Tim Rohrer is president, CEO, and founder of Exiscan, a Rochester, NY-based provider of infrared windows and other industrial electrical safety products. At UE Systems’ Reliable Asset World conference in May, he previewed the 2018 revision of NFPA 70E, the Standard for Electrical Safety in the Workplace. One of the biggest changes for 2018, Rohrer says, is the heightened focus on following the six-level hierarchy of risk controls to protect workers from electrical hazards. Rohrer spoke recently with Plant Services about what this means for employers – and workers.
PS: The hierarchy of risk controls – (1) hazard elimination, (2) substitution, (3) engineering controls, (4) warnings, (5) administrative controls/training, and (6) personal protective equipment (PPE) – isn’t new. So how does NFPA 70E 2018 call greater attention to it, and what’s the reason for doing so?
TR: In the 2015 revision, they moved the references to the hierarchy of risk controls from the appendix into an informational note in the body of the text, but the appendix and informational notes are referred to as optional language. It’s not part of the mandatory language of the text. In this revision cycle, there is a greater emphasis on risk assessment, and there’s better clarification on how to perform a risk assessment.
The upcoming revision, expected to be released in September, will move the hierarchy to mandatory language by clarifying the risk assessment process. After identifying a hazard, you will assess the likelihood that a person would be exposed to the hazard – for example, an arc flash event. If a likelihood exists, the hazard must be mitigated using the hierarchy of risk controls. You’ll seek to mitigate risk by the most effective method available, preferably by eliminating the hazard. If elimination is not an option, then substitution is the second-most-effective method, then engineering controls, and on down the line to PPE. That’s not to say PPE isn’t important; it’s critically important if you can’t mitigate otherwise. Using this hierarchy protects personnel by controlling risks in the most effective manner available.
Hazard elimination has always been the prime directive. I tell people, NFPA 70E is really a very simple document; if you want to boil it down to one sentence, it’s, “Turn it off before you go in.” De-energizing has always been the #1 thing you’re supposed to do. Unfortunately, when people would pick through the document, they often saw the old table section and mistakenly interpreted it as “identify the hazard, and grab your PPE if you want to work energized.”
PS: What’s your sense of the early response to this revision?
TR: It really depends on the facility. Progressive facilities that place a higher emphasis on worker safety, they have a “we don’t do that here” kind of a philosophy. “We just don’t open energized gear on site, end of story.” Others will try to jump through the loophole of infeasibility. The infeasibility clause basically allows for energized work if it’s not feasible to do your task in another way, and it gives the example of doing diagnostics such as thermography. But what a lot of facilities will try to stretch that into is, “Well, it’s not feasible to shut down because we’re trying to get all the product out the door that we can this week.” That’s not infeasible; that’s inconvenient. And those are two entirely different things.
PS: What should EH&S and maintenance teams do to prepare for the changes in NFPA 70E 2018?
TR: Take a look at the work processes (you) have in place for various tasks, especially routine tasks, and just start to pick through it and say, OK, how could we do this with a higher order of risk control rather than jumping right straight to PPE? If I were a pit-crew boss for a racecar, I would never say to my driver, “Hey, we’ve got a lot of looseness on the right front tire, and we’ve got some funkiness going on over here, but don’t worry – you’ve got your magic suit and helmet on, so you’ll be safe.” You’d never say that. You’d first try to tighten that car up so that it was as safe as possible. It’s a similar analogy to how people should be approaching electrical preventive maintenance.
Similarly, I’d never go to my driver and say, “Hey, this car is probably the safest thing we’ve ever put on the track; you can leave the magic suit and helmet in your locker.” If the worst-case scenario ever happened, you would want them to be wearing their PPE. If you’re not able to eliminate the hazard or substitute it down to an acceptable level, you’ll be using PPE as part of a suite of control measures.