Assessing for regulatory compliance of your facility’s electrical system

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Many organizations understand the importance of assessing their operations but often operate on their own self-assessments that measure against their own criteria. Organizations such as the National Fire Protection Agency (NFPA) and the Occupational Safety and Health Administration (OSHA) have published regulations that are the industry standard to ensure organizations are operating their electrical systems as safe as possible, and sometimes a facility’s internal criteria do not measure up to these standards.

Compliance with standards is a complex topic, and to mitigate the risk of non-compliance many organizations partner with external advisors. When we assess a facility there is oftentimes a gap in understanding of what is required for the safe operation of facility power systems. While some of the customers we work with are taking steps to bring their electrical safety policy into compliance with current versions of applicable OSHA and NFPA standards, some policies do not meet the intent of the industry standards.

It is critical facilities know and understand these regulations and try their best to have their facilities comply with them. Schneider Electric has a six-step process to assess facilities and ensure they are in compliance.

The six steps to a proper assessment of your facility’s electrical system

  1. Audit the Electrical Safe Work Practices (ESWP) Policy: This is a written document that covers all areas of the company’s electrical safety practices and includes lock out/tag out procedures, method of qualifying the workers, selection, and application of PPE and more. Organizations should plan to audit the safety policy every three years to assure continued compliance. The policy needs to be continually revised over time to ensure that it is up to industry standard.
  2. Review the Incident Energy Analysis (Arc Flash Study) and Equipment Labeling Practices: NFPA 70E-2018 Section 130.5 states an arc flash risk assessment shall be performed to identify arc flash hazards and estimate the likelihood of injury or damage to health, to assess the potential severity of injury or damage to health, and to determine if additional protective measures are required, including the use of PPE. Arc flash PPE may be selected either by the incident energy analysis method or by the PPE category method. The incident energy analysis method is a study that is overseen by professional engineers who are familiar with the power distribution and control equipment, and the calculation methods required.
  3. Evaluate the Implementation of Strategies to Mitigate and Control the Risk Associated with Arc Flash: In 2018, NFPA 70E mandated the use of the hierarchy of risk control methods when conducting task risk assessments for electrical work. The hierarchy of risk control implements preventative and protective risk control methods in the following order from most effective to least effective:
    • Elimination (physically remove the hazard)
    • Substitution (replace the hazard)
    • Engineering Controls (isolate the hazard)
    • Awareness (train, inform and warn)
    • Administrative Controls (change work habits)
    • PPE (protect workers from the hazard)

It’s important to note that using PPE is the least effective means of risk control and is essentially the last line of defense to worker protection.

  1. Review the Electrical Safety Training Program Content and Implementation: NFPA 70E-2018 defines a qualified person as “one who has demonstrated skill and knowledge related to the construction and operation of electrical equipment and installations and has received safety training to identify and avoid the hazards involved.” Having this background means that the employee must have received safety training specified to identify the hazards and reduce the associated risk. Electrical workers are not considered to be qualified by OSHA until they have received this specific training.
  2. Evaluate the Maintenance Practices and Methodologies of Power Distribution Equipment: It is crucial to keep “active” components in electrical distribution systems such as fuses, circuit breakers, and protective relays in proper operating condition with a regular maintenance program. Without proper over-current protection, sustained arcing can subject electrical workers to much higher levels of energy. Unless adequate maintenance is performed, the electrical system study and the arc flash analysis will not be a correct representation of the potential performance of the power system.
  3. Review the Approach to Electrical PPE and Tools: Employees working in areas where there are potential electrical hazards should be provided with PPE that is appropriate for the specific parts of the body to be protected. This can include an arc-resistant shirt, pants or coveralls, or a multi-layer flash suit.

Much like a personal financial investor can mitigate the risk of financial loss, a power system engineer that is well trained in electrical safety can ensure facilities operate under the most current rules and guidelines, mitigating the risk of non-compliance, safety citations and personnel injury.

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