Tips on Creating an Effective Electrical PPE Program

There is still a lot to consider when it comes to fully protecting workers form arc flash and electrical shock hazards.

Electrical safety has made significant headway over the past 20 years as overall awareness of electrical hazards and the NFPA 70E standard has increased substantially. While this is definitely a positive, there is still a lot of work ahead of us to fully protect workers from the devastating effects of arc flash and electrical shock hazards.

The Hidden Hazard and Complacency
I think most safety professional would agree that electrical hazards don’t get the same level of attention as hazards that happen more frequently. This makes sense since arc flashes and electrical shock accidents don’t happen nearly as often as trips & falls, cuts, back injuries, moving vehicle and machinery accidents etc. However, the results of an electrical incident are typically far more severe and catastrophic compared to other hazards. In addition, electricity is one of the few hazards that doesn’t have many “warning” signs. You normally can’t see, hear, smell or feel anything right before an arc flash or shock accident happens. Unfortunately, this reduced frequency and lack of warning signs can result in complacency. Many workers don’t even realize they are falling into this dangerous complacency trap. They just know that they haven’t been injured, or even had an incident in years, so why should they be so concerned about it now. If they’ve been working with electricity long enough, they’ve probably had a few near-misses they weren’t even aware of.

It is critically important for safety professional to combat complacency through constant communication and education. Fortunately, there are many educational resources available as well as hundreds of videos on the internet that put a spotlight on this “hidden hazard” and clearly demonstrate the devastation that arc flash and electrical shock incidents can have on workers. There are many strategies and tactics on how to effectively address this problem, and some companies do a better job than others. An approach that may enhance your program is to collaborate with peers to share electrical safety ideas and best practices. There are some great organizations and events, such as the IEEE Electrical Safety Workshop, that can serve as an excellent venue to collaborate with others on important electrical safety topics.

Electrical PPE: The Last Line of Defense
It is commonly understood that electrical PPE is considered the “last line of defense” in the hierarchy of controls. This makes sense since it’s far more effective to eliminate, substitute or find engineering or other controls to remove the hazard in the first place. However, arc flashes and shocks can still happen so PPE is a critical component to an electrical safe work practices program. The most severe and fatal injuries from arc flashes are caused by regular non-flame resistant clothing ignition and/ or direct thermal exposure to unprotected areas such as the head/ face and arms/ hands. The most serious electrical shock injuries occur when rubber voltage rated gloves & leather protectors are not used and/or because the rubber gloves were damaged but not inspected prior to use, or ineffective due to age.

Companies have invested large amounts of money to do detailed studies with specific software programs to determine the arc flash energy potential. This is great news, but these studies can be very expensive and take years to complete in some cases. While calculating all of the potential exposure energies and clearly labeling them on every piece of electrical equipment would be considered the ideal way to implement a comprehensive electrical safety program, there are some watchouts. As an example, starting a program that is too specific, requiring multiple levels of arc flash protection could inadvertently harm the effectiveness of the program. You also don’t want to wait to provide guidance on what level PPE your workers need to protect themselves just because you don’t have the detailed calculations completed yet. This is less of a problem today than it was 10 or 20 years ago, but it still exists.

Resources in the NFPA 70E; 2021 Standard
Fortunately, the NFPA 70E standard allows you to use some quick and very effective tools to get a PPE program started right away. If you look at page 75 in the 2021 edition of NFPA 70E, you will see “Informative Annex H - Guidance of Selection of Protective Clothing and Other Personal Protective Equipment (PPE)”. This annex is not officially part of the NFPA 70E standard, but it was included to provide some simple common-sense alternatives. They offer guidance on a “simplified two-category clothing” approach for electrical workers within facilities with large and diverse electrical systems. The concern with this simplified approach is that it can lead to “over-protection”. While this is a good thing for arc flash protection, if it negatively impacts comfort, mobility and visibility, it could inadvertently create some other issues. It reminds me of the scene in “A Christmas Story” when little Randy’s mom bundled him up in thick outwear to protect him from the cold, but other unintended hazards emerged because he couldn’t move his arms. In the case of arc flash suits, this was a legitimate concern with a lot of the traditional PPE because it’s heavy, stiff and inflexible, just like little Randy’s winterwear. Fortunately, there has been a tremendous amount of progress and innovation to advance arc flash safety in recent years. The options that exist today are significantly lighter in weight, softer and more flexible, so this downside of “over-protecting” can be pulled off the table. In addition, implementing a simplified approach to protect workers reduces the number of decisions that need to be made in the field and reduces complexity. This can increase the likelihood that workers will wear the PPE when it’s required and wear it properly.

Options to Protect Workers from Arc Flashes
There are a couple ways to provide workers with the electrical PPE they need to protect themselves from arc flash hazards. You can provide your employees with a full wardrobe of arc-rated FR clothing so they can wear it all day, every day. This is what is commonly known as an FR/AR daily wear program. This can be an effective way to comply for PPE CAT 2 tasks, but they would still need to bring other important PPE with them to protect the head, face and hands. This includes a balaclava & face shield (or hood with shield), hard hat, ear plugs, safety glasses and voltage rated rubber gloves with leather protectors. You would also need to provide additional protective systems for tasks that require more than 8 cals of protection.

The other option is to implement a “task-based” PPE program, which workers utilize a full arc flash kit that includes all of the above along with an arc flash suit for the level of protection they need. When workers are conducting an electrical task that requires PPE, they would simply put on the appropriate level arc flash suit over their clothing along with a balaclava & face shield (or hood with shield), hard hat, ear plugs, safety glasses and voltage rated rubber gloves with leather protectors.

The concern around task-based programs centers around whether workers will don the suits when they are required to. This is a legitimate concern, but it’s important to understand that regardless of whether your workers are in an FR/AR daily wear program or a task-based program, they still have a responsibility to don other PPE to fully protect themselves from the hazards. An FR/AR daily wear program does not eliminate this concern of taking shortcuts when it comes to protecting your head, face and hands as well as insulating workers from electrical shock.

The bottom line is both programs can be effective in protecting employees from arc flash hazards. It’s critical for everyone to understand what PPE is required before they start the task and then don the proper PPE. While arc-rated daily wear could save a few minutes, the fact remains that this step needs to take place regardless of what they are wearing to work. In addition, many companies have found that task-based programs are a much better solution for workers that are only doing a handful of electrical tasks each week.

Look for Win-Win Solutions
Although electrical accidents occur less frequently than other hazards, they can and do happen on a regular basis and every year the statistics show how devastating they are. It’s crucial to recognize that complacency and human error still exist, so it’s important to keep the complexity out and establish a program that provides the necessary protection, while being as simple as possible. Yes, this may result in “over-protection” in some cases. However, building in some conservatism without the downside of compromising other areas like comfort and mobility is a win-win for safety leadership and workers.

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