From: Daryn Lewellyn
Date: 19 May 2015

Dear CEO:

Allow me to cut to the chase: It is imperative your organization invests the money and resources needed to improve electrical safety in your facilities. The best way to do this is adherence to NFPA 70E. This could be argued from a human interest perspective, and I have ample anecdotal evidence of terrible stories of personal loss as a result of electrical accidents. Instead, I want to discuss improving electrical safety from a purely business point of view.

Over the past 30 years there have been major advances in electrical safety, including, but not limited to: research on the effects of shock on the human body, research on arc flash and new ways to predict its severity, and new fabrics developed to prevent burn injuries. Thousands of dedicated volunteers have spent countless hours developing new standards, like NFPA 70E, based on this research. This enlightenment has shown us we can avoid and/or mitigate injuries caused by electrical hazards. Sadly, in spite of all these advances, many facilities continue to unnecessarily expose their employees to electrical hazards the same way we did 30 years ago.

Taking the proper steps to protect employees can be expensive. But what is the cost of doing nothing? Analysis of electrical accidents shows that while they may be small in terms of percentage of all workplace accidents, the severity of the injury incurred and the fatality rate is much higher. Therefore, the impact can be much longer-lasting.

If an electrician suffers a severe burn from an electrical arc flash event, the costs of that accident to the organization over the next five or ten years could be in the tens of millions of dollars. Firstly, OSHA will likely issue a citation for failing to protect your employee. But that will be insignificant "chump change" compared to the other costs to come. These costs include equipment damage, lost product, downtime, medical bills, insurance premium increases, workers comp, attorney fees, accident investigation costs, law suits, retraining, etc. Indirect costs can be even more costly such as bad publicity when OSHA writes you a citation and posts a news release on the front page of their website, as they commonly do. The news release will explain to the world, mentioning your company by name, that "this accident could have been avoided by following recognized safe practices for working around electrical hazards." Instantly, safety newsletters and blogs will pick up the story and in minutes the news is spread around the world.

It's hard to put a price tag on some of these costs, but experience has shown us, without question, it is far more expensive to allow one of these preventable accidents to occur than it is to avoid it.

Aversion of high cost is only one argument made against properly protecting employees from electrical hazards. Another argument from upper management is that OSHA regulations do not explicitly require compliance with the NFPA 70E standard. This attitude borders on willful ignorance and must be addressed.

OSHA regulations concerning electrical hazards are simple. They state that you must protect employees from electrical hazards - shock and arc flash - but they do not specify how accomplish that. OSHA requires proper personal protective equipment (PPE) be provided as a line of defense against these hazards. OSHA requires "specific safety related work practices" be employed that are consistent with the associated electrical hazard. OSHA requires employers to perform, and document, assessments of the workplace to determine the PPE required, OSHA requires employers to train employees on the proper use of this PPE. The list goes on.

OSHA requires all of these things without giving you enough detail on how to accomplish them. That's where 70E comes in. It is a bridge between OSHA regulations and compliance. As top OSHA officials have said, "If I were an employer, and I had to protect my employees from electrical hazards, the first place I would look is NFPA 70E." Do not misunderstand: Items do not have to be explicitly spelled out in OSHA regulations for OSHA to expect you to do them. It does not matter that NFPA 70E is not mentioned by name in OSHA regulations; it is the recognized best practice for electrical safety in the workplace. OSHA does require employers follow recognized best practices.

Implementing NFPA 70E in all facilities is a good business decision. It protects the employee and the assets of the organization. Yes, it will involve a significant upfront investment, but it will protect the organization for years to come. If an injury or fatality were to occur on your watch stemming from something warned against in NFPA 70E, it would be very difficult to defend.

Protection from arc flash and shock is not something to prepare for. It is required now. If you are not going to follow NFPA 70E then to which recognized best practice will you adhere? The cost of inaction is far too steep for any responsible businessperson to ignore.

Daryn Lewellyn
Founder of Lewellyn Technology