In my visits to various commercial, industrial and health care facilities to present electrical safety practices training and other types of electrical systems technical training, I continue to shake-my-head at how many of those facilities do not have a functional Electrical Safety Program. The mindset I’m witnessing is facility employees don’t work on energized electrical equipment and/or they bring in outside contractors to complete such work on their electrical equipment. Those facilities do follow the Occupational Safety and Health Administration (OSHA) requirements to provide employees a place of employment free from recognized hazards that can cause or likely to cause death or serious harm. However, they do not fully understand that OSHA considers the process of de-energizing and verifying a zero energy state to be “live” electrical work, requiring the employee to be provided with appropriate training and personal protective equipment (PPE). With respect to workplace electrical safety OSHA has summarized that “any employer looking/wanting to comply with the general requirements for protecting employees from electrical hazards – look at the National Fire Protection Association (NFPA) standard for Electrical Safety in the Workplace; NFPA 70E.”
NFPA 70E-2015 edition, Article 110-General Requirements for Electrical Safety-Related Work Practices identifies the employer implement and document an overall Electrical Safety Program (ESP), a.k.a. The Plan. The ESP directs employee activity appropriate to the risks associated when working with or about electrical hazards. The ESP may be part of the overall facility Environmental Health and Safety Program or a standalone document used to outline employee activity appropriate to the risks associated with electrical hazards.
The ESP needs to include, but not be limited to, identifying safety-related work practices, elements involved with establishing an electrically safe work condition, verification of proper maintenance and installation, alerting techniques, procedures to follow by employees exposed to energized hazards, application of electrical PPE, Lockout and Tag-out (LOTO) practices, auditing requirements, and employee training to meet the overall program objectives.
Training is an OSHA mandate for all employees who face a risk associated with an electrical hazard not reduced to a safe level by applicable installation requirements. Training applies to all those affected by the electrical hazard. Two employee types are identified when working on or about electrical equipment, or electrical systems. A qualified person is one who has demonstrated skills and knowledge related to the construction and operation of electrical equipment and has received appropriate safety training to identify and avoid those hazards involved. An unqualified person also needs to be trained in, and be familiar with, any electrical safety-related practices necessary for their safety. Both the qualified and unqualified workers need to know their roles and limitations when establishing an electrically safe work environment as identified within the ESP. In addition, employee retraining in safety-related work practices and applicable changes in the NFPA 70E standard need to be at intervals not to exceed three years or sooner based on the facility requirements.
Electrical power distribution schemes today are often very complex. Distribution panel instrumentation, controls, protective devises, switching sequences and interlock systems demand that employees be trained and qualified at a high skill level. Safety requirements and operating procedures practiced when working on these systems are equally as complex, requiring employees be expertly trained in all safety practices and procedures. OSHA regulations require employers to document that employees have demonstrated proficiency in electrical tasks. Employers must certify that their employees are qualified and that certification is maintained for the duration of the employee’s employment.
Larry Lind is the Safety and Training Coordinator at Southwest Energy Systems. He is a National Fire Protection Association (NFPA) Certified Electrical Safety Compliance Professional (CESCP) and inactive ICBO/IAEI Electrical Inspector. Larry has 38+ years’ experience, including 24 years active military service, as a Prime Power Production Specialist operating, maintaining, testing, and designing medium voltage class mobile power generation and distribution equipment.