$150,000 in fines for failure to train temporary employees in electrical safety

The Occupational Safety and Health Administration (OSHA) plans to heavily fine two companies for “failure to train employees in electrical safety-related work practices, including wearing electric arc flash and shock protection equipment.” OSHA became involved after a maintenance employee came in contact with electrical equipment and suffered electrical shock. The employee was unable to work for four months after the incident.

OSHA cited Arvato Digital Services for one willful and 10 serious safety violations, resulting in proposed fines of $124,000. Parallel Employment Group, the temporary agency that provided the worker to Arvato, was cited for four serious violations, with proposed fines of $24,000. The single willful violation alone resulted in a fine of $70,000.

View the full text of the OSHA news release…

Read the entire Citation and Notification of Penalty…

Wisconsin firm fined $119,000 for Arc Flash Incident

OSHA plans a fine of $119,000 for a Wisconsin firm after a worker was severely burned by an arc flash last June. The citation says Pure Power Technologies willfully failed to ensure the employee was using proper protective equipment (PPE) while working on a 480-volt circuit breaker while the cover was removed. While PPE is a critical element of electrical safety in the workplace, Mark Mitchell of Mitchell & Lindsey says it is not enough. “In this case, the company was cited for the employee’s failure to use PPE,” said Mitchell. “However, experience shows that PPE alone is not sufficient protection against the dangers of arc flash. There are many other steps that can and should be taken to properly protect those working highly charged electrical equipment.” View the full text of the OSHA news release…

Arc Flash PPE – What You Need to Know

Understanding the requirements for Arc Flash PPE can be confusing and often misunderstood.  In this article I am going to review the requirements and why they exist.  First, let’s understand why there are requirements in the first place.  Before reading further it might help to download the latest PPE Chart as a guide.

NFPA 70E section 130.7(C )(1) requires all workers within the flash protection boundary to wear PPE.  How much and what type of PPE depends on the hazard.  Let’s remember that the purpose of this is to protect anyone working on live electrical equipment from injury or death in the event of an arc flash incident.

The folks that write the standard are fully aware of the purpose.  They realize that too little PPE exposes a worker to serious injury or death.  They also realize that high levels of PPE are bulky, cumbersome, and hot.  These high levels also restrict hearing and field of vision and make the tools hard to handle.  This can not only increase the difficulty of the task, but also introduce other safety hazards.

For this purpose NFPA 70E has provided 5 levels of protection.  Most of these levels require protection that is easy to work in.  They leave the most cumbersome PPE for only those hopefully rare occasions when you would work on extremely high energy electrical equipment in a live state.  This is why NFPA 70E and any solid electrical safety program recommends working de-energized as much as possible.

Calories and Levels of PPE

All PPE is rated in calories.  Calories/cm2  is a unit of heat and energy.  This is how all potential arc flash events are measured.  A compliant arc flash label will show a value in cal/cm2 on the label.  This is called incident energy and it tells a worker how much PPE should be worn for protection.  The higher the value the higher the risk.

NFPA 70E has created 5 risk categories that are all based on the incident energy (cal/cm2).  This is shown in the following table.

Level                           Incident energy

0                                 0 cal/cm2

1                                 4 cal/cm2

2                                 8 cal/cm2

3                                 25 cal/cm2

4                                 40 cal/cm2

The level of arc flash should also be on the arc flash label.  A worker can use the level or incident energy on the label to determine risk and PPE.  If you are to work energized on an electrical panel that has an arc flash PPE Level l with an incident energy of 3 cal/cm2 you will need to suit up to PPE providing up to 4 calories of protection.  Furthermore if the label states Level III you will need a 25 cal/cm2 suit.

Again, the reason for so many levels and categories is too aid the worker.  We don’t want you wearing a giant space suit if the risk doesn’t warrant it.

Clothing

Clothing refers to the garments required for the risk category.  It refers to shirt, pants, shoes, coveralls, etc.  Arc Flash clothing is rated in cal/cm2 to help you choose the proper protection.  The clothing should meet ASTM F1506 approval to be considered fire retardant and safe.  Be sure to identify this approval when purchasing.  In addition, you will want to check the laundering methods and how they affect the FR rating of the garment.  The supplier should be able to guide you on this.  Below is a table covering the requirements.  The letters FR refer to fire resistant meaning that the garment will self-extinguish once the fire ceases.

 Hazard/Risk Category  Clothing Description  Required Minimum       Clothing Arc Rating
0 Non-melting, flammable material
with fabric weight of at least 4.5 oz/yd2
Not applicable
1 Arc-rated FR shirt + FR pants or FR coveralls 4 calories/cm²
2 Arc-rated FR shirt + FR pants or FR coveralls 8 calories/cm²
3 Arc-rated FR shirt + FR pants or FR coveralls, and Arc-rated flash suit, the layered system must meet the required minimum rating. 25 calories/cm²
4 Arc-rated FR shirt + FR pants or FR coveralls, and Arc-rated flash suit, the layered system must meet the required minimum rating. 40 calories/cm²

Equipment

Arc flash equipment refers to face shields, hard hats, hearing protection, eye protection and gloves.  There are also requirements for equipment that go along with each risk level.  It’s not enough in many instances to just have FR rated clothing.  We also want to protect our hands, face and head from exposure.  This is summarized in the following table.  Remember that face and head protection also has a calorie rating.

  Hazard/Risk
Category
  Eye protection, ear canal inserts, long sleeve shirt and pants   Arc rated clothing   Face & Head Protection   Flash Suit Hood
0

X

1 X X X
2 X X X
3 X X X X
4 X X X X

Confused yet?  Me too.  That’s why we’ve put it together in one easy to follow table for you.  Click here to download the table.  Many facilities find it helpful to print out a chart like the one below to hang in the electrical rooms and maintenance shop.

Hopefully the above tables helped explain it in a step-by-step manner to get you to this point.  However, the table below provides an overview of the calories, category level, clothing and equipment.  It should be all you need to make a decision on protection.

One Final Note

At first glance these charts can be confusing.  The first reaction by many is that from this point forward you will need to wear something equivalent to a space suit every time you work on electrical equipment.  In reality it’s not as bad as it seems.

The overwhelming majority of electrical equipment falls in the ranges between Level 0 and Level II.  These require protection up to 0, 4 and 8 cal/cm2 respectively.  Clothing with an 8 cal/cm2 rating is not cumbersome to work in.  Our workers including myself work in 8 calorie clothing full time when we are on-site collecting data.  It does not restrict movement or prevent you from doing anything you can’t do with everyday clothing on.

The rest of your electrical system, and in most cases this is usually the overwhelming minority, is rated at category III or IV.  In these cases you will need to suit up to either 25 or 40 calories.  This is where it becomes hot, tedious and cumbersome.

Let me repeat.  In most facilities these levels constitute a minority of the electrical system and the PPE doesn’t even apply if you are working de-energized.  What this means is that in most cases it is a rare occurrence that you would be interacting with live electrical equipment above a category level II.  However, in those rare instances isn’t it worth the time to protect yourself?  It only takes one incident to change or end your life.

Arc Flash PPE – Simplified

Have you ever heard the old John Wooden saying, “Be quick, but don’t hurry.”  When I first heard those words I was confused for a brief moment until I quickly realized how profound they were.  It is very much like another saying I’ve heard from parts unknown which is, “It’s not difficult, but it’s complicated.”  When you first hear these words, you tend to give a quizzical look to the person who said them, but then you realize that it is actually a very profound statement that can be applied to many things in life. I think one of them is Arc Flash PPE.

Yes, maybe I need to get out of my cave more, but I completely think this statement applies to PPE.  Arc Flash PPE is not difficult.  You can google a PPE chart and hundreds of pictures will come up explaining it.  There are five arc flash hazard levels and each has its own level of PPE associated with it.  Click here to download the latest PPE Chart.  Again, it’s not difficult.  But it does get complicated when it comes to purchasing and using PPE in your daily work.

To most of my customers the first thought that comes to mind is that it is going to be expensive to purchase and it’s going to be over-complicated to implement.  Purchasing five levels of PPE for every employee can get pricy.  Their faced with buying five levels of PPE and then you have to multiply that by the number of employees and also decide how many of each level the employees receive.  It can literally be tens of thousands of dollars depending on the number of workers that need the gear.

Once you go through the expense of purchasing PPE, you’re faced with the day in and day out decisions of what to where and when.  If a worker is performing a task on an electrical device rated at category 1, he needs a 4 calorie suit, hood, etc.  If he moves over to a category 2 device he needs to change into an 8 calorie suit, hood and so on.  How much time will be wasted everyday changing in and out of PPE?

It’s no wonder so many managers and workers resist the NFPA 70E Arc Flash Standard.  Again, it’s not difficult to understand, but it is complicated to do.  Well we’re here to make the complicated easy.  There is a way to simplify the whole PPE issue that makes it much less expensive and much easier to follow.

The Simplified (2–4) Method

We recommend doing what we call the 2-4 method of protection.  Simply put,  you either work in Level II PPE or Level IV PPE.  Forget about level 0, level 1 and level 3.  By doing this we eliminate 60% of the decision making and 60% of the cost.  I’m all about simplicity, and this is the simplest and most efficient way to do it in my opinion.

Here is how it works.  Make it a policy that all workers who might work on energized electrical equipment work full time in Level II shirts, pants and shoes.  This protects them at level 0, level 1 and level 2 without the need to change clothing.  Obviously they would need to put face, hand and head protection on when they are actually interacting with live electrical equipment, but they don’t have to change or add clothing.

Level II PPE is not cumbersome to work in, and it doesn’t prevent us from performing any task that we couldn’t normally perform.  It doesn’t restrict our field of vision either.  All of our workers at Mitchell & Lindsey, including myself are suited up in Level II PPE whenever we are in the field.  The only disadvantage to a Level II versus a Level I is that Level II can be a little warmer to work in.  But I’ve worked countless hours in Level II gear and it’s not that bad to work in on a full time basis.

In the event that your workers need to work on electrical equipment at level III or level IV they simply put on level IV gear.  Hopefully the number of items in your facility falling under these categories are few and far between comparatively speaking.  And hopefully you can find a way to de-energize those items when working on them is necessary.  In those rare instances that you are working on more hazardous equipment it should be an easy decision to take the time to wear Level IV gear and accept the fact that the little time you spend in this suit is going to be hot and tedious.  But again, in most facilities this is more of a rare occurrence than a daily activity.

Using the 2-4 method is less costly and easier to follow.  I also believe that your workers will be more inclined to accept and follow the standard this way.

In summary, we recommend purchasing level II PPE for all your workers to be in on a full time basis.  We recommend having at least 1 category IV set of PPE that any worker can use as needed.  Depending on the size (literally and figuratively) of your maintenance team you might want to purchase more and with varying sizes for comfort.

This way on a full time basis your workers are protected on the first three levels all day every day, and they can take the time to suit up to the highest levels by wearing a Category IV suit on those rare occasions that call for it.  It’s less pricey.  It’s simple.  It’s more likely to be accepted.  It’s more likely to be followed.  And ultimately this accomplishes what we are all looking for which is a safer working environment.

Beyond Compliance: There are Multiple Benefits to an Arc Flash Study

Conducting an arc flash study on your electrical system is a major step towards compliance with OSHA requirements for providing safe work environments for your employees, and this is one of the biggest motivations I hear from customers who decide to hire us.  Other reasons include corporate policy, insurance requirements, certifications, etc.  My hope is that as time goes on, the main reason is to create a safe electrical environment.  After all, this is the motivation behind NFPA 70E and OSHA.

Electrical safety is the driving force behind all of this and an effective arc flash study accomplishes this by providing multiple benefits beyond just compliance or corporate policy.

An arc flash study is a labor intensive process that includes multiple steps.  Each of these steps build upon one another to create a clear picture of your electrical distribution system, warts and all.  In addition, each step provides you with valuable benefits.

Step 1: Data Collection

The first section of an arc flash report contains a goldmine of information for plant engineers and maintenance personnel.  In spreadsheet form you receive all of the information you will ever need about each electrical device in your facility.

Breakers:  Manufacuturer –Type – Frame/Sensor Rating – Trip Settings – Voltage-Amps

Transformers:  Type – KVA  -Impedance – Primary Voltage – Secondary Voltage – Winding Design

Fuses:  Manufacturer – Type – Amp Rating – Switch Rating

Cables:  Size – Insulation – Length – Number per phase – Netural/Ground Info – Load Type

In most cases maintenance teams have never had the time or resources to catalog this information.

Step 2: Arc Flash Drawings

Once the data is collected an arc flash drawing is created.  This drawing is a map of the electrical system from main utility transformer all the way down to branch panel boards and mechanical disconnects.  Some maintenance personnel are as excited as kids on Christmas morning when I show them these drawings.  For many facilities the current drawings they have are out of date or a hodge-podge of documents created during various expansions and additions.  Finally, they now have one concise, detailed map of the entire electrical distribution system.  And just as important, they have a simple plan in place to ensure that future changes can easily be updated and that they always have an accurate drawing of their system.

Step 3: Arc Flash Calculations

This is where the rubber meets the road in regards to the data collection and drawings.  All the labor intensive work so far leads to this point where we calculate the hazard at each electrical device.  This is important because this is where we find out two key points of information: the incident energy and the PPE level required to work on the device energized.  This is important for two reasons:

  1. It provides us with minimum requirements for protection so we can work safely.
  2. Because we know the precise hazard, we don’t have to go through the inconvenience of over-protecting. Over-protection can be cumbersome, hot and tedious.  Without all of the data collection from earlier we wouldn’t be able to do this.  We would constantly be overestimating and in some cases underestimating the risk involved.

Step 4: Coordination & Mitigation

This steps provides benefits to safety and plant operation.  Coordination identifies circuits in your electrical distribution system in which the over-current protective devices (breakers and fuses) aren’t opening in the proper sequence.  If you were to have an incident or fault in the electrical system, it would be ideal if the breaker that trips is the closest breaker to the fault.  For safety reasons, it clears the fault more quickly.  For operational reasons, it shuts off power to only the panel where the fault occurred.  In a mis-coordinated system, the breaker that trips is often all the way back at the main switchboard creating a more hazardous situation and likely shutting down a larger portion of your operations.

Mitigation is different than coordination.  During the mitigation analysis we identify areas where we might be able to reduce the hazard.  As an example, let’s say you have a control panel that is identified as a category IV hazard.  A category IV is the highest level of hazard and requires the most PPE to work on energized.  Often, we can mitigate this hazard to a Level I or even a Level 0.  This not only makes your electrical system safer, but it allows you to work on the equipment with a lower level of PPE.

Many times coordination and mitigation issues can be corrected by simply changing an upstream breaker setting.  Other times it requires the expense of adding new equipment.  Either way, it is designed to make your electrical system safer and more efficient.

Step 5: Installing Labels

The next step is label installation.  An arc flash warning label such as the one shown below is placed on every electrical device.  This label identifies the level of hazard for that specific piece of equipment along with shock and arc flash boundaries.  It is invaluable information during the process of deciding whether or not to work energized and if working energized, what precautions and PPE should be considered.

These labels allow you to make decisions based on real information and not just guesswork.

Sample arc flash label with incident energy, PPE requirements and hazard boundaries

Sample arc flash label with incident energy, PPE requirements and hazard boundaries

Sample arc flash label with incident energy, PPE requirements and hazard boundaries

Step 6: Training

All arc flash studies should end with a comprehensive training session.  The training session should not only include arc flash topics, but should also address NFPA 70E.  The goal of each training session is not just to raise awareness about electrical safety, but also the incentive to make electrical safety practices habitual.  Awareness is great, but forming safety habits that become automatic over time is the real goal.

Bottom Line

Arc Flash Studies are not only important in order to be compliant or fulfill a corporate policy.  They are designed to create a safer electrical environment for you and your workers.  Each step in the process provides its own unique benefits that contribute to this goal along with the added benefits of valuable information and resources you can use in your day to day work.