A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program (Part 6 - Inspections)
NFPA 70E®, Standard for Electrical Safety in the Workplace® has requirements for what should be included in an electrical safety program (ESP) but does not provide details. The requirement in Section 110.5(B) to inspect electrical equipment is one where it is the employer’s responsibility to fill in the gaps. A properly documented ESP does not exist until that has been accomplished. The policies and procedures in your ESP are what employees must be trained to follow.
The ESP must address the inspection of newly installed or modified equipment. Does your ESP have a way to assign this responsibility? A newly hired, residential electrician may not be the appropriate inspector for a smelting facility. The local electrical inspector often does not inspect equipment that falls under NFPA 70E. Equipment is installed, maintained, repaired, and replaced by an employee or an outside contractor. The responsible person will need to not only determine that an installation meets the applicable manufacturer requirements but also those of applicable standards. This is not limited to electrical standards since things like improperly installed pressure systems in electrical equipment may affect safety. What are the ESP policies and procedures for these inspections?
An ESP that requires that equipment be verified as complying with the NEC is not enough. Electrical system and equipment compliance with the NEC is often only determined during building construction. The NEC does not address maintenance nor is internal electrical circuits part of the NEC. However, technicians maintaining motor control equipment must know the applicable NEC requirements. A contracted HVAC technician may be required to provide documentation that their work complies with applicable standards and codes, as well as the facilities requirements. Is their work inspected by a facility employee? Who is authorized to inspect repairs on custom production line equipment? It might not be desirable for the employee performing the work to also perform the inspection. The ESP must address not only these issues but also the training of the employee conducting inspections.
The ESP might permit some types of electrical work to be completed without additional inspection. Do employees know which specific equipment is permitted to be energized before or without the additional inspection? A contractor may not follow the same safety protocol. Perhaps, it is not the equipment but the task that directs an inspection before energization. The ESP must address how to document all of this and what is to happen with the results. A requirement for the inspector to evaluate alternate installation methods may provide a means to mitigate hazards or repeated exposures. However, this most likely will not happen without a statement to do so in the ESP.
Proper installation, repair, and modification of electrical equipment play a major role in protecting every employee from electrical hazards. Inspection to determine that fact is a requirement in NFPA 70E. NFPA 70E is a safe work practice standard that is not appropriate to be used as the procedure for equipment inspection. It is critical to train an employee on inspection policies and procedures contained in the documented ESP.