Saving Lives by Following the Law and an Electrical Safety Program
OSHA requires employers to provide their employees with a working environment that is free from known and recognized hazards. That is the law and there is no getting around it. For the electrical world, in order to do this, an employer must develop an electrical safety program. This program becomes the blueprint for the procedures that employees must follow, and the safety measures that employers must put in place to protect employees from the hazards that electricity presents. But what goes into developing an electrical safety program? As we close out National Electrical Safety Month this week, we're addressing this question that has troubled employers since they first learned they need to have a safety program. Developing an electrical safety program that ensures nothing bad will ever happen is the top priority from most employers, however, it's difficult to know how every written procedure will work before putting it into practice and seeing how well it performs. So, where do we start? NFPA 70E, Standard for Electrical Safety in the Workplace, spells out what an electrical safety program must contain in section 110.1 in the 2018 edition. (And just a side note - the 2021 edition that will be released later this year will see this section shift to 110.5. This is essentially just a re-organization move as other requirements are moved to Article 110 from 130.) There is also information found in Annex E that is intended to help employers understand what goes into an electrical safety program. But regardless of where in the book this information resides, these are just the building blocks; how the program looks, feels, and gets developed is 100 percent up to the employer. The first thing I like to stress when I am in front of a class, like the Developing an Electrical Safety Program Workshop that we developed for the NFPA training department, is that the program must identify the principles on which it is based. Examples of electrical safety program principles can be found in Annex E. My personal favorite is to de-energize whenever and wherever possible. So many put such an emphasis in their programs around procedures and policies for working energized that they forget the most important thing: the safest way to work on electrical equipment is in an electrically safe work condition. An electrical safety program that makes an electrically safe work condition the number one priority is a requirement if an employer is following NFPA 70E. Other examples of electrical safety principles to develop a program around might be that all work will have some sort of pre-planning activity prior to commencing, or another principle could be to expect the unexpected. If it can go wrong, it probably will at some point. Once we have our guiding principles upon which our program will be based, we need to have a way to measure the success of what we have built. This is where the program controls come into play: What type of training will you provide your employees? How will you ensure that employees are indeed qualified persons for a given task or on a certain piece of equipment? How will an employee make sure that every necessary question has been asked and answered before they start the task? These are just a few examples of the controls that must be worked into an employer's program so that the program has the best chance of providing that workplace free from hazards to employees that OSHA requires. Last but certainly not least, after we have identified what our program is based on and how to ensure the success of our program, then we can get into to the details, or the actual procedures that employees will follow. The procedures will spell out the specific steps to ensuring employee safety. These will include items like the steps for establishing an electrically safe work condition, assessing the risk to the employee performing certain tasks, and the process for filling out an energized electrical work permit. There must also be a procedure laid out in the program that spells out how it will be determined what additional measures must be taken to protect employees when they must be exposed to a hazard. Keep in mind that even if a program is based on zero energized work being performed, even the process of establishing an electrically safe work condition can expose an employee to both shock and arc flash hazards. These hazards exist until the voltage has been verified that it has been removed and steps have been taken to ensure it can't be turned back on without the worker's knowledge. Whatever measures are taken, they must be determined in accordance with the hierarchy of risk control methods which emphasizes what priority must be given to each method of mitigating risks to employees. This hierarchy lists hazard elimination as the most effective method and personal protective equipment, or PPE, as the least effective method in protecting employees. Therefore, it should also make sense that an electrical safety program must make an established and verified electrically safe work condition a founding principle for which the program is based on. This is a lot to take in and can be a massive undertaking depending on the size and type of employer. For example, a “Big 3” auto maker's electrical safety program most likely took many months and many people to develop, whereas a coffee shop in the local strip mall might not require the same level of detail and procedures due to the nature of the work and the type of equipment involved. One employer might benefit from establishing an electrical safety committee that will handle the development, implementation, and auditing of the program. Others might have a committee of one. Each program is as unique as the employer who develops it. And since the electrical safety program is the document that protects an employer's most critical asset, an investment in time and money to establish, implement, and improve a program that is uniquely specific to an employer is worth every minute and every penny. So, if you or your employer does not have a program in place, it is time to stop everything and build one. Not only will it help save the lives of employees, but it is also the law. Interested to learn more? My colleague, Corey Hannahs, wrote recently about electrical safety programs and the knowledge, application, and responsibility that must be shared by both employees and employers. Find additional information about the standard by visiting the NFPA 70E webpage. As all of us continue to navigate the evolving situation with COVID-19, NFPA remains committed to supporting you with the resources you need to minimize risk and help prevent loss, injuries, and death from fire, electrical, and other hazards. For information on NFPA's response to the coronavirus, please visit our webpage.