A Useful Bureaucracy
Jumping through hoops on the way to safe electrical work practices
NFPA Journal®, November/December 2011
When we talk about personal protective equipment, we typically picture arc-rated clothing, face shields, insulated gloves, and balaclavas. Insulated tools, non-conductive ladders, rubber insulating mats, and protective temporary grounding equipment also fit into the broader category of equipment designed to protect employees against electrical hazards.
I recently talked to an electrical contractor about an important shift in attitude in the electrical community, one that has moved from working hot and asking permission later to turning the power off and creating an electrically safe work condition. He told me that at his company, in order to perform energized work, written permission has to be secured, including signatures from multiple levels of management all the way up to the company president. "I hate bureaucracy," my contractor friend told me.
In this case, though, the purposeful creation of a bureaucratic paper trail with multiple levels of approval has had a positive impact. By creating this internal bureaucracy, the company has made it cumbersome to obtain permission to perform energized electrical work. "Now my employees turn the power off as their first course of action," he told me.
The amount of energized work his employees perform has decreased substantially, he said; it’s now unusual to perform more than one energized task over the course of a year. His employees just don’t want to spend the time securing the necessary signatures. Also, customers who in the past have been unreceptive to planned outages to facilitate safe work processes have backed off on their objections when faced with signing the authorization document.
I asked him about the possibility of employees ignoring the process and undertaking unauthorized energized work. I also asked him about the difference between a cumbersome process and getting genuine buy-in on the power-off approach. "This is where communication comes into play, and the safety attitude has to be embraced from the top down," he said. "In safety meetings I ask how many of their parents put them in car seats and not many hands go up. Then I ask how many of them put their own children in car seats and the response is nearly unanimous."
His example shows how our frame of reference has changed. Child car seats were developed in response to terrible accidents, and now their benefits are well understood. The same can be said for turning the power off prior to working on electrical equipment, or wearing the appropriate level of personal protective equipment when energized work is justified. The consequences of electrical accidents and their causes are well documented, and the common denominator is that the power was on. No mitigation strategy is simpler, or more effective, than turning the power off.
The 2012 edition of NFPA 70E® contains revisions to the required information that is to be included on the energized electrical work permit (EWP). The EWP provides detailed safety information for the specific justified energized tasks that will be undertaken. Some may see the level of detail as unnecessary red tape, but the information has a singular purpose: to protect the employee who is performing the energized work. An EWP has to be signed by at least one person responsible for employee safety in order for the energized work to occur. The EWP, like the process implemented by my contactor friend, emphasizes the need for proper planning of the task, for briefing of employees on the associated hazards, for identifying the appropriate level of PPE, and for accountability by those authorizing the task. This important information helps ensure the employee’s safety. If the process results in less energized work or in properly planned jobs with properly trained and protected employees, then the bureaucracy is worth it.
Jeffrey Sargent is NFPA's senior electrical specilist and is staff liason for NFPA 70E.