Electrical safety: How to move beyond basic compliance

Including risk analysis in a plant’s electrical safety program can improve overall safety

By H. Landis “Lanny” Floyd June 27, 2024
Courtesy: NIOSH


Learning Objectives

  • Learn to define a compliance-based culture for electrical safety.
  • Describe benefits and limitations of a compliance-based safety culture impact on their electrical safety program.
  • Understand techniques to identify and address residual risk in an electrical safety program.


Electrical safety insights

  • A compliance-based safety culture is based on the belief that simply complying with regulations, codes and standards will achieve safety performance objectives.
  • Countries that have moved beyond simple compliance to include risk analysis of residual risk have demonstrated significant results.

Since President Nixon signed into law the Occupational Safety and Health Act of 1970, workplace electrical safety in the U.S. has primarily focused on compliance with the minimum safe work practices in Occupational Health and Safety Administration (OSHA) regulations and, after first published in 1979, compliance with requirements of the safe work practices in NFPA 70E: Standard for Electrical Safety in the Workplace.

The requirements in NFPA 70E are also considered minimum electrical injury risk control measures. Without taking away from the importance of the minimum requirements in the regulations and standards, this article explores the limitations of compliance-based safety culture and the benefits of a more comprehensive solution that includes proven concepts of risk management.

Residual risk is the amount of risk, associated with a task or process, remaining after inherent risks have been reduced by risk controls. What if inherent hazards and risks are not completely identified? How do you know if the residual risk has been reduced to a level acceptable to the worker and to the organization?

There may be hidden danger outside the control of a worker exposed to hazardous energy, including responsibilities of management/leadership, facilities design, safe work practices, incident learning reviews, procurement and outsourcing.

How can plant engineers and electrical safety experts identify opportunities and techniques to look beyond simply complying with regulations and standards so that we can optimize safety of workers potentially exposed to hazardous electrical energy?

Compliance-based electrical safety

Have you ever heard someone say, “If OSHA or NFPA 70E do not require it, why should we do it?” Statements like this are characteristic of a compliance-based safety culture, which embraces the belief that simply complying with safety regulations, codes and standards will achieve the desired safety performance. This approach, although limited, has resulted in long-term trends in reducing fatal and non-fatal occupational injuries in the U.S.

Emergence of the first OSHA laws in 1970 stimulated development of industry consensus standards documenting safe work practices such as NFPA 70E. A compliance-based culture has been effective in improving safety performance in the U.S. Nearly 15,000 occupational fatalities from all causes occurred in the U.S. in 1970. With a workforce that has doubled since 1970, there were 5,486 occupational fatalities in 2022, according to the Bureau of Labor Statistics.

Figure 1 shows significant reduction in nonfatal lost time injuries fatalities from exposure to hazardous electrical energy, and the downward trend appears to have flattened in recent years. The flattening trend could be incorrectly interpreted that the U.S. may be at a theoretical limit in reducing serious electrical injuries.

Figure 1: Lost time injuries from contact with or exposure to electrical energy in the U.S. 1992 to 2020. Courtesy: Electrical Safety Foundation

Figure 1: Lost time injuries from contact with or exposure to electrical energy in the U.S. 1992 to 2020. Courtesy: Electrical Safety Foundation

However, other countries have demonstrated significantly lower occupational fatality rates, including electrical fatality, than the U.S. The report “Occupational fatality risks in the United States and the United Kingdom,” by Mendleoff and Staatsky published in the American Journal of Industrial Medicine in 2014, showed that the overall occupational fatality rate in the UK was approximately one-third that of the U.S. The fatality rate from exposure to electrical energy was about 25% that of the U.S.

The study did not attempt to determine what has contributed to the difference in safety performance, however the safety management regulations in the UK place more emphasis and resources on risk assessment than the compliance-based approach common in the U.S.

Calculating electrical risk

Based on Bureau of Labor Statistics data, less than 0.2% or less than 1 in 500, lost time injuries in the U.S. in 2019 were attributed to exposure to hazardous electrical energy. The relative infrequency of electrical injuries can create an illusion impacting estimation of likelihood of exposure to hazardous energy when performing a task.

Incidents that are low in frequency can also mean that a company or organization does not have sufficient internal data on electrical injuries to be statistically meaningful. Due to the inherent low-frequency occurrence of electrical injuries, an individual or company may not recognize the potential for a fatal injury.

Consider a task in which the likelihood of injury when a worker performs a task is viewed as unlikely. The worker and management may consider the risk acceptable and proceed to perform the task without any additional controls to reduce risk further.

Now consider the worker may perform a similar task every day over a 20-year career, which could mean the worker could perform tasks with unlikely injury potential 4,000 times during the worker’s career. Now the “unlikely” incident may be up to 4,000 times more likely to occur sometime during the worker’s career. Is this an acceptable risk if the potential severity is serious injury or death?

Or consider a large company with many manufacturing facilities in which the task could be performed 1 million times/year. Now the “unlikely” incident based on assessing one task is 1 million times more likely to occur to a worker somewhere in the company’s facilities. Underestimating the potential frequency of a serious incident could have tragic consequences.

Electrically safe work conditions

Residual risk is the risk that remains after risk controls are considered. The primary goal in risk based occupational safety management is to reduce risk to as low as reasonably practicable (ALARP). In conducting risk assessments, if frequency of exposure is underestimated, control effectiveness over estimated or potential severity of consequences under recognized, the resulting residual risk may fall short of ALARP.

When establishing an electrically safe work condition, there may be residual risks that if assessed, could be further addressed with additional controls. Consider an example of a lineup of 15 kilovolt (kV) industrial switchgear on which maintenance tasks of cleaning, inspections and testing are to be performed. Ask these questions:

  • Is it feasible that an error could have occurred in establishing an electrically safe work condition?

  • Is it feasible that an isolation point could have been missed, perhaps a potential transformer that could back feed the 15 kV bus from a 120 V source?

  • Is it feasible that the physical boundaries of the electrically safe work condition could be misunderstood by a worker?

  • Could a worker be confused by “look alike” equipment that is outside the safe work zone?

  • Could a worker remove a cover exposing hazardous energy?

To address these and other remaining risks, additional controls may be needed. Overestimating effectiveness of the compliance-based controls could create an illusion of safety for workers.

The hierarchy of risk controls have been in safety management standards and literature for more than 50 years (see Figure 2). Except for a control measure that permanently removes the hazard ensuring that no worker can be exposed to the hazard under any foreseeable circumstances or one that substitutes a less severe hazard, other control measures serve to reduce likelihood of exposure, but do not change the potential severity of exposure to a hazard.

Figure 2: The hierarchy of risk controls from National Institute for Occupational Safety and Health (NIOSH). Courtesy: NIOSH

Figure 2: The hierarchy of risk controls from National Institute for Occupational Safety and Health (NIOSH). Courtesy: NIOSH

In Figure 2, the vertical shading on the left denotes relative effectiveness in risk mitigation. The top control measures have the highest effectiveness and value and the bottom control measures are less effective in that they are more vulnerable to human error. Unless a hazard can be eliminated such that there is no foreseeable way for exposure to occur, a combination of controls in the hierarchy is required.

For example, a ground-fault circuit interrupter (GFCI) outlet is an engineering control that provides a barrier from a lethal electric shock, however a GFCI can fail. To verify its functionality, a GFCI requires periodic testing, an administrative control.

The control measures of administrative controls and personal protective equipment are vulnerable to human error that reduce control measure effectiveness. The relative infrequent occurrence of electrical injuries as compared to other injuries from other hazards in the workplace can create a false sense of immunity from severe consequences of contact with electrical energy.

Having personnel competent in risk assessment methods and an ongoing robust process to facilitate identification, quantification and reduction of risk is essential to achieving risk ALARP. Safeguarding workers from the pitfalls discussed above requires investment in time and money to develop competency in risk assessment and mitigation tools and methods.

The Three Mile Island nuclear power station accident in 1979 highlighted limitations of a compliance-based safety culture. The Report of the President’s Commission on the Three Mile Island Nuclear Accident included these statements:

“We note a preoccupation with regulations … we are convinced that regulations alone cannot assure safety … This commission believes that it is an absorbing concern with safety that will bring about safety — not just the meeting of narrowly prescribed and complex regulations.”

If compliance with regulations is not sufficient in nuclear safety, could this learning also apply to electrical safety? How can learnings to control the extraordinary potential catastrophic consequences of a nuclear incident be applied to create “an absorbing concern with safety” to manage the risk to workers exposed to hazardous electrical energy?

Exploring the residual risks that may remain after compliance with regulations and standards involves having a heightened understanding of hazard identification, risk assessment and risk reduction to supplement the results in injury prevention afforded by a compliance only approach. Employers and workers and organizations must recognize that simple compliance with the minimum requirements of regulations and industry standards may have residual risk that may not be as low as reasonably practicable.

Risk management for electrical safety

After achieving compliance with safe work practices, applying risk management techniques includes exploring answers to questions (Figure 3). When there is possible exposure to hazardous electrical energy, asking and answering these questions can help move beyond compliance with minimum requirements to see hidden danger and how residual risk can be reduced further.

Figure 3: Questions that can help identify hidden danger. Courtesy: H. Landis Floyd

Figure 3: Questions that can help identify hidden danger. Courtesy: H. Landis Floyd

Electrical safety leaders can explore these questions throughout the life cycle of a facility or system, including initial design, equipment specification and procurement, task planning, job safety analysis and incident investigations.

As illustrated in Figure 4, an organization’s electrical safety program requires integration of regulations, codes and standards that establish minimum requirements for the safe design, installation, operation and maintenance of electrical systems. By consciously looking beyond compliance, electrical safety leaders can be vigilant in identifying hidden danger and further reduce residual risk throughout the life cycle of a facility.

Figure 4: The electrical safety program requires integrating requirements of multiple regulations, codes and standards. Courtesy: H. Landis Floyd

Figure 4: The electrical safety program requires integrating requirements of multiple regulations, codes and standards. Courtesy: H. Landis Floyd

Continuing safety approaches

The National Safety Council, the American Society of Safety Professionals and OSHA have partnered to provide resources to help organizations compliment a traditional compliance-based approach to one that more effectively uses risk-based tools to move beyond simple compliance.

We can explore the “hidden danger” that may remain after simple complying with regulations, codes and standards. To achieve full potential in injury and fatality reduction, electrical safety practitioners will need to invest time and energy to develop competency in moving beyond compliance. The stakes are high and there are demonstrated results as noted in the examples in this article.

Author Bio: H. Landis “Lanny” Floyd, PE, CSP, CESCP, CUSP, CMRP, CRL, Life Fellow IEEE, is a member of Plant Engineering's editorial advisory board. He is an adjunct professor in the Advanced Safety Engineering and Management graduate engineering program at the University of Alabama at Birmingham. He retired from DuPont in 2014 after a 45-year career devoted to prevention of electrical injuries and fatalities.