A Better Understanding of NFPA 70E: The Employer's Responsibility
What are the primary NFPA 70E®, Standard for Electrical Safety in the Workplace® requirements for an employer? Section 105.3(A) narrows it to basically two. The first is that the employer establish, document, and implement safety-related work practices and procedures. The second is that the employer provide safety-related work practices and procedures training to employees. From the federal side, 1910.332(b)(1) states that employees must be trained in and familiar with the safety-related work practices that pertain to their respective job assignments. Before any of this starts the employer must be committed to improving electrical safety within their facility.
Overriding principles to protect employees must be established. Management must commit to protecting the employee by providing guidelines. Establishing an electrically safe work condition will be the primary safe work procedure. All electrical equipment will be inspected and maintained. All work tasks will be planned. Proper tools and equipment will be provided. Employee qualifications will be ensured. Electrical installations will comply with the National Electrical Code (NEC). All employee safety concerns will be addressed. These principles should be documented in order to form the basis for the safe work procedures.
order to establish safety-related practices and procedures, the employer must understand the electrical hazards and risks that employees face as part of their daily tasks. Do employees use portable tools? Does a security guard turn the production floor lights on at a panelboard? What voltages are present in the facility? Are contractors hired to work on electrical equipment? Do contractors engage in energized work? Do electricians install equipment, or do they also maintain it? Do employees open electrical equipment enclosures? Once it has been determined that employees are at risk, it is necessary to determine steps to protect them.
With an understanding of the tasks performed and risks faced, and by overlaying the safety principles, the employer can establish safe work procedures. Employee involvement in developing procedures typically increases the likelihood of the procedure being used. What are the steps necessary to safely operate Circuit Breaker #23 in Subpanel #8 to turn on the production floor lights? How does a cord-and-plug connected drill get inspected before use? What is the proper method of establishing an electrically safe work condition for Acme Company, Model 123 motor starter as it has been installed on Production Line #5? What about the starter on Production Line #1? What is the correct lockout procedure for a hydraulic press? What is the applicable testing protocol for insulated gloves? The procedures will be used as part of the required field audits. They should be detailed and controlled so that continued improvement can be implemented.
Once all this is documented, the practices and procedures must be implemented. Placing the documents into a file cabinet without this stage is a job poorly done. How will all this safety information be distributed? Who is responsible for making sure the proper information is given to those in need? How will training be implemented? Who oversees implementation of the safety program? How will revisions be incorporated?
Lastly, employees must be trained to follow the procedures. How will they be trained? Is there necessary prequalification? Who is qualified to train an employee for a specific task? Who verifies that they are qualified to perform the task? Does the ability to follow the procedure qualify an employee for the task? How will general safety training occur when a detailed procedure may not be necessary, such as how to properly unplug equipment from a receptacle? How does an employee recognize that it is safe to operate electrical equipment? How will a qualified person demonstrate the skills necessary for a task? How will the training be documented? How will the field audits address training or procedure deficiencies?
Safe work practices, policies, and procedures will be part of the larger electrical safety program. Electrical safety is not a static thing. Lessons learned through field audits and employee feedback should be evaluated to improve safety. Procedures should be reviewed for relevance and new ones developed when necessary. The goal is to minimize risk and work towards elimination of employee injuries.
Next time: An Employee's Responsibility.
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