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Evaluating your facility’s electrical infrastructure for regulatory compliance

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Many companies understand the importance of assessing their operations, but they frequently depend on self-evaluations based on their own criteria. Industry-standard regulation has been provided by organisations such as the National Fire Protection Agency (NFPA) and the Occupational Safety and Health Administration (OSHA) for a reason. They ensure that companies run their electric systems safely. However, more often than not a facility’s internal criteria is not meeting these specifications.

Standards regulation is a complex issue, and many companies hire external consultants to help them avoid noncompliance. When we review a facility, we often discover that there is a misconception of what is required for the facility’s power systems to operate safely. While some customers are attempting to align their electrical safety policies with the most recent versions of applicable OSHA and NFPA regulations, some policies fail to meet the industry standards’ objectives.

It is important that facilities are aware of and understand these regulations, and that they make every effort to ensure that their facilities adhere to them. Following a six-step process will ensure that facilities are assessed and remain compliant for the benefit of their organisation and their employees.

The six steps to assessing your facility’s electrical system

Audit the Electrical Safe Work Practices (ESWP) Policy

This is a written document that covers all areas of the company’s electrical safety practices and includes lock out/tag out procedures, method of qualifying the workers, selection, application of PPE and more. Organisations should plan to audit the safety policy every three years to assure continued compliance. The policy needs to be continually revised over time to ensure that it is up to industry standard.

Review the Incident Energy Analysis (Arc Flash Study) and Equipment Labelling Practices 

NFPA 70E-2018 Section 130.5 states an arc flash risk assessment shall be performed to identify arc flash hazards and estimate the likelihood of injury or damage to health, as well as the potential severity of such injury or damage to health. The risk assessment must determine if additional protective measures are required, including the use of PPE. Arc flash PPE may be selected either by the incident energy analysis method or by the PPE category method. The incident energy analysis method is a study that is overseen by professional engineers who are familiar with the power distribution and control equipment, and the calculation methods required.

Evaluate the Implementation of Strategies to Mitigate and Control the Risk Associated with Arc Flash

In 2018, NFPA 70E mandated the use of the hierarchy of risk control methods when conducting task risk assessments for electrical work. The hierarchy of risk control implements preventative and protective risk control methods in the following order from most effective to least effective. Elimination (physically remove the hazard), substitution (replace the hazard), engineering controls (isolate the hazard), awareness (train, inform and warn), administrative controls (change work habits) and lastly PPE (protect workers from the hazard). It’s important to note that using PPE is the least effective means of risk control and is essentially the last line of defence for worker protection.

Review the Electrical Safety Training Program Content and Implementation 

NFPA 70E-2018 defines a qualified person as “one who has demonstrated skill and knowledge related to the construction and operation of electrical equipment and installations and has received safety training to identify and avoid the hazards involved.” Having this background means that the employee must have received the safety training specified to identify hazards and reduce the associated risk. Electrical workers are not considered to be qualified by OSHA until they have received this specific training.

Evaluate the Maintenance Practices and Methodologies of Power Distribution Equipment

It is crucial to keep “active” components in electrical distribution systems such as fuses, circuit breakers, and protective relays in proper operating condition with a regular maintenance program. Without proper overcurrent protection, sustained arcing can subject electrical workers to much higher levels of energy. Unless adequate maintenance is performed, the electrical system study and the arc flash analysis will not be a correct representation of the potential performance of the power system.

Review the Approach to Electrical PPE and Tools 

Employees working in areas where there are potential electrical hazards should be provided with PPE that is appropriate for the specific parts of the body to be protected. This can include an arc-resistant shirt, pants or coveralls, or a multi-layer flash suit.

A power system engineer who is well trained in electrical safety can ensure that facilities operate under the most current rules and guidelines, reducing the risk of non-compliance, safety citations, and personnel injury. Regulations are there for a reason. Exploring the essential steps to ensuring your electrical system is compliant with the regulatory standards in the electrical industry will ensure safety and success in the long term.

Nico Van Der Merwe

Vice President of Home and Distribution at Schneider Electric

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