By Terry Becker, P.Eng., Electrical Safety Specialist, TW Becker Electrical Safety Consulting Inc.

What I see happening in the industry across Canada and the USA in the last three to five years is complacency in electrical safety.

“No electrical incidents occurring so we don’t need to do anything else than what we have done, e.g. incident energy analysis study and equipment labels installed, bought some arc flash PPE and we trained the electricians three to five years ago so we are compliant.”

“We don’t need to update our electrical safety program. It is based on the 2012 Edition of CSA Z462 and is still valid.”

“We just need an arc flash program.”

One of the challenges of these types of statements as a defence in court is that the applicable industry standard for Canada, CSA Z462, changes every three years, the same for NFPA 70E in the USA. Your company’s policies, practices and procedures for electrical safety and energized electrical work should also be updated every three years and align with the latest edition of the CSA Z462 standard for the most effective and defendable due diligence if your company ever does have an electrical incident.

Implementing and auditing a compliant electrical safety program should be your first priority as outlined in CSA Z462 Clause 4.1.6 Electrical safety program. This would also align with expected due diligence by workplace health and safety regulators in Canada and the USA. The Certificate of Recognition (COR) program also validates the importance of developing, implementing and auditing an occupational health and safety management system (OHSMS). In the case of arc flash and shock hazards, this OHSMS is a specific electrical safety program that complements your overall OHSMS for all workplace hazards.

Additionally, the electrical hazard of shock should be identified and treated with equal if not a higher priority with respect to hazard identification against energized electrical work tasks and the implementation of additional protective measures than arc flash. Statistically in North America (and I am sure internationally), shocks leading to electrocution result in 99% of electrical incident fatalities.

I have communicated in the past that employers are blindsided by non-compliant “arc flash awareness” or “arc flash training” that focuses only on the arc flash hazard and neglects the shock hazard, uses fear-based training with a lot of videos, storytelling and misinformation, and doesn’t include any training content on completing a risk assessment procedure for energized electrical work.

Other myths and miss information continue to propagate throughout industry across Canada:

1. It is illegal to perform energized electrical work.

2. Working on electrical equipment with an incident energy >40 cal/cm2 is “dangerous” and “no PPE exists.”

3. Operating energized electrical equipment requires that arc flash PPE be worn.

4. Arc flash PPE is identified with a category # that replaces the HRC #.

5. “I am the CEO and I issued a policy to all of the electricians that work for me that we don’t work live!” “We do not need an electrical safety program.”

6. “We need an arc flash program. We are going to hire an engineer to do the calculations and provide us with equipment labels; this is our arc flash program.”

7. “We bought arc flash PPE and sent the electricians for training, so our due diligence is good. The supervisor didn’t have time and didn’t attend the training.”

Common gaps related to an electrical safety program include:

NO documented purpose, principles, or scope for energized electrical work.
NO documented roles and responsibilities for energized electrical work.
NO documented process for completing the required risk assessment procedure.
NO documented policies for energized electrical work, e.g. establishing an electrically safe work condition (EEWP), use of EEWP, working alone, no jewellery policy, look-alike equipment, alertness, housekeeping, confined spaces, a requirement for GFCI, etc.
NO documentation related to the specification, procurement, inventorying, issuing individually or shared, pre-use inspection, care, use and maintenance of electrical specific PPE, tools and equipment.
NO documentation defining electrical safety training and who should receive it and when, e.g. no electrical safety training matrix.
NO documentation related to electrical incident reporting policy and management.
NO documentation related to emergency response to an electrical incident.
NO documentation for the management of contractors.
NO documentation defining audit requirements and an internal electrical safety audit process.
NO documentation with respect to formal change management process for energized electrical equipment.
Electrical safety competency is not validated.
NO formal compliant electrical safety program that includes the requirements listed above.

My concern is the employer has a false sense of security believing they are demonstrating due diligence when in reality all they have are equipment labels and arc flash PPE.

Unfortunately, I have been involved in several electrical incident investigations. With respect to documentation in most cases, there was either nothing or the documentation was not a compliant electrical safety program. There was a lack of field-based electrical safety documentation that was completed and signed by the qualified electrical worker before they proceeded with energized electrical work. There was no risk assessment completed. In some cases, this resulted in a fatality.

Establishing a compliant electrical safety program and ensuring it is audited on a regular frequency (e.g. internal electrical safety audit annually and external electrical safety audit at least every three years) will ensure your company can demonstrate measurable, sustainable and defendable due diligence. If you have no documentation or documentation that is not complete or compliant, your company, managers, supervisors and workers are at risk of government oversight if an electrical incident occurs.

Please follow up and ensure your documentation is appropriate, up to date and valid. In the end, it is all about the worker going home safe.

Terry Becker, P.Eng., CESCP, IEEE Senior Member is the first past Vice-Chair of the CSA Z462 Workplace electrical safety Standard Technical Committee and currently a Voting Member and Working Group Leader for Clause 4.1 and the Annexes. Terry is also a Voting Member on the CSA Z463 Maintenance of electrical systems Standard and a Voting Member of the IEEE 1584 Guide for Performing Arc-Flash Hazard Calculations. Terry has presented at conferences and workshops on electrical safety in Canada, the USA, India, and Australia. Terry is a Professional Engineer in AB, BC, SK, MN and ON. Terry is an Electrical Safety Specialist, Management Consultant at TW Becker Electrical Safety Consulting Inc. and can be reached at 587-433-3777 or by email: terry.becker@twbesc.ca.