From 2015–2019, total installed solar energy capacity in the United States nearly tripled from 23.44 gigawatts (GW) to 62.3 GW. While this solar energy boom is a positive sign of the country’s transition to green energy, it requires increased understanding of the hazards associated with solar energy project construction. Many contractors must contend with the fact that construction workers may need to access energized areas within the solar arrays. Energized work plans and other required health and safety plans serve as a checks-and-balances system for worker accountability, ensuring safety can be achieved while working in energized work areas.
What plans are required?
Several types of site safety plans, procedures, and hazard assessments are either required or recommended for work on large-scale utility solar projects. Required plans include:
- Health and Safety Plan. Describes how a project will identify physical and health hazards that could harm workers, protocols to be taken for accident prevention, and the procedures to follow if an accident occurs.
- Lockout/Tagout (LOTO) Plan. Describes “the practices and procedures necessary to disable machinery or equipment to prevent hazardous energy release” while machinery or equipment is being serviced or maintained.
- Emergency Response Plan. Identifies potential emergency scenarios, as well as describes what steps will be taken to protect the safety of those at the facility and then stabilize the incident.
- Audit Plan. Establishes the parameters for the scope and schedule of safety audits. Safety audits identify gaps in safety management procedures, project site safety compliance and proactively identifies hazards before they become incidents and injuries.
Additionally, in a complex site arrangement or with a compressed schedule, owners and prime contractors may be required to send electrically affected workers into an energized area. Electrically affected workers are those workers that are required to enter energized work areas to complete tasks such as housekeeping, heavy equipment operation, or labor-specific tasks, but that do not meet the National Fire Protection Association’s (NFPA) definition of a qualified worker. In these cases, an energized work plan and permit are required.
What is an energized work plan?
An energized work plan is comprised of smaller sections that detail all aspects of safety related to working in energized areas and describe how workers will be protected from energized circuits. Many contractors aren’t aware that an energized work plan is required for solar project construction and that the plan must be written and signed off on by a qualified electrical worker in order to secure an Energized Work Permit. Energized work plan sections include:
- Job Hazard Analysis. Requires careful thought about the risks of the job/environment and documentation of procedures to deal with that risk.
- Shock Risk Assessment. Determination of the voltage level of the circuit being worked with to ensure use of the right tools and adequate personal protective equipment (PPE).
- Arc Flash Risk Assessment. Determination of PPE needed to protect against arc flash and the distance required for barriers.
- Restricted Area Control Plan. Outlines whose presence is necessary when working with electrified equipment and describes where physical barriers should be placed to ensure restricted access is maintained.
- Pre-Job Briefing. Ensures that the Person-in Charge (PIC) and potential workers understand the scope of the work to be performed by discussing the tasks involved.
What does a third-party audit of an energized work plan entail?
Once the electrical and commissioning phases of work are scheduled, soliciting a third-party audit can help ensure the plans and procedures laid out have considered all possible ways to control the energized area most cost effectively. Take for example an instance in which a contractor has agreed to the project owner’s plan to utilize a “red rope area control” for energized areas. If the contractor has not implemented this method of access control before, they may underestimate the cost of material and labor impacts, leading to expensive, inadequate access control. But, if the prime contractor recommends implementation of another effective form of access control they have past experience with, the project owner may not have the resources or time to review the contractor’s preferred method prior to project start.
In this case, a third-party auditor could review both proposed access control plans, employ their expertise on cost and timeline relative to effectiveness and safety, and provide a recommendation on the best course of action with the necessary resources to ensure all parties are comfortable with and fully understand the chosen method. A third-party audit is useful during all phases of work, but can be particularly valuable when high-risk activities are being scheduled, such as commissioning, energization, or electrical testing.
How can Dudek help?
Dudek’s environmental health and safety professionals have worked with numerous energy clients to review individual energized work plans and procedures while ensuring that the safety measures the project owner puts into place do not create a bottleneck in the schedule, introduce additional safety hazards, or diminish the return on investment in safety procedures. Our environmental health and safety team recently worked with a solar energy developer to audit their energized work plans and procedures, as well as implementation of those procedures on two project sites. After reviewing the prime contractor’s energized work plan and procedures, Dudek’s environmental health and safety experts identified gaps in the plans and work implementation. We then coordinated with the owner and contractor to close those gaps to ensure work in energized areas took place within the scope of safe work procedures.
Each project site is unique, so each energized work plan must also be unique to adequately protect electrically affected workers. Dudek’s experts provide site-specific recommendations that ensure a project’s budget and schedule are maintained while keeping the contractor compliant with site safety plans, federal and state regulations, as well as contractor agreements.
For more information, contact Environmental Health and Safety Lead Julie Stiglish. Ms. Stiglish has a master electrical license and 9 years’ experience in solar-specific safety, including photovoltaic lockout/tagout and battery energy storage systems safety. Her experience also includes lead incident management and root cause investigation performed on energized work hazards.