Safety Program Development
Free OSHA required written safety programs ready to use today? Buying a generic electrical safety program template, using the find/replace function on another organizations electrical safety manual, downloading a free electrical safety program – you get what you pay for. When was that program put together? What edition of OSHA, CalOSHA, MSHA, NFPA 70E, or NEC was it created to comply with? Do you have equipment that isn’t addressed in it? Does it even apply to your industry? Are you a contractor? A safety program that doesn’t apply to your organization (and won’t be looked at twice by your employees) isn’t worth the paper it’s printed on. And it’s definitely not worth it to invest your time in something an OSHA inspector will see right through when you dust it off. Inspectors interview employees and watch your staff at work so if you don’t implement your safety program, it will be obvious.
OSHA established the mandate for an electrical safety program in 29 CFR 1910.333(a), which states, “Safety-related work practices shall be employed to prevent electric shock or other injuries resulting from either direct or indirect electrical contacts, when work is performed near or on equipment or circuits which are or may be energized. The specific safety-related work practices shall be consistent with the nature and extent of the associated electrical hazards.”
The OSHA Directorate of Compliance states, “If the employer does not de-energize then suitable safe work practices for the conditions under which the work is to be performed shall be included in the written procedure and strictly enforced.” Therefore, OSHA requires you to have an electrical safety program that addresses employee exposure to specific hazards that exist in your workplace. The program should establish minimum standards to prevent hazardous electrical exposures to personnel and ensure compliance with regulatory requirements applicable to your electrical systems.
NFPA 70E Article 110.7 specifically addresses safety programs by stating “The employer shall implement and document an overall electrical safety program that directs activity appropriate for the voltage, energy level, and circuit conditions.”
While the NESC doesn’t explicitly state that a written safety program is required, it is repeatedly implied. Section 420.A.1 states “Employees shall carefully read and study the safety rules, and may be called upon at any time to show their knowledge of the rules.”
The IEEE Yellow Book, Std. 902, Chapter 8 “Establishing an Electrical Safety Program”, states “an employer should develop and implement some form of an electrical safety program to give overall safety directions for facility activities related to electrical work.”
An electrical safety program is a necessity for every organization. But often, the development project is assigned to a safety expert, with little electrical knowledge or an electrical expert, with little safety knowledge. It takes a unique set of skills to put together an effective electrical safety program that considers the realities of electrical maintenance operations.
So where do you start?
NFPA 70E®, the “how-to” guide for OSHA compliance, outlines the fundamentals of an electrical safety program in 110.7.
Awareness and Self-Discipline
In order for a worker to avoid exposure to the hazards, they must be aware of the work environment. Your electrical safety program must address how it will increase employee awareness and self-discipline.
Electrical Safety Program Principles and Controls
Will your program be based on de-energized work only? Will a lockout/tagout program be enforced? How will employees choose the right tools and PPE for the job? Who’s “Qualified” for electrical work and who’s not? What’s documented and where does it go? Your electrical safety program is required to identify the principles upon which it is based and the controls by which it is measured and monitored.
Electrical Safety Program Procedures
All tasks in your facility that involve exposure to electrical hazards must have a specific procedure. Not just procedures for accomplishing the task, procedures for accomplishing the task safely.
Hazard/Risk Evaluation Procedure
Will employees use an energized work permit? The electrical safety program must have a procedure that can be used by employees to assess the hazards and risks associated with each task.
Job Briefings
Your expectations for job briefings must be clear. How often, how long, what topics? How will you make (and keep) them effective?
Electrical Safety Auditing
What’s your track record? Every electrical safety program must have an established periodic auditing process to ensure that it is effective.
Schedule a free consultation today to discuss your electrical safety compliance assessment.
AVO knows what to look for at your facility, the right questions to ask you and your staff, the current applicable standards and the most economical way to get you in compliance fast. Schedule a free consultation today to discuss your electrical safety program.