Working On or Near Exposed Energised Conductors Policy

Background

Workplace Health & Safety is a fundamental tenet of the electrical contracting industry.

Safety in the workplace is a priority for NECA, given the nature of the work carried out by electrical industry employees whilst working on the construction, maintenance or repair of homes and buildings.

The potential workplace dangers for workers within the industry include exposure to live electricity. The biggest dangers are shock, arc flashes and arc blasts, which can reach a temperature of 19,000°C – hotter than the surface of the sun. Over the past four years more than 2000 people have received electric shocks in NSW workplaces. Six were permanently disabled and five died.

The regulations on the prohibition of energised electrical work are stipulated in the NSW WHS Regulations 2011 and the code of practice Managing Electrical Risks in the Workplace.

Regulation 152, 157

A person conducting a business or undertaking carrying out electrical work must ensure the work is not carried out on energised electrical equipment unless:

• it is necessary in the interests of health and safety that the electrical work is carried out while the equipment is energised (e.g. it may be necessary for life-saving equipment to remain energised and operating while electrical work is carried out on the equipment), or
• it is necessary that the electrical equipment to be worked on is energised in order for the work to be carried out properly, or
• it is necessary for the purposes of testing to ensure the equipment is de-energised as required by regulation 155, or
• there is no reasonable alternative means of carrying out the work.

These requirements in relation to energised electrical work do not apply to work carried out by or on behalf of electricity supply authorities on the electrical equipment, including line-associated equipment, controlled or operated by the authority to transform, transmit or supply electricity. These authorities may be covered by separate electrical safety requirements.

Energised electrical work is generally prohibited unless one or more of the exceptions under the WHS Regulations applies and the work is carried out in accordance with the WHS Regulations. A situation where an electrical worker is considered working on or near exposed energised conductors or live conductive parts is when there is a reasonable possibility that the electrical worker’s body, or any conducting medium the electrical worker may be carrying or touching during the course of the work, may come closer to the exposed energised conductors or live conductive parts than 500 mm. Switching, isolating, removing fuses or links, isolation verification, testing and fault finding are daily tasks where licenced electricians find themselves working on or near exposed energised conductors. On rare occasion. ‘Live electrical work’ is also carried out where necessary and permitted by the regulation.

Requiring electrical work to be carried out while the equipment is energised when it could be avoided places an onerous responsibility on the business or undertaking commissioning the work to minimise the risks. Should an incident occur as a result of carrying out energised electrical work, the business or undertaking commissioning the work is at risk of being found not to have provided a safe workplace. This could contravene the primary duty of care under the WHS Act.

Key Issues and recommendations

Lack of competency of licenced electricians

Apprentices and trainees are not permitted under any circumstances to work on live equipment, other than fault finding, commissioning and testing. This results in a training gap and a lack of competency that is required to undertake work on or near exposed energised conductors once the apprentice moves on as a licensed tradesman and maybe be expected to work alone.

The WHS regulation stipulates that a competent person undertakes this work and a risk assessment is undertaken prior to this work. Apprentices are not allowed to be trained in this work but are expected to carry out this work once their training has ended with no additional training.

What this means, in reality, is that there needs to be some form of proof that the licenced electrician has been trained in the safe working procedures for working on or near exposed electrical conductors. Verbal instruction is not an effective method of training as it could be misunderstood and it lacks written proof of training evidence.

Therefore, NECA NSW advocates for additional competency based training to carry out these tasks are carried out as safely as possible and in compliance with the WHS Regulation. This competency based training would need nationally recognised units of competency to be developed by the industry with a prerequisite of certificate III in Electrotechnology.

NECA believes that the industry will benefit from ongoing safety related electrical training similar to that set up by the EWPA for elevated work platforms (EWP). The EWP Operator Training Program or ‘Yellow Card’ is the result of the EWPA helping the industry to comply with the Acts.

To address the training gap, NECA would like to develop its own Energised work safety program or ‘Red Card’ to help electricians comply with WHS Acts and regulation. The Red Card will be proof of completion in one or more modules in various types of energised work. Initially the card will have six different training modules.

The new modules will cover:

Smart meters

From the 1 December 2017, type 5 and 6 meters can no longer be installed and all new and replacement meters must be type 4 smart meters.  Any licensed electrician engaged by a metering provider will be able to install these type 4 smart meters, subject to any minimum safety requirements that may be mandated by the Government.

The Bill mandates that any person engaged to install smart meters must have undertaken appropriate training, including with respect to de-energisation and re-energisation of electrical installations.

The exact nature of this training will be determined prior to the implementation of the legislation.  In respect of this, NECA’s submission to the government included:

• A level of training equivalent to that undertaken by ASP Level 2s with respect to metering will be required for all licensed electricians engaged in the roll-out of smart meters; and
• That ASP 2s will automatically qualify to conduct installations (but as a subcontractor of a meter provider, not in a direct contractual relationship with a customer).

NECA is concerned with recent debate that will allow licenced electricians to undertake without completing any additional safety training for safe installation of direct-connected whole current electricity metering in NSW.

Metering work requires work that is considered work on or near exposed energised conductors as defined in the NSW WHS Regulation 2011. Work including testing prior to isolation, isolation, isolation verification and re-energisation. In addition to this, a number of dangerous situations can be found within the installation including:

• any exposure of live parts (except those exposed during the carrying out of work which can be reinstated at the completion of the work).
• incorrect polarity.
• risk of short circuiting.
• immediate risk of an ignition point.
• compromised earthing or neutral integrity through open (or risk of open) circuits.

NECA believes that it is imperative that proper training is carried out to reduce injuries and prevent fatalities with this planned roll out of smart meters. With the size and scope of the roll out, if this additional training is not made a priority, than it will be likely that fatalities will occur.

NECA strongly advocates for prohibition for smart meter installers without a level of training equivalent to or better than that undertaken by ASP Level 2s for:

• removing service fuse carriers that require specialist equipment, training, authorisation and qualifications where the installer does not meet the necessary requirements (for example barge board fuses).
•  working within the safe approach distances specified by a distributor to their overhead services and equipment.
• working on equipment mounted on or within distributor network equipment (for example: substations, poles and pillars).
• working on meter boxes on substation poles.

NECA further advocates prohibition for smart meter installers to change meters live in instances where no service fuse or service protection device is available or found inoperable or to install or upgrade service fuse carriers live. Should this be required isolation should be carried out by a level 2 service provider or Network Operator under the Electricity Supply Act.  The Level two service provider or network operator employee can then working under the requirements of his Authorisation determine by risk assessment the safest way  to install or maintain a Service Protection device or Service fuse Carrier for suitable isolation by the Smart meter Installer for the meter installation. The Authorised Level two service provider used can be the same person as the smart meter installer when available.

Clothing/uniform policy

NECA is committed to the health, safety and welfare of electrical workers and others that may be affected by our work.  This includes the protection of our workers from arc flash, harmful effects of outdoor elements and in other harsh environments.  Our objective is to minimise the potential for skin disorders, burns, and uniform ignition from arc flash, ageing, sunburn, windburn, heat stress and dehydration through effective risk management.

NECA recommends the minimum requirement for all site works will be as follows:

1. Must wear at  a minimum 155 gsm cotton clothing covering the full body (neck to wrist to ankle);
2. Be worn so that the body is covered from neck to wrist to ankle. Shirt, coat or jacket, and/or overalls shall be fastened at both the wrist and neck area;
3. Fabrics such as nylon and polyesters should not be used or brought to the workplace because they are prone to melting
4. Have non-metallic fasteners or have fasteners protected by a layer of the same material as that of the garment on both the top and undersides

Additional protective clothing should be worn by electrical workers if working on or near energised electrical equipment. This includes tasks such as fault-finding, supply verification and testing on low voltage equipment. The protective equipment shall be selected in accordance with a risk assessment and guidelines of Managing Electrical Risks in the Workplace Code of Practice, AS 4836:2011 section 9 (Safe Working on or Near Low Voltage Electrical Installation) and ENA NENS 09-2014 National Guideline for the Selection, Use and Maintenance of Personal Protective Equipment for Electrical Arc Hazards.

The minimum requirements for these electrical works set out in the above guidelines are as follows:

• Flame-retardant clothing covering the full body (neck to wrist to ankle) and not made from conductive material or containing metal threads. Preferably, use fabrics that are arc rated with a minimum Arc Thermal Performance Value (ATPV) of 4 cal/cm2.
• Flame resistant gloves as required
• Safety glasses or face shield with chin cup as required

Appropriate protection should be used when working in restricted work areas such as under floors and in ceiling spaces and unclean environments to protect against minor cuts and abrasions.

Ensure high visibility clothing is suitable for electrical work and wear it in traffic areas or when required by the site rules.

First Aid Policy

Providing immediate and effective first aid to workers or others who have been injured or become ill at the workplace may reduce the severity of the injury or illness and promote recovery. In some cases it could mean the difference between life and death.

The selection of First aid requirements will vary from one workplace to the next, depending on the nature of the work, the type of hazards, the workplace size and location, as well as the number of people at the workplace. These factors must be taken into account when deciding what first aid arrangements need to be provided.

Using a risk management approach to tailor first aid that suits the circumstances of your workplace, while also providing guidance on the number of first aid kits, their contents and the number of trained first aiders that are appropriate for some types of workplaces.

The risk management approach involves the following four steps:

• identifying hazards that could result in work-related injury or illness
• assessing the type, severity and likelihood of injuries and illness
• providing the appropriate first aid equipment, facilities and training
• reviewing your first aid requirements on a regular basis or as circumstances change

Additional precautions should be taken for electrical workers if working on or near energised electrical equipment. This includes tasks such as fault-finding, supply verification and testing on low voltage equipment. The protective equipment shall be selected in accordance with a risk assessment and guidelines of SafeWork NSW – First aid in the workplace – code of practice 2015.

A list of additional items that may be included in first aid kits used in the Electrotechnology industry include:

Automated external defibrillators

Providing an automated external defibrillator can reduce the risk of fatality from cardiac arrest and is a useful addition for workplaces where there is a risk of electrocution or where there are large numbers of members of the public.

Automated external defibrillators are designed to be used by trained or untrained persons. They should be located in an area that is clearly visible, accessible and not exposed to extreme temperatures. They should be clearly signed and maintained according to the manufacturer’s specifications.

NECA’s policy with respect to automated external defibrillator is that electrical workers should:

• Wherever possible, attempt to ascertain the location(s) of defibrillators whenever they commence working at a new premises; and
• Recommends that an automated external defibrillator is available for any work where there is a risk of electrocution
• Download the relevant mobile phone app(s) that allow NECA Members to quickly determine the locations of the closest defibrillators, and also contribute the locations of any of their own defibrillators to assist in case of emergency