Risk Control Hierarchy Refines Electrical Safety

In the late 1880s, a young boy was electrocuted6. Personal Protection -Reducing risks of working
when he accidentally touched an unlabeled,on live voltage.
energized telegraph wire. That incident ignited anElectrical workers are exposed to the greatest
inventor by the name of Harold Pitney Brown torisks at the lower levels of the RCH. Recognizing
make an impassioned plea in a New York Postthat these 'residual risks' are present; the NFPA
editorial to limit telegraph transmissions to what he70e tells workers how to perform their work
considered a safer level of 300 Volts.safely in spite of these risks. In fact a large
Perhaps Harold thought that limiting electricalportion of the NFPA 70e details how to best
transmissions to levels of 300 Volts or less wouldmanage these risks through Awareness,
provide instant electrical safety. With over 120Administration, and Personal Protection. On the
years of hindsight, we view things muchother hand, the greatest opportunity for risk
differently today. Yet, Harold stumbled acrossreduction comes by focusing in the upper part of
two important concepts. The notion of "300the RCH. Huge improvements in electrical safety
Volts" is a technical discussion about the laws ofwill come by Eliminating Substituting, and
electrical energy (Ohm's Law, etc) that lendsEngineering solutions that manage electrical energy
understanding to how electrical energy can kill orexposure.
maim. On the other hand, the term "safe" reflectsThe Department of Energy (DOE)
a working knowledge of the fundamental principlesFor better insight into the RCH process, let's look
of safety. Our challenge is to combine ourat a 2005 Department of Energy report on their
technical understanding of electricity with theelectrical safety record. This report cited six
principles of safety to ensure electrical safety isreasons for their 14.1 electrical incidents per
both practical and effective. The better wemonth.
understand both concepts the greater theWithin this DOE report, "hazard identification"
likelihood we will have to improve the status quo.[Table 1] stood out as an administrative control
The Risk Control Hierarchy (RCH) does anissue resulting in numerous electrical incidents. The
excellent job in blending these two key concepts.solution was to get tougher administrators or look
Risk Control Hierarchyfor improvements higher up in the RCH. Right
The heartbeat of safety is the Risk Controlabove Administrative Controls (see Figure 1) we
Hierarchy (RCH), which is found in Appendix G oflearn that increasing employee's awareness of
the ANSI Z10 Standard. The RCH helps uselectrical hazards will reduce these types of
prioritize safety initiatives from least effective toincidents. A potential solution is to label and mark
most effective. For example, will you be saferall voltage sources (hazards) feeding the electrical
wearing a helmet while riding a motorcycle or bysystem. Voltage indicators and voltage portals
selling it altogether? Obviously, selling thewired to each voltage source provides two
motorcycle eliminates the risk of an accident,benefits: It identifies the voltage source and
while wearing a helmet offers protection to yourprovides a means to check the status of that
head from the risk of a head injury during anvoltage source without exposure to voltage.
accident. The RCH works by helping us rank riskApply the same process to "LO/TO violations".
reduction measures from most effective to leastCAUSES OF INCIDENTS PRESENT RCH
effective as per below:PRINCIPLE INCREASED RISK REDUCTION RCH
1.) Eliminating the risk.PRINCIPLE Lack of hazard identification.
2.) Substituting a lesser risk.ADMINISTRATIVE Properly administrating NFPA
3.) Engineering around risk.70e requires all electrical enclosures to have
4.) Awareness of every risk.warning labels with incident energy level (calories).
5.) Administrate and regulate behavior around risk.AWARENESS /ELIMINATION Marking all energy
6.) Protect workers while exposed to risk.sources on the panel exterior provides personnel
Note that each step above is equally important,with simple yet safe hazard identification.
yet not equally effective in protecting workers.LO/TO violations including shortcuts or lack of
Eliminating a risk is the most effective way toenergy verification
keep workers safe while protection from a riskADMINISTRATIVE Can the LO/TO procedure be
by using Personal Protection Equipment (PPE) isrewritten to reduce exposure to voltage?
least effective. There have been greatELIMINATION /SUBSTITUTION Thru-door voltage
improvements in the design of PPE, but itspre-checking 'eliminates' all exposure to voltage
primary purpose is keeping workers alive - notfor mechanical LO/TO* and provide significant risk
100% safe.reduction for Electrical LO/TO.
Safety and RiskReducing electrical energy to Cat 0/1 will greatly
Risk, which is defined as exposure to a hazard, isreduce the potential arc flash energy
two-pronged. There is the probability of exposureSUBSTITUTION Lowering the arc flash energy
and severity of potential injury. For example, aeffectively 'substitutes' for a lower risk for a
120V outlet is a greater risk than a 13.8KVhigher risk.
switchgear line-up because more people areElimination: The Hall of Fame of Safety
exposed to the 120V outlet. Since risk isWe can enter the Electrical Safety Hall of Fame
exposure to hazards, then safety is the reductionby finding ways to eliminate voltage exposure.
and management of risk. The managementHere are a few practical examples that can be
responsibility of an electrical safety programimplemented today:o Mechanical Lock-out Tag-out
typically falls to an electrical engineer because he[LOTO]: LOTO procedures requiring electricians to
or she understands electricity. In our modernverify zero energy before performing mechanical
world we can never eliminate the risk, but aremaintenance needlessly exposes workers to
very good at finding new ways to reduce risk.voltage. Since all voltages do not create
Another way to look at risk is the chart (Figure 2)mechanical motion, thru-door voltage checking
developed by Ray Jones which shows thedevices as part of a mechanical LOTO procedure
relationship between the worker and the safetywill eliminate voltage exposure (see Appendix B).o
infrastructure above him. A worker performingWhy open a control panel? What maintenance
tasks must make many complex and specific thefunctions can be moved to the outside of the
decisions that affect his safety. In the case ofpanel? Thru-door data access ports are becoming
electrical safety, energy isolation is very personalcommonplace because they allow programming
for electricians facing deadly electrical energywith the panel door closed (Figure 3). A more
every time they open a panel. By the time theyrecent example is an unmanaged Ethernet switch
touch electricity, it's too late.mounted outside the panel. This unique device
Zero Energy Verification--Is There Voltage?allows full thru-door access for a worker to
Electrical accidents are impossible without electricaltroubleshoot and reset the Ethernet switch (Figure
energy. If an electrician comes into direct contact4). What other devices can be re-engineered
with electrical energy, there is a 5% fatality rate.around thru-door electrical safety? Perhaps putting
Shocks and burns comprise the remaining 95%.certain branch circuit breakers on the outside of
The NFPA 70e is very specific on how to isolatethe panel is a good application?o Control Panel
electrical energy. First, all voltage sources must beDesign: Provide a physical separation between the
located and labeled. Multiple voltage sources arepower and control compartments within an
commonplace today due to the proliferation ofenclosure may become a standard. Voltages
back-up generators and UPS's. Next, voltageunder 50 volts are considered safe, so reducing
testing devices must be validated using thethe control power to 24VDC makes the control
LIVE-DEAD-LIVE procedure. Additionally, thepower section safe to work on while it is
voltage tester must also physically contact theenergized.
voltage and must verify each phase voltage toThese above examples are only 'scratching the
ground.surface', so I challenge you to find ways to
The RCH and Electrical Safetyeliminate voltage exposure.
How does the RCH apply to electrical safety?Conclusion
1. Elimination -Removing all electrical energyWhen safety works perfectly, nothing happens!
exposure.When there is an incident or a close call the RCH
2. Substitution -Lowering the electrical energyshould be an inspiration to find a better way. By
exposure.applying the RCH principles to electrical safety
3. Engineering Controls -Reinventing ways torisks, it will open our eyes to see more practical
control electrical energy exposure.ways to reduce those risks. Perhaps, we would
4. Awareness -Revealing and labeling all sources ofexpend more resources finding electrical safety
electrical energy.solutions that will provide both higher safety and
5. Administrative Controls -Regulations that teachproductivity dividends.
personnel safety around electrical energy.