A Better Understanding of NFPA 70E: Job Safety Planning and Job Briefing
Before starting each job that involves exposure to electrical hazards, the employee in charge must complete a job safety plan and conduct a job briefing with the employees involved. That is the NFPA 70E®, Standard for Electrical Safety in the Workplace® requirement. It makes sense for the occasional need to justifiably expose an employee an electrical hazard but what about tasks that expose an employee to an electrical hazard daily? The short answer is yes; the requirement applies to those. The requirements apply just as written, the briefing and planning must be conducted before each job that exposes any employee to an electrical hazard. What if it is a multistory printing press that has several problems every day? The answer is still yes.
The primary method of protecting an employee from electrical hazards must be establishing an electrically safe work condition. Any exposure must be properly justified regardless of its nature. Documented procedures are necessary whether it is troubleshooting that exposes an employee to hazards or justified energized work that does. There is difference between troubleshooting and repair as I have pointed out many times. There are exclusions to requiring an energized work permit but that does not remove the need for a planning and briefing. How a facility’s electric safety program (ESP) is written plays a big part on how this is handled. A well written ESP should not allow any employee to decide on their own when or why they will be exposed to an electrical hazard. The ESP should not allow an employee to make up a work procedure on the fly or guess at the hazards or protective equipment (PPE) necessary to perform the task even if the task is perceived as routine.
If an employee is exposed daily to an electrical hazard because of the same issue it would be better to fix the problem rather than expose them to the hazard daily. Maybe the problem cannot be fixed because of the nature of the equipment’s use, but it might be possible to use the hierarchy of risk controls to reduce the hazard or risk while performing that daily task. Either way, each day you will find a way to justify exposing the employee to the hazard. A safety procedure and energized work permit could be written for that specific repetitive task. NFPA 70E does not prohibit such a permit but there are many safety issues that should be addressed before doing so. There may be no such thing as routine when it comes to electrical safety. For example, the need to enter an enclosure because of a thermal trip does not mean that the cause of the thermal trip is the same every time. A different hazard or risk could be lurking inside and, if the employee is not prepared for it, could lead to an injury. An energized work permit may not be required if the task is limited to troubleshooting. However, the documented procedure, proper protective equipment, planning and briefing must still be used. All of this is true whether it is a single recurring issue or tens of recurring issues.
Section 110.5(I)(1) covers the minimum requirements for the planning stage and one requirement is that it be documented. Any task must be planned in detail for there to be an effective job briefing. If the task is being conducted for the first time, work procedures must be developed before work begins. If the planning reveals shortcomings in the established ESP or work procedure, these must be addressed before the task is performed. The planning stage is when the specific hazards associated with the specific task are identified. It should be verified that necessary equipment will be available to perform the task. The job planning section does not address the energized work permit, but the permit could be used to gather the necessary information.
Section 110.5(I)(2) addresses the job briefing. This is when the employee in charge goes over the plan and discusses the energized work permit with the employee assigned to the task. The job briefing needs to be performed before the work tasks are started. However, it should not be performed so far ahead that the employees involved might forget what was covered. The briefing should include a discussion of the work procedure so that all parties fully understand the procedure. The briefing also gives employees the opportunity to express any concerns they have about the task, the procedure, their qualifications, or their safety. The employee should affirm that they will not deviate from the plan or task scope. They should also acknowledge that any deviation from the specific assigned task must be discussed before being implemented and modified in the work plan or procedure. It should be confirmed that the appropriate and necessary equipment and current procedures have been given to the employee. NFPA 70E does not require that the briefing be documented since the documented plan and work permit cover the issues discussed. As the employee in charge, I would add briefing notes to the documented plan especially if there were issues raised during the briefing. I would also have the employee sign the plan or permit as acknowledgement that the briefing was conducted.
The job briefing also serves a purpose to the employee in charge and the employer. The briefing is the time to verify that the energized work permit is properly authorized or that the task is limited to troubleshooting. The employee in charge is responsible for assuring the employee is qualified not only for the task on the specific equipment but they are the right employee for the assigned task. They should assess if the employee is impaired in some manner. They may have to apply for a new work permit before the task is started based on the briefing. They need to address any issues raised by the employee before permitting them to begin the task. They will be the point of contact if the assigned task evolves into something else.
There nothing prohibiting the employee in charge from being the employee assigned the task. It might seem excessive for them to establish a plan and hold a briefing for themselves. Their self-briefing allows them to verify that everything for their safety has been considered. It also gives them time to question their own qualification for the task and equipment. They should not be up to their elbows in energized equipment then realize that the work procedure has not been updated for new equipment that had recently replaced the old equipment.
This is all to protect an employee from becoming an injury or fatality. An employer should know who, when, why, and where an employee may need to be rescued after an incident. Every employee should know what is expected of them before they are put at risk of an injury. Any employee assigned energized work or exposed to electrical hazards is at risk of a potential injury even if they are wearing PPE. Skipping the required planning and job briefing may seem convenient until an employee is injured. An investigator might consider that nothing was done leading up to the injury without a record of a job safety planning and briefing regardless of the employer’s documented ESP.
Did you know that the first program in the NFPA 125th Conference Series, “Empowering Electrical Design, Installation and Safety,” is now available on demand? Get additional insights about electrical safety in the workplace and NFPA 70E through a series of engaging presentations from industry experts. Topics include a look at electrical shock injuries and the effect on both the mind and body, electrical incident data and the importance of safety training, electric shock hazards and the relationship to new technology, and how OSHA uses 70E. A special roundtable discussion also features questions and answers about staying safe on the job. Register today and earn CEU credits for participating. The program is available on demand through May 18, 2022.