A written electrical safety program (ESP) is a key part of the e-Hazard Safety Cycle™. Moreover, it is required by law. Yet even though OSHA requires them, ESPs are often missing from companies’ safety plans. A written ESP clarifies policy for training and enforcement of safe electrical practices; without one, training and auditing are hampered before you start.
For industrial sites, an electrical safety-related work practices program using OSHA 29 CFR 1910.331 – 335 and 399 is a minimum. If the industrial site has generation, transmission or distribution of electricity, it must also have a program complying with OSHA 1910.269. Many companies use NFPA 70E® and/or the NESC® to comply with the OSHA standards, but having a written program based on the documents is more cost effective and practical (from a copyright perspective) than directly training to specific standards. The standards are program-guidance documents rather than program documents. Many companies choose to train directly from NFPA 70E® due to its practical nature, but a written electrical safety program using ALL the standards (NFPA, NETA®, OSHA, and NESC®) for reference can be more practical when company policy differs from the standards (for example, by allowing exceptions, or by requiring MORE than any given standard). While it may take time to write the ESP, it is required. If it is thorough, the ESP can essentially become your standard and can be more effective than using a standard program guide without interpretation.
According to OSHA and NFPA 70E®, training must be provided to employees whose work might expose them to a risk of electrical shock while working on or near to exposed live parts or other electrical equipment. The content of the training shall include all work practices addressed in the standard. Also, written lockout/tagout procedures must be provided for work on the electrical systems. If all these elements are present in your ESP, that document could be adequate for your training program.
An acceptable written electrical safety program will contain the following elements:
- Hazard Control
- Engineering Controls (equipment requirements or standards, etc.)
- Administrative Controls (energized work permits, equipment labeling, etc.)
- Work Practice Controls
- Electrical Equipment Inspections
- Personnel Audits
- Equipment Requirements or Standards
- Personal Protective Equipment
- Employee Training & Qualification
- Qualified Employees
- Affected Employees
- Unqualified Employees
- References (OSHA, ASTM, IEEE, NETA®, NFPA, IEC, CSA, EN and other references which are used to build the document for future or further reference).