In the food industry, we are required to comply with many regulations and guidelines. We do a great job of understanding food safety regulations and labeling requirements, but often overlook certain safety regulations. OSHA has provided a number of standards that dictate what we must do to establish safe working conditions. Usually lockout/tagout, confined space entry, and hearing conservation come to mind when we think about OSHA standards for the food industry. However, an often overlooked but very important standard is 29 CFR 1910.333: Electrical Safety Related Work Practices. Its purpose is to develop work practices that prevent electric shock or other injuries caused by direct or indirect contact with electricity while working on or near energized equipment or circuits.
When you think of violations related to electrical codes, you likely think of installation, design and maintenance violations. However, 20% of citations are from safe work practice issues. Installation issues account for only 9% of injuries while the lack of safe work practices account for 91% of all electrical related accidents. If we want to address issues before they become serious injuries, we need to focus on safe work practices.
WHAT IS NFPA 70E?
The National Fire Protection Association (NFPA) publishes many standards related to electrical safety. The current version of NFPA 70E: Standard for Electrical Safety in the Workplace was approved as an American National Standards Institute (ANDI) standard in February 2004. It focuses on electrical safety requirements for workplaces necessary for safeguarding employees and assuring a safe work environment. OSHA mandates and expects that you prevent electrical injury; NFPA 70E explains how you do it. Essentially, the OSHA standard is the law and NFPA 70E is the guidance document.
WHY IS IT IMPORTANT?
In a food manufacturing environment, we sometimes expect maintenance employees or members of the food safety team to open electrical panels for cleanings or inspections. When the cover on a live electrical system is opened, the employee is exposed to the threat of electrical shock, arc flash, and arc blast. If we expect employees to perform these functions without any training or hazard education, we put their safety at risk. If untrained individuals are expected to work near live electrical systems, we violate OSHA regulations.
OSHA used NFPA 70E as a reference to develop its standard to improve electrical safety (29 CFR 1910.300–399). NFPA 70E provides guidance on how to avoid electrical injury, including shock, arc flash, and electrocution and how to achieve safe working conditions and practices for your employees. It focuses on conditions that could exist which may expose people to hazards. Awareness of hazards, safe operating practices, and personal protective equipment is essential if injury is to be avoided. NFPA 70E is an important standard and must be incorporated into the electrical safety program at your facility.
WHO IS AFFECTED?
It is important to carefully read the OSHA electrical safety regulations and the NFPA 70E standard. These documents explain what is needed and expected. One of the first requirements is to identify which employees these standards affect. Each regulation refers to two types of persons, the qualified person and the unqualified person. A qualified person is someone with the skills and knowledge related to the construction and operation of the electrical equipment and installations and has received safety training on the hazards involved. An unqualified person is anyone who is not a qualified person. An unqualified person may be trained to perform specific tasks and become qualified for that task, but unqualified for others. So, individuals that inspect and clean electrical panels may be trained to perform that task safely, but not be qualified to perform any other task related to electrical installation or maintenance.
WHAT ARE THE REQUIREMENTS?
The best way to understand what you must do to comply with the standard is to read NFPA 70E: Standard for Electrical Safety in the Workplace. Article 110 describes the elements needed when developing an Electrical Safety Program.
Without a doubt, this standard impacts how employees in a food plant work with or near live electrical systems. Article 130.1, Justification for Work, indicates that when an employee is or could be exposed to live electrical parts, safe work conditions must be achieved before work can be done. Essentially this means that all electrical power to the system must be shutdown (deenergize) and the equipment isolated from all power sources before work can begin.
If the employer can demonstrate that deenergizing electrical equipment introduces additional or increased hazards or is infeasible due to equipment design or operational limitations (inconvenience and difficulty is not considered an operational limitation), then the electrical system may not be deenergized. If live parts are not located in an electrically safe work condition, then the task will be considered energized electrical work and must be performed by written permit only.
The work permit includes 11 elements, but more may be needed depending on the type of work environment or hazard exposure in your facility.
* Description of the circuit and equipment to be worked on and location.
* Justification for why the work is to be done in an energized condition.
* Description of all safe work practices to be used.
* Results of the shock hazard analysis.
* Establishment of shock protection boundaries.
* Flash hazard analysis results.
* The Flash Protection Boundary.
* Required personal protective equipment necessary to safely perform assigned task.
* Methods to be used to limit access of unqualified person from the area.
* Verification of job briefing which identifies and discusses any job-specific hazards.
* Signatures of responsible management personnel authorizing and approving work on energized equipment.
NFPA 70E defines three shock approach boundaries (limited, restricted, and prohibited) which are based on the voltage of the energized equipment. The standard also requires that employees must perform a flash hazard assessment before approaching any exposed electric conductors or circuit parts that have not been placed in a safe work condition. Until equipment is placed in a safe work condition, it is considered live. The analysis should determine the flash protection boundary and level of personal protective equipment that must be worn.
Limited Approach Boundary: a shock protection boundary to be crossed by only qualified persons and is not to be crossed by unqualified persons unless escorted by a qualified person. Appropriate PPE and training is required.
Restricted Approach Boundary: a shock protection boundary to be crossed by only qualified persons, which requires the use of shock protection techniques and equipment when crossed. The qualified person must wear required PPE and have a written approved plan for the work to be performed.
Prohibited Approach Boundary: a shock protection boundary to be crossed only by qualified persons which, when crossed by a body part or object, requires the same protection as if direct contact is made with a live part. Only qualified personnel wearing appropriate PPE and having specific training and a documented plan justifying the work may cross the boundary.
Essentially, unqualified persons are not necessarily capable of recognizing potential shock and flash hazards. Therefore, they should stay at a safer distance from open and exposed live conductors.
In a food manufacturing plant, it is common to place electrical panels on a cleaning schedule to prevent mold and stored product insect infestations. It is obviously difficult to perform this task from a 3.5 foot distance, as required by NFPA 70E. For this reason, it is necessary to train the employees who inspect and clean electrical panels so they may become qualified to perform these tasks. Also, a qualified person must explain the potential hazards and risks and make sure unqualified persons are safeguarded before they cross the Limited Approach Boundary. Under no circumstance shall escorted unqualified persons be permitted to cross the Restricted Approach Boundary.
Exposure to live electrical systems is a significant hazard and threat to employee safety. We face this threat every day in food manufacturing and distribution facilities. However, safe work environments can be achieved with proper training and supervision, compliance programs, safety policies, and safe operating practices. Facilities should conduct a comprehensive study of NFPA 70E: Standard for Electrical Safety in the Workplace and OSHA regulations to understand what is required of the employer and employees. Compliance may seem inconvenient and time consuming, but it’s essential because the safety and lives of your employees are at stake. AIB
Jon Anderson is Head of OSHA Compliance & Educational Product Development, AIB International.