By Brian McFadden, Contributor
OSHA’s regulations are meant to keep workers safe. However, it takes a long time and a lot of effort to update regulations at the federal level, so those rules only describe a legal minimum—not best practices for safety. For more detailed and current guidelines, many organizations turn to respected industry standards, like NFPA 70E.
NFPA 70E includes a wide variety of detailed recommendations and processes for safe electrical work. When implemented effectively, those elements are all tied together into one complete system: an organization’s Electrical Safety Program, or ESP. NFPA 70E describes its requirements for Electrical Safety Programs in Article 110.5.
Programs, Policies, and Procedures
An ESP is a “program,” meaning that it’s a written plan for ongoing operations, identifying what needs to be done, who will do it, and how that work will be tracked or measured. The force behind a program comes from its driving “policies,” which are meaningful written commitments to general goals. Most programs will include a collection of “procedures,” which give detailed instructions for specific tasks. Policies, programs, and procedures all tie together to help an organization achieve its goals.
Often, one program will refer to another. For example, Lockout/Tagout (LO/TO) is one of the most important ways to protect workers from electrical hazards; the NFPA standard calls for an ESP to either include a complete LO/TO Program, or refer to a separate LO/TO Program, whichever is more appropriate for the organization.
Some organizations use an overall Occupational Safety and Health (OSH) Program to organize all their safety-related programs under a single umbrella. In these cases, the ESP will fit into that overall OSH Program.
An effective ESP needs to explicitly call out its driving policies. To meet NFPA requirements, it must specifically include the organization’s Electrically Safe Work Condition Policy.
The greatest plan in the world won’t mean a thing if nobody follows it. A good ESP needs to include a way to ensure appropriate training for workers, so they have the awareness and self-discipline needed to perform their work safely. Overall requirements for electrical training are given in Article 110.6 of the NFPA 70E standard.
Many workers will already have the general knowledge and expertise needed for their jobs, but specific information may still need to be provided by the employer, and the employer has the ultimate responsibility for providing safety training. Document any training that has been completed, along with what was covered and when it was done.
One of the most important parts of an ESP is the specific process that will be used to identify hazards, assess the risks involved with those hazards, and implement controls (using the Hierarchy of Hazard Controls) to mitigate those risks. This process should be written down and included in the ESP as the Risk Assessment Procedure. Controls can include a variety of methods for protecting workers, such as remote shutoff equipment to separate a worker from a hazard, or arc flash warning labels to provide detailed information at the point of need.
Two specific kinds of Risk Assessments get special attention in NFPA 70E: Shock Risk Assessments (described in Article 130.4) and Arc Flash Risk Assessments (described in Article 130.5). These detailed approaches are important, but focus only on specific hazards. Electrical work can also expose workers to other hazards, such as cuts or crushing from moving parts; the overall risk assessment process needs to consider these possibilities.
Procedures for Safe Work
When procedures are established for specific work tasks, those Standard Operating Procedures (SOPs) should be included in the ESP. Each SOP should identify the task and its hazards, the qualifications needed to carry out the work, the tools and protective equipment to be used, and the steps to be followed.
The ESP must also include the process to be used for creating new SOPs—that is, the process of Job Safety Planning. This process will include risk assessments and decisions on appropriate procedures and protections, and it must be done by a qualified person. The end results will include a written document that includes a description of the job, the results of its risk assessments, and the work procedures and controls that will be used: the foundation of a new SOP.
The ESP must call for a Job Safety Briefing before work begins. These briefings ensure that each affected worker has the information from the Job Safety Planning process. Workers need to understand the plan and have a chance to raise any concerns.
When equipment is installed or modified, an inspection is often called for to ensure code compliance or correct implementation before the equipment is used. The ESP needs to include a way to verify those inspections. Records of inspections do not need to be included in the ESP itself, but the program should identify where the records are kept.
After installation, the ESP will need to consider the condition of maintenance for each piece of equipment. Because ongoing maintenance is so important and so often overlooked, it may be a good idea to collect the specific maintenance requirements for each piece of equipment, as well as records of maintenance done, in a single location. If your organization does this, identify where this information is kept as part of the ESP.
Investigations and Audits
As time passes, the ESP needs to be able to respond to events and changes in the work. For example, a good ESP must include a system for investigating any incident that resulted in an injury (or could have resulted in one). Due to the nature of electrical work, any “near-miss” is effectively a near-fatality, so it’s critical to pay attention to these events. Investigations may uncover weak spots or omissions in the ESP. Some organizations already have near-miss reporting programs in place, and the ESP may refer to those programs.
The ESP also needs to be periodically reviewed, even when everything seems to be working as intended. Audits should be performed on:
- the ESP itself, at least once every three years;
- work done according to procedures, at least once each year; and
- the LO/TO Program and each of its elements, at least once each year.
These audits are not meant to catch and punish violations, but to verify that the ESP is doing its job. To help make these audits meaningful, the ESP should identify specific and quantifiable metrics that will be used to check its overall performance. Some possible metrics are year-to-year increases in near-miss reporting, or decreases in actual injuries. The goal of an ESP is to improve worker safety, and a well-planned and executed ESP can make a huge difference.
Brian McFadden is a Compliance Specialist and Technical Writer for Graphic Products, the makers of the DuraLabel line of industrial label and sign printers (www.GraphicProducts.com).