How safe are your electrical system work practices?
Although it probably won’t come as a surprise to some, a lot of plant and controls engineers are taking what appear to be risks in the workplace today. Many simply aren’t following workplace standards and regulations—in particular NFPA 70E (Standard for Electrical Safety in the Workplace; www.nfpa.org)—when it comes to working on energized electrical equipment. Everyone agrees the ramifications of ignoring safety practices when handling electricity can be lethal, but are the risks being taken really what they seem?
In a recent Control Engineering article (see “Codes and Regulations: Electrical Controls’ Dirty Little Secret: We Don’t Follow NFPA Rules” at http://bit.ly/ovLLWF), an experienced controls engineer took a different kind of risk by suggesting that he’s not the only one out there who has opened a live panel and changed a speed setting on a VFD using no electrical personal protective equipment (PPE). Yes, he’s putting himself in harm’s way…but, he asks, how much so? How much risk is too much? How much PPE really needs to be worn? Are requirements unreasonable, too cumbersome or complex, or in need of reform?
The printed and posted version of the article invited Control Engineering readers to share their thoughts about these matters in an informal poll linked to the article above. The survey generated lively discussion with more than 300 responding to the dozen questions posed. Following are highlights of findings, along with a selection of candid observations about this controversial issue.
Those responding to the survey knew of what they spoke: Nearly all (96%) said they worked on applications requiring the electrical PPE specified in NFPA 70E. However, more than half (59%) also said they “rarely” or “never” wore the required protective equipment. Another quarter (27%) said they donned required PPE only “sometimes.”
Nevertheless, companies apparently provided the needed PPE. Nearly 40% of survey participants indicated electrical PPE was “always” available for them to use and another 37% said it was available “sometimes” or “mostly.” Only 12% said needed PPE was “rarely” or “never” available. Further, nearly two-thirds (66%) said their companies required electrical PPE, including fire-retardant clothing, to be worn when working on energized panels greater than 50 V.
Then why wasn’t it used? The comments of a number of respondents were enlightening: “PPE gear restricts me from being able to constructively do what needs to be done,” said one. “Protective equipment presently available causes more safety issues than it solves. When using a full suit, your vision and feel are very limited,” said another. “Gloves I can’t feel with and a shield I can’t see out of are more of a hazard than the electricity itself,” offered a third.
Additional questions further probed respondents’ safety habits when working on industrial control panels. A whopping 84% said they “rarely” or “never” used electrical PPE when performing non-high-voltage tasks such as programming an ac VFD. Nearly two-thirds (66%) said they “rarely” or “never” used electrical PPE when using an electrical meter. More than half (56%) admitted they worked on (actually touched) energized circuits greater than 120 V, and nearly three-quarters (74%) said they worked on (actually touched) energized circuits above 50 V. Almost all respondents rejected extremes such as wearing electrical PPE to plug in a floor lamp at home. “If we applied safety rules at home like they are in industry, doors would need to be removed or protected to remove pinch points, bathtubs would be a drowning hazard, and we would be required to lock out a lamp before replacing the bulb,” added one respondent.
A cry for clarification, reform
Finally, the survey asked respondents some pointed questions about today’s standards and regulations. Surprisingly—or perhaps not—almost everyone (92%) revealed they “sometimes” violated NFPA 70E rules when working on industrial control panels. Some 72% of these admitted to these practices “always” or “mostly.” Why might so many who should, and do, know better engage in such risky practices? For one, nearly all (94%) believe that NFPA 70E is too complex to follow and too restrictive for everyday use. And nearly 90% of respondents said that industrial control panels should have their own arc flash standard.
Comments largely attacked the complexity of NFPA 70E regulations. Said one respondent, “They are so complex and restrictive that they have had the opposite effect than intended. Most controls guys have elected to completely ignore them—even the regulations they should be paying attention to.” Another pleaded simply: “Please make the standards easier to read and understand.” Disapproval, however, was not universal. “NFPA 70E is aggravating, but it is the law of the land,” observed another. “Getting caught with an injured or dead employee not following the electrical safety rules can get you a one way trip to prison.”
The poll does unequivocally suggest a strong need for further investigation into the viability of safety standards such as NFPA 70E. “What happened to common sense safety measures?” queried one respondent. “Working on energized equipment is inherently dangerous. It always will be, but it is often the only way to fix or even find a problem. Training is the key!”
We all know electricity can be dangerous. We also know that life by its very nature holds risks. Balancing hazards against the safety measures that offset them is often a fence walk. Despite what regulations require, it is obvious that many disagree with them. They have chosen—for various reasons—to disregard them and take risks they believe are reasonable and educated. What is also obvious is that the controversy—and the discussion—involving these issues are far from over.
Doorway to dialogue, action
This survey provoked intense, prolific response and reaction. The topic obviously struck a nerve for many, as more than 40% of the respondents took time to add comments and offer observations. Concerns focused on two areas: personal protective equipment and complex regulations. A sampling of thoughts and opinions is included below.
“I’ve been working on 480 V ac panels for 20 years,” said one respondent. “PPE gear restricts me from being able to constructively do what needs to be done when troubleshooting downed automated equipment. This leads to longer downtimes and lost production.” Others agreed. “Companies that strictly adhere to NFPA 70E make it almost impossible to troubleshoot our systems,” said one. “We service systems that were built from the late 1950s to the present. We are trained to work safely, but if we adhered to all of today’s standards, a service call that normally would take a few days would take a few weeks!”
Another respondent agreed: “It is too difficult to perform necessary work when following the NFPA 70E.”
Another noted that the burden is clearly on employers to provide, require the use of, and train workers on PPE. “Regardless of what your common practice is,” he said, “if ultimately someone is injured and was not using the correct PPE, had not been trained, or the required PPE was not available (that’s three violations), then the employer will have a large liability and civil penalty exposure.”
Many others said they believed PPE requirements were burdensome. Said one respondent, “There are many problems in VFD controls that must be troubleshot with power on and under a load. The NFPA gear would make the job more hazardous, since it restricts your view and range of motion and manual dexterity.” In another’s view, “The limited visibility and dexterity from the use of arc flash PPE is more of a hazard than the threat it is supposed to protect us from.”
One respondent went so far as to say he’s “yet to witness anyone put on PPE to open, inspect, or work on a live drive or control panel—whether in a union plant or otherwise. I’m aware of new or pending arc flash requirements, and I do think a separate specification for control panel safety is appropriate.” In the opinion of yet another, the required PPE for arc flash mitigation on circuits over 50V but below 600V are “frequently so restrictive that the PPE itself becomes a serious hazard to being able to install, repair, or troubleshoot…resulting in the worker being unable to hold tools, use tools, or see well enough to reasonably avoid the PPE from being the cause of a disaster.”
Among the biggest concerns was that the PPE causes more safety problems than it solves. According to several respondents, protective equipment is restrictive and limiting. Said one, “This, in turn, causes me to feel very nervous because I don’t have precise control. This also ties in with control panels as some of them are designed with very little working room. Add loss of vision and feel to that and again you are creating more hazards than you solve. Imagine having to wear gloves to attach your programming cable to a PLC with the power switch located beside the communication port.”
Another provided this observation: “I have been designing industrial control panels for over 40 years. I am a registered PE and take my safety seriously. I am well aware of the dangers and risks involved while working on ‘live’ circuits. I take PPE precautions when there is sufficient danger of personal injury. However, in most circumstances, PPE is either not needed or uncalled for. In many cases, NFPA 70E calls for extreme PPE that in my opinion is not needed. When I need to spend many continuous hours troubleshooting a motor drive or heating control system that operates on 480V, it is impossible to wear the specified PPE and operate test equipment under those conditions.”
Call for simplification, common sense
Numerous respondents also expressed a desire to see standards such as NFPA 70E revised and/or simplified, and they supported a proposal for a separate arc flash standard for industrial control panels. But mostly they asked that common sense prevail. “More common sense needs to be added to the rules,” said one survey participant. “It seems they have taken the extreme side on safety. A well-designed control panel accessed by authorized (trained) personnel should have lower mandatory requirements.”
Added another, “Overregulation creates dangerous situations where none would exist if common sense coupled with adequate training prevailed!” And from yet another: “There is no substitute for common sense when it comes to safety. When it comes to control panels, NFPA 70E isn’t common sense.”
Another respondent agreed, saying he would be happy to see a less restrictive standard on control panels. “NFPA 70E seems to make troubleshooting more dangerous due to the mobility limitations created by the PPE you are wearing,” he said. “I think we spend more time in a panel because of it. We all know there are some problems you cannot troubleshoot with the door closed, or with the door open and the power off. PPE makes working with small hand tools a clumsy event. I would go so far to say that the current NFPA 70E standards have taken a lot of the fun out of working on control panels.”
The standard is too complex and overcautious as it relates to control panels, offered another participant. “That is why most disregard the standard,” he said. “The litigious nature of the U.S. has ‘helped’ this standard to be adopted by large companies without regard for the actual hazard or the practical use of PPE. A huge industry has been created for NFPA 70E PPE products and devices. I would be surprised to see the standard amended to reduce the need of PPE in some cases.”
One respondent went so far as to call today’s arc flash standards “a running joke.” He added, “I can count on one hand the number of times I have even seen someone (let alone been suited up myself) wearing a full set of PPE. Then, it is so cumbersome that the actual work cannot be performed without someone right next to him—without the PPE—handing him tools, reading instruments, and holding probes. And then that extra person is actually in violation, so…what’s the point? Standards to follow are a good approach, but they must be clear and not make a job so expensive that the business will be lost to someone who doesn’t follow them.”
Finally, one respondent offered congratulations to the integrator who raised the issue in the first place. “I congratulate the mystery man for his efforts to bring some reasonableness to the arc flash discussion,” he said. “It’s sad that we can’t criticize the safety industry without fear of reprisal, however. That indicates that safety rules by fear rather than reason, doesn’t it?”
Survey questions and results: Survey was available on the Control Engineering website, www.controleng.com, for readers of the PPE safety article cited above. It was available from Oct. 17 to Dec. 16, 2011. Total responses=302.
Question 1: Do you work on applications requiring electrical personal protective equipment (PPE) according to NFPA 70e?
- Yes: 289 (96%)
- No: 13 (4%)
2. Do you wear PPE as required?
- Always 18 (6%)
- Mostly 41 (14%)
- Sometimes 81 (27%)
- Rarely 98 (32%) (Rarely + Never = 59%)
- Never 63 (21%)
- No response 1 (negligible)
3. Do you have electrical PPE available to use?
- Always 119 (39%)
- Mostly 56 (18%) (Mostly + Sometimes = 37%)
- Sometimes 55 (18%)
- Rarely 37 (12%)
- Never 30 (10%)
- No response 5 (2%)
4. Is fire-retardant clothing (and other PPE) required when working on energized panels greater than 50 V?
- Yes 199 (66%)
- No 96 (32%)
- No response 7 (2%)
5. Do you use electrical PPE when working on non-high-voltage problems (such as programming an ac variable frequency drive)?
- Always 11 (4%)
- Mostly 7 (2%)
- Sometimes 25 (8%)
- Rarely 72 (23%)
- Never 183 (61%) (Rarely + Never = 84%)
- No response 4 (1%)
6. Do you use electrical PPE when using your electrical meter?
- Always 17 (6%)
- Mostly 22 (7%)
- Sometimes 60 (20%)
- Rarely 97 (32%)
- Never 102 (34%) (Rarely + Never = 66%)
- No response 4 (1%)
7. Do you work on (actually touch) energized circuits greater than 120 V?
- Yes 170 (56%)
- No 124 (41%)
- No response 8 (3%)
8. Do you work on (actually touch) energized circuits greater than 50 V?
- Yes 222 (74%)
- No 75 (25%)
- No response 5 (2%)
9. Would you wear your electrical PPE to plug in a floor lamp in your home?
- Yes 1 (negligible)
- No 295 (98%)
- No response 6 (2%)
10. Do you regularly violate NFPA 70e rules when working on control panels?
- Always 104 (34%) (Always + Mostly=72%)
- Mostly 115 (38%)
- Sometimes 59 (19%)
- Rarely 13 (4%)
- Never 8 (3%)
- No response 3 (1%)
11. Is the NFPA 70E standard too complex to follow and too restrictive for everyday use?
- Yes 283 (94%)
- No 17 (6%)
- No response 2 (negligible)
12. Should industrial control panels have their own arc flash standard?
- Yes 269 (89%)
- No 28 (9%)
- No response 5 (2%)
For more information on these topics…
Are there international implications? See http://www.controleng.com/blogs/machine-safety/blog/machine-safety-nfpa-70e-and-international-requirements/d34a06a9fe.html
– Attend an arc-flash webcast at www.plantengineering.com/webcasts.
– See the original article that sparked the survey. Codes and Regulations: Electrical Controls’ Dirty Little Secret: We Don’t Follow NFPA Rule at http://bit.ly/ovLLWF
– Safety and Security Channel www.controleng.com/channels/plant-safety-and-security.html
– Machine Safety blog www.controleng.com/blogs/machine-safety.html