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Home > Videos > NFPA 70E/CSA Z462 - Field Implementation of Risk Assessment Procedure
NFPA 70E/CSA Z462 - Field Implementation of Risk Assessment Procedure

This webinar, given by Terry Becker at ESPS, provides a review of the requirement for a company's Electrical Safety Program to provide resources that can be used to complete the implementation of a Risk Assessment Procedure for energized electrical work tasks assigned to Qualified Persons. A Work Flow Process is discussed and how a Risk Register Table and Electrical Hazard Risk Assessment Matrix can be used. Arc Flash and Shock Risk Assessments are components of the overall work task's Risk Assessment Procedure.

See the full transcript of the webinar below.

 
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Full Transcript of the Video

Terry Becker: Good morning or good afternoon, and welcome to this EasyPower Webinar. Today's topic will be NFPA 70E/CSA Z462, a Field Implementation of the Risk Assessment Procedure. My name is Terry Becker, I'm an electrical engineer. I'm the Senior Vice President at Danatec Educational Services. I'm a certified Electrical Safety Compliance professional, I'm an IEEE senior member, I am the first past Vice-Chair of the CSA Z462 WorkPlace Electrical Safety Standard. I'm currently the Working Group Leader for the Annexes, also a voting member on the CSA Z462 Tech Committee. I do attend and participate in the NFPA 70E Tech Committee meetings, and specifically do support the Annexes Committee Working Group. I'm a voting member on the IEEE 1584 Tech Committee. In Canada, I'm also an Associate Member on the CSA Z463 Guideline for Maintenance of Electrical Systems. My work involves (00:01:00) completing electrical safety audits, and developing and implementing Electrical Safety Programs, providing low- and high-voltage training solutions to industry as well as blended training, which is e-learning and instructor-led training.

I am the subject matter expert and visionary of the Electrical Safety Training System Electrical Worker United Course. You may have known of me through ESPS, Electrical Safety Programs Solutions Inc. I sold my company, ESPS, to Danatec Educational Services effective August 1, and I continue to offer all of the electrical safety consulting products and training solutions that ESPS had offered. So, there's a bit of a disclaimer that I always offer when I do public presentations, because I am a voting member of the CSA Z462 Tech Committee. Basically today, I am here presenting on my own personal technical opinions and interpretations of both the NFPA 70E, Standard for Electrical Safety in the Workplace and CSA Z462 Standard, and any official (00:02:00) interpretation that you may require, you are encouraged to consult the published editions of NFPA 70E, the 2018 Edition, and in January, we published an edition of CSA Z462-2018, and you can also consult with NFPA or CSA for a specific technical interpretation from those organizations.

So, our agenda for today is I wanted to spend some time discussing the Risk Assessment Procedure requirement of NFPA 70E and Z462. As a word of note, those documents are technically harmonized, so when I do present this information, I will be using content from NFPA 70E, the 2018 Edition, which published here in the last couple of weeks, but when I make technical comments, it does apply equally to the CSA Z462 Standard, the 2018 Edition that will publish in January.

So, basically I will just provide some comments on the standards, and briefly (00:03:00) the differences that we will be seeing in the 2018 editions, specifically related to the Risk Assessment Procedure. I will put this under the context of an Electrical Safety Program requirement, which is a mandatory requirement of both NFPA 70E and CSA Z462. Just some brief definitions of what is risk and risk assessment. What I've found in working with industry is that there's a misunderstanding of the Risk Assessment Procedure, and so we've just got to pull back from that, and we've gotta look at what is risk and what's risk assessment, and then within the context of NFPA 70E and Z462, and what I've listed next in the agenda is Article 110.1 the Risk Assessment Procedure, and in NFPA 70E, the 2015 edition, and then it is now changed, and it has moved to 110.1 Risk Assessment Procedure in the NFPA 70E 2018 Edition, so we're gonna specifically focus in on that article, or the equivalent clause in CSA Z462 today.

I'm gonna discuss those articles (00:04:00) or clauses, and then I'm going to put my sort of interpretation on what is this Risk Assessment Procedure, and specifically how can you implement a process to actually document your risk assessments for discrete energized electrical work tasks. Again, I will emphasize that I believe this is misunderstood in industry, and then basically the next bullet says what is the role of the Arc Flash Risk Assessment and the Shock Risk Assessment that are also a mandatory requirement to be completed within your company's electric safety program and by the qualified person, or what I call the qualified electrical worker, so that the context of those risk assessments.

I'll comment on them, and there has been some updates to those Risk Assessment Articles or Clauses, specifically some significant changes to the Arc Flash Risk Assessment Clause, and quite a material change to it, actually, and a material change to the related (00:05:00) Arc Flash PP Category Tables, which in previous editions of 70E and Z462 was the hazardous category table method, and then field implementation of Risk Assessment Procedure will be a specific example of a tailored, customized Risk Assessment Procedure that includes a risk register table, and an electrical hazard risk assessment matrix. So, again, I've got a limited amount of time, and we'll dive right into this. So, we continue to see evolution and change in NFPA 70E, and again, Z462, that's tech re-harmonized.

The standards continue to become more focused on occupational health and safety management systems, and the requirements under that context, and this does relate specifically to the risk assessment content of the document, and so in the '018 editions, there's been further clarity in different articles and clauses to clean up any (00:06:00) miscommunication that we're strictly looking at hazards. We are not. Identifying hazards is only one component of the overall Risk Assessment Procedure, so I encourage you to get more information among 2018 edition, and if your company has not even moved to implementing any practices or updating your Electrical Safety Program to the 2015 edition, I really do encourage you to catch up quickly. Again, the '015 editions did change significantly, that's where we saw the focus change from hazards to risk, and as I said, in the '018 editions the language in the articles and clauses further cleans up making sure that the language and the processes are risk assessment-based.

So, the context and Electrical Safety Program, and again, in my travels, in industry, and doing consulting work, and attending conferences, specifically IEEE Electrical Safety Workshop, (00:07:00) I think there is still a misunderstanding of what an Electrical Safety Program is. NFPA 70E-2018 is still Article 110.1 with a series of sub-article requirements, including the Risk Assessment Procedure, and you'll notice back here that that was Article 110 under Electrical Safety Program, currently now in the '018 edition it's sub-article.

So, your company needs to have a documented Electrical Safety Program, and it is prescriptive language in the standards, so it shall be documented and implemented as a component of your overall Occupational Health and Safety Management System, so I believe companies really have not spent enough time to get into that, to really make the Electrical Safety Program their core focus, and within the Electrical Safety Program, the Risk Assessment Procedure needs to be included, so your Electrical Safety Program should identify the Risk Assessment Procedure requirement. It should provide a process for your company to (00:08:00) document a discrete energized electrical work tasks risk assessment procedure, and we will again, today go through a specific example. There are many ways to implement risk assessments, and the one that I have used is actually from the 2015 edition of NFPA 70E. So, what is risk and risk assessment? So, ANSI Z10 is the Occupational Health and Safety Management System standard for the United States. In Canada, we have CSA Z1000. Z10 has these definitions of risk assessments, where you'll find CSA Z1000 does not. So, risk, and this is important, is an estimate of the combination of the likelihood of occurrence of a hazard event or exposures, and the severity of injury or illness that may be caused by the event or exposure, and its pointing to Appendix in ANSI Z10. The risk assessment, and it says it right there, is a process or processes used to evaluate the level of risk (00:09:00) associated with the identified hazards and system issues.

Now, with the NFPA 70E and Z462, we have some definitions for risk and risk assessment that are slightly different, and then they're more aligned with the Risk Assessment Procedure that's identified in NFPA 70E and Z462, so I'll read those out. It says, "Risk, a combination of the likelihood "of occurrence of injury or damage to health "and the severity of injury or damage "to health that results from a hazard," so you can see that between ANSI Z10, and 70E, and Z462, it's similar, and now the risk assessment is slightly different, and it says an overall process that identifies hazards, estimates the likelihood of occurrence of injury or damage to health, estimates the potential severity of injury or damage to health, and determines if protective measures are required. Alright, so the other thing, and why I did have it on the screen is the informational note is important. As used in this standard, Arc Flash Risk Assessment and Shock Risk Assessment are types of risk (00:10:00) assessments, so that's important to note the overall Risk Assessment Procedure is a separate process from an Arc Flash Risk Assessment and a Shock Risk Assessment. The Arc Flash and Shock Risk Assessments feed in additional protective measures into the overall Risk Assessment Procedure to reduce the inherent or initial risk level to a residual risk level that will be as low as is reasonably practicable, but only from the perspective of potential of injury or damage to health.

The Arc Flash and Shock Risk Assessments only provide additional protective measures to hopefully drive down or mitigate the harm or drive it down. For instance, Arc Flash PPE drives down the inherent potential injury or damage to health from third-degree burn or worse to the 50 percent probability of the onset of a second-degree burn. So, when you do your risk assessments, you're gonna look at, (00:11:00) again, severity of injury or damage to health, and you're gonna compare it to the likelihood of occurrence, and we'll have some more information coming on likelihood of occurrence. Now, what we have on the screen now, is the NFPA 70E or Z462-2015 Risk Assessment Procedure Article, in this case, it's the 70E Article, so basically what you see on the screen is there's three steps, which were identified in the definition. So, previously, NFPA 70E required you to do an electrical hazard analysis. It was strictly focused on the hazards, and get PPE on a worker, a qualified person, and establish boundaries. Now that context changed in the '015 edition, and you're going to see that the Risk Assessment Procedure has a substantial change to it in the 2018 edition.

So, I wanted to start here saying this is what 70E mandates as the Risk Assessment Procedure, and says your Electrical Safety Program shall include a Risk Assessment Procedure that addresses employee exposure to electrical hazards. (00:12:00) The procedure should identify the process to be used by the employee before the work is started to carry out the following: identify if they are exposed to arc flash and shock hazards, assess risks related to the work tasks assigned to them, and then implement risk control according to the hierarchy of methods. Now, the hierarchy of methods, as you can see, was an informational note in the 2015 edition, and it does quote ANSI Z10, and now that will be a significant change in the '018 as that informational note now moves into a Subarticle, and therefore it's mandatory that you should consider all of the hierarchy of controls, and you should be looking at them from top down, not bottom up. The mistake that's happened in industry is a bottom-up approach was taken to the application of these control methods, because the focus was on hazard and PPE, which you can see is at the bottom. When in reality, 70E and Z462 basically say we need to be energized, first as a priority, then justify energized electrical work, (00:13:00) and then proceed with that work, and then, with this Risk Assessment Procedure, we should really be looking at the remaining controls to reduce the inherent or initial risk level to a residual risk level that is as low as is reasonably practicable.

So, what we're going to see is that the change, this is the change, this is the 2018 Risk Assessment Procedure that will be both in 70E and Z462. Now, you can see that that front end is the same. There is, in all the first element of this, our first sub-article of this item , is to identify hazards, assess risks, implement risk control, so that was similar, but you'll notice that there's been a little bit of a clarification, and now human error has been added. Human error was not noted at all, and as well, there's a brand-new informative Annex , which is human performance in electrical safety, so it puts focus on human error, now, (00:14:00) in the Risk Assessment Procedure in that you shall consider human error when you do your likelihood of occurrence evaluation, or that component of the Risk Assessment Procedure, and now you shall use this hierarchy of risk controls, so on the left-hand side, you'll notice that there's three, and then the other three on the right-hand side, and then there's been some additional information and notes added, though an important one is information, well they're all important, but the informational one says elimination, substitution, engineering controls are the most effective methods to reduce risk as they usually are applied to the source of possible injury or damage to health, and they're less likely to be affected by human error. Awareness, administrative controls, and PPE are the least-effective methods to reduce risk, as they're not applied at the source, and they are more likely to be affected by human error.

So, again, this whole concept of human error is now embedded, and if you weren't considering human error in your Risk Assessment Procedure, you definitely need to, but if you had effectively (00:15:00) interpreted the Risk Assessment Procedure, you most likely were considering human error. Again, so I'm setting the tone here for this example, this field implementation of Risk Assessment Procedure that I'm going to cover. So, some general comments about a Risk Assessment Procedure. It is an analytical process, and again, you can use different methods to put some values against harm and likelihood of occurrence, and you'll see an example of that, and it's important that the Risk Assessment Procedure puts weight on both consequence, which is severity of injury or damage to health, in this case from arc flash, arc blast, because arc blast has had a profile in industry, but we need to downplay the arc blast issue, and we will and I'll make some comments on that, and then shock.

And then in the context of the Risk Assessment Procedure, we have an energized electrical work task discretely identified as voltage measurement as an example, and then we will have voltage measurement (00:16:00) with what's called a work task hazard pair, voltage measurement on some electrical equipment at some maximum level of voltage, based on the maximum level of voltage, then we would determine if an arcing fault and arc flash can occur, and result in the potential for injury or damage to health related to burn injury. Alright, and then basically, separately, you would consider blast as a secondary effect, and then separately, for a voltage measurement, you know is the voltage, the nominal voltage high enough, AC or DC that there's a shock risk? And again, this is that qualified person or qualified electric worker getting the voltage measurement work task, identifying it as on some electrical equipment, and then getting the maximum normal voltage in the box, and then saying they are exposed, sot that's the first step of the Risk Assessment Procedure.

And again, we're now moving into what the second and third step are as I get closer to giving you some information here on how you can use our risk register table and an electrical hazard risk assessment matrix to actually implement (00:17:00) the actual Risk Assessment Procedure, so that's a subjective process, you have to be very careful that you're not too conservative, that you are very practical in your assessment, specifically of likelihood of occurrence parameters related to probability of the arcing fault and arc flash, and probability of the shock exposure, and again, you shall apply the hierarchy of control methods to reduce the risk level.

This statement, there is no zero risk level, there's always going to be some residual risk, right, and this is the risk that's left over, and it's this concept of risk, so the risk can be that there's still some potential harm, and there's still likelihood of occurrence that's residual after applying the hierarchy of controls, but that that residual risk level low or medium, is how I would discuss it, is acceptable, and we proceed, but then we have to make sure we document all of the control methods that are applied basically in our Risk Assessment Procedure to achieve the residual risk level. I know this is a (00:18:00) mouthful, and it's bit to take in, but it's not that complicated. I've heard statements that, "Oh, an electrician can't "be trained to do this. "We don't know how to do this." Well, know you have to spend some time, and you have to put some information in your Electrical Safety Program, and find a method that will work for your company.

Your company might have have an existing Risk Assessment Procedure and a matrix for large industrials, specifically petrochemical, very common, but you have to be careful when you have that overall risk-assessment process and matrix, because that matrix would be maybe somewhat complicated for an employee to apply, because it typically considers stock price, impact on environment, safety, so there's other elements or other consequences that those risk assessments consider, and we don't want the qualified person, qualified electrical worker to get bogged down on that. They will reject that, but if you use the Risk Assessment Procedure that was provided in NFPA 70E, Z462-2015 (00:19 :00) and Annex , you can come up with a process that I think is simple. There's some flow charts, you can simplify the flow charts, and you can create a risk register table, you can go through the process with your electrical safety steering committee, just don't be too conservative, but obviously then don't be too as well on the risk side. Be practical in your assessment of arcing fault probability, and the impact of blast pressure. For blast pressure, I call it the 40-cal myth. Industry has unfortunately established that 40 calories per centimeter squared is a dangerous incendiary level, and that's not true. And again, the two notes actually, that mentioned increased emphasis on 40, it's above 40 calories, will be deleted, finally from the standards.

So, moving back to the Risk Assessment Procedure, once you get into this process, you have to apply the hierarchy of control methods, which show up in ANSI Z10, CSA Z1000, and now, are part of the main requirements of Z462 and 70E (00:20:00) in the Risk Assessment Procedure Article clause. So here they are again, elimination, and there has been some additional changes in the 2018 edition related to elimination, the lock-out, tag-out content has been rejected and improved upon. The training requirements for lock-out, tag-out are now embedded in Article 110, after about 110.1, where lock-out, tag-out training is now identified in the training section, so if you don't have formal lock-out, tag-out training, it's now highlighted that you need to, again, so rework of the lock-out, tag-out requirements, so just be cognizant of that as you're reading the differences between '015 and '018, that the lock-out, tag-out section has been updated, and some content shifted around related to training. So, elimination is establishing electrically safe work conditions, and that process, by the way, has also changed in the 2018 edition of Z462 and 70E, so make sure you do look at (00:21:00) the changes to establishing electrically safe work conditions. Now, there are eight steps, instead of six possible steps, to implementing that process.

So, substitution with other material systems or processes, engineering controls, so an engineering control would be we do an arc flash and energy-analysis study, and we install some mitigation to reduce the incident energy. Arc flash relays means more switches, just changing protective device settings, so that's engineering controls as an example. Awareness is warning signs and barricading, using equipment labels for arc flash and shock that have put more attention on signage and establishing electrical work zone with the boundary information that comes from the Arc Flash Risk Assessment. Administrative controls are training and procedures. A lot of training's happening, but I do find gaps with procedures being written in the workplace, alright? So again, that's a little information on hierarchy of controls. As I said earlier, the role of the Arc Flash Risk Assessment and the Shock Risk (00:22:00) Assessment is independent of the Risk Assessment Procedure. They feed additional protective measures into the Risk Assessment Procedure to drive down the potential of injury or damage to health. These two assessments are not the Risk Assessment Procedure.

What I've come across in industry is that they may have been trained or an assessment that the Risk Assessment Procedure is just completing the Arc Flash Risk Assessment and the Shock Risk Assessment, which is not true. Those are two separate risk assessments, which I've said earlier there's a bit of a note that has clarified that, so both of these articles have had some minor updates in the 2018 edition of the standards, and specifically the Arc Flash Risk Assessment has changed substantially. So again, be aware of that, and make sure you do put some focus on reviewing the Arc Flash Risk Assessment, as it is improved, in my opinion. It is again, further aligned with risk assessment standards, and the existing Table 130.7 (00:23:00), which is Table 4 in Z462, has now been completely removed from the Arc Flash PPE Category Table Method, so we basically have the Shock Risk Assessment, and the really, the big change in the Shock Risk Assessment and the Arc Flash Risk Assessment are at the front, is they now include sort of the three steps again of the overall Risk Assessment Procedure that's specific to the shock hazard and the arc flash hazard. Identify if you are exposed to a shock hazard.

Make sure you do an estimate of the likelihood of occurrence of injury, and injury or damage to health, and the potential severity of injury or damage to health, and then the third step is determine if additional protective measures, that's sort of a new term now, determine if additional protective measures are required, including the use of PPE, so these additional protective measures for the Shock Risk Assessment, and the Arc Flash Risk Assessment would be the boundaries, with one, an arc flash boundary, and two, shock-approach (00:24:00) boundaries, limited or restricted, and those boundaries then provide guidance on what worker can encroach on them, and when you need PPE, for instance, inside Restricted you have to have shock-related PPE to all the equipment used. If you're inside the arc-flash boundary, and you create an arcing fault potential, do your work task, then the arc-flash boundary is real, and the arc-flash boundary is related to keeping unqualified, unprotected people out, because you will have the PPE on, as you identified in the Arc Flash Risk Assessment for the related arc-flash hazard. So again, remember, these are independent of the Risk Assessment Procedure, but they feed into the Risk Assessment Procedure, specifically again, to affecting in a positive manner, the potential of injury or damage to health.

So field implementation of the Risk Assessment Procedure, it really needs to include a document of the Electrical Safety Program. Your company has to have one developed and implemented, and within the Electrical Safety Program, you embed (00:25:00) the Risk Assessment Procedure as basically a discussion of how you expect it to be completed, then if you, again, develop a specific risk register table, and a specific electrical hazardous assessment matrix, you would further explain how those tools are used to complete a discrete energized electrical work task risk-assessment procedure, and again, documenting that in this case the process I'm going to show you that you've taken the inherent or initial risk level, and you've reduced it such that the residual risk level is again, as low as reasonably practical. So what I do is I recommend companies get program, and then they have an Electrical Safety Steering Committee that's responsible for the ongoing management of that program. After it's developed, the Electrical Safety Steering Committee has a responsibility for maintenance and updating the program. The Electrical Safety Steering Committee could be a committee-based risk assessment procedure for typically inventory of energized electrical work tasks. (00:26:00) The beauty of 70E and Z462 is with the changes to the new edition, they've made this table independent for arc flash specifically, which used to be one of the previous tables I mentioned earlier, so the new table for 70E is Table 130.7 , and the new table for CSA Z462 is Table 2. Those are work task tables, and then they talk about condition or maintenance, and now they've changed the context to likelihood of occurrence of an arcing fault and an arc flash, and these two tables are now used independently, right, of the actual incident energy analysis or the arc-flash PPE category table method as the starting point of your arc-flash risk assessment.

Work task, condition of equipment, likelihood of occurrence, yes or no, and if it's yes, then you would proceed to then identify additional protective measures, PPE and the arc-flash boundary, only in the working distance for the qualified person to execute the work task with. So again, your committee would also (00:27:00) hopefully take some ownership to get the arc-flash risk assessment data, either incident analysis or the confirmation of the parameters of the arc-flash PPE category table sorted out for your workers, so you do committee-based risk assessments, which is what I recommend, and you'll have maybe a management sponsor, an electrical engineer if you have one on staff, most companies don't, but you'll have your electrical maintenance supervisor and representatives of the electrical workers, and then you'll basically, as a committee do these risk assessments for typical work tasks, and you can deliver those to the working community, and then the key is is the workers that receive these risk levels, for instance a voltage measurement, maybe it's a medium risk, the workers have to then confirm the application and document their application of the hierarchy of control methods that were assumed by the committee-based risk assessment to be applied.

So again, the process that I'm outlining, it starts with an inherent or initial risk level being determined, and in this case, (00:28:00) if you do and have referred to Annex from 70E, has a flow chart that talks about an iterative process of the application of the control methods. I basically say, "Hey, let's apply them "all at the same time. "Let's apply every one of those hierarchy of controls "from inherent, to initial risk level, "to the residual risk level." You do one iteration, alright, and then you achieve this residual risk level. The key is, repeating myself, the qualified electrical worker, the qualified person, shall document their application of the assumed control methods that delivered an acceptable residual risk level, low or medium risk level in the process that I'm going to show you here shortly. So, I'll use a simple flow chart, one that you've probably seen possibly before, but it's a high-level flow chart for risk assessment. We established the context of the risk assessment.

Again, you have to identify the hazards. We do risk analysis, risk evaluation. You apply risk controls, then you need to monitor and review those controls, alight, which is again this field documentation (00:29:00) component that I talk about, and then this communication and consultation, so you do need to work with the workers that are going to be exposed, using, well if it's just a supervisor that's doing the risk assessment with the employees, yes, you have to completely consult and communicate with them, but if you do this by committee, there definitely has to be some communication and interaction and collaboration with the greater community of electrical workers within your company, or if you use contractors, and that's a whole other discussion if you have only contractors working for you, and you're the owner of the facility, then you'd have to work with your electrical contractor and communicate, again, that there's hazards of arc flash and shock, and you've assessed the risks, and here's what we believe the residual risk level is, if the hierarchy of controls are applied.

So, when you go on the Internet, and you just search risk assessment, this is what you'll probably see. These are matrices, of course, and you can see, how many are on there, (00:30:00) it looks like nine, 10, 13 or so, so these are all applicable to whoever developed them and how they're being used. I'm going to show you one that will look very similar to these, and usually, you've got severity on the one side, and likelihood of occurrence on the other side, so X and Y axes, and again, you've gotta be careful, these are configured differently when you do look at them and try to understand the context of the matrix and how it's applied in the Risk Assessment Procedure that you perform. Now, here's the one that I use, and I recommend, it's very simple. So, there's an electrical hazardous matrix over here on the left you'll see. This looks similar to some of these, right, and then we have this risk register table, which is just a simple table. Over here on the right-hand side you'll see sort of a spreadsheet version, and then there's three work-task hazard pairs, so you would enter voltage measurement up here, and then identify the maximum normal voltage of the voltage measurements. You would identify the equipment that the voltage measurements (00:31:00) would be performed on, and then you would do your inherent and residual risk assessment, but I broke out the three work tasks hazard pairs.

So, over here on the left, arc flash is a burn injury problem. Blast is a physical trauma problem, and shock is a unique electrical phenomenon of current flow through the human body, with an effect based on how much current flows through the body, the flow and direction through the body, and the duration of exposure. So, and then there's consequence or severity values that are equated against the different levels of harm, and again, over here on the left, there's just I've lumped them all over the left, and basically you'd have to know what the different severities are, which is broken out in this example over on my right-hand side here. Then, the likelihood of occurrence parameters and they are derived from, again, Annex of the 2015 edition of 70E and Z462.

There are three sub-parameters of likelihood of occurrence to consider, frequency of exposure, (00:32:00) the probability, and avoidance, and really the frequency of this context is how often is the worker exposed to arc flash and shock, or how often do they do voltage measurements at your facility, and then you would select hourly, daily, weekly, and you would enter that value in your risk register table, and then probability is really where the highest impact is, and the way that I frame probability is do you have qualified and competent workers, do you manage their human performance behavior, and do you manage the condition and maintenance of your electrical equipment, and the condition and maintenance has been propped up in several articles and clauses in 70E and Z462, that it is a key requirement, related to probability of an arcing fault, specifically an arc flash, and could be another factor related to shock, with degradation of insulation in electrical equipment.

Avoidance, and the context of avoidance the way that I explain it, is to focus on two items, (00:33:00) is by the design of the equipment, could we avoid exposure to arc flash and shock? And if a worker does detect some abnormal condition in real-time, a change maybe from normal to abnormal while they're working on the electrical equipment, can they egress, can they identify an egress, and is it likely possible or impossible, sort of blending those two requirements under avoidance. So, sort of what I'm framing for you, is you have this matrix, the context of the matrix is severity or injury or damage to health is on the left-hand side of the scanned example I'm providing. You, and the likelihood of occurrence on the right-hand side, and you need to do this evaluation, so you have to do an evaluation now using this information in the matrix, which occurs in the risk register table.

So now here's an example where the risk register table has been filled out. We have some new acronyms, and the Risk Assessment Procedure comes with new language, so we have to learn some new terms and phrases, some new acronyms, and (00:34:00) depending on how your company sets it up, it can be a process of multiplication or summation, but I've just used a simple summation process, and blending severity and likelihood of occurrence to come off the risk class, for the work task hazard pair, and again, you would apply this to voltage measurement, to current measurement, blacking out power to the circuit breaker, installing tempered to protect the grounds, any additional work tasks here that we have a list in 70E and Z462, so you inherently do a baseline on risk level, or inherent risk level. In this case, I said, "Let's start with "no electrical-specific PPE tools and equipment," and that was the past, but it really does frame it for you that without PPE, using risk assessment procedure, we have higher risk for arc flash and we have higher risk for shock.

The way that I frame blasts, is blast is a secondary effect of arc flash, and there's no documented fatalities related to blast pressure, so I put the severity down to basically repairable physical trauma, inherently, and then residually for blasts, I said (00:35:00) there's no PPE, so the residual harm would still be the same, which could be repairable physical trauma, but inherently, we know that arc flash can ignite non arc-rated clothing, causing a third-degree burn injury, which accelerates and the worker doesn't survive, and then for inherent risk, for shock, basically I said if you're not wearing rubber-insulated gloves with leather protectors when using leather-insulating and insulating hand tools, you can get electrocuted, so this is the context that I'm explaining to you in this example, and so inherently, we take the highest risk level of the three work task hazard pairs, and that's the overall inherent risk level of the work task, in this case, voltage measurement as our example. So, that's not acceptable.

So then we apply arc flash and shock risk assessments, we look at the hierarchy of control methods, procedures, more training, and can we do anything to lower the arc flash? Again, the other control methods, and when we apply the arc flash and shock risk assessments you can see that arc flash gets driven down (00:36:00) from a severity of 8 to a severity of 3, so arc flash, we know that PPE only limits the burn injury, to a 50% probability of the onset of second-degree burn. Blast, I said there's no PPE, and again, I want to make a comment here that electricians have called arc flash suits bomb suits, and they're not bomb suits. I'd encourage you to watch the movie The Hurt Locker with Jeremy Renner, and it's a really good movie by the way, but he is a bomb squad technician in the U.S. Army, and that movie is based in Afghanistan, and it's a really good example of the bomb suit, but also of the limitations of any PPE, and the bomb suit he wears protects his core body from the pressure wave released from the explosion that occurs, but his limbs would potentially be damaged or potentially blown off, and his hands, he doesn't have anything on his fingers, 'cause he needs to diffuse bombs with wire gauges that are significantly small, so small wire (00:37:00) size, so again, that's an example where blast pressure, we don't want to call flash suits bomb suits, they're not.

They don't provide any blast protection. They could only, again, provide burn injury reduction for workers, so we apply the PPE and the control methods and boundaries, and make decisions, and have training, and procedures, and warning signs and barricading, and other engineering and safety by design, and substitution controls. You evaluate the impact, with attention on frequency of exposure, probability, and avoidance, so you can see that I've used a 4, which was that we're weekly doing voltage checks at our facility, and then for probability, for my assessment and my assumptions, I assume that we have qualified and competent workers. I've assumed that we had employees who are behavior managed, and I assumed that we do maintenance, so basically I put the probability of an arcing fault and arc flash, and shock risk exposure as negligible, and avoidance, initially, (00:38:00) maybe we had some older equipment, amongst newer equipment, and we couldn't have trust and avoidance of the older equipment, so initially we had that, but we replaced that equipment, so residually, the avoidance went from possible to likely, in which you'll see the risk class numbers changed, alright, to a quite a significant lower number based on the reduction of injury or damage to health, and the impact of avoidance also being reduced in this case. Each one of these would be a potential sensitivity analysis, and you then adjust the numbers based on changing the context.

What if we didn't have a qualified, competent worker? What would happen? Would the risk level go up? Well, it should, so again, you start with your baseline, and then your baseline residual, and then you can run sensitivity analysis using this tool. So, ultimately this is a documented Risk Assessment Procedure, using again, Annex , which I created a risk register table and a matrix, and a process, and this works. (00:39:00) This does work to document energized electrical work tasks Risk Assessment Procedure. Now, this is an example of taking it to the next level, so if you take the whole list of energized electrical work tasks from 70E and Z462, and put it in a spreadsheet, and then you layer in some additional information, do we need an energized electrical work permit? How are we documenting the actual information in the field? Do we have a document to do that? We also put it in the context of the workers and impact, qualified operations workers in large industrial facilities. They operate energized electrical equipment, turn it on and off. They do isolations, so you can expand the context above and beyond a qualified person, or qualified electrical worker, and you'll notice that I've put in the spreadsheet inherent risk level columns and residual risk level columns.

So again, you can move from a simple Excel spreadsheet risk register table to a more complicated, not complicated, more detailed (00:40:00) and complete, Excel spreadsheet as a risk register, again, documenting the Risk Assessment Procedure for your company, for your electrical systems and your staff or contractors. So, again, I had a a limited amount of time today, so I've gone through this fairly quickly, and I hope that you will have received some additional insight into what you may be doing, and going, "Yeah, we're doing something like that, "this looks good," or "Wow, you're right, we did not, "and have not been doing a Risk Assessment Procedure. "We have only been doing Arc Flash Risk Assessment "and Shock Risk Assessment."

So, again, I encourage you to, and if you are listening, you want to get additional information, that you do when this is emailed out to you, take a second or third listen to this webinar, and again, just closing remarks, (00:41:00) you've got to have a documented Electrical Safety Program that's compliant, so there's another word that I didn't mention earlier, a compliant Electrical Safety Program. If you don't know what that means, find out, and I do know what that means, so your Electrical Safety Program can't be one page, it can't be ten, it needs to be a few more pages than that, but it's really not the pages, just the framework. It's the framework of the Table of Contents. Is it complete, and can you audit against Occupational Health and Management Systems for completeness?

The Risk Assessment Procedure shall be documented, and your Electrical Safety Program has to basically outline the specific risk assessment procedure that you'll be implementing with what tools you're going to use to document it. Again, the qualified person or qualified electrical worker, as I call it, they need to be integral to that discussion, either because they're part of a committee and doing typical risk assessments and making assumptions, and/or they are the individual, actual worker, (00:42:00) that receives a work order, planned to react to it, and then has to go, "What am I doing? "What are the discrete energized electrical work tasks "related to the work order? "Am I exposed to arc flash and shock?" And then they understand the context of risk, what does it mean to them now, as far as their personal risk, 'cause that's the goal here, is we do not want the worker to be exposed at all, but we will always need energized electrical work, we will always need diagnostic troubleshooting and isolation-related work tasks. The only way we can establish a likely safe work condition is by turning the power off, and then isolating the power, following the steps of establishing a likely safe work condition, which involves potential exposure to arc flash and shock, and then testing for zero volts. It is energized electrical work, so again, we'll have to apply the Risk Assessment Procedure to just isolation activities, because there is arc flash and risk exposure to a qualified person/ (00:43:00) qualified electrical worker, even just to do isolation.

So we need diagnostic troubleshooting, and we need isolation to continue, and again, you need to properly interpret what 70E and Z462 are communicating to us, and properly implement its requirements under a compliant Electrical Safety Program. Remember, the Arc Flash Risk Assessment and the Shock Risk Assessment, they are not the Risk Assessment Procedure. Those are separate risk assessments that are important to the overall risk assessment procedure. Field implementation requires that your Risk Assessment Procedure be documented, and that it include documenting the hierarchy of control methods applied to achieve the residual risk level. This is critical. OSHA in the U.S., and OH&S regulations in Canada. There's three words I tell people.

Document, document, document, so again, I do talk to a lot of people in the industry. I work with a lot of people, (00:44:00) and I tell them that you just can't take 70E and Z462, and train a worker on it and buy him PPE. It's weak, due diligence, and if you do have an incident, you will still potentially be fined or worse, so you've got to make sure that you pay attention to where you are in this process, and the timeline of implementing 70E or Z462's requirements, and you need to get an Electrical Safety Program and drive everything through the Electrical Safety Program. It all goes back to the Electrical Safety Program, everything you do, why you do it, the benefit, right, the justification for doing it. It's all driven through the Electrical Safety Program. It's all driven through risk reduction, and the worker.

So, at the end of it, implementing a program is not easy. It needs to be managed, so you can't just say we trained the workers five years ago, we bought 'em PTM. Well, I think they're doing this, right. It's an ongoing endeavor. it's a continuous improvement model, a plan, do, check, (00:45:00) act model, right, you cannot stop. Once you start, you're in it, and every three years, 70E and Z462 change, and you must understand those changes, and you must implement and update your practices through your program, and in turn, yes, train your workers on the new requirements, and this Risk Assessment Procedure and the concept of risk is here to stay. It is not complicated. It is not difficult. It isn't necessarily easy, but easy's a relative term.

The Risk Assessment Procedure I just showed you is easy, but you have to implement some documentation, understand the documentation, and make sure that your workers understand it, your supervisors understand it, management sponsors it, and that you do the risk assessments, and back to what I said, implement those controls. You must have documentation that you've implemented control methods to achieve the residual risk level related to a discrete energized electrical work task, so remember, under a work order or a job, (00:46:00) there maybe be multiple discrete energized electrical work tasks to achieve fulfilling that work order, solving the problem, so be careful, too, because the work tasks have to be risked independently, alright? Details required, documentation shall be created and utilized. Now, as far as the differences, if you need more information, it's out there. So get information on the differences, understand them, update your Electrical Safety Work Program, train your workers on the new requirements, please, this is really important, it's important to the workers and it's important to your company that we achieve sustainable and measurable results in electrical safety. We do that through the implementation of Electrical Safety Work Programs, with a documented Risk Assessment Procedure, and there, it's quoted right there. That's how you will achieve sustainable, measurable results in performance, and compliance, compliance to OSHA in the U.S. and compliance to OH&S regulations in Canada that your company can defend.

(00:47:00) So again, I do appreciate EasyPower, for allowing me to present this webinar to you today. I do hope that all of you did learn something, or that you'll go, "Oh, okay, I didn't interpret it this way," so I hope that I've achieved that today. I do appreciate you, again, participating in this today, and again, lastly, hope that this webinar has enlightened you to the Risk Assessment Procedure requirements in NFPA 70E and CSA Z462. So, thank you, and have a great day.