Mark Scott Henrik von der Lippe Bob Candelario

1. The LBNL Electrical Equipment Safety Program (EESP) Mark ScottHenrik von der LippeBob Candelario EETD Lunchtime Seminar February 21st, 2013

2. The LBNL Electrical Safety Program

3. The LBNL Electrical Safety Program Objectives Scope • Prevent electrical-related injuries • Implement proactive controls across the spectrum of expected hazards • Educate the lab population about electrical hazards • Promote a vibrant electrical safety culture • Demonstrate compliance to established standards

4. Reenergizing the Lab Electrical Safety Culture “Safety is Elemental”

5. Establishing an Effective Program It’s a journey! SLAC Injury (2004) 10CFR851 (2006)

6. Compliance-Driven Program 2007-2011 • 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

7. Culture-Driven Program 2011 – Present: Defining the future state • 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

8. 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

9. 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)

10. 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)

11. The Electrical Equipment Safety Program Overview of Basic Requirements

12. Electrical Equipment Approval All electrical equipment used at Berkeley Lab, or in the field by Berkeley Lab employees or affiliates, must be “Approved” Electrical equipment is “Approved” only if it is “Acceptable” to the Authority Having Jurisdiction (AHJ). Electrical equipment is “Acceptable” only if either: • 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 OR • It is inspected and/or tested and is found to meet applicable codes and standards

13. Electrical Equipment Approval All electrical equipment used at Berkeley Lab, or in the field by Berkeley Lab employees or affiliates, must be “Approved” • 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.

14. AHJ Delegations EESP

15. The Inspection The 5 Basic Inspection Points • Grounding • Enclosure • Overcurrent Protection • Cord Condition • Electrical Marking

16. The Inspection The 5 Basic Inspection Points Grounding • Grounding • Enclosure • Overcurrent Protection • Cord Condition • 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

17. The Inspection The 5 Basic Inspection Points Enclosure • Grounding • Enclosure • Overcurrent Protection • Cord Condition • 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

18. The Inspection The 5 Basic Inspection Points Overcurrent Protection • Grounding • Enclosure • Overcurrent Protection • Cord Condition • 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

19. The Inspection The 5 Basic Inspection Points Cord Condition • Grounding • Enclosure • Overcurrent Protection • Cord Condition • 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

20. The Inspection The 5 Basic Inspection Points Electrical Marking • Grounding • Enclosure • Overcurrent Protection • Cord Condition • 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

21. 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

22. 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)

23. The Electrical Equipment Safety Program Common Issues

24. CE Equipment Does not meet Listing requirement • 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

25. 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

28. The Electrical Equipment Safety Program Recent Process Changes & Improvements

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

30. 2008-2012 Performance Significant carryover of backlog from year to year

31. Implemented Risk-Ranked Inspection Approach SAC initiative with EHSS

32. Electrical Equipment Safety Program (EESP) Inspection baseline and progress to date Inspected (10/1/2012) Uninspected (10/1/2012) FY 2014 FY 2013 27% (as of 1/31/13)

33. AHJ Acceptance Process

34. 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

35. 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 NRTL Labels

36. 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

37. Footer Acceptance • Permanently increase baseline +0.5 FTE for expected annual influx • Surge +2.5 FTE for 2 years to eliminate the current backlog • FY13: Target 5,300 items in high-risk category • FY14: Remaining 7,700 medium/low risk equipment

38. The LBNL Electrical Safety Program Objectives Scope • Prevent electrical-related injuries • Implement proactive controls across the spectrum of expected hazards • Educate the lab population about electrical hazards • Promote a vibrant electrical safety culture • Demonstrate compliance to established standards

39. UNIVERSITY OF CALIFORNIA