Risk Assessment and Your Electrical Safety Program

Paper No. ESW2015-28

Daniel Roberts
Senior Member IEEE
Schneider Electric Canada Inc.
5985 McLaughlin Road
Mississauga, ON L5R 1B8
daniel.roberts@schneider-electric.com
Abstract The 2015 editions of NFPA 70E and CSA Z462

published in 1979 and included only Part I, installation

requirements. The second edition was published in 1981
and included Part II, work practice requirements.
The focus in Part II work practice requirements up to and
including the sixth edition in 2000 was on establishing
protection and approach boundaries and the use of personal
protective equipment (PPE). From an Occupational Health
and Safety (OHS) perspective, administrative methods and
PPE are the least effective risk control methods.
In this regard, the first substantive change occurred in the
2004 edition. Part II work practice requirements was retitled and relocated to Chapter 1. The chapter was
reorganized to emphasize working on live parts as the last
alternative work practice and an energized electrical work
permit and related requirements were incorporated.
The next big step forward from an OHS perspective was
two editions later in 2012. Article 110.7(F) revised to
clarify the separate but directly related concepts of hazard
identification and risk assessment. While this might not
seem like a substantive revision, it set the stage for the major
revisions to the 2015 edition.
Following the publication of the 2012 edition, a task
force was established by the chair of the 70E technical
committee to review the use of the terms hazard and risk,
comparing them to other standards that deal with the topic.
The task force created 85 proposals for revision, all of which
were accepted in one form or another. To summarize the
task groups work:
Propose definitions for Hazard, Risk and Risk
Assessment that were consistent with other safety
standards;
Propose revisions to the rest of the document to
ensure the consistent use of these terms;
Propose inclusion of a hierarchy of risk control
methods consistent with other safety standards such
as ANSI Z10 and CSA Z1000.
The Electrical Safety Program requirements were given
further prominence as they are relocated to the front of
Article 110. Additionally, an employers electrical safety
Program must be part of their Occupational Health and
Safety Management System (OHSMS), when one exists.
This subtle, but ultimately substantive revision will be
discussed in this paper.

have taken a significant step forward by integrating Occupational Health and Safety Management Systems and Risk
Management principles. This paper will explore how this
changes and advances the electrical safety culture and enables sustainable improvement in prevention of electrical
incidents and injuries. The paper will also discuss how these
changes can be integrated into an organizations electrical
safety program and how risk assessment can be performed at
an organizational level and at a worker level.
Index terms acceptable risk, ANSI/AIHA Z10, CSA Z462,
electrical safety, hazard, hazard identification, ISO 31000,
NFPA 70E, Occupational Health and Safety Management,
OHSMS, risk, risk analysis, risk assessment, risk control, risk
evaluation, risk management

I. INTRODUCTION
Until recently electrical safety has largely been left to the
electrical professional. Most safety professionals receive
little if any education about electricity, arguably one of the
most ubiquitous hazards. However, electrical hazards are
not so unique that the risk associated with those hazards
needs to be managed differently than any other safety risk
[1]. With the 2015 editions of NFPA 70E and CSA Z462,
electrical safety has embraced safety theory.
II. HISTORY OF NFPA 70E [2]
At the urging of the US Occupational Safety and Health
Administration (OSHA), electrical professionals rose to the
challenge. January 7, 1976 the Standards Council of the
National Fire Protection Association announced the formal
appointment of the Committee on Electrical Safety
Requirements for Employee Workplaces, NFPA 70E. The
committees mandate was to assist OSHA in preparing
electrical safety standards that would serve OSHAs needs
and that could be expeditiously promulgated through the
provisions of Section 6(b) of the Occupational Safety and
Health Act [2].
The new standard was visualized as consisting of four
major sections: Part I, Installation Safety Requirements; Part
II, Safety-Related Work Practices; Part III, Safety-Related
Maintenance Requirements; and Part IV, Safety
Requirements for Special Equipment. The first edition was

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used that many times it is important that the meaning be

clear and consistent [4].
In the 2015 edition, the term risk is used 89 times in
Chapters 1 to 3 and the Annexes, and each time it means the
same thing: The combination of the likelihood of occurrence
and the severity of harm. The phrase hazard/risk is no
longer used.
The result is clarity and consistency within the document
and with other safety standards such as ANSI Z10, CSA
Z1000 and Z1002. Health and Safety professionals will find
the documents easier to navigate and comprehend. They can
collaborate intelligently with the Electrical Professional to
advance and change the electrical safety culture.

Table 1 provides an overview of the development and

substantive revisions to NFPA 70E since the first edition
was released in 1979.
III. OHSMS
The new requirement for employers to integrate their
electric safety program into their OHSMS, when one exists,
will bring the benefits of a management systems approach to
electrical
safety.
Management
systems
improve
organizational performance by applying a systematic
approach to a specific risk [3].
Management systems, including safety management
systems, are founded on six common elements: Leadership
commitment; a management system Policy; and a repeating
cycle of Plan-Do-Check-Act (PDCA).
When an organizations Leadership is committed to and
sponsors an initiative it gets attention from everyone. It
becomes a priority. Clarity and focus result when the
initiatives goals and objectives are clearly articulated in the
management system Policy.
Benefits of the PDCA cycle are compatibility, integration
and
participation,
continuous
improvement
and
sustainability.
Compatibility facilitates integration of all risks, including
safety, into an organizations day to day operation. Safety is
not the safety managers job; it is everybodys job from the
CEO to the person making the product or delivering the
service. Every person in the organization has a vested
interest and plays a part in managing safety. Safety results
do not rise and fall with a single champion; they are part of
an organizations culture, their DNA.
The best state for a given risk cannot be achieved at once
[3]. The repeating nature of the PDCA cycle, when properly
implemented, results in continuous and sustainable
improvement in risk reduction a safer work environment.

IV. RISK ASSESSMENT

Risk is the combination of the likelihood of harm
occurring and the severity of that harm. Two key concepts in
the definition of risk are likelihood and severity.
Risk assessment is a process that begins with hazard
identification, analyzes the risk associated with that hazard,
and concludes with risk evaluation.
Analyzing risk involves quantitatively or qualitatively
estimating the likelihood of harm occurring and the severity
of that harm. The analysis can involve complex charts to
quantitatively predict the likelihood of occurrence and
severity of harm, or it can be a simple qualitative two-bytwo digital matrix.
Most people practice a qualitative form risk assessment
as we engage in everyday activities. They perform this
assessment without using a complex matrix to analyze each
factor that contributes to the likelihood of occurrence of
harm and the severity of harm, rather, they use the most
elementary of risk matrices: Yes and No.
During everyday normal activities people consciously or
subconsciously assess risk. They identify sources of harm
(What can hurt me?), and analyze and estimate the risk
associated with each identified source (Can I get hurt? How
bad could it be?). Then they qualitatively evaluate the level
of risk as acceptable or unacceptable with a simple Yes or
No response.
Research suggests that most people tend to underestimate
the likelihood of the occurrence of harm, and greatly
underestimate the severity of harm (the bad things happen
to someone else syndrome). This is due to how we develop
our perception of risk. There are two mental systems used to
process risk: analytical and experiential. The former is logicoriented and governed by conscious thought processes while
the latter is feeling-based and governed by associative
connections from previous experiences. Most people tend to
favour the latter because it is quicker and easier [5].
Applying the principles of OH&S risk assessment brings
methodology and rigour to the process. It forces us to be
analytical and, very importantly, it comes with a hierarchy of
risk control methods based on three simple principles [6]:
Remove the source

IV. RISK MANAGEMENT PRINCIPLES

Incorporating risk management principles into NFPA 70E
and CSA Z462 will bring many benefits to electrical safety.
As electrical safety standards NFPA 70E and CSA Z462 are
unique. There is nothing quite like them anywhere else in
the world. However, they did not always align with how
other recognized safety standards approach the related but
different topics of hazard and risk.
As noted, the 2015 edition defines key risk management
terms such as hazard, risk and risk assessment. Why is this
important?
Definitions are the anchor of any standard. For example,
the term risk is used 133 times in Chapters 1 to 3 and the
Annexes of 70E-2012 with different shades of meaning.
Sometimes it refers to the likelihood of something occurring
and sometimes it refers to the combination of the likelihood
of occurrence and the severity of harm (the OHS meaning of
the term). Sometimes, as in the phrase hazard/risk, the
meaning isnt at all clear. When a key term such as risk is

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Change the consequences

Change the likelihood

When designing, specifying and purchasing electrical

distribution equipment, an employer can reduce risk by
specifying substitution and engineering risk control
methods that affect the likelihood of occurrence or severity
of consequence.
Risk treatment for severity of consequence could include:
Reduce incident energy by faster arcing fault
detection and interruption time
Divert the arc flash energy crowbar the
conductors to collapse the voltage and extinguish the
arcing event
Contain the arc flash energy through arc resistant
design
Create distance between personnel and the arc flash
energy through the use of remote operation and
remote racking
Risk treatment for likelihood during the design phase and
pre-use phase could include:
Equipment design features such as insulated bus
Distribution system design such as high-resistance
grounded distribution system
Finger-safe technology
24vac rather than 120vac controls
Externally
accessible
reset
controls
and
communication ports rather than controls and ports
that are only accessible by opening equipment doors
Process example:
Pumps of varying descriptions are utilized to move
effluent through waste water treatment processes. Frequent
operations of motor overloads occur when large objects such
as pieces of wood get caught in effluent impellers. The
process to clear the blockage involves locking out the motor
control disconnect, accessing the impeller to remove the
blocked material, resetting the motor overload, and placing
the motor back into service. Some of the hazards involved
with these activities include:
Ergonomic and mechanical hazards while accessing
the impeller. Case history: The Vancouver Airport
discovered that sometimes the blockage is small
enough that it can be dislodged by reversing the
impeller. By installing a motor-reverse switch they
reduced the frequency of worker exposure to those
hazards.
Resetting the motor overload. Performing this
activity on older motor control centres (MCC)
usually involves increasing the likelihood of
electric shock as the MCC door must be opened to
access the reset button. Retrofitting a reset button
on the door eliminates the need to open the door
and thus reduces the likelihood of electric shock.

IV. INTEGRATION INTO AN ELECTRICAL SAFETY PROGRAM

Table 2 demonstrates how the six key elements of
OHSMS and risk management can be integrated into an
electrical safety program by following the requirements of
NFPA 70E-2015 and CSA Z462-2015.
TABLE 2
INTEGRATION OF KEY OHSMS AND RISK ASSESSMENT
ELEMENTS INTO AN ELECTRICAL SAFETY PROGRAM [6]
Elements
NFPA 70E-2015
Leadership 110.1 (A) Establish, implement and document an electrical
safety program that is part of the employers OHSMS, when
one exists
110.1(D) Identify the principles upon which the electrical
Policy
safety program is based, including:
(1) De-energizing if possible
(2) Job planning
(3) Maintenance
(4) Auditing
Plan
110.1 (A) The electrical safety program must direct activity
appropriate to the risk associated with electrical hazards
Do
110.1(G) Establish a risk assessment procedure to: (1) Identify hazards; (2) Assess risks; (3) Implement risk control
according to a hierarchy of methods
110.1(H) Job briefing before starting each job to discuss
hazards, procedures, energy source controls, etc.
110.2(D)(b)(4) Qualified workers must be able to: (1) Perform job safety planning; (2) Identify electrical hazards (3)
Assess the associated risk; (4) Select appropriate risk control
methods from the hierarchy of controls
Check
110.1(I) Audits:
(1) The electrical safety program (at least every 3 years)
(2) Field work (annually)
Act
110.1(I) Audit results are used to revise the program, training
or procedures to ensure:
(1) Compliance with the Standard
(2) Adherence to the principles and procedures

V. RISK ASSESSMENT AT THE ORGANIZATIONAL LEVEL

Risk assessment and the hierarchy of risk controls can be
applied to any type of risk at any stage in the life cycle of a
product, process or service [7]. It enables decision-makers to
effectively reduce risk before the worker begins interacting
with the process or product.
Risk assessment commonly involves either a task-based
approach or a hazard-based approach [8]. While either
approach can be applied at the both organizational and field
level, this paper will apply a hazard-based approach at the
organizational level.
In the hazard-based approach hazards are identified and
characterized for materials, processes, the worksite and the
environment. Activities that might be affected by those
hazards are identified. The risk associated with each activity
is analyzed for likelihood of harm and severity of harm.
Material purchasing examples:

VI. RISK ASSESSMENT AT THE WORKER LEVEL [4]

Task-based risk assessment begins with a job, breaks it
down into discrete tasks, identifies hazards associated with

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or approach within the arc-over distance specified in Annex

C of NFPA 70E and CSA Z462. In this table Voltage Above
or Below Selected Threshold means the voltage threshold at
which electric contact is not likely to result in harm. NFPA
70E and CSA Z462 indicate that this threshold is 50 Vac and
100 Vdc. In some jurisdictions the accepted thresholds are
lower [9].

each task and then analyzes the risk. This is the most
common approach when performing a field level risk
assessment. A what-if analysis is performed on human
behaviors involved with the task, to include foreseeable
interactions with equipment, the work site, and environment,
and possible failures, malfunctions, or deficiencies. This
analysis anticipates adverse outcomes and their most
probable severity [8].
At the field level, where the electrical professional is
practicing their craft, this risk assessment can be quite
simple. Consider the example of a shock risk assessment.
Electric shock occurs when electric current passes through
the human body. Shock from electrical equipment is usually
prevented by substitution and engineering risk control
methods such as insulation, isolation, guarding, equipment
design or a combination thereof.
Hazard identification
Identifying the potential for electric shock involves
identifying situations when exposure to electric conductors
is not adequately controlled by insulation, isolation,
guarding, or equipment design. This usually occurs when the
electrical worker removes a cover or in some other way
compromises the insulation, isolation, and guarding or
equipment design. This might be done for the purposes of
maintenance, installation, repair or testing.
Risk analysis
Analyze the likelihood of making electrical contact using
a Yes or No matrix. Is the insulation, isolation, guarding or
equipment design compromised, or will a workers actions
compromise it such that electrical contact is possible? Notice
that the question is about the possibility of electrical contact
(analytical) not whether the worker can be careful enough to
avoid electrical contact (experiential). CSA Z462 and NFPA
70E identify a safety boundary called the restricted
approach boundary as the distance within which contact
should be considered a possibility.
Analyze the severity of harm of using a Yes or No
matrix. Could electrical contact result in harm (e.g. burns,
loss of body parts or death)? This is where some electrical
workers get themselves into trouble; it is likely they have
endured several electrical contacts during their career
without any measurable physiological effects (experiential),
yet they know that electrical contacteven at 120Vcan be
fatal (analytical).
When the answer to both questions is YES, the worker
must utilize the hierarchy of controls starting with
elimination. Is possible to eliminate the hazard (de-energize
by following an approved lockout procedure) and still
complete the task (analytical)? For example, it is possible to
perform maintenance, installation and repair while
equipment is de-energized, but it is usually not possible to
perform diagnostic testing while equipment is de-energized.
Table 3 is an example of a two-by-two YES/NO risk
acceptable/unacceptable risk analysis matrix for shock
hazards. In this table, electrical contact means direct contact

TABLE 3
SHOCK HAZARD FIELD LEVEL RISK ANALYSIS MATRIX
Electrical Contact
Electrical Contact
NOT Possible
Possible
Voltage
Risk Acceptable
Risk Acceptable
[Selected Threshold]
Voltage >
Risk Acceptable
Risk Unacceptable
[Selected Threshold]

The Canadian Electrical Code Part I addresses the

possible versus not possible question in Subrule 2-304(1):
No repairs or alterations shall be carried out on any live
equipment except where complete disconnection of the
equipment is not feasible.
Appendix B of the Code defines not feasible as
troubleshooting of control circuits, testing and diagnostics.
Note feasible does not include installation, maintenance,
repair or alterations.
When de-energizing is not feasible, the tendency is to
jump to the last risk control method: PPE. While the risk
control method of substitution is not usually possible at the
field level, the use of engineering controls such as temporary
barriers (rubber insulating blankets or other cover-up
materials) can be an effective risk control method.
Diagnostic testing, including testing for the absence of
voltage during a lockout procedure, requires the use of a
combination of administrative risk control methods (e.g.
worker qualifications, training, procedures and PPE).
VII. CONCLUSION
The integration of OHSMS principles and risk
management principles into the 2015 editions of NFPA 70E
and CSA Z462 will make these Standards more accessible to
OHS professionals.
Partnering Electrical and OHS
professionals can only benefit electrical safety.
This integration will also provide employers and workers
with a method of sustainable and continuous improvement in
electrical safety performance.
The most effective
application of the requirements of hazard-specific Standards
is achieved within the framework of an OHSMS.
Additionally, adhering to risk management principles
ensures that risk control methods are systematically
identified and applied in a hierarchical approach.
Most importantly, this approach will benefit all electrical
workers by directing them away from an experiential
response to a structured analytical response to electrical
hazards.

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VII. REFERENCES
[1] Roberts, D. T.; Risk Management of Electrical Hazards; IEEE IAS
Applications Magazine Vol. 19, No. 3; May/June 2013, page 21
[2] NFPA 70E 2015 Forward
[3] Moraru, I.R.; Current Trends and Future Developments in Occupational
Health and Safety Risk Management;
http://www.intechopen.com/books/risk-management-for-the-futuretheory-and-cases/current-trends-and-future-developments-inoccupational-health-and-safety-risk-management
[4] Roberts, D.T.; Hazard vs. Risk; Electrical Business Magazine;
September, 2014
[5] Floyd, A. and Floyd H.L.; Cultural Drift and the Occlusion of Electrical
Safety; IEEE Transactions on Industry Applications, Volume: 50, Issue:
3
[5] ISO/IEC Guide 51:2014(E) Safety aspects Guidelines for their
inclusion in standards
[6] Roberts, D. T.; Integrating OHSMS, Risk Management & Electrical
Safety; Paper No. ESW2014-38; IEEE IAS 2014 ESW
[7] CSA Z1002-2012 Hazard identification and elimination and risk
assessment and control; Preface
[8] ANSI Z10-2012 Occupational Health and Safety Management Systems;
Appendix F
[9] Roberts, D.T.; 50 V Shock Hazard Threshold; IEEE Transactions on
Industry Applications, Volume: 46, Issue: 1; Page 102

IX. VITA
Daniel Roberts is the Senior Manager, Electrical Safety
Consulting at Schneider Electric Canada.
Daniel is a longstanding Canadian Standards Association
(CSA) member and serves on several CSA Technical
Committees including the Canadian Electrical Code Part 1,
CSA Z1000, Z1001, and Z1002. He is the vice-chair of the
CSA Z462 Workplace Electrical Safety Technical
Committee. Daniel received the CSA 2013 Award of Merit
for sustained and influential contributions to OHS and
Electrical Safety Standards. He is also an ASSE member
and an IEEE Senior member.

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Table 1 Summary of substantive OHS revisions to NFPA 70E

Edition
1979
1981
1983
1988
1995
2000

Installation Safety Requirements

Part I Compilation of NEC
requirements
Minor revisions
Minor revisions
Minor revisions
Updated to correlate with the
1993 edition of NEC
Updated to correlate with the
1999 edition of NEC

2004

Relocated to Chapter 4
Updated to correlate with the
2002 edition of NEC

2009

Chapter 4 deleted

2012

N/A

2015

N/A

Safety-Related Work Practices

N/A

Safety-Related Maintenance Requirements

N/A

Safety Requirements
for Special Equipment
N/A

Part II created
Minor revisions
Minor revisions
Limits of approach and arc flash concepts introduced

N/A
Part III created
Minor revisions
Minor revisions

N/A
N/A
N/A
N/A

Hazard/risk category method added.

Focus continues on establishing protection and approach
boundaries and the use of personal protective equipment.
Relocated to Chapter 1
Reorganized to emphasize working on live parts as the last
alternative work practice. An energized electrical work
permit and related requirements incorporated.
Significant revisions to Annex D, F, and J and the addition
of Annex M, N, and O
Article 110.7(F) revised to clarify the separate but directly
related concepts of hazard identification and risk assessment.
Flame-resistant (FR) term replaced by arc-rated
throughout the standard.
Short-circuit current, fault clearing time, and potential arc
flash boundary information in the hazard/risk category
tables relocated from the notes to the body of the table.
Four new definitions related to hazard and risk.
Entire document revised to ensure consistent use of hazard
and risk terminology.
Hierarchy of risk control methods added.
Electrical safety program required to be part of the employers Occupational Health and Safety Management System (OHSMS) when one exists.
Prohibited Approach Boundary deleted.
Hazard/Risk category method revised to the Arc Flash PPE
category method. The new method separates likelihood of
occurrence from severity of occurrence.
Hazard/Risk category 0 deleted.

Minor revisions

Part IV created

Relocated Chapter 2

Relocated Chapter 3

Minor revisions

Article 350 added for

R&D facilities
Installation requirements removed

Minor revisions

Equipment owner or
designated representative is responsible for
maintenance of the
electrical equipment
and documentation
related to maintenance.

Risk assessment to be
performed prior to any
work on a battery system to identify the
chemical, electrical
shock, and arc flash
hazards and assess the
risks associated with
the type of tasks to be
performed.

Note: The title of NFPA 70E from 1979 to 2000 was Standard for Electrical Safety Requirements for Employee Workplaces.
Since 2004 the title has been Standard for Electrical Safety in the Workplace. In 2004 the four Parts became Chapters.

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