A Better Understanding of NFPA 70E: Why appointing an authority having jurisdiction (AHJ) can be a challenging task
NFPA 70E®, Standard for Electrical Safety in the Workplace® is a safe work practice standard. So, although electrical installation (National Electrical Code®) and maintenance (NFPA 70B) play a role, the procedures necessary to do either are not within the NFPA 70E scope. The required electrical safety program should cover them as well as the NFPA 70E requirements. What users need to know is the authority having jurisdiction (AHJ) for electrical safety, although NFPA 70E has been around for fifty years. NFPA 70E, in a nutshell, requires that an employer protect employees from electrical hazards regardless of the task they are performing. Consider why a standard would tell you that an AHJ should be the CEO, safety officer, human resource person, or department manager? They may not be qualified at your facility so why would a standard assign them as an AHJ? Do you want a standard to require that electrical inspections be conducted by a minimum 15-year master electrician with at least 25 years of experience installing and maintaining the specific equipment to be inspected? It is probable that no one at your facility has those qualifications. You have the safety requirements in the standard. So, what does it take for someone to know what they are enforcing?
Common sense helps when assigning an AHJ for determining compliance with NFPA 70E requirements. An employee could be injured if you do not. Ask yourself, should the AHJ responsible for written procedures have used the procedures and operated the equipment covered by the procedure? Should the AHJ responsible for inspecting an in-house electrical installation know the NEC and manufacturer’s requirements for that type of installation? Can an employee be ‘the AHJ’ for their own work? Should the AHJ for a lockout program not only know the requirements but know what type of equipment requires lockout? Should the AHJ responsible for field audits know the procedures an employee should be following? Does one person at your facility have all this knowledge? You get the point. Do you permit unqualified employees to run the human resource department, act as CEO, handle finances, or design new products? Did a standard tell you who was qualified and what qualifications were necessary for those positions? You have assigned qualified employees to perform many tasks within your facility, the same applies for qualified electrical safety AHJs.
I am often asked who should be considered an AHJ and what qualifications they should have. I believe the AHJ should be whoever you determine is qualified to fill that role. Their title does not matter. The person may be more important than the job position when looking for an AHJ. As many of my blogs point out, assigning an individual AHJ for all the requirements in NFPA 70E will often be a mistake. Their qualifications should be whatever you deem necessary. Consider this: do you want an “official AHJ” to inspect your in-house electrical installations? Then you should invite the local electrical inspector (legislated AHJ) to do inspections before you power up installed equipment. Does it take an electrical engineer to determine the compliance for what you ask? Then they should be an electrical engineer. Will only a master electrician be able to determine if an employee is following the documented safe work practices? Then they should be a master electrician. If no one is qualified to inspect personal protective equipment (PPE), you need to determine what would make someone qualified before assigning the job.
The legislated electrical inspector plays a major role in complying with the NEC. The appointed AHJ for other standards, such as NFPA 70E, is just as important. In the end, however, a trusted, competent person must oversee each requirement. Remember that when you assign any AHJ.
Next time: The 2024 edition of NFPA 70E, Standard for Electrical Safety in the Workplace.
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