Why investing in electrical safety is important now more than ever
An analysis of OSHA’s top 10 most cited violations for control of hazardous energy.
In March 2021, the official OSHA top 10 Violations for 2020 were published after an understandable delay not unlike what we had grown accustomed to amid the COVID-19 pandemic. This year’s top 10 saw the Standard (1910.147) for The Control of Hazardous Energy (Lockout/Tagout) drop to the No. 6 spot with 2,065 total violations — 541 less than the previous year. Each year, safety conscious employers depend on the OSHA’s top 10 most cited violations data to better inform them on the riskiest scenarios in their safety programs. The total violations are typically released at the end of the fiscal year in September.
Veteran safety consultants urge employers to keep an eye out for the annual OSHA top 10 report. This list is one of the best starting points on the path toward fostering a robust safety culture. In an interview with Safety+Health magazine, one safety consultant advises, “Minimally, an employer should have the responsibility of asking, ‘Do any of these top 10 affect me?’ Because this is the easiest place if our friends from OSHA should come to visit,” said JoAnn Dankert, senior safety consultant from the National Safety Council (NSC).
With our electrical safety background, Grace Technologies look at this list to analyze the most cited violations for the Control of Hazardous Energy standard CFR 1910.147, and provide solutions on how to avoid the most common mistakes in electrical safety. The most important item to note is that the training and communication regulation CFR 1910.147(c)(7) is frequently at the top of OSHA’s most cited violations for Control of Hazardous Energy. As the pandemic wreaked havoc on industry revenues in 2020, experts were concerned with how organizations would respond with their training programs.
“When revenue goes down, organizations tend to sometimes pull back on training,” said Dankert, “and I would encourage people not to pull back on your safety training. With some things, we’re struggling within organizations because maybe we’ve done classroom training, but now because of physical distancing and so forth, we don’t want to put too many people in an area. That might mean we’ve got to have more classroom training sessions.”
Applicable to electrical safety
This is true as it relates to electrical safety and the control of hazardous energy. When training in your electrical safety program, start by looking at the recurring top 10 most cited OSHA violations related to the control of hazardous energy. This standard covers the servicing and maintenance of machines and equipment in which the unexpected energization or startup of the machines or equipment, or release of stored energy, could harm personnel.
One of the consistently most cited violations under control of hazardous energy is the communication and training regulation CFR 1910.147(c)(7). As Dankert pointed out, the CDC guidelines for operation have changed the way we can perform training. In addition, loss of revenue is a primary factor for maintaining the integrity of your electrical safety program. The most important investment an employer can make is in their employee’s health and safety. This should be the last area cut from the budget, not one of the first.
Failure to perform proper mechanical or electrical lockout/tagout (LO/TO) can lead to electrocution, electrical shock, arc flash and other hazards. In addition to huge penalties, these hazards often result in lost time wages, compensation claims, permanent disability and fatalities. Employers cited under this standard failed to establish an energy control procedure, either partially or altogether, while others were cited for failing to provide adequate employee training, failing to conduct periodic evaluations of procedures and failing to use LO/TO devices or equipment.
At the National Safety Council 2019 Congress & Expo, Patrick Kapust, deputy director of OSHA’s Directorate of Enforcement Programs reported: “These are common violations that we’re finding — they’ve been in place for a lot of years. The answers are out there, and employers shouldn’t feel like these are very complex issues. If you don’t know the answers, we encourage you to contact OSHA,” Kapust said.
“I would like to remind people, as difficult as it is to comply, that’s the minimum we must do to protect employees. OSHA doesn’t have a standard for every possible hazard we might have in our facility or on our jobsite,” Dankert said. “So, as difficult as it is to be compliant, we also need to understand the inherent hazards in our processes that OSHA doesn’t cover and seek those best practices to continue to protect our employees.”
Striving for the minimum requirements of compliance does not lead to achieving minimum risk or maximum productivity levels available today. Furthermore, human error plays a vital role in failing to comply with standards. Despite thorough training, documentation and experience, there will always exist that risky margin of a person just simply making a mistake, no matter how many times they have performed the task at hand.
For example, qualified maintenance personnel performing mechanical LO/TO are tasked with isolating electrical energy. As part of the verification of de-energized condition, OSHA requires a person to operate the equipment controls, also known as a try/test, to ensure the equipment cannot be restarted. There are several significant risks associated with solely relying on the try/test. These risks often include isolating the wrong controls, accidental restart of the equipment, getting caught in the equipment or contact with live source of energy at the machine level.
Safety conscious and forward-thinking companies understood these risks early on and started to require electricians to perform absence of voltage testing for mechanical LO/TO. With the advent of NFPA 70E: Standard for Electrical Safety in the Workplace and research on arc flash, employers began to realize through job hazard analysis that this task, while reducing the hazards of the energized condition of the equipment, greatly increased the exposure to electricity in performing the test itself. Additionally, the involvement of an electrician in a simple mechanical LO/TO further hampered productivity.
A safety-by-design solution was found for this scenario in an externally mounted LED voltage presence indicator. This provides an alternative means to verify the voltage presence inside an electrical panel while safely unexposed from the outside in addition to the OSHA required try/test. Without a voltage indicator, a mechanic performing mechanical LO/TO would be required to work in tandem with an electrician using a voltmeter to physically verify voltage inside an electrical panel (see Figure 1). In this case, the electrician is exposed to voltage. With the combination of the try/test and through-door LED voltage presence indicators, the mechanic can solely verify when the panel is in an energized condition without any voltage exposure.
Who needs training?
When it comes to OSHA and LO/TO, the code recognizes two categories of people that need training: authorized and affected employees. Under the training mandated to companies by OSHA, “Each authorized employee shall receive training in the recognition of applicable hazardous energy sources, the type and magnitude of the energy available in the workplace and the methods and means necessary for energy isolation and control. Each affected employee shall be instructed in the purpose and use of the energy control procedure.”
To summarize, “authorized employees” are those who are applying the locks and “affected employees” are those in the area during a lockout. The latter can range anywhere from operators to third-party contractors. If they are within the vicinity of the procedure, they are affected.
While OSHA requires all authorized and affected employees receive periodic training, the implemented training program at any organization can be customized to meet precise needs. However, as previously stated, companies training their employees to meet the minimum compliance standards does not result in achieving maximum safety and productivity.
Even before the pandemic, employers were consistently failing upward to comply with minimum performance requirements and it is becoming more apparent that we’re far past the time for them to adopt safety-by-design solutions. Companies must start looking at safety as an investment. OSHA’s Regulatory Analysis has proven that for every $1 invested in health and safety, employers can expect a return of $4 to $6.
A robust electrical safety program goes beyond legislation and minimum compliance. A highly productive and efficient environment is a culture where employees are safe, secure and cared for. According to the U.S. Department of Labor, a safe and healthy workplace not only protects workers from injury and illness, but it can also lower injury/illness costs, reduce absenteeism and turnover, increase productivity and quality and raise overall employee morale. In other words, fostering a safety culture is not just a good practice, it is good for business.
Read more of Schiltz’ work on Grace’s weekly electrical safety and reliability maintenance centered blog, Humpday.