Almost every compliance audit I do results in one or more findings related to electrical safety, from the ubiquitous improper use of extension cords and power strips to high risk issues like uncontrolled work on energized equipment (with or without suitable personal protective equipment). These situations are clear indicators of gaps in the safety management system. Let's consider some example cases, starting with the common, lower risk issues.
At almost every site, I find a few overloaded or daisy-chained power strips and extension cords. Generally, this happens when someone needs to plug in something far away from the closest wall receptacle, or the number of items to plug in exceeds the number of outlets available. Before you know it, two refrigerators, a pump, and a soldering iron are all plugged into one 15-amp power strip, which is plugged into an extension cord that runs behind a bench and 2 file cabinets to the wall receptacle half-way around the room. Why? Because the workers who use this equipment, as well as their supervisor, weren't aware that this arrangement creates a safety hazard; no internal safety walk-through had identified it; and no one thought of moving the equipment nearer to the wall receptacle or requesting the installation of a quadruple wall receptacle near the equipment. That's because no one saw any problem with the set up. Lack of awareness and inadequate inspections are also the most frequent causes of findings like blocked electrical panels and cut-off switches.
Higher in the risk spectrum is equipment that has not been evaluated for arc flash hazard. Some facility managers aren't aware that such an assessment is required; others just haven't gotten around to doing it. In other cases, certain pieces of equipment were missed or excluded when the assessment was done. Often the arc-flash hazard assessment is done by a contractor, so the project has to go through layers of budgeting, bid solicitation, and scheduling. Scheduling can be particularly onerous if production equipment has to be shut down to complete the study. But a thorough hazard assessment is essential to building a constructive safety management system -- without that step, it's impossible to implement effective controls.
Even greater risk is posed by the combination of serious hazards and gaps in controls when I find people working on energized equipment. Rarely does such work fall within OSHA's allowable live electrical work justifications or the minor servicing exemption for Lockout/Tagout. Why then are employees working on live equipment? They say they can't shut down production -- they don't even bother to ask.
In these cases, I usually also find the organization lacks a written permit system, which is required by NFPA 70E when work is performed on energized equipment within the limited approach boundary or the arc-flash boundary. Furthermore, employees are often working without appropriate PPE (that is, PPE rated for the level of hazard that has been properly tested and maintained). The safety management system has failed to implement important hazard and work practice controls.
Electrical safety, like any other aspect of safety, requires a well-planned and carefully implemented management system including hazard and risk analysis; knowledge and understanding of legal requirements; assignment of clearly defined roles, responsibilities, and authority; training and awareness; communication and employee involvement; hazard controls; operational controls; inspections; reviews; and management of change. It sounds simple, but of course it's not.
If you're uncertain how well your electrical safety program is functioning, walk around and look carefully at the electrical equipment in your facility. Talk with the people who maintain and service it and see if any gaps begin to appear.
Barbara Jo Ruble, QEP, CPEA is the President of Specialty Technical Consultants. She has more than 30 years of experience helping clients in a wide variety of industries to develop, assess, and improve their EHS management systems and compliance programs. Barb has performed more than 200 EHS compliance audits or management systems assessments of industrial facilities worldwide. She has also provided independent review of corporate EHS auditing programs. Barb is the primary author of OHSAS 18001/OSHA-VPP Occupational Health & Safety Management Systems: A Complete Implementation Guide, published by Specialty Technical Publishers of Vancouver, Canada.
For more information about STC's EHS auditing services or to discuss this article, contact Barb at bruble@stcenv.com or at 410-625-1952.
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