NFPA 70E – 2018 Edition Changes

NFPA will be issuing the updated 2018 edition of NFPA 70E in late October. Major changes to the standard include:

Changes in Job Safety Planning
Incident Reporting Changes
New Changes in Risk Assessments
Personal Protective Equipment (PPE) Standardization
Vocabulary and Wording Changes

We will review these changes in detail during our November 10, 2017 NFPA 70E course. Click here for more information.


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Machine Guarding – Minimum sized opening for pinch point hazard

During a recent client meeting, a question was asked regarding what is minimum sized opening that would represent a pinch point hazard. Keep in mind there are many variables to consider – distance from nip point, etc.

One-fourth of an inch is considered the minimum sized dimension that OSHA considers a potential pinch point hazard. If you look at 1910.217 – Table 0-10 (Mechanical Power Press Standard), the smallest opening they have listed in right column is 1/4 inch. A woman with a size 6 glove could potentially receive a pinch point hazard based on this sized opening.


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Performing an Effective Incident Investigation

I am commonly asked by clients to participate in or review the thoroughness of an incident investigation. Based upon my experience, many of these incidents are incomplete and fail to accurately satisfy the objective: identify the actual root cause(s) to prevent a similar future incident. Listed below are some of the major shortcomings I have noticed with incident investigations:

1. Failure to identify the real root cause(s): Incident team members sometimes don’t utilize an effective investigation method, such as TapRoot, Failure Mode and Effects Analysis (FMEA), as well as many other equally effective investigative tools. This results many times in incomplete analysis which identify symptoms but not the underlying root cause(s).
2. Lack of team Expertise: The team may not be comprised of the necessary technical expertise to perform a thorough incident analysis. Has the team leader assembled the necessary personnel to perform the review? This may include an electrical engineer; an electrical & instrumentation specialist; a metallurgist; etc. Assembling a complete investigative team reduces the likelihood of overlooking potentially critical evidence.
3. Confirmation Bias: This occurs when the team or a team member reaches an early conclusion to the root cause and only considers evidence supporting it. Other critical evidence may be ignored potentially resulting in an incomplete investigation.
4. Normalized Deviation: A simple way of restating this is seeing something wrong for so long you accept it as correct. When performing an incident investigation, it is paramount that you review work practices and compare them against standardized acceptable practices. In many cases, a company has established work practices but they are not followed. To determine if normalized deviation has occurred, it is sometimes beneficial to assign a team member from outside the immediate incident area. He/she may ask very elementary questions as part of the investigation that identify a significant problem.

This is by no means a comprehensive list but is intended as a tool in assisting you in performing effective, thorough incident investigations.


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Couple injured after igniting gas grill inside vehicle – importance of employee safety orientation

A recent incident involved multiple injuries after a woman attempted to light a cigarette with a gas grill inside their rental SUV. Please click here for more details. Although this incident did not happen in the workplace, it illustrates the importance of not assuming new employees have the base safety awareness required for safely working at your facility. Do you have safety awareness training for new employees? Are they required to receive prior to performing any work at your facility? Does your facility have any unique safety hazards that are specific only to your industry? For instance, my Father worked for 40 years at an aluminum smelting/rolling facility. Aluminum soda cans were prohibited anywhere in the facility due to an explosion where an employee innocently placed a soda can inside an aluminum scrap container. During heating the aluminum in the furnace, the liquid residue in the soda can converting to steam resulting in a dangerous froth over.

Don’t assume your new or existing employees have all the hazard recognition tools to safely perform their jobs. Identify potential deficiencies and train your employees to be aware of all potential safety hazards.


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Company cited by OSHA for lamp ballast incident

According to the International Brotherhood of Electrical Workers (IBEW), changing a ballast in a 277 volt circuit is the #1 cause of electrocutions for IBEW trained electricians. The combination of the shock and fall can result in serious injure/death. OSHA cited a hospital recently due to a fatality while an employee was changing a lamp ballast. Click here to read the OSHA News Brief. Also, article 410.130 (G) of the National Electrical Code (NEC) requires a ballast disconnect on new fluorescent fixtures.

Click here for information on our February 10, 2017 NFPA 70E course in Greensboro, North Carolina.

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Arc-Rated Clothing – laundering practices

A common question is raised during my NFPA 70E electrical safety courses: what precautions are necessary for laundering arc-rated garments. A few suggestions:

1. Always follow manufacturer recommendations.

2. Do not use fabric softener or bleach.

3. Do not use dryer sheets as Dryer sheets as they add a small amount of fat and a Quaternary ammonium that can weaken the fabric and reduce flame resistance.

For more information on electrical safety attend one of our upcoming NFPA 70E seminars:

Raleigh, NC: October 28, 2016
Greensboro, NC: November 18, 2016

Click here for more information.


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FAA Unmanned Aircraft System (Drone) Regulations

The Federal Aviation Administration (FAA) recently placed new regulations into effect regarding the use of unmanned aircraft systems (UAS) – sometimes referred to as drones. Below is a summary of key points of the new regulation.

What is an unmanned aircraft system (UAS)?
• An unmanned aircraft system is an unmanned aircraft and the equipment necessary for the safe and efficient operation of that aircraft.
• An unmanned aircraft is a component of a UAS. It is defined by statute as an aircraft that is operated without the possibility of direct human intervention from within or on the aircraft.
• The NEW Small UAS Rule (Part 107), including all pilot and operating rules, is in effect as of 12:01 a.m. EDT on August 29, 2016.
• An unmanned aircraft system (UAS), sometimes called a drone, is an aircraft without a human pilot onboard – instead, the UAS is controlled from an operator on the ground.
• When you fly a drone in the United States, it is your responsibility to understand and abide by the rules.
• The rules for operating an unmanned aircraft depend on why you want to fly.

To fly UAS for commercial use, you must follow the FAA’s set of operational rules (known as “Part 107”). These rules went into effect on August 29, 2016.
What is a commercial use of UAS?

Any commercial use in connection with a business, including:
• Selling photos or videos taken from a UAS.
• Using UAS to provide contract services, such as industrial equipment or safety inspections.
• Using UAS to provide professional services, such as security or telecommunications.
• Using UAS to monitor the progress of work your company is performing.
• What are some examples of commercial uses of UAS?
• Real estate, professional photography, film or television production, services for mapping or land surveys, agriculture, construction and engineering, security.

What requirements to fly commercially?
Remote Pilot requirements:
• Must be at least 16 years of age.
• Must hold a remote pilot airman certificate with a small UAS rating or be under the direct supervision of someone holding a remote pilot airman certificate (Pass Part 107 exam).
• Must pass the applicable Transportation Security Administration (TSA) vetting.

UAS requirements:
• Must weigh less than 55 lbs.
• Must undergo pre-flight check by remote pilot in command (You or the person supervising the operation).
• Location requirements:
• Operations in Class B, C, D and E airspace are allowed with the required Air Traffic Controller (ATC) permission.
• Operations in Class G airspace are allowed without ATC permission.

If I meet all the requirements to fly commercially, what are the operating rules?
• Fly under 400 feet above ground level (AGL) or, if flying at an altitude higher than 400 feet AGL, stay within 400 feet of a structure.
• Keep the UAS in sight, either by the remote pilot in command or a visual observer.
• Fly during daylight hours or civil twilight hours with appropriate anti-collision lighting.
• Fly at or below 100 mph.
• Yield right of way to manned aircraft.
• Do not fly over people.
• Do not fly from a moving vehicle.

What is recreational use of sUAS?
• Operation of an unmanned aircraft for personal interests and enjoyment.
• Using a sUAS to take photographs for your own personal use would be considered recreational; using the same device to take photographs or videos for compensation or sale to another individual would be considered a commercial operation.
• Should check with the FAA for further determination as to what constitutes commercial or other non-hobby, non-recreational sUAS operations.


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OSHA Recordkeeping Standard and post-incident drug testing

I recently had a question concerning OSHA’s Recordkeeping standard with respect to employee injury reporting and discrimination by drug testing. Federal OSHA states the following:

“The rule does not prohibit drug testing of employees. It only prohibits employers from using drug testing, or the threat of drug testing, as a form of retaliation against employees who report injuries or illnesses. If an employer conducts drug testing to comply with the requirements of a state or federal law or regulation, the employer’s motive would not be retaliatory and this rule would not prohibit such testing.”

Click here to read the OSHA link.

As stated by OSHA, drug testing to comply with state and federal regulations is not considered retaliatory. In addition, many companies have mandatory drug testing programs including post-incident testing. It appears the key issue is whether or not employers who perform drug testing have a consistent and documented drug testing program – not just used as a retaliatory tool discouraging employees to report injuries and illnesses.


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Race Report – 2016 Escape from Alcatraz Triathlon

I completed the 2015 Escape from Alcatraz Triathlon with one year of training. It was a great experience. Alcatraz is an iconic race – swimming 1.5 miles in frigid waters from Alcatraz to shore; bicycling 18 miles up the steep San Francisco roads, finishing with an 8 mile run, including the infamous Equinox Sand Ladder – 400 stairs climbing up the side of Baker Beach. For the 2016 race I had two primary goals – improve my speed in bicycling and running. I made significant improvements in both and feel I came into the 2016 race in far better cardio condition as compared to 2015. Also, my goal in the swim was to lower my 2015 48 minute swim time by three minutes to 45 minutes. Two days prior to the race (Friday) I did a pre-race swim to practice my open water sighting. The currents were extremely smooth – I am confident I would have completed the swim in 40 minutes had I swam the entire course on Friday. I went into Sunday feeling very good about the swim.

My nutrition Saturday and Sunday morning was probably better than any race I’ve ever had. For Alcatraz you really need to have your nutrition nailed down – it’s not the place to get hungry midway through the race. I jumped off the boat and everything felt great – for about a minute. I immediately noticed how strong the current was – waves were coming over top of me. I fought very hard to swim towards shore before making a right-hand turn but the current was too strong. I was making progress but the waves were pulling me away from shore. I continued swimming wondering when would I finally arrive at St. Francis Yacht Club? About 5 minutes from shore I saw a jet ski pulling another athlete towards shore. I was later informed that over 25 athletes had to be rescued because of the strong currents. I finally made it to the swim exit – 17 minutes slower than my 2015 time.

My slow swim time put me significantly behind my 2015 pace. However, on the bicycle I finished two minutes and 35 seconds quicker than 2015. Onto the last leg – the run. The 2016 run course was one-half mile longer than the 2015 course. My pace was actually 43 seconds per mile quicker than 2015. I completed the race with a time of 04:10. My 2016 time was 10 minutes slower than 2015, however, the overall average time for all athletes was 20 minutes longer as compared with 2015. Race organizers stated the water was the roughest in several years. Overall, I felt good about the event – my bike and run were significantly improved and I completed a very challenging swim. Most importantly, I wasn’t injured!

Thanks to all who helped made it possible!
There are so many people to thank for supporting me on this venture! Joseph and Carolina Lepera, who not only talked me into entering Alcatraz, but housed and fed me. My triathlon coach, Emily Cocks, who developed a customized 2016 training program, answered all of my questions along the way, and frequently checked in to see how my training was progressing. Coach Pedro Ordenes, of Water World Swim, for his expertise in instructing me how to complete the swim from Alcatraz to St. Francis Yacht Club. A special thanks to all the volunteers who made this such a great event!

Attached link is Alcatraz swim. I’m wearing the orange swim cap.


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UNC Worker burned in electrical incident: January 20, 2016

On January 20, 2016 a University of North Carolina at Chapel Hill employee was burned in an electrical incident and transported to the hospital. Click here for more details.

Do your electrical employees wear arc-rated clothing to protect them in the event of an electric arc? On February 12, 2016 I will be teaching a one day NFPA 70E electrical safety course that reviews the requirements for arc-rated clothing. Click here for more details.NFPA70E_02122016


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