LL OF GENERAL INDUSTRY IN THE

United States, represented by the partici-

pants in the IEEE/IAS Petroleum and
Chemical Industry Committee Technical
Conference (PCIC), is regulated by the federal govern-
ment to have an electrical safety program. The Depart-
ment of Labors Occupational Safety and Health
Administrations (OSHA) documents that drive the elec-
trical safety of employees in the workplace is written in
performance language.
Companies trying to conformare having difficulties with
the prescriptive means to comply. Emergingelectrical safety
issues are difficult to answer since they involve both techno-
logical and cultural changes. Many of the electri-
cal-safety-related work practices and most all of the
electrical-safety-by-design features that improve electrical
safety escalate the cost of electrical equipment andfacilities.
Employers generally want to do the right thing and
will do so, even if the cost is higher, if they are convinced
that others are also going the extra mile. Benchmarking
10
1077-2618/03/$17.002003 IEEE
I
E
E
E
I
N
D
U
S
T
R
Y
A
P
P
L
I
C
A
T
I
O
N
S
M
A
G
A
Z
I
N
E

M
A
Y
|
J
U
N
E
2
0
0
3

W
W
W
.
I
E
E
E
.
O
R
G
/
I
A
S
A

C
L
I
P
A
R
T
I
D
S
can provide the direction and the sup-
port needed to convince industrial com-
pany business managers when more
complicated and expensive features can
really enhance electrical safety for the
employee workplace.
The results of questionnaires circu-
lated and discussed in meetings to
benchmark electrical safety over the last
year are presented. Present understand-
ing and acceptance reinforces the im-
pression that further dialogue is needed
on this subject.
Background
Thirteen separate entities participated in
the background discussions held on 15
February 2000 and 9 September 2000,
both in San Antonio, Texas, USA. All 24
participants (some entities had multiple
participants) admitted struggling to in-
terpret the performance language of
OSHA s electrical-safety standards. During the
benchmarking, 19 scenarios of varying importance were
addressed. Up to 15 questions per scenario were utilized to
cover a subject.
It is obvious that traditional internal-accounting sys-
tems cannot supply all the information management
needs for effective decision making. When companies
and managers are not aware of opportunities they are
missing, there is no incentive to get better. Once it is un-
derstood that measuring performance is the first step to
improving performance and that benchmarking is a sim-
plified way of developing metrics by which to measure
performance, benchmarking obtains the high-level sup-
port it needs to prevail.
Benchmarking
Benchmarking is a process in which all participants must
have a chance to participate equally and anonymity of any
single individual input must be respected. Entities know
their own responses and, thus, can judge where they or
their employer stands relative to the groups response for a
given scenario or question. Benchmarking may disclose a
consensus of actions, but there is no attempt to argue
ones point of view. Most participants recognize there are
multiple ways to accomplish a task or more than one solu-
tion to a dilemma.
Benchmarking is a method of comparing design, in-
stallations, programs, policies, philosophies, principles,
safety-related practices, operations and maintenance pro-
cedures, and work processes to determine best practices.
Benchmarking of electrical safety-related issues is not
considered to be a proprietary activity; i.e., participants
from industry have freely contributed to the National
Fire Protection Associations National Electrical Code
(NFPA 70) and Electrical Safety Requirements for the Em-
ployee Workplace (NFPA 70E). Benchmarking is the best
recourse by which industrial companies can compre-
hend/develop an interpretation of the performance lan-
guage used in OSHAs:
n OSHA 29 CFR 1910.119Process
Safety Management
n OSHA 29 CFR 1910.137Elec-
trical Protective Equipment
n OSHA 29 CFR 1910.145Speci-
fications for Accident Prevention and
Tags
n OSHA 29 CFR 1910.147The
Control of Hazardous Energy (Lock-
out/Tagout)
n OSHA29 CFR1926.400 through
449 (Subpart K)Electrical
n OSHA 29 CFR 1910. 269
(Subpart R)Electrical Power Gen-
eration, Transmission, and Distribu-
tion
n OSHA29 CFR1910.301 through
399 (Subpart S)Electrical
n OSHA 29 CFR 1926. 950
(Subpart V)Power Transmission
and Distribution
n OSHA29 CFR1910.254 (Subpart
Q)Arc Welding and Cutting.
All participants can measure their relative standings
and determine where to emphasize needed improve-
ments. Performance measurement by benchmarking is
just the first step in overall improvement. Within any
one industrial company, it must be followed up by de-
veloping a strategy, solving problems, and changing
cultures to implement the obvious solutions. This must
be complemented by establishing a program that en-
compasses corporate philosophies, policies, principles,
practices, procedures, and controls by which to audit
and measure performance.
Scenarios
The 19 scenarios addressed were as complex as the subject
of electrical-equipment ratings, which required 15 ques-
tions, and as simple as Do you have an electrical-safety
program? which required one question. This article pro-
vides the scenarios in the positive response, out of a possi-
ble 13 yeses or nos or any combinationonly the quantity
of yeses will be related following the scenario in this article.
Scenario 1
OSHA was formed as a result of the Williams-Steiger Act of
1970. The 1968 National Electric Code (NEC) was a princi-
ple reference at that time. By 1981, OSHA removed direct
references to the NEC. In 1991, OSHA added Safety-Related
Work Practices 1910.331 through 1910.335 to Subpart S.
OSHA Subpart SElectrical: 29 CFR1910.301-399 pro-
vides the mandatedelectrical safety requirements for premises
wiring and the utilization of electrical equipment. It is appli-
cable in general industry to employers engaged in interstate
commerce. Subpart SElectrical requires electrical facilities
be installed in accordance with recognized safe electrical
equipment and installation practices. It is based on the prem-
ise that electrical equipment is safe until deterioration devel-
ops, unsafe acts are performed, or carelessness occurs. Subpart
S requires employees working on or near exposed energized
11
I
E
E
E
I
N
D
U
S
T
R
Y
A
P
P
L
I
C
A
T
I
O
N
S
M
A
G
A
Z
I
N
E

M
A
Y
|
J
U
N
E
2
0
0
3

W
W
W
.
I
E
E
E
.
O
R
G
/
I
A
S
COMPANIES
TRYING TO
CONFORM ARE
HAVING
DIFFICULTIES
WITH THE
PRESCRIPTIVE
MEANS TO
COMPLY.
electrical conductors and circuit parts
be qualified. In 1994, OSHA added
Electric Power Generation, Transmission,
and Distribution 1910.269 to Subpart
R. OSHA Subpart RElectric Power
Generation, Transmission, and Distribu-
tion: 29 CFR1910.269 provides the
mandated electrical-safety require-
ments for the employees of utilities or
industrial establishments. It is based
on the premise that the highly trained
and properly supervised employee can
work safely around known electrical
hazards and take precautions to avoid
unsafe acts and minimize effects of carelessness.
n Six entities integrate the Subparts S and R safe-work
activities in one program.
n Nine entities require electricians working with
Subpart R facilities to have a higher level of train-
ing/skill so they are essentially certified.
n Nine entities recognize that OSHA expects electrical
installations to be installed in accordance with NEC,
National Electrical Safety Code (NESC), OSHA,
and/or reasonable and generally accepted good engi-
neering practices (RAGAGEP).
n Six entities acknowledged OSHA expects employers
to provide an electrical safety program.
n Nine entities understand the assistant secretary of labor
for OSHA or his/her designated representative is the
authority having jurisdiction (AHJ) for OSHA laws.
n Seven entities believe the owner or his/her desig-
nated representative, the city, or other government
agencies are the AHJ for enforcement of the NEC.
n Eight entities recognize that OSHA requires electri-
cal installations to utilize electrical equipment that
is approved (listed or labeled) for the purpose.
n Nine entities knowthat OSHAapplies to companies
engaged in interstate commerce.
n Five entities apply some concepts from OSHAs 29
CFR 1910.119Process Safety Management to elec-
trical installations and equipment. However, they
know that electrical shock and arc flash/blast have
minor consequences compared to major petrochemi-
cal process leaks of toxic or explosive gases.
Scenario 2
An electrical-safety program is a written compendium of
experience and technical-based information intended to
protect employees from accidental exposure to electrical
shock and arc flash burn/blasts. OSHA requires an em-
ployer to provide an electrical-safety program.
n Nine entities agreed.
n Nine entities recognized that electrical-safety pro-
grams for multisite ownership require a corporate
base, as well as divisional or site supplements.
Scenario 3
An electrical-safety policy stipulates that the safety of per-
sonnel will not be compromised. Electrical installations
will be constructed essentially free from hazards. Electrical
safe work practices will be provided.
Electrical operating and maintenance
procedures will be provided. Personnel
will be trained and qualified for the
task(s) to which they will be assigned.
n Nine entities have electrical safety
polices.
Scenario 4
The employer will provide an atmo-
sphere to enable each employee to learn
and exercise his/her own electrical-safety
principles.
n Eight entities recognize the basic
safety principles of planning the job, anticipating
the unexpected, using the right tools, using pro-
cedures as tools, isolating electrical equipment,
identifying electrical hazards, minimizing the
electrical hazard, controlling electrical hazards,
protecting the person, accessing peoples abili-
ties, and auditing the electrical-safety principle.
Scenario 5
All electrical-related injuries are preventable. Each person
is responsible to identify unsafe acts and avoid exposure to
electrical safety hazards.
n Nine entities operate on the philosophy that electri-
cal-related injuries are preventable and have a writ-
ten philosophy mandating electrical safety.
Scenario 6
Electrical-safety-related work practices provide guidance
for proven methods of avoiding electrical shock, arc flash
burns/blasts, and other hazards associated with the genera-
tion, transmission, distribution, and utilization of electric-
ity. A reference to practices simplifies and standardizes the
development of procedures.
n Seven entities have electrical-safety practices for es-
tablishing an electrically safe work condition, elec-
trical-safe-approach distances for shock and arc
flash, electrical switching, electrical hot work,
electrical hazardous work permit, rubber insulat-
ing equipment, personal protective equipment,
voltage-rated test equipment, insulated tools,
personal protective grounds, portable electrical
equipment, lift work near power lines, and pro-
tocol for electrical safety procedures.
n Two entities have most, but not all, of the above elec-
trical-safety practices.
Scenario 7
Procedures serve as tools for safely accomplishing a job.
These tools help plan work and must be properly main-
tained. Each step identified in a procedure should be fol-
lowed unless there is reason to perform a task a different
way with less exposure to electrical hazards.
n Nine entities have electrical operating procedures,
as well as electrical maintenance procedures. Of all
procedures available, eight find the switching pro-
12
I
E
E
E
I
N
D
U
S
T
R
Y
A
P
P
L
I
C
A
T
I
O
N
S
M
A
G
A
Z
I
N
E

M
A
Y
|
J
U
N
E
2
0
0
3

W
W
W
.
I
E
E
E
.
O
R
G
/
I
A
S
EMPLOYERS
GENERALLY
WANT TO DO
THE RIGHT
THING.
c e dur e s , i nc l udi ng l oc k-
out/tagout; three find infrared
t e c hnol ogy t wo f i nd
switchgear installation; one
finds oil testing; and one finds
meggering and high-potential
testing to be most effective.
Scenario 8
Electrical equipment must have suit-
able ratings for the service. Electrical
systems must be capable of sustaining
adequate voltage and carrying the load
current. Electrical protection must be
applied to quickly detect and isolate
electrical overloads and short-circuit
conditions. Electrical-system studies
are required to provide the basis for the
equipment ratings.
n Nine entities perform short-cir-
cuit studiesprotective-device
coordination studiesand volt-
age-profile studies.
n Two entities perform short-circuit
studies below the 480-V level,
with two additional entities per-
forming them below 480-V only for large systems.
n Two entities perform short-circuit studies for large
dc systems.
n Eight entities perform these studies for any change
or addition to the electrical installation/equipment
or for any change in the electrical-power supply.
n Two entities revalidate the studies every three to five
years, whether changes have occurred or not.
n Nine entities utilize one or the other among central
group, division group/plant group, or contractors to
perform electrical system studies.
Scenario 9
Single-line diagrams provide an easy and quick reference
for the electrical-system concept, interconnections, load
flow, and circuit-isolating devices. Single-line diagrams
serve many purposes. Engineering, commissioning, opera-
tions, maintenance, and production groups can use them.
They can be simplified for operations with only isolating
devices shown for lockout/tagout purposes. Including de-
tails for equipment identification, sizing, rating, ranges,
etc., needed for engineering or maintenance can compli-
cate them.
n Eleven entities require single-line diagrams that con-
tain operating data, such as single-line diagrams
with isolating/disconnect switches, equipment
identification, equipment name-plate data, and
equipment sizing, and/or engineering data, such as
isolating/disconnect switches, equipment identifi-
cation, equipment name-plate data, equipment
sizing, equipment rating, equipment ranges,
current transformers, voltage transformers, pro-
tective relays, and transformer phase shift.
n Eight entities utilize computer-
aided drafting to develop single-
line diagrams in two layers: one for
operations and one for engineering
or maintenance.
n Eleven entities agree that single-
line diagrams must be perpetually
maintained and that they must be
updated for any change or addition
to the electrical installation/
equipment or any change in the
electric-power supply.
n Two entities revalidate the single-
line diagrams every three to five
years, whether changes have oc-
curred or not.
n Single-line diagrams are utilized
by all entities for engineering,
commissioning operations, main-
tenance, and production. They
serve as records retention for elec-
trical-system studies, new pro-
jects, switching, lockout/tagout,
and identification.
n One entity has a standardized de-
velopment process for single-line
diagrams.
n Six entities utilize the combination of single-line dia-
grams or panel schedules to maintain knowledge of
120/240-V, 120/208-V, 125-V dc, and lower volt-
age-level systems.
Scenario 10
OSHA dictates that all electrical equipment be operated
within its rating.
n Eleven entities believe this includes interrupting ca-
pacity.
n Nine entities do not expect it to include internal
arc-flash/blast withstand.
n Seven entities believe the interrupting capacity rat-
ing can be exceeded for short durations, such as
closed-tie transitions of double- ended substations
with or without automatic circuit-breaker control or
remote operation of the circuit breakers.
n Eleven entities utilize listing, manufacturers test
data, or the AHJ to ensure compliance with ratings.
n Nine entities do not require NEMA frame size,
three-phase induction motors installed in electrical
classified Division II areas to include T rating.
n Eleven entities do not recognize the not to be ap-
plied above 10,000 A.I.C. marking on explosion-
proof motor-control enclosures.
n Three entities relate that independent testing, man-
ufacturers testing, or manufacturers data deter-
mines custom-equipment ratings.
n Eight entities have been eliminating custom-fabri-
cated, antique, and one-of-a-kind electrical equip-
ment components whose ratings are questionable.
13
I
E
E
E
I
N
D
U
S
T
R
Y
A
P
P
L
I
C
A
T
I
O
N
S
M
A
G
A
Z
I
N
E

M
A
Y
|
J
U
N
E
2
0
0
3

W
W
W
.
I
E
E
E
.
O
R
G
/
I
A
S
TRADITIONAL
INTERNAL-
ACCOUNTING
SYSTEMS
CANNOT SUPPLY
ALL THE
INFORMATION
MANAGEMENT
NEEDS FOR
EFFECTIVE
DECISION
MAKING.
Scenario 11
Installed operating or spare electrical
equipment that is still operable but no
longer being used for its original purpose
should be suitable for being placed into
service or reuse.
n Eleven entities justify continued
use of existing electrical equip-
ment that has no listing or label,
installed years ago, based on expe-
rience, maintenance, and accept-
able level of risk.
n Six entities do not re-use existing
electrical equipment that has no
listing or label, installed years
ago, for expansions or new pro-
jects unless they have like-for-
like replacements.
n Eleven entities will place spares in service fromexist-
ing electrical equipment that has no listing or label,
installed years ago.
n Eleven entities agree electrical equipment utilized in
classified areas requires listing or labeling for the
hazardous atmosphere, and any repairs must be done
by shops certified for hazardous area rework.
Scenario 12
OSHA identifies that electrical equipment may not be
used unless the manufacturers name, trademark, or other
descriptive marking, by which the organization responsi-
ble for the product may be identified, is placed on the
equipment. Each disconnecting means for motors and ap-
pliances shall be legibly marked to indicate its purpose un-
less located and arranged so the purpose is evident. Each
service, feeder, and branch circuit shall be legibly marked
at its disconnecting means or overcurrent device to indi-
cate its purpose, unless located and arranged so the purpose
is evident.
n Nine entities require or add marking and identifi-
cation, as stated above.
n Four entities utilize additional markings other
than the minimum required by OSHA, such as in-
terrupting capacity and markings for arc-flash
hazard distance.
Scenario 13
OSHA takes the position that electrical equipment should
be installed so it is safe until deterioration occurs, unsafe
acts are performed, or carelessness takes place. OSHA fur-
ther indicates that the equipment should be maintained in
like-new condition.
n Five entities utilize maintenance frequencies as es-
tablished by NFPA 70B, manufacturers instruc-
tions, site experience, and/or historical records.
Scenario 14
OSHA mandates that qualified employees be utilized for
electrical work.
n One entity routinely assesses the
skill level of their electricians or of
contract electricians.
n Two entities assess the skill level
of craftspeople by first-line su-
pervisors.
n One entity utilizes a craft-qualifi-
cation program.
n One entity segregates electrical
craftspeople by skill level.
n Three entities manage assignment
of craftsmen work, based on skill
level, by supervisors.
n One entity manages the assign-
ment of craftsmen work by train-
ing craftsmen for assigned tasks.
n Three entities develop and main-
tain skill knowledge by in-house
training.
n Two entities develop and maintain skill knowledge
by outside craft qualification, plus specific training
on new equipment.
Scenario 15
Arc blast is one of the three electrical-safety hazards. Elec-
trical-equipment manufacturers are just beginning to
sanction and deal with arc blast with the development of
arc-resistant switchgear that is designed to contain/direct
the products of the arc away from people who might be op-
erating around the switchgear to take readings or move
handles or punch pushbuttons. Where arc-resistant
switchgear is not in place, other precautions must be taken
to minimize operators time intervals in close proximity to
the switchgear, such as the use of mimic panels with me-
ters and operating control switches or long plug-in umbili-
cal cords with operating control switches. At the
minimum, the products of an electrical arcing fault are
pressure wave, hot gases, molten metal plasma, and shrap-
nel. The intensity of the explosive disruption is based on
the short-circuit current (amperes) available and the time
interval (seconds) required for detection and isolation by
circuit protective devices.
Placement of the body/body parts and use of personal
protective equipment are the only precautions for provid-
ing protection against this scarce occurrence when it is not
eliminated by arc-resistant switchgear or mitigated by
mimic panels or long umbilical cords. Special calculations
are needed to determine the magnitude of the arc flash/arc
blast. It is rather intuitive to remain clear of a full door
swing that may be associated with a major internal arcing
fault in non-arc-resistant switching equipment.
NFPA 70E provides details for determining the arc
flash hazard distance from an arcing fault that must be
maintained to avoid serious thermal burn and for deter-
mining the type, thickness, and layers of personal protec-
tive equipment that must be worn to avoid serious
thermal burn when/if the body must be placed inside the
arc-flash hazard distance of a potential arc source. The
protection of the body against the effects of pressure
waves created by a sudden and violent arcing fault have
not been fully analyzed.
14
I
E
E
E
I
N
D
U
S
T
R
Y
A
P
P
L
I
C
A
T
I
O
N
S
M
A
G
A
Z
I
N
E

M
A
Y
|
J
U
N
E
2
0
0
3

W
W
W
.
I
E
E
E
.
O
R
G
/
I
A
S
IF
BENCHMARKING
OBTAINS THE
HIGH-LEVEL
SUPPORT IT
NEEDS, IT WILL
PREVAIL.
n Five entities recognize that arc-blast hazard aware-
ness and mitigation should be a part of their electri-
cal-safety program and are applying pressure to
manufacturers to address this arc-blast hazard.
n Three entities now have standards or purchase re-
quirements for internal arc-flash testing of electrical
equipment.
Scenario 16
An industrial facility with a perimeter fence and guarded
access has open, bare substations fenced with gates having
Authorized Personnel Only signs and enclosed substa-
tions having door access with Authorized Personnel
Only signs.
n One entity requires padlocks or door locks for access
to any electrical equipment that contains exposed
energized electrical conductors or circuit parts.
Scenario 17
NFPA 70E 2000 Electrical Safety Requirements for Employee
Workplaces is the mature sixth edition of a document that
OSHA requested assistance from NFPA to develop. It is
now the premiere consensus document covering electrical
safe-work practices.
n Five entities will be adopting and using NFPA-70E
in their electrical safety program.
Scenario 18
Multiple outlet power strips are proliferating throughout
residential, commercial, and industrial establishments.
n Five entities permit multiple outlet power strips, as
needed, provided they include built-in circuit
overcurrent protection and/or transient protection,
are limited to one-in-series or are secured in place, or
are connected to a ground-fault circuit interrupter
(GFCI) receptacle.
Scenario 19
Many maintenance or operational electrical jobs are being
performed by contract personnel or by service representa-
tives for specialized electrical equipment.
n Two entities require equipment manufacturers au-
thorized service representatives to be trained in their
electrical-safe-work conditions.
n Three entities acknowledge that authorized service
representatives, certified to work on the specific
equipment of the manufacturers, are in compliance
with their electrical-safe-work conditions.
n One entity would permit contract electric service
people from Manufacturer A to work on Manufac-
turer Bs electrical equipment without being specifi-
cally trained to do so.
n One entity would permit utility service people to work
on their electrical equipment without being trained to
work with their electrical-safe-work conditions.
Acknowledgments
The 24 individuals that participated represented 11 indus-
trial companies, one retired consultant, and one health pro-
fessional.
n Ken White (Olin)
n John Gallagher (Bayer)
n Rick Bried, Mike Bostic, and John Propst (Equilon)
n Paul Dobrowsky (Eastman Kodak)
n Kim Eastwood and Mike Legg (Thermon)
n Jose Vallejo and Clive Henton (Coastal Power)
n Danny Liggett and Lanny Floyd (DuPont)
n Bruce McClung, Mary Jo Hendricks, Ronnie
Powell, Danny Cano, TomCruey, and Daleep Mohla
(Union Carbide Corporation)
n Lynn Saunders and Mike Hittel (General Motors)
n Ralph Prichard (Hercules)
n Daryld Crow (Duke Engineering Services)
n Bill Jordan (retired)
n Mary Capelli-Schellpfeffer (health professional).
All participants related that their sponsoring organi-
zations were more interested in the safety and health of
their employees than in protecting their cache of electri-
cal-safe-work practices, i.e., they held no proprietary
electrical-safety programs/practices/procedures. All par-
ticipants shared freely and openly. The participants re-
quested anonymity of any single individual response to
common questions. Thus, all answers reported out of the
working group are couched in terms of one through
eleven respondents replied_______.
L. Bruce McClung is with Union Carbide Corporation in South
Charleston, West Virginia, USA. He is a Fellow of the IEEE.
This article first appeared in its orginal form at the 2001
IEEE/IAS Petroleum and Chemical Industry Committee Techni-
cal Conference.
15
I
E
E
E
I
N
D
U
S
T
R
Y
A
P
P
L
I
C
A
T
I
O
N
S
M
A
G
A
Z
I
N
E

M
A
Y
|
J
U
N
E
2
0
0
3

W
W
W
.
I
E
E
E
.
O
R
G
/
I
A
S