The “PPE First” Fallacy

This is the belief that some electrical workers have related to the idea that their employer gave them the arc flash PPE, so let’s just put it on and get the work done. PPE should be viewed as the last line of defense and used only after all other options have been exhausted. Article 130 of the NFPA 70E requires an arc flash risk assessment to include evaluating electrical tasks using the hierarchy of risk control method. Electrical professionals should always evaluate methods for eliminating the hazard, shielding themselves from the hazard, and any other step to keep workers out of the line of fire. If our risk assessment results in no other option than being exposed to the potential arc flash hazard, then the employee determines the appropriate PPE needed to execute the task safely.

An example of managing this mindset to drive a positive culture can be seen in an approach I have used for voltage-rated tools. When managing a group of electrical workers, I provided them with electrical safety training, which included the requirement for voltage-rated tools when working inside the restricted approach boundary (RAB) of exposed energized conductors. After the training, I was told that they all needed to be provided with individual sets of voltage-rated tools because on any given day they could receive a maintenance task that would require performing work inside the RAB. Knowing that I was the author and provider of the electrical safety training that taught them the requirement, you can imagine their surprise when I declined their request.

I explained that if I provided each employee with their own set of voltage-rated tools, I am implying that I expect them all to perform repair-type work within the RAB when, in fact, my expectation is the exact opposite. Instead of individually issued tools, I provided two toolboxes with voltage-rated tools that were kept locked, and I retained the keys. Working inside the RAB for non-diagnostic tasks requires an energized electrical work permit (EEWP). A task that would require voltage-rated tools also required an EEWP approved by me. If the EEWP and hazard risk assessment process resulted in verifying that the task was infeasible to complete in an electrically safe work condition, then I would approve the plan and provide a key to the voltage-rated tools. The result was that those tools rarely were used because the process worked as intended. Instead of jumping right in and executing the task with PPE, we took some time to think about what needed to be done and determine if there was a way to do the work while minimizing the need for PPE. In most cases, we found ways to execute the task with significantly reduced exposure to electrical hazards.

That scenario demonstrates the goal of the requirements for an electrical safety program. The goal is to drive a culture of continuous evaluation of how we execute our tasks with the mindset of minimizing our exposure to hazards. The days of ‘taking risks because we are electrical workers and we knew the risk when we signed up for the job’ is over. There is no task in the electrical industry that is important enough to risk our life to execute. Given what we understand about electrical hazards and the procedures and technology available, there is no reason for anyone to ever be injured or killed by an electrical hazard. There is always a method for protecting workers from the hazard. The solution is in driving a culture that prioritizes safety at work and home so that taking risks is replaced with taking time to plan the work to be executed safely.