Now that the 2015 Edition of NPFA 70E has been out for about a year, this weeks' question is about your thoughts of the "risk assessment" approach to the arc flash and shock hazard.

Do you like the risk assessment / risk management approach in the 2015 Edition of NFPA 70E?
Yes - Thumbs Up
No - Thumbs Down
No Opinion / Neutral

What are your stories about using the risk assessment/risk management approach?

I believe I heard sometime ago that the Risk Assessment method has been used in parts of Europe / UK for a very long time. It seems to work well for them so it is nice to see that it became part of NFPA 70E.

Yes, but...

There's a problem. Risk assessments are at least theoretically required for all recognized hazards in the workplace in the U.S. That doesn't mean it happens in practice. Quite often with broad categories such as lockout/tagout or confined space, we have a pretty fixed set of rules that covers all risks. The "frontiers" without decades of established procedure are where employers are on their own.

The general principle for the general cases, both IEC/ISO and ANSI standards, is to get together a panel of experts to look at the hazards overall and design out the problems or have procedures, PPE, etc., for the few that remain. Equipment has to be "maintained" in its intended condition including interlocks, etc.

But the challenge with all of these things is when those original design premises are no longer true. And this goes double for electrical equipment. Usually when it comes to mechanical equipment maintenance, it is almost always immediately clear from visual inspection when something is not right. By its nature though we cover up and shield everything electrical to begin with, and you can't actually see electricity, only the effects of it when it doesn't go where its supposed to.

We're "covered" in general by NEC or NESC as far as making equipment safe for operation and even for the most part maintenance, when it's maintained and functioning the way it's supposed to. In other words, electrical equipment is not inherently dangerous when designed, installed, and maintained correctly. And the likelihood of failure causing harm is extremely low compared to most other types of equipment, but the fatality rate when it does happen is very high.

The problem is when it's not, we're out on a limb. We have to first recognize that something is wrong. Then even once we get there, even the task of fixing it can be pretty hazardous. We can't just shut off the power, unlike mechanical repairs, because it IS the power source.

So where 70E is going, especially in the 2018 draft, is to require field inspections to a greater degree than ever. This version of risk assessments is quite outside of what OSHA for instance means by "risk assessments".

The biggest issue is it is poorly understood. There are too many engineers still performing an incident energy analysis and calling it a risk assessment. Also, users are used to having an engineer hand them PPE solutions for each location. A proper risk assessment must be performed with the direct input of or overseen by the user. It cannot be determined by the incident energy alone.

Users and some engineers are still confused about the table and the HRC terminology which has been discontinued. Folks are still trying to use the tables to determine PPE with an incident energy analysis.

Personally, I don't care for the changes. He's my reasons: I think arc flash labels should be used to warn the worker of the hazards and quantify them. That way he or she can take the necessary steps to protect themselves as well as establish the proper boundaries to protect others. Labeling that states Arc flash and Shock Risk Assessment with Appropriate PPE Required seems confusing. To me, the label should unambiguously warn and quantify.

The language about risk assessment could be misunderstood. Someone might read this and wonder if they're supposed to do an arc flash hazard analysis? Yet the label clearly gives the arc flash energy and boundary, so does this mean that he's supposed to double check the arc flash calculations because of some unknown change? In fact, it could cause a person to distrust everything on the label. A worker could read the label and end up confused, angry and frustrated. Those conditions often lead to ignoring the warning and accidents.

The labels we use state Arc Flash and Shock Hazard with appropriate PPE required, but also state that before working on the equipment a Risk Assessment is mandatory. Two separate statements. One quantifies the hazards, the second mandates the risk assessment. I might be splitting hairs with my comments, but isn’t the whole purpose with labeling to act to warn and quantify the hazards and not to confuse? And isn't that so workers have the proper information so they can take the right steps to protect themselves? With the arc flash and shock information clearly stated, he can then consider if any other risks exist. Plus, risks can change with time and with the context for the work. Risks are often unique with each situation. For example, is it day or night, is the equipment loaded or unloaded, is the location of the equipment compromised by stored materials. To me, information on arc flash and shock hazard is a small piece of a larger whole.