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Risk Assessment and Your Electrical Safety Program

Paper No. ESW2015-28
Daniel Roberts
Senior Member IEEE
Schneider Electric Canada Inc.
5985 McLaughlin Road
Mississauga, ON L5R 1B8
daniel.roberts@schneider-electric.com
Abstract – The 2015 editions of NFPA 70E and CSA Z462

published in 1979 and included only Part I, installation
requirements. The second edition was published in 1981
and included Part II, work practice requirements.
The focus in Part II work practice requirements up to and
including the sixth edition in 2000 was on establishing
protection and approach boundaries and the use of personal
protective equipment (PPE). From an Occupational Health
and Safety (OHS) perspective, administrative methods and
PPE are the least effective risk control methods.
In this regard, the first substantive change occurred in the
2004 edition. Part II work practice requirements was retitled and relocated to Chapter 1. The chapter was
reorganized to emphasize working on live parts as the last
alternative work practice and an energized electrical work
permit and related requirements were incorporated.
The next big step forward from an OHS perspective was
two editions later in 2012. Article 110.7(F) revised to
clarify the separate but directly related concepts of hazard
identification and risk assessment. While this might not
seem like a substantive revision, it set the stage for the major
revisions to the 2015 edition.
Following the publication of the 2012 edition, a task
force was established by the chair of the 70E technical
committee to review the use of the terms hazard and risk,
comparing them to other standards that deal with the topic.
The task force created 85 proposals for revision, all of which
were accepted in one form or another. To summarize the
task group’s work:
• Propose definitions for Hazard, Risk and Risk
Assessment that were consistent with other safety
standards;
• Propose revisions to the rest of the document to
ensure the consistent use of these terms;
• Propose inclusion of a hierarchy of risk control
methods consistent with other safety standards such
as ANSI Z10 and CSA Z1000.
The Electrical Safety Program requirements were given
further prominence as they are relocated to the front of
Article 110. Additionally, an employer’s electrical safety
Program must be part of their Occupational Health and
Safety Management System (OHSMS), when one exists.
This subtle, but ultimately substantive revision will be
discussed in this paper.

have taken a significant step forward by integrating Occupational Health and Safety Management Systems and Risk
Management principles. This paper will explore how this
changes and advances the electrical safety culture and enables sustainable improvement in prevention of electrical
incidents and injuries. The paper will also discuss how these
changes can be integrated into an organizations electrical
safety program and how risk assessment can be performed at
an organizational level and at a worker level.
Index terms – acceptable risk, ANSI/AIHA Z10, CSA Z462,
electrical safety, hazard, hazard identification, ISO 31000,
NFPA 70E, Occupational Health and Safety Management,
OHSMS, risk, risk analysis, risk assessment, risk control, risk
evaluation, risk management

I. INTRODUCTION
Until recently electrical safety has largely been left to the
electrical professional. Most safety professionals receive
little if any education about electricity, arguably one of the
most ubiquitous hazards. However, electrical hazards are
not so unique that the risk associated with those hazards
needs to be managed differently than any other safety risk
[1]. With the 2015 editions of NFPA 70E and CSA Z462,
electrical safety has embraced safety theory.
II. HISTORY OF NFPA 70E [2]
At the urging of the US Occupational Safety and Health
Administration (OSHA), electrical professionals rose to the
challenge. January 7, 1976 the Standards Council of the
National Fire Protection Association announced the formal
appointment of the Committee on Electrical Safety
Requirements for Employee Workplaces, NFPA 70E. The
committee’s mandate was to assist OSHA in preparing
electrical safety standards that would serve OSHA’s needs
and that could be expeditiously promulgated through the
provisions of Section 6(b) of the Occupational Safety and
Health Act [2].
The new standard was visualized as consisting of four
major sections: Part I, Installation Safety Requirements; Part
II, Safety-Related Work Practices; Part III, Safety-Related
Maintenance Requirements; and Part IV, Safety
Requirements for Special Equipment. The first edition was

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It forces us to be analytical and. will bring the benefits of a management systems approach to electrical safety. analyzes the risk associated with that hazard. their DNA. Why is this important? Definitions are the anchor of any standard. Research suggests that most people tend to underestimate the likelihood of the occurrence of harm. integration and participation. As electrical safety standards NFPA 70E and CSA Z462 are unique. results in continuous and sustainable improvement in risk reduction – a safer work environment. are founded on six common elements: Leadership commitment. The analysis can involve complex charts to quantitatively predict the likelihood of occurrence and severity of harm. They perform this assessment without using a complex matrix to analyze each factor that contributes to the likelihood of occurrence of harm and the severity of harm. Applying the principles of OH&S risk assessment brings methodology and rigour to the process. and analyze and estimate the risk associated with each identified source (Can I get hurt? How bad could it be?). There is nothing quite like them anywhere else in the world. and each time it means the same thing: The combination of the likelihood of occurrence and the severity of harm. RISK ASSESSMENT Risk is the combination of the likelihood of harm occurring and the severity of that harm. In the 2015 edition. There are two mental systems used to process risk: analytical and experiential. OHSMS The new requirement for employers to integrate their electric safety program into their OHSMS. Benefits of the PDCA cycle are compatibility. The phrase hazard/risk is no longer used. Health and Safety professionals will find the documents easier to navigate and comprehend. Safety results do not rise and fall with a single champion. they use the most elementary of risk matrices: Yes and No. They can collaborate intelligently with the Electrical Professional to advance and change the electrical safety culture. a management system Policy. when one exists.00 ©2015 IEEE . The former is logicoriented and governed by conscious thought processes while the latter is feeling-based and governed by associative connections from previous experiences. and a repeating cycle of Plan-Do-Check-Act (PDCA). the term risk is used 89 times in Chapters 1 to 3 and the Annexes. The repeating nature of the PDCA cycle. As noted. Sometimes it refers to the likelihood of something occurring and sometimes it refers to the combination of the likelihood of occurrence and the severity of harm (the OHS meaning of the term). For example. This is due to how we develop our perception of risk. However. they are part of an organization’s culture. When a key term such as risk is 2 978-1-4799-4782-9/15/$31. Compatibility facilitates integration of all risks. risk and risk assessment. Risk assessment is a process that begins with hazard identification. into an organization’s day to day operation. IV. Management systems improve organizational performance by applying a systematic approach to a specific risk [3]. During everyday normal activities people consciously or subconsciously assess risk. Every person in the organization has a vested interest and plays a part in managing safety. Table 1 provides an overview of the development and substantive revisions to NFPA 70E since the first edition was released in 1979. Then they qualitatively evaluate the level of risk as acceptable or unacceptable with a simple Yes or No response. rather. including safety. when properly implemented. The best state for a given risk cannot be achieved at once [3]. the term risk is used 133 times in Chapters 1 to 3 and the Annexes of 70E-2012 with different shades of meaning. RISK MANAGEMENT PRINCIPLES Incorporating risk management principles into NFPA 70E and CSA Z462 will bring many benefits to electrical safety. CSA Z1000 and Z1002. they did not always align with how other recognized safety standards approach the related but different topics of hazard and risk. Analyzing risk involves quantitatively or qualitatively estimating the likelihood of harm occurring and the severity of that harm. Management systems. and greatly underestimate the severity of harm (the “bad things happen to someone else” syndrome). and concludes with risk evaluation. Most people tend to favour the latter because it is quicker and easier [5]. Safety is not the safety manager’s job. The result is clarity and consistency within the document and with other safety standards such as ANSI Z10. III. very importantly. including safety management systems. When an organization’s Leadership is committed to and sponsors an initiative it gets attention – from everyone. or it can be a simple qualitative two-bytwo digital matrix. as in the phrase hazard/risk. it comes with a hierarchy of risk control methods based on three simple principles [6]: • Remove the source IV. Sometimes.used that many times it is important that the meaning be clear and consistent [4]. the 2015 edition defines key risk management terms such as hazard. It becomes a priority. They identify sources of harm (What can hurt me?). the meaning isn’t at all clear. it is everybody’s job from the CEO to the person making the product or delivering the service. Clarity and focus result when the initiative’s goals and objectives are clearly articulated in the management system Policy. Two key concepts in the definition of risk are likelihood and severity. Most people practice a qualitative form risk assessment as we engage in everyday activities. continuous improvement and sustainability.

Case history: The Vancouver Airport discovered that sometimes the blockage is small enough that it can be dislodged by reversing the impeller. identifies hazards associated with 3 978-1-4799-4782-9/15/$31. Retrofitting a reset button on the door eliminates the need to open the door and thus reduces the likelihood of electric shock. Risk assessment commonly involves either a task-based approach or a hazard-based approach [8]. TABLE 2 INTEGRATION OF KEY OHSMS AND RISK ASSESSMENT ELEMENTS INTO AN ELECTRICAL SAFETY PROGRAM [6] Elements NFPA 70E-2015 Leadership 110. etc.1(D) Identify the principles upon which the electrical Policy safety program is based. (2) Identify electrical hazards (3) Assess the associated risk. Some of the hazards involved with these activities include: • Ergonomic and mechanical hazards while accessing the impeller. Performing this activity on older motor control centres (MCC) usually involves increasing the likelihood of electric shock as the MCC door must be opened to access the reset button. Material purchasing examples: VI.1 (A) Establish. In the hazard-based approach hazards are identified and characterized for materials. accessing the impeller to remove the blocked material.1(G) Establish a risk assessment procedure to: (1) Identify hazards. Activities that might be affected by those hazards are identified. implement and document an electrical safety program that is part of the employer’s OHSMS. the worksite and the environment. 110. (2) Assess risks. (3) Implement risk control according to a hierarchy of methods 110.00 ©2015 IEEE . training or procedures to ensure: (1) Compliance with the Standard (2) Adherence to the principles and procedures V. this paper will apply a hazard-based approach at the organizational level. IV.2(D)(b)(4) Qualified workers must be able to: (1) Perform job safety planning.1(H) Job briefing before starting each job to discuss hazards. INTEGRATION INTO AN ELECTRICAL SAFETY PROGRAM Table 2 demonstrates how the six key elements of OHSMS and risk management can be integrated into an electrical safety program by following the requirements of NFPA 70E-2015 and CSA Z462-2015. specifying and purchasing electrical distribution equipment.1 (A) The electrical safety program must direct activity appropriate to the risk associated with electrical hazards Do 110. RISK ASSESSMENT AT THE ORGANIZATIONAL LEVEL Risk assessment and the hierarchy of risk controls can be applied to any type of risk at any stage in the life cycle of a product.• • Change the consequences Change the likelihood When designing. While either approach can be applied at the both organizational and field level. breaks it down into discrete tasks. The process to clear the blockage involves locking out the motor control disconnect. processes. process or service [7]. resetting the motor overload. The risk associated with each activity is analyzed for likelihood of harm and severity of harm. By installing a motor-reverse switch they reduced the frequency of worker exposure to those hazards.1(I) Audit results are used to revise the program. Frequent operations of motor overloads occur when large objects such as pieces of wood get caught in effluent impellers. (4) Select appropriate risk control methods from the hierarchy of controls Check 110. procedures. RISK ASSESSMENT AT THE WORKER LEVEL [4] Task-based risk assessment begins with a job. It enables decision-makers to effectively reduce risk before the worker begins interacting with the process or product. • Resetting the motor overload.1(I) Audits: (1) The electrical safety program (at least every 3 years) (2) Field work (annually) Act 110. when one exists 110. an employer can reduce risk by specifying ‘substitution’ and ‘engineering’ risk control methods that affect the likelihood of occurrence or severity of consequence. energy source controls. and placing the motor back into service. Risk treatment for severity of consequence could include: • Reduce incident energy by faster arcing fault detection and interruption time • Divert the arc flash energy – “crowbar” the conductors to collapse the voltage and extinguish the arcing event • Contain the arc flash energy through arc resistant design • Create distance between personnel and the arc flash energy through the use of remote operation and remote racking Risk treatment for likelihood during the design phase and pre-use phase could include: • Equipment design features such as insulated bus • Distribution system design such as high-resistance grounded distribution system • ‘Finger-safe’ technology • 24vac rather than 120vac controls • Externally accessible reset controls and communication ports rather than controls and ports that are only accessible by opening equipment doors Process example: Pumps of varying descriptions are utilized to move effluent through waste water treatment processes. including: (1) De-energizing if possible (2) Job planning (3) Maintenance (4) Auditing Plan 110.

to include foreseeable interactions with equipment. In this table Voltage Above or Below Selected Threshold means the voltage threshold at which electric contact is not likely to result in harm. repair or testing. maintenance. NFPA 70E and CSA Z462 indicate that this threshold is 50 Vac and 100 Vdc. the work site. the use of engineering controls such as temporary barriers (rubber insulating blankets or other cover-up materials) can be an effective risk control method. it is likely they have endured several electrical contacts during their career without any measurable physiological effects (experiential). When de-energizing is not feasible. Is the insulation. Partnering Electrical and OHS professionals can only benefit electrical safety. “Note feasible” does not include installation. but it is usually not possible to perform diagnostic testing while equipment is de-energized. This integration will also provide employers and workers with a method of sustainable and continuous improvement in electrical safety performance. In some jurisdictions the accepted thresholds are lower [9]. and possible failures. Hazard identification Identifying the potential for electric shock involves identifying situations when exposure to electric conductors is not adequately controlled by insulation. This usually occurs when the electrical worker removes a cover or in some other way compromises the insulation. installation and repair while equipment is de-energized. malfunctions. guarding. In this table. isolation. procedures and PPE). Appendix B of the Code defines “not feasible” as “troubleshooting of control circuits. This is the most common approach when performing a field level risk assessment. Electric shock occurs when electric current passes through the human body. this risk assessment can be quite simple. or equipment design. including testing for the absence of voltage during a lockout procedure.00 ©2015 IEEE . CONCLUSION The integration of OHSMS principles and risk management principles into the 2015 editions of NFPA 70E and CSA Z462 will make these Standards more accessible to OHS professionals. testing and diagnostics”. Diagnostic testing. Most importantly. isolation. Shock from electrical equipment is usually prevented by ‘substitution’ and ‘engineering’ risk control methods such as insulation. electrical contact means direct contact TABLE 3 SHOCK HAZARD FIELD LEVEL RISK ANALYSIS MATRIX Electrical Contact Electrical Contact NOT Possible Possible Voltage ≤ Risk Acceptable Risk Acceptable [Selected Threshold] Voltage > Risk Acceptable Risk Unacceptable [Selected Threshold] The Canadian Electrical Code Part I addresses the “possible versus not possible” question in Subrule 2-304(1): “No repairs or alterations shall be carried out on any live equipment except where complete disconnection of the equipment is not feasible”.g. and guarding or equipment design. training. equipment design or a combination thereof. When the answer to both questions is YES. Additionally. where the electrical professional is practicing their craft. The most effective application of the requirements of hazard-specific Standards is achieved within the framework of an OHSMS. Analyze the severity of harm of using a Yes or No matrix. VII.g. loss of body parts or death)? This is where some electrical workers get themselves into trouble. guarding. isolation. installation. it is possible to perform maintenance. Risk analysis Analyze the likelihood of making electrical contact using a Yes or No matrix. burns. yet they know that electrical contact—even at 120V—can be fatal (analytical). the worker must utilize the hierarchy of controls starting with elimination. worker qualifications. requires the use of a combination of administrative risk control methods (e. and environment. each task and then analyzes the risk. Could electrical contact result in harm (e. this approach will benefit all electrical workers by directing them away from an experiential response to a structured analytical response to electrical hazards. Consider the example of a shock risk assessment. This might be done for the purposes of maintenance. This analysis anticipates adverse outcomes and their most probable severity [8]. CSA Z462 and NFPA 70E identify a safety boundary called the restricted approach boundary as the distance within which contact should be considered a possibility.or approach within the arc-over distance specified in Annex C of NFPA 70E and CSA Z462. the tendency is to jump to the last risk control method: PPE. repair or alterations. Table 3 is an example of a two-by-two YES/NO – risk acceptable/unacceptable – risk analysis matrix for shock hazards. A “what-if” analysis is performed on human behaviors involved with the task. or will a worker’s actions compromise it such that electrical contact is possible? Notice that the question is about the possibility of electrical contact (analytical) not whether the worker can be careful enough to avoid electrical contact (experiential). adhering to risk management principles ensures that risk control methods are systematically identified and applied in a hierarchical approach. 4 978-1-4799-4782-9/15/$31. isolation. Is possible to eliminate the hazard (de-energize by following an approved lockout procedure) and still complete the task (analytical)? For example. guarding or equipment design compromised. At the field level. While the risk control method of substitution is not usually possible at the field level. or deficiencies.

Preface [8] ANSI Z10-2012 Occupational Health and Safety Management Systems.intechopen. Current Trends and Future Developments in Occupational Health and Safety Risk Management. He is the vice-chair of the CSA Z462 Workplace Electrical Safety Technical Committee. and Floyd H. Issue: 1. No. Daniel is a longstanding Canadian Standards Association (CSA) member and serves on several CSA Technical Committees including the Canadian Electrical Code Part 1. 50 V Shock Hazard Threshold. Risk Management & Electrical Safety.T. 3. T. Volume: 46.T. Integrating OHSMS. D. D..R. A.L. Daniel received the CSA 2013 Award of Merit for sustained and influential contributions to OHS and Electrical Safety Standards.. 5 978-1-4799-4782-9/15/$31.. I. He is also an ASSE member and an IEEE Senior member. Page 102 IX. Paper No. Electrical Safety Consulting at Schneider Electric Canada. Risk.VII. ESW2014-38. D.. Electrical Business Magazine. VITA Daniel Roberts is the Senior Manager. 19. IEEE Transactions on Industry Applications. IEEE Transactions on Industry Applications. Appendix F [9] Roberts. Volume: 50. September. Risk Management of Electrical Hazards.. Hazard vs. and Z1002. Cultural Drift and the Occlusion of Electrical Safety. REFERENCES [1] Roberts. IEEE IAS 2014 ESW [7] CSA Z1002-2012 Hazard identification and elimination and risk assessment and control. Z1001. D.com/books/risk-management-for-the-futuretheory-and-cases/current-trends-and-future-developments-inoccupational-health-and-safety-risk-management [4] Roberts. IEEE IAS Applications Magazine Vol. May/June 2013. page 21 [2] NFPA 70E – 2015 Forward [3] Moraru.00 ©2015 IEEE . CSA Z1000. http://www. T. 2014 [5] Floyd.. Issue: 3 [5] ISO/IEC Guide 51:2014(E) Safety aspects – Guidelines for their inclusion in standards [6] Roberts.

and potential arc flash boundary information in the hazard/risk category tables relocated from the notes to the body of the table. Since 2004 the title has been Standard for Electrical Safety in the Workplace. An energized electrical work permit and related requirements incorporated. electrical shock. Hierarchy of risk control methods added. In 2004 the four Parts became Chapters. N. Note: The title of NFPA 70E from 1979 to 2000 was Standard for Electrical Safety Requirements for Employee Workplaces. The new method separates likelihood of occurrence from severity of occurrence.7(F) revised to clarify the separate but directly related concepts of hazard identification and risk assessment. and J and the addition of Annex M. Significant revisions to Annex D. Minor revisions Part IV created Relocated Chapter 2 Relocated Chapter 3 Minor revisions Article 350 added for R&D facilities Installation requirements removed Minor revisions Equipment owner or designated representative is responsible for maintenance of the electrical equipment and documentation related to maintenance. Risk assessment to be performed prior to any work on a battery system to identify the chemical.00 ©2015 IEEE .Table 1 – Summary of substantive OHS revisions to NFPA 70E Edition 1979 1981 1983 1988 1995 2000 Installation Safety Requirements Part I – Compilation of NEC requirements Minor revisions Minor revisions Minor revisions Updated to correlate with the 1993 edition of NEC Updated to correlate with the 1999 edition of NEC 2004 Relocated to Chapter 4 Updated to correlate with the 2002 edition of NEC 2009 Chapter 4 deleted 2012 N/A 2015 N/A Safety-Related Work Practices N/A Safety-Related Maintenance Requirements N/A Safety Requirements for Special Equipment N/A Part II created Minor revisions Minor revisions ‘‘Limits of approach’’ and ‘‘arc flash’’ concepts introduced N/A Part III created Minor revisions Minor revisions N/A N/A N/A N/A Hazard/risk category method added. ‘‘Flame-resistant (FR)’’ term replaced by ‘‘arc-rated’’ throughout the standard. Prohibited Approach Boundary deleted. Relocated to Chapter 1 Reorganized to emphasize working on live parts as the last alternative work practice. 6 978-1-4799-4782-9/15/$31. and O Article 110. Short-circuit current. Focus continues on establishing protection and approach boundaries and the use of personal protective equipment. Four new definitions related to hazard and risk. Electrical safety program required to be part of the employer’s Occupational Health and Safety Management System (OHSMS) when one exists. F. Hazard/Risk category 0 deleted. and arc flash hazards and assess the risks associated with the type of tasks to be performed. Entire document revised to ensure consistent use of hazard and risk terminology. fault clearing time. Hazard/Risk category method revised to the Arc Flash PPE category method.