When considering electrical injuries and fatalities, the common focus of electrical safety programs is on the workers most likely to come into contact with energized electrical parts on a daily basis. The electrician maintaining power systems or the instrumentation technicians adjusting and calibrating 120 volt field process devices are two common examples of workers in this higher risk group. Company safety professionals fully understand, both by regulation and practice, that any possibility of workers coming into contact or working “near” live parts 50 volts and above must be controlled by policy or a combination of safe work procedures while utilizing all appropriate PPE. Many training hours and subsequent equipment expenditures have been spent to ensure these workers with the highest perceived possibility and consequence of electrical contact are both prepared and protected. Recently released data suggests that nearly half of the electrical contact incidents reported are involving workers whose primary job function is not in this group normally considered at high risk of electrical contact. Both NFPA 70E and CSA Z462 include language recognizing that the employer must direct all activities in the workplace where there is use of electricity or maintenance of the electrical system. Job title or job description is not really relevant where electrons are concerned. Electrons can be called “Equal Opportunity Offenders” when the human body is involved.
Tasks as significantly minor in risk of electrical contact as plugging in a cord to power an office device or visually inspecting electrical equipment during preventative maintenance tasks performed by non-electrical workers can result in injury or death. The employer is as equally responsible to prepare and protect these workers with the same vigor as those workers who may intentionally come into closer proximity to energized parts on a daily basis. Those whose job tasks require removing designed protection of covers and doors resulting in exposure to energized electrical parts must possess knowledge and skills with demonstrated proficiency to recognize the hazards and avoid injury. These we call “qualified electrical workers” and recognize their risk of contact. Extensive training and competency validation follows to ensure they are adequately protected. After thorough review of their work assignments and plant conditions the electrical safety program contains specific line items on where, when and how they may do certain energized electrical tasks. Workers whose job tasks involve using electricity, especially cord and plug connected tools, yet are not directed to maintain the electrical system or tools must have equally clear instruction. This lower perceived risk group we call “non-qualified workers” and protect them from contact by denying permission to come into an area or condition where contact with energized electrical parts is possible. Given this resolve how then do we explain the incident data revealing this non-electrical group comprises nearly half the electrical injuries and fatalities? Training and required PPE is naturally reduced for this lower risk group to be commensurate to their potential exposure but can it be eliminated altogether? Workers who in their assigned tasks plug into energized circuits with cord and plug connected devices or turn on/off switches to control plant equipment must have their knowledge of electrical hazard awareness and avoidance while doing these tasks validated to ensure compliance to company policies and procedures. Can these workers visually inspect a cord and determine its condition, the outlet for evidence of impending failure or their equipment for fitness for use? As their employer, how do you know for sure? Are there processes in place to document that information and immediate action plans be put into place? When we use the terms “Qualified and Non-Qualified” in conjunction with electrical tasks we have done a disservice which has resulted in safety and compliance confusion. The fact remains that the employer must qualify every worker for every task to which they will be assigned. It is just the extent of the qualification process that is in question, not the idea that a qualification process is somehow an optional activity.
- Does your company electrical safety program specifically cover all workers that may utilize electrical equipment in the performance of their work tasks, not just the electrical workers alone?
- How do you qualify non-electrical workers to safely do their assigned tasks in compliance to your electrical safety program?
- For these non-electrical workers, does your company electrical safety program provide clear direction on the use of electrical equipment and cords and how they are to be tested, inspected and maintained?