The Mission of Electrical Safety
Questions that often come up during a class on electrical safety are, “How do you apply NFPA 70E®: Standard for Electrical Safety in the Workplace?” or “What does OSHA require?”
Sometimes the answer is clear-cut and straightforward. Other times it is not, and sometimes the best answer doesn’t come from NFPA or OSHA. Sometimes a more practical approach to keeping workers out of harm’s way is better than trying to decipher what is written in the regulations. Some might call this approach more of a best practice or recommended practice. Regardless, the mission at the end of the day is to ensure that everyone working in the electrical industry goes home after a hard day’s work in the same condition they showed up: alive and uninjured!
This is the first of a blog series that will address many of the most commonly used strategies for keeping employees safe. We will explore what is required in regulations like OSHA and NFPA 70E® and how an electrical safety program can provide a better level of safety and lower the liability that employers face from workplace electrical injuries. So, let’s start there, with the electrical safety program, or ESP.
The Electrical Safety Program: Why is This Important?
At its very essence, the ESP is the foundation for a safe workplace relative to electrical hazards. Sure, OSHA states that employers must provide a workplace free from known hazards, and NFPA 70E® has a number of requirements for how to do just that. But it is the ESP that takes the rules and applies them to a specific workplace.
NFPA 70E® requires that an employer develop and implement an ESP. In the standard, we can find a number of required components of such a program. Section 110.5 requires that an ESP identify the principles on which it is based, the controls by which it will be measured for success, and the procedures that must be followed to achieve safety within the facility.
From a practical standpoint, it is the ESP that becomes the most important document there is for electrical safety in the workplace. The ESP can be the document that answers all the questions that come up during training. Use this program to define when and where approach boundaries exist. Lay out the type of tasks within the facility that require equipment to be placed in an electrically safe work condition.
Also, because this electrical safety program is under the control of the employer, it can be customized to fit within the environment that exists at each workplace. In fact, many very successful programs exist that do not follow the directives within regulations to the letter. These companies enjoy the benefits that come with providing safe workplaces.
The KISS Approach
One approach that seems to work very well is the KISS approach. Keep It Super Simple, or KISS, is a philosophy that many have adopted when developing an ESP. The thought behind this, and I personally am a big fan of this, is that the more complicated a policy is, the more likely it is that employees will find a way around it.
Say, for instance, that an employee will be working in close proximity to exposed energized parts. Often, we find employers asking how to develop a procedure so that employees know exactly where to place barricades when performing energized work. They have employees consult the shock approach tables in NFPA 70E®. If there are no labels on the equipment, the employee must also consult the PPE category tables to determine the arc flash boundary. Then they should establish the barricades at the greater of the two boundaries.
That is the way most of us were taught to do it, right? But what if there were a way to make that process simpler? Why not write in the ESP that barricades be set up at a much greater distance than the standard calls for? What if the employer marked on the floor exactly where the barricades must be placed for each piece of equipment? Or eliminate the need for a barricade altogether and have a second person able to warn off unqualified persons before they enter the hazardous area? The ESP can spell out any of the above and eliminate any guesswork on the part of the worker.
Keep the Process Simple!
Keeping the decision-making process as simple as possible can both help workers stay safe and lessen the liability an employer faces when employees make the wrong decision. Applying this approach will help us shift from what is in the rules to how we keep employees safe in a practical way. Having a practical understanding of how to implement a safety culture in our workplaces benefits us all.
Join me next time as I break down when and how we must place electrical equipment in an electrically safe work condition. Until then, take care and stay safe!