HAZARD/RISK EVALUATION WHAT IS IT?

Copyright Material IEEE Paper No. PCIC-2007-41

Danny Liggett Senior Member, IEEE DuPont Engineering C/O CDI Engineering 9800 Centre Parkway Suite 300 Houston, TX 77036 USA danny.liggett@ieee.org

Abstract - The term Hazard/Risk Evaluation is misunderstood. Some believe the procedures they have in place make up a hazard/risk evaluation. A Hazard/Risk Evaluation is a thought process. Many have struggled with how to address the requirement for an evaluation contained in NFPA 70E [1]. Many believe that Risk Management meets this requirement. This paper will provide one definition for what a Hazard/Risk Evaluation is and one method for performing a Hazard/Risk Evaluation. This paper will discuss risk assessment and how it fits in an overall risk management process. This paper will discuss the relationship between Risk Assessment and Hazard/Risk Evaluation. The flowchart currently in NFPA 70E does not start with the right question and needs modifying. This paper will explore a new starting place for the thought process and suggest that the flow-chart in NFPA 70E needs modification. Index Terms Risk Management, Risk Analysis, Hazard Risk Evaluation, Hazard, Risk I. INTRODUCTION

The thought process needs to be done in a specific sequence in order for it to be effective. II. WHY DO A HAZARD/RISK EVALUATION? Several years ago Ray Jones developed a model, shown in Fig. 1, showing the relationship between regulations, standards and procedures.

Government Regulations National Consensus Standards Corporate Policies Site Requirements Personal Beliefs Fig 1 Control Measure Relationships At the top of the triangle is government regulation. As you can see the level of the detail is narrow. It is intended to be more general in nature and written in performance-based language. Its purpose is not to tell you how to do something but rather what the end result must be. As we move down the triangle the more detailed the information becomes. This is as it should be. The closer you get to the worker the information and guidance needs to be more detailed and specific. The bottom box of the triangle is the area within which the worker will work. Jen Rasmussen concluded that Workers will make decisions within boundaries established by administrative, functional and safety constraints [2]. Freedom left open by

Contained in the 2004 edition of NFPA 70E Section 110.7(F), is a requirement for a Hazard/Risk Evaluation Procedure to be used. Annex F of NFPA 70E shows one example of how to accomplish this requirement. The problem is many people do not understand how to execute the process or even see the need for the process. They believe that their procedures, such as Working On or Near Energized Electrical Equipment, satisfy the requirement. Most electrical safety procedures outline the Personal Protective Equipment to be used when performing tasks On or Near energized electrical equipment. What these procedures do not cover is how to determine when an electrical hazard exposure is present. The same can be said of Risk Assessment programs. The primary purpose of a Hazard/Risk Evaluation is to identify the electrical hazard exposure that may be encountered during the execution of a task or job. The Evaluation must identify both shock and arc flash hazard exposures. The evaluation is more of a thought process than it is a procedure. It is a manner of thinking about the task in a way that identifies the electrical hazards the person performing the task might be exposed to.

lack of guidance sets the stage for human error. The point is simple. The larger the box at the bottom the more decisions the worker has to make. The worker will make these decisions based upon that workers knowledge, experience and the tools available to the worker at the time the task is being performed. The bottom box can only get deeper or shallower but it will not be narrower. Many people think in terms of what do I need to do and how do I do it. As part of this evaluation process we need to help assure that they will also consider the safety implications. Many incidents, injuries and fatalities have shown us that a single action can start the chain of events that lead to these incidents occurring. Completely controlling behaviors through rigid and voluminous procedures cannot be done because of the complex nature and design of the electrical equipment and the complexity of our facilities. These complexities provide so many possible situations a worker may face that procedures cannot address all of them. Because of this, there is a need to help assure that personnel use the right thought processes to plan any task they are given in a way that allows them to complete the task safely. Having useful, practical procedures that set highly visible boundaries within which the workers can work is a more effective way. Practical procedures allows for those cases that werent thought of during the development of the procedures. Even the most thorough procedures still leave room for workers to make some decisions. If we are to allow the kind of decision making freedom required by the complexities, we must help assure that the workers are given the tools to help guide their decisions. Having a well-understood Hazard/Risk Evaluation process allows workers to work within the rules based upon the conditions of the area and equipment, and the objectives of the task or job. The evaluation process provides the necessary guidance for the worker to identify the hazards associated with the job or task. The procedures established through risk management at the site provide the necessary control measures and personal protective equipment requirements to eliminate the hazards, reduce the hazards or address the remaining hazards. III. RISK MANAGEMENT VERSUS HAZARD/RISK EVALUATION Risk management is a method of identifying the potential hazards of a process and provide the measures to address those hazards. Risk management is not task specific but is more generic. Bill Anderson stated that concepts of safety are more effective when they are applied early and throughout the development process [3]. Bill was referring to Machine Development but it applies to electrical safety as well. Risk Management is a tool that can be used to determine the risks associated with the hazards in any work process, machine, or chemical process. When electricity is present there is a shock hazard and an arc flash hazard. Part of risk management is defining the severity of the hazard. Performing an arc flash analysis is part of electrical safety risk management. An arc flash study identifies the potential arc flash hazard for a piece of equipment. Knowing the potential hazard, ways can be found to mitigate the hazard or provide Personal Protective Equipment (PPE) for use when there is a hazard exposure.

The arc flash analysis is not task specific. What the arc flash study does not do is identify when there is an exposure to an electrical hazard while performing a specific job or task. Task specific hazard identification is the main difference between risk management and hazard/risk evaluation. Risk management assessments are usually performed well in advance of jobs or tasks being performed. Basically it assists in establishing control measures, in the form of safety procedures, and Personal Protective Equipment requirements to be utilized when specific hazards are present. This assessment should be completed long before personnel face the hazards. The hazard/risk evaluation is performed during the planning stage of a job or task. Risk management, such as the arc flash study, is an important part of an overall safety program. It identifies the hazards and allows for the site to put the appropriate procedures in place so that when there is a potential exposure to a hazard the right work guidance and PPE is already available. Hazard/Risk Evaluation identifies if there is an electrical hazard exposure associated with an individual job or task. IV. RISK ASSESSMENT

Risk assessment is a part of risk management. Once the hazards are identified the risk assessment can be performed. Risk assessments can be performed either quantitatively or qualitatively. Both systems look at the severity of the hazard, The frequency of the exposure and the probability of the hazard causing an injury. Typically the formula is Severity x Exposure x Probability equals the risk value. When a true quantitative analysis is performed all of the variables are determined by using hard numbers. Severity could be determined from using the amount of exposure to say, a chemical. If the person is exposed X amount of the chemical the person would suffer a recoverable injury. If the person is exposed to Y amount then the person would sustain a disabling injury. If the person is exposed to Z amount the exposure would cause death. Each of these levels would be given a value. Frequency of exposure to the specific hazard is determined by known experience similar to the way injury frequency rate is determined. Probability would again be based upon actual experience. From the formula given above a risk number is generated. As part of the quantitative analysis a value or level is determined for what is considered an acceptable risk. Any value derived from the analysis above this identified level would require some action or actions to be taken to lower the risk value. A qualitative analysis is much more subjective and allows for more flexibility than having a number. A chart is developed using the same three elements. The severity of the possible injury is broken into three levels, Lost Workday Case/Fatality, Medical Treatment Case/Restricted Workday Case, and First Aid Case. Exposure consists of two levels, High and Low. Probability of injury is expressed as; Expected, Possible, Unusual, Borderline, Improbable, and Practically Impossible. As you can see these breakdowns are not based upon numbers. Each person will select the level of severity, exposure and probability element based on their individual experiences. As with the quantitative method a level of acceptable risk is established. Attachment A shows one

example of this method and what is considered to be an acceptable risk. One method that is becoming popular is a semi-quantitative approach [4]. It is a combination of the two methods discussed above. The semi-quantitative approach still has the same elements, severity, exposure and probability as the others but it is a combination of the two concepts. Attachment B provides an example of one method of performing a semi-quantitative analysis. Each of the elements is broken down into 5 or 6 levels and each level is given a numeric value. This allows the analysis process to generate a numeric risk value. As with the quantitative method a level is established to define what is an acceptable risk. All three of the concepts have some issues. All depend on electrical injuries following the same spread as the injuries in the other safety competencies. But experience by one large science company indicates that the relationship between incidents, injuries and fatalities in electrical work do not follow the same relationship as they do in other safety competencies. The usual relationship in other competencies may be in the range of 300 recordable injures to 1 fatality. In electrical it approaches 10 recordable injuries to 1 fatality. Exposures to most hazards have a predictable injury. It is easy to assume the more severe the hazard the more severe the resulting injury will be. Electrical hazards are not as predictable. This is especially true with electrical shock. Although 120 volts is a lethal level of voltage, a 120-volt electrical shock is not always deadly. The same can be said of higher voltages. Again it is assumed that a shock at 15,000 volts will result in a fatality. We know this is not always the case. There are too many variables in an electrical shock to assume one will provide a mild tingle while another will be certain death. All electrical shocks over 50 volts must be considered as potentially fatal. An arc flash event has multiple hazards and it not yet completely understood. The arc flash 2 event with incident energies above 40 cal/cm is not predictable enough to state with any accuracy what the outcome will be other than there is a significant burn hazard and possibly a significant blast pressure hazard. At lower levels, less than 40 2 cal/cm , we can state there will be burns to unexposed skin and we can somewhat predict whether these will be medical treatment, restricted workday, or lost workday cases. We do not know at what level of incident energy where death will be a strong possibility or certainty. All of the concepts depend on the hazards being identified before beginning the analysis process yet none of them provide any guidance as to how to do this. V. HOW TO DO A HAZARD/RISK EVALUATION

The purpose of the hazard/risk evaluation is to determine if any hazards will be present and the extent of the hazards during the performance of a job or task. The hazard/risk evaluation is a thought process centered on a series of questions that need to be asked in a specific order. Think of it this way. You are about to enter an electrical control room (ECR). As you step into the ECR you need to ask Is any of the equipment energized? then, Am I within the arc flash boundary of a piece of equipment? As you get closer you want to ask Are there any openings in the equipment that expose uninsulated energized components? As you continue to get closer the questions change but the concept is to ask the

questions in the order in which you may be exposed to potential hazards. These questions should be asked to determine the hazards associated with the job or task. Jobs that contain multiple tasks should be broken down into smaller tasks and each task evaluated. With electrical equipment both the arc flash hazard and the shock hazard needs to be identified. The severity of the hazard needs to be identified also. Each hazard needs to be dealt with separately. Using a flow chart like the one in NFPA 70E provides us with the right questions to ask and the order they need to be asked. The first question in the flow chart in Annex F of NFPA 70E asks if there is exposure to an energized electrical component. There is a perception that NFPA 70E only applies when there is an exposure to uninsulated energized components. The author suggests that the first question should be whether there is any component in the equipment that is energized. If there is to be any interaction with energized electrical equipment then this is an important question. By knowing this we are driven to identify what component is energized and its relationship to the interaction with the equipment. Even if there is no exposure to energized electrical equipment arc flash PPE may be required if the interaction is within the arc flash boundary of the equipment. Most electrical equipment in service today may not contain an arcing fault. Interaction with this electrical equipment may present an arc flash hazard. It needs to be determined if the interaction or task will be inside the arc flash boundary even with the door closed or if the equipment can contain an arcing fault. Knowing the worker will be inside the arc flash boundary is just one part of the arc flash hazard. We still need to know what the incident energy is so that the worker will have arc flash PPE appropriate for the hazard exposure. Understanding what is energized is just as important as understanding what is in an electrically safe work condition. There are always hazards associated with working on or near electrical equipment that is or can be energized. Identifying what is energized and where the energized components are is important for task planning. Too many incidents occur where people get outside the electrically safe work condition and contact energized components without realizing there were any energized components in the equipment. Once it is established that some part of the equipment is energized, the next question is to ask if there will be exposure to uninsulated energized components. If there is exposure then the level of voltage needs to be determined. Knowing the voltage level will direct the person to the shock protection rated for that voltage. For the sake of discussion we will assume: Some part of the equipment is energized The task is inside the arc flash boundary 2 The incident energy is 5 cal/cm There is exposure to uninsulated energized conductors The voltage is 480 volts The next step is to determine if there will be contact, by tools or body parts, with uninsulated energized conductors. This is necessary to differentiate between testing for the absence of voltage, measuring voltage, and performing work on energized components. If the task is to test for the absence of voltage the requirements may be different than measuring voltage. The

site or company may choose to require the use of single function testers for testing for the absence of voltage. One thought is that we should not overly restrict the electrician from testing for the absence of voltage. Measuring voltage or diagnostic tasks may require a different tester or meter. Performing work on energized components has a completely different set of requirements. Lets assume there will not be contact with energized components. We have established the following Some part of the equipment is energized The task is inside the arc flash boundary 2 The incident energy is 5 cal/cm There is exposure to uninsulated energized conductors The voltage is 480 volts No contact with uninsulated energized conductors If there will not be contact with uninsulated energized conductors then how close will the person be to the uninsulated energized conductors? We know the voltage so we can use the approach distance chart in NFPA 70E as a guide. If the work is inside the Limited Approach Boundary, in this case 42, but outside the Restricted Approach Boundary (12) the requirements for working in the Limited Approach space apply. If the work is inside the Restricted Approach Boundary but outside the Prohibited Approach Boundary (1) then the requirements of the Restricted Approach space apply. If the work is inside the Prohibited Approach Boundary then this is the same as if you were in contact with the uninsulated energized conductors. Understanding the distance from the uninsulated energized components helps assure that the right work practices and PPE will be used. For discussion we will assume the task is in the Limited Approach space. In some tasks long objects that could penetrate the other Approach boundaries may be handled and this needs to be considered while performing the hazard/risk evaluation. We will assume no long objects will be handled. Lets review what we know Some part of the equipment is energized The task is inside the arc flash boundary 2 The incident energy is 5 cal/cm There is exposure to uninsulated energized conductors The voltage is 480 volts No contact with uninsulated energized conductors The work will be in the Limited Approach space. As you can see we have gathered several pieces of information that are critical to the safety of the worker. Now that we know this information what do we do with it? By knowing that some part of the equipment is energized we know there is an electrical hazard. Energized compartments, sections or parts can be identified. It can never be assumed that people will know what is and what is not energized. Knowing the task will be performed inside the arc flash boundary and knowing the level of the incident energy, we can provide the appropriate arc flash PPE. Knowing there are exposed energized parts operating at 480 volts alerts us we may need shock PPE. By understanding the distance from the energized parts allows us to choose the appropriate work practices and PPE for that task. Having all of this information also provides us with fact-based information by which we can determine whether we will perform the task with the equipment energized. When we are requesting a shutdown of equipment we are usually dealing

with non-electrical personnel. Having the information on the hazards, the hazard levels and the required PPE will help nonelectrical personnel make better decisions. It helps us make better decisions.

VI.

TRAINING

This thought process is not intuitive. It requires training and explaining. Today many, but not all people, understand there is a shock hazard and an arc flash hazard associated with electricity. It is easy to assume that people will always think about the right things and will always ask the right questions. After all they are electricians. In the past it has been well documented by several companies that many electricians do not understand all of the hazards of electricity and cannot ask the right questions. Not only is it important to know which questions to ask but also why that question needs to be asked. The importance of each question must be conveyed in a way that achieves understanding. Handing out a flow chart and saying use this does not convey that understanding. A training session needs to be put in place to review the hazard/risk evaluation process that is to be used. Assumption is proving to be a major contributor to electrical incidents. VII. CONCLUSIONS

Risk Management consists of identifying the hazards and understanding the risks associated with them. Knowing the general hazards associated with electrical work allows us to feed that information into the Risk Assessment Analysis. Risk Assessment allows us to establish a level of acceptable risk. The level of acceptable risk drives us to mitigate the hazards or to provide control measures and PPE when the hazards may still be present. These are tools for management. Hazard/Risk Evaluation is a tool for the worker to identify hazards for jobs and tasks. Performing a Hazard/Risk Evaluation prior to starting any task is essential to the safe execution of the task. Identifying the hazards associated with the task is the only way to put the appropriate barriers between the worker and the hazards. As you saw in Section V we identified seven different pieces of information related to electrical hazards. When we do a task do we think in a manner that would identify all seven of these items? Not only is the evaluation needed for planning but also as changes occur during the execution of the task or job. Changes occur on frequent basis therefore re-planning is just as important. This process needs to be stepped through for every task. A hazard/risk evaluation process is not one that comes naturally. People are interested in the getting the job done and will spend most of their time thinking in terms of what to do and how to do it. Too many people still believe being exposed to the hazards associated with electrical work is just part of the job. If we provide procedures that dictate every action then we are essentially saying to our workers check your brain at the gate. That is not what we need. We need people who can think and make good decisions.

If we depend solely on the worker to make the right choices without some guidance then we are setting the stage for incidents, injuries and fatalities. No one gets up in the morning and says I think Ill go get hurt today. People show up at work every day to do a good job. It is our responsibility to provide them with the tools to help them do that job in a way that it can be completed safety. These tools include not only the drill motors, hand tools, PPE and other physical equipment but also the mental tools that are needed to think about how to do the task or job safely. One of those mental tools is a Hazard/Risk Evaluation Process. A hazard/risk evaluation is the not the silver bullet or the answer to all of our problems. With this evaluation we still have to have in place the procedures that provide information such as, what are the requirements for working in the Limited Approach space and what arc flash PPE is required for 5 2 cal/cm . The hazard/risk evaluation is one part of a holistic approach to electrical safety. Employees need to understand the basics of electrical safety such as the hazards of electricity. This comes from training. They need to know how to recognize when the electrical hazards are present. The hazard/risk evaluation helps them do this. They need to know how to protect themselves from these hazards. Thats where the procedures come in. VIII. ACKNOWLEDGEMENTS

Danny Liggett has been employed by DuPont since 1989. He was employed by an Engineering /Construction firm from 1968 until his employment by DuPont. During his employment with the Engineering /Construction firm he worked as an Electrical Superintendent for over 15 years. During his employment with DuPont he has worked as an Electrical Consultant with primary focus on construction activities and electrical safety. His work also involves work with maintenance activities at the DuPont sites. He is a member of DuPont's Corporate Electrical Safety Team. He is a Senior Member of the IEEE, past Chair for the IEEE PCIC Safety Subcommittee and past Chair for the IEEE PCIC Tutorial Subcommittee. He currently serves as the Chair for the IEEE PCIC Electrical Safety Workshop Subcommittee. Danny has served as the chair for two of the IAS PCIC Electrical Safety Workshops. He has served on National Electrical Code Panel 8 representing the Cable Tray Institute and served as the Chair of the Technical Advisory Committee to the Cable Tray Institute. He has served on the National Electrical Code Panel 6 representing the American Chemistry Council. He currently represents the American Chemical Council as an alternate on the National Electrical Code Technical Correlating Committee and as an alternate on Panel 3.

There are a lot of people who have influenced my thinking concerning electrical safety training. Every conversation I have on electrical safety improves my understanding and thinking. Thanks to all. I would like specifically to thank Ray Jones who has influenced my thinking and encouraged me to learn. He continues to challenge and stretch my thinking. Catherine Irwin and Aubrey Heflin provided insight into the use of the Risk Assessment methods discussed in this paper, my thanks to them. IX. [1] [2] REFERENCES

NFPA 70E, 2004 Standard for Electrical Safety in the Workplace, Quincy, MA: NFPA. Jens Rasmussen, Risk Management in a Dynamic Society: A Modeling Problem, Safety Science Vol. 27, No. 2/3, pp 183-213 William E. Anderson, Risk Analysis Methodology Applied to Industrial Machine Development, IEEE Transactions on Industry Applications, Vol. 41, No. 1, January/February 2005 A. M. Donoghue, The Design Of Hazard Risk Assessment Matrices For Ranking Occupational Health Risks And Their Application In Mining And Minerals Processing, Occup. Med. Vol. 5 No. 2, pp. 118-123, 2001

[3]

[4]

X.

VITA

ATTACHMENT A Quantitative Analysis Method

Severity LWC/Fatality MTC/RWC FAC Exposure High Low High Low High Low Expected Possible Not Acceptable Acceptable Fig. 2 Quantitative Risk Evaluation Matrix Unusual Borderline Improbable Practically Impossible

ATTACHMENT B Semi-Quantitative Method

Exposure Very Rarely Rarely Sometimes Now & Then Frequently Continuous Minor Major Serious Critical Disaster Virtually Impossible Conceivable Improbable Unusual Possibe Expected < 1 every year Few times per year Once or twice a month 1 every week 1 every day > 2 every day Severity First aid case Medical treatment or restricted workday case Irreversible effect, handicap, Lost workday case One fatality, instantly or afterwards More than one fatality, instantly or afterwards Probability > 20 year, once in a life time, only theoretical case Once in a career, 1 per 20 years 1 per 10 years 1 per 3 years 1 ever 6 months 1 every week 0.5 1 2 3 6 10 1 4 7 15 40 0.2 0.5 1 3 6 10

Exposure x Severity x Probability = Risk Score Risk Score <20 20 to 70 70 to 100 >200 Interpretation Very limited risk acceptable Measures required Immediate measures required Stop work until measures taken Fig. 3 Semi-Quantitative Matrix