Mark ScottHenrik von der LippeBob CandelarioEETD Lunchtime SeminarFebruary 21st, 2013

The LBNL

Electrical Equipment Safety Program (EESP)

The LBNL Electrical Safety Program

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The LBNL Electrical Safety Program

1. Prevent electrical-related injuries

2. Implement proactive controls across the spectrum of expected hazards

3. Educate the lab population about electrical hazards

4. Promote a vibrant electrical safety culture

5. Demonstrate compliance to established standards

Objectives Scope

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Zero Electrical Injuries

Qualified Electrical Workers

Safe Equipment

Non-Electrical Workers

Safe Work Practices

Reenergizing the Lab Electrical Safety Culture“Safety is Elemental”

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Establishing an Effective Program

2005-2007: Initial Rollout

2007-2011: Compliance Driven Program

2011-Present: Transition to a Culture-Driven Program with Compliance as a Baseline

It’s a journey!

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SLAC Injury (2004)

10CFR851 (2006)

Compliance-Driven Program

• Recognizing the drawbacks:• Safety by compliance becomes an endlessly frustrating policing exercise• Build-up of conflict between EH&S and process users• Greatest frustration is felt by the Facilities Department, which is caught

between internal science customers and EH&S requirements

• Overall effectiveness is marginal:• Most high-risk incidents are prevented but many low risk violations

antagonize the users• Perception indicates that safety processes are overly difficult and do not

improve safety• Multitude of incidents cannot be corrected without addressing the culture,

which results in recurring incident investigations and more ineffective corrective actions

2007-2011

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Culture-Driven Program

• Starts with recognizing the limits of a compliance-driven program

• Reach out to the Lab population and eliminate the word “compliance” from the vocabulary (it’s still there, but in the background)

• Subject Matter Experts must be able to defend all requirements on their own merit and logic, supported with pertinent examples and best practices

• This includes the most basic questions such as:• “Why should I lock out? There’s already a lock!”• “Why should I test? It’s already turned off!”• Waving NFPA 70E around is a sure way to lose the argument

2011 – Present: Defining the future state

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Electrical Safety Sub Committee

• Expanded membership, reaching out to non-electrical worker community at LBNL

• Revised Charter: more proactive role in setting goals, developing workable policies, and promoting a vibrant electrical safety culture

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Electrical Equipment Hazards

• In the US between 2003 – 2007: • 1,213 people were killed by electrical accidents.• 13,150 people suffered lost time injuries from electrical accidents

• The 3rd leading category of electrical fatalities involved workers coming into contact with electric current from machines, tools, appliances, or light fixtures.

(Source: Brent C. Brenner, Occupational Electrical Injury and Fatality Trends and Statistics: 1992–2007, IAEI Magazine, May 5, 2009)

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Electrical Equipment Hazards

• Accidental electrocution due to contact with tools and apparatus whose grounding conductors were faulty … accounted for 18 percent of all electrical fatalities and 35 percent of nonfatal electrical accidents [in the period 2003-2007].

(Source: Brent C. Brenner, Occupational Electrical Injury and Fatality Trends and Statistics: 1992–2007, IAEI Magazine, May 5, 2009)

• FY2012: • 50% of all LBNL scientific division occurrences have been related to electrical

equipment (23% of total)

The Electrical Equipment Safety ProgramOverview of Basic Requirements

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Electrical Equipment Approval

Electrical equipment is “Approved” only if it is “Acceptable” to the Authority Having Jurisdiction (AHJ).

Electrical equipment is “Acceptable” only if either:1. It is Listed by a Nationally Recognized Testing Laboratory (NRTL)

• This includes UL, ETL, and others• OSHA NRTL program: http://www.osha.gov/dts/otpca/nrtl/index.html

OR2. It is inspected and/or tested and is found to meet applicable codes and

standards

All electrical equipment used at Berkeley Lab, or in the field by Berkeley Lab employees or affiliates, must be “Approved”

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Electrical Equipment Approval

• If available, Listed electrical equipment must be used and the inspection process does not apply.

• The EESP inspection process applies for equipment where no Listed product is available.

• If Listed equipment is modified or is used outside of its listing intent, it is also subject to the EESP inspection process.

All electrical equipment used at Berkeley Lab, or in the field by Berkeley Lab employees or affiliates, must be “Approved”

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AHJ DelegationsDOE

Aundra Richards

LBNL DirectorPaul Alivisatos

ENG DirectorKem Robinson

EESP Program Manager

Mark Scott

R&D Equipment & Apparatus

FAC DirectorJennifer Ridgeway

Electrical EngineerDoug Burkhardt

Facilities Distribution, Wiring and Equipment

EHSS DirectorJoe Dionne

Electrical Safety Officer

Mark Scott

Work Practices & Workplace Conditions

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EESP

The Inspection

1. Grounding

2. Enclosure

3. Overcurrent Protection

4. Cord Condition

5. Electrical Marking

The 5 Basic Inspection Points

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The Inspection

1. Grounding

2. Enclosure

3. Overcurrent Protection

4. Cord Condition

5. Electrical Marking

• Must be “effective”

• Usually tested with a ground bond tester

• Ensures that the circuit breaker will trip immediately if the casing becomes energized

The 5 Basic Inspection Points Grounding

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The Inspection

1. Grounding

2. Enclosure

3. Overcurrent Protection

4. Cord Condition

5. Electrical Marking

• All exposed energized parts must be covered, even during access for adjusting controls

• Casing strength and material type must be suitable for the environment

• Door interlocks to remove power

The 5 Basic Inspection Points Enclosure

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The Inspection

1. Grounding

2. Enclosure

3. Overcurrent Protection

4. Cord Condition

5. Electrical Marking

• Fusing or circuit breakers must be properly located and rated for the load current

• The neutral cannot be fused

• The phase conductor(s) must be fused

The 5 Basic Inspection Points Overcurrent Protection

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The Inspection

1. Grounding

2. Enclosure

3. Overcurrent Protection

4. Cord Condition

5. Electrical Marking

• Proper voltage and current rating

• Must be listed by an NRTL

• Cord cap must be appropriate for the amperage and application

• Not frayed or damaged

The 5 Basic Inspection Points Cord Condition

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The Inspection

1. Grounding

2. Enclosure

3. Overcurrent Protection

4. Cord Condition

5. Electrical Marking

• Power input must be marked with “nameplate” information:• Voltage, frequency, current,

power• Fuses must be labeled with

replacement types• Shock and arc warning• Multiple source warning• Stored energy warning• Special instructions

The 5 Basic Inspection Points Electrical Marking

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The Codes

• NFPA 790/NFPA 791 contain the basic requirements for administering the inspection program

• The proper primary standard must be selected based on the type of equipment:• NFPA 70: National Electrical Code• NFPA 79: Industrial Machinery• UL 508: Industrial Control Equipment• UL 508A: Industrial Control Panels• UL 61010-1: Laboratory Equipment• UL 60950-1: IT Equipment• Many others as applicable

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New vs Legacy Equipment

• New equipment is expected to meet the code in its entirety• Waivers may be granted by the AHJ depending on application and on a case

by case basis

• Legacy equipment is inspected to the 5 Basic Points, only major safety concerns are corrected to meet acceptance requirement

• Equipment intended for use in homes must meet “Code-Plus”:• Code must be met as closely as is allowed by the equipment type• Failure modes must be eliminated as much as possible to reduce risk of fire or

shock to ALARA (as low as reasonably achievable)

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The Electrical Equipment Safety ProgramCommon Issues

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CE Equipment

• CE Standards are very similar to US standards, and there is an ongoing process of alignment between the two

• CE certification is a manufacturer’s self-declaration of conformity, and is required for selling equipment in the European Union

• Most EU countries have additional national requirements, some also include 3rd-party verification

• NRTL Listing requires a 3rd-party verification of conformity to US standards

Does not meet Listing requirement

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Lack of Design

• Equipment built as a proof of concept must be converted to a safe assembly through proper design.

• Some items inspected can be corrected on the spot, but many lab-built items need complete re-design to incorporate code requirements

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The Electrical Equipment Safety ProgramRecent Process Changes & Improvements

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Benchmark – LBNL Compared to Other LabsNote: Benchmark by phone interview with AHJ at other labs

Lab Year Initiated

Number in inventory

Number inspected total/annual

Staffing for Inspection

LBNL 2008 27,000 14,000/1,500 1.5 FTEs, centralized

Sandia 2007 ~20,000 (recent audit indicates under estimate)

11,000/2,000 135 trained, decentralized

ORNL 2009 2,000Estimate 30,000

1,000/500 26 trained, decentralized

SLAC 2005 29,000 4,000/2,500 60 trained, decentralized

LLNL 2001 No central inventory – audit shows10% unlisted

26,000/700 2 FTEs centralized, 24 decentralized

BNL 2008 40,000 40,000/500 50 trained,decentralized

2008-2012 Performance

Per YearSurveyed Inspected Fail

12/31/08 1588 6 612/31/09 21,297 3407 14812/31/10 1832 4552 26612/31/11 1570 3976 322

4/18/12 762 951 46Total 27049 12892 788

Significant carryover of backlog from year to year

12/1/08

2/1/09

4/1/09

6/1/09

8/1/09

10/1/09

12/1/09

2/1/10

4/1/10

6/1/10

8/1/10

10/1/10

12/1/10

2/1/11

4/1/11

6/1/11

8/1/11

10/1/11

12/1/11

2/1/12

4/1/12

0

5000

10000

15000

20000

25000

30000

SurveyedInspectedFail

CumulativeSurveyed Inspected Fail

12/31/08 1588 6 612/31/09 22,885 3,413 15412/31/10 24,717 7,965 42012/31/11 26,287 11,941 742

4/18/12 27,049 12,892 788

Implemented Risk-Ranked Inspection ApproachSAC initiative with EHSS

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Risk Group

Description Uninspected

Low • 120 VAC CE or similarly marked • Any CSA• Identical to previously inspected

equipment• Reputable manufacturer

975

Medium ≥208 VAC CE or similarly marked 8,014

High Not listed above (eg. custom) 5,363

Total 14,352

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Inspected (10/1/2012) Uninspected (10/1/2012)

FY 2

013

FY 2

014

27%(as of 1/31/13)

Electrical Equipment Safety Program (EESP)

Inspection baseline and progress to date

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AHJ Acceptance Process

Acquisition•Procure only NRTL when possibleSurvey •All non-NRTL

equipment is entered into tracking database

Inspection•Surveyed equipment is risk-ranked and scheduled for inspection

Acceptance

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Acquisition

• Continue existing requirement that equipment must be NRTL approved or AHJ accepted before being put into operation.

• Procurement will build etools to help users purchase NRTL listed equipment (or confirm no listed equipment exits)

• Divisions will purchase listed equipment when possible

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Survey

• Each division is responsible for identifying/surveying all unlisted electrical equipment*

• Divisions to identify surveyors by November 1, 2012 and trained by December 15, 2012*

• Survey all division equipment before September 30, 2013

• On-going assurance through combination of EHSS and division programs

Survey looks for UL or other NRTLLabels

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Inspection

• The cost of inspections of all non-NRTL equipment identified by September 30, 2013 will be borne by the Electrical Equipment Safety Program (EESP)• Costs of repairs / alterations of electrical

equipment necessary to receive AHJ approval is borne by the division/program/project that owns the equipment

Inspection training at LBNL

LBNL sticker

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Acceptance

• Permanently increase baseline +0.5 FTE for expected annual influx

• Surge +2.5 FTE for 2 years to eliminate the current backlog

1. FY13: Target 5,300 items in high-risk category

2. FY14: Remaining 7,700 medium/low risk equipment

FY12 FY13FY14FY150

0.51

1.52

2.53

3.54

4.55

SurgeBaseline

Footer

The LBNL Electrical Safety Program

1. Prevent electrical-related injuries

2. Implement proactive controls across the spectrum of expected hazards

3. Educate the lab population about electrical hazards

4. Promote a vibrant electrical safety culture

5. Demonstrate compliance to established standards

Objectives Scope

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Zero Electrical Injuries

UNIVERSITY OFCALIFORNIAUNIVERSITY OFCALIFORNIA