Why Compliance based Electrical Safety Programs Fail

The tables in NFPA 70E directing PPE usage are a perfect example.

• By Daryn Lewellyn
• Nov 02, 2009

There once was a suburban doctor whose practice served a seemingly homogenous group: young, educated, "Type A" professionals who commuted to the city for their white-collar jobs at high-profile employers. Increasingly, this doctor's patients began to complain of a similar symptom: chronic headaches.

The well-meaning doctor, already overworked due to a double patient load and now faced with a budding epidemic, began to look for the first similarity he could find among the headache sufferers. "Aha!" he exclaimed with no small amount of satisfaction. "It's their stressful lifestyle! These people need to learn to slow down." Without further examination or evaluation, he instructed each one of his patients who had come to him complaining of headaches to take a vacation to relieve stress. Th at would undoubtedly take care of the problem, he assured them.

It is easy to chuckle at this fictional account, yet many managers exhibit the same kind of carelessness when developing their electrical safety programs. Instead of focusing on safety (i.e., the avoidance of employee injury), many are focused on compliance (i.e., the avoidance of regulatory action taken against them). To put it another way, compliance-first is a mindset that asks, "What do I need to do to stay safe in the eyes of the government?" while a safety-first mindset frames the issue more simply: "What do I need to do to stay safe?"

It is somewhat understandable, given the numerous responsibilities handed to safety managers today. Many do not have any background in electrical maintenance and therefore will turn to a trusted source to seek the path of least resistance — compliance. While there may appear to be only six words' difference in the above statements, the implication of that difference is far-reaching and potentially deadly.

The Difference Between Calculated and Actual Hazard Levels

The problem is that, too oft en, compliance-based safety programs apply a rigid set of guidelines to unique situations that the well-meaning creators of those guidelines could not foresee. A perfect example is the set of tables found in NFPA 70E directing personal protective equipment (PPE) usage. As every safety manager should be aware, OSHA requires employers to protect employees from electrical hazards, including arc flash and shock. Managers with a complianceonly mindset will merely hire someone to look at these tables, prescribe the proper PPE, and call it a day.

The tables may be a good place to begin the process of eliminating electrical hazards but will fall woefully short if they are the only step taken to keep employees safe.

The tables are task-based and divided into eight equipment- and voltage-specific sections. In each section are several tasks that might be performed on that piece of equipment. For example, in the section labeled "600V Class Motor Control Centers (MCCs)," one of the 10 tasks listed for that piece of equipment is "Work on energized parts, including voltage testing." The table says that task on that piece of equipment is a Hazard Risk Category 2*. A worker could then look at a separate chart specifying the PPE needed to satisfy a Category 2 rating. The asterisk means a double layer switching hood is also required. Voltage rated gloves and tools also must be used.

Th is procedure may seem simple enough, but using a tables-only approach to protect from electrical hazards overlooks the critical flaw in the tables' creation: The authors have not visited every facility. The tables are limited to only eight specific pieces of equipment. Although the equipment list covers most situations, it does not cover all of them. If equipment, voltage, or a task is not listed, 70E requires an arc flash analysis. Another limitation is they cover situations only up to Category 4. Some equipment has a hazard risk higher than Category 4; this level means the arc flash will be so severe you cannot work on the panel live.

But the tables' most glaring shortcoming is that they are based on a predetermined available short circuit current and clearing time. Th is current is the maximum amount that would flow during a short circuit at that point. The clearing time is the length of time it would take the circuit protective device to open and clear the fault. The problem with assuming a certain level of current is that your facility may have a higher current or a lower current, and either can result in an increased thermal hazard: More current can mean a higher temperature and larger flash, while a lower current can result in a smaller flash but a longer clearing time, lengthening the duration of the arc flash. Both of these scenarios increase the extent of the burn injury to the employee.

Furthermore, the clearing times for the circuit protective devices that are assumed by the tables may not be accurate in every instance at that current level. Th is will introduce huge inaccuracies in the PPE selected: either not enough protection or too much. Th rough years of doing hundreds of studies, we've encountered numerous examples in which the table has prescribed PPE for a Category 1, while the calculated actual hazard level is a Category 4. More oft en, we find situations in which the tables have ordered too much PPE for the actual calculated hazard level. Th is makes a profound difference to your electrician and his or her ability to work.

Needless to say, these shortcomings can produce a dangerous environment for employees working on or near electrical equipment. Yet the employers who simply uses tables to assess electrical hazards may well appear to be in compliance by virtue of the labels affixed neatly to their electrical panels.

Safety Yields Compliance

Th is brings us back to the doctor. If it was so foolish for the overworked doctor to simply look for similarities in symptoms and lifestyle to diagnose a medical problem, why is it acceptable for the overworked safety professional merely to look for similarities in equipment and tasks to diagnose electrical hazards, given the above mentioned gaps in information? The doctor's prescription may have been spot on in some cases, but by applying a blanket diagnosis to specific patients, the doctor may be overlooking a potentially deadly condition. His patients were probably more than willing to accept a vacation as opposed to a more intensive form of treatment, based on their trust in their medical caregiver. His desire to clear out some of the patient backlog may have left his patients open to worsening health conditions and thus the need for more appointments and office time, and his practice is open to a lawsuit.

And that may be the most ironic aspect of a policy that values compliance over safety: It likely will compound the problems it is intended to avoid. When the goal is simply avoidance of regulatory action from OSHA or another body, safety can be compromised and people can be injured. In that case, there well may be an OSHA citation on the horizon, but if the incident is serious enough, the check for that citation will be the smallest check a company writes. Legal bills, cost of downtime, replaced equipment, employee injury rehabilitation — all will dwarf the cost of that dreaded citation penalty in short order. Compliance-first is a shortsighted goal that in the end may do more harm than good.

Safety at a specific facility cannot be solely arbitrated by people who have never walked the floor there. When managers adopt policies in which safety is valued over compliance, the decisions about what is safe and what is not are taken out of the hands of these at-large arbiters and placed back into the hands of the people who are responsible for seeing their fellow employees go home from their jobs safely. Under this paradigm, thorough analyses are conducted of the hazards specific to the facility, and recommendations to fix them are implemented. Plans are put in place to change the safety culture, which may be the most difficult and timeconsuming aspect of the entire policy.

Then, an interesting thing happens: Compliance is achieved. Many people think safety is the byproduct of compliance. Just the opposite is true: Compliance is the result of operating a safe workplace. The doctor would be no less careless if he prescribed aspirin for all the headache sufferers because that treats a symptom, not the cause of the illness. Likewise, failure to comply is a symptom of a lack of safety.

Like good doctors, safety managers should treat the cause, not the symptom. If a company operates a safe facility, compliance will follow.

This article originally appeared in the November 2009 issue of Occupational Health & Safety.