Welcome back to my 5-part blog series on Electrical Safety Plans. In this last post, I will cover required training, audits, definitions, references, revision history and approvals.
Part 1: Purpose, Scope and Responsibilities
Part 2: Requirements and Protective Measures
Part 3: Required Safe Work Practices
Part 4: Required Safe Work Practices Continued
The next section of your ESP will be training. Training is an important part of keeping your staff safe and plays an integral part in keeping your staff up to date on all aspects of their daily work. As management you need to create policies and establish your company’s electrical training program. Training may include classroom and on the job training, in my opinion a mix of both is required. Other things to consider are any company requirements for documentation of completion you may currently have in place. From a safety aspect the training you choose needs to cover a wide array of topics. Consider the following as a starting point.
- General Electrical Safety Facts
- Government Regulations & Standards
- Electrical Hazards & Protective Strategies
- Arc Flash
- Arc-Rated PPE
- Risk Assessment
- Safety Related Work Practices
- Recognizing Hazards & Poor Work Practices
As part of the process to deem individuals qualified you need to clearly define what requirements and skills they need to possess. As management you need to then train those folks to match the established requirements. Some skills that your qualified persons should have include the ability to identify energized parts and determine what the nominal voltage is. Your qualified folks should have a much broader understanding of the systems they work on. Similar to qualified persons, training needs to be established for task qualified persons as well. The training needs to focus on the exact tasks that they will be allowed to complete.
Auditing is the next component that should be included in your Electrical Safety Program. The program needs to be audited to review if it is still in compliance with OSHA and the latest edition of NFPA 70E. The plan should be reviewed at the very least every three years, this ensures that you can make adjustments as newer versions of 70E come out. It would be best practice to incorporate random spot audits annually to evaluate staff compliance and document legitimacy. It is important to make sure that the rules you lay out work, are the safest, and that your employees are following them. Audits come in many forms, but supervisory audits should be happening more frequently to help identify noncompliance in the field. Any issues that are found should be documented and any retraining that needs to occur should happen. Energy control procedure (LOTO) audits should be conducted by a qualified person and any gaps or inconsistencies should be addressed immediately.
From my past experience I have found that it is not be a bad idea to include general audit requirements that encompass an annual committee meeting. The point of this meeting will be to discuss the past years electric safety audit, address any findings, and make any appropriate changes that need to be made to increase safety. I have found that bringing a mixture of management and frontline workers into these groups help paint a larger picture of why things may or may not be working.
Closing out your document, a few sections to consider would first be a list of document specific definitions as well as including a list of references for referral. This information can be pulled out of the 70E document. Another section to include would be revision tracking to ensure that whoever is using the document has the most up-to-date version. Finally, the last component of your document should be a signed approval by someone in management. I would recommend the CEO or president of your organization. Getting someone at the top of your organization will likely lead to more stringent compliance enforcement and legitimacy.
This concludes the final part of my 5-part series on ESPs. Please take the time needed to create a well thought out and inclusive document. Remember that it isn’t a bad idea to involve some of the folks that do the work to be included when creating and auditing the document. I mentioned it earlier and I really stand by it, this document is the cornerstone of a safe work environment. It is your chance to address as many issues and scenarios to ensure that your staff is working as safe as possible. Remember that when it comes to recordable incidents caused by electricity, 1 in 10 is a fatality. In closing, I hope this fact reinforces the need for you to create, implement, and enforce an Electrical Safety Plan.
If you have any questions, please reach out to me and I will be happy to do whatever I can to make sure you and your staff are working safely. I can be reached at firstname.lastname@example.org or by calling us at (508)-821-9759. Stay Safe!
About the author
Jason Mazzola is the Director of Electrical Safety Services for Southern New England out of our Mansfield, MA office. He joined Hallam-ICS in 2019 and prior to that spent 10 years in utility industry in various engineering and leadership roles.
Hallam-ICS is an engineering and automation company that designs MEP systems for facilities and plants, engineers control and automation solutions, and ensures safety and regulatory compliance through arc flash studies, commissioning, and validation. Our offices are located in Massachusetts, Connecticut, New York, Vermont and North Carolina and our projects take us world-wide.