline, director of OSHA’s Charleston Area Office.

https://www.osha.gov/ooc/citations/WayneLumberandMulch_1132246.pdf

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