A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program (Part 3 - Procedures)
NFPA 70E®, Standard for Electrical Safety in the Workplace® requires that an electrical safety program (ESP) be established and documented. Section 110.5(G) requires that electrical safety procedures be developed, and Annex E provides guidance on things to include in a detailed procedure. It is the employer’s responsibility to document procedures applicable to the tasks performed by employees and to train employees on using those procedures. Procedures are required to be in place before an employee conducts a task. NFPA 70E does not contain safety procedures that an employee can be trained to follow. An ESP that directs an employee to follow NFPA 70E, Section 120.5 as the procedure for establishing an electrically safe work condition (ESWC) in the specific workplace violates the 110.5(G) requirement. Section 120.5 is the process necessary for establishing an ESWC. It is not a proper procedure for doing so on any specific piece of equipment. However, Section 120.5 is a good start of what to include in the procedure. Conceivably, a detailed procedure should be developed for any task an employee may perform on equipment. Using the ESWC as an example, the requirement to determine all possible sources of electrical supply to the specific equipment is not a procedure for a piece of equipment. An employee should not be required to determine power sources each time they work on the equipment. The procedure for Motor Starter #4 should direct them to Subpanel #2 to open Circuit Breaker #15. The procedure should say wait 15 minutes after removal of power to allow stored energy to dissipate rather than need to determine how to release stored electrical energy each time. Section 120.5(6) indicates that it is not appropriate to be used as a procedure; “apply lockout/tagout devices in accordance with a documented and established procedure.” This is often a separate, detailed procedure rather than being part of the ESWC procedure. The remaining ESWC requirements need to be detailed for the specific equipment. Correct your ESP if it depends on employees using NFPA 70E as the documented procedure for establishing an ESWC or for any other task. Just documenting a procedure is not enough. It is beneficial to try out a new procedure on the equipment to identify missing steps, expose shortcomings, determine necessary tools, or reveal improvements before it is applied by an employee in the field. Once completed, employees must be trained to understand and use the procedure. Although the EMP must include regular auditing of a procedure (Sections 120.5(M)(2) and 120.5(M)3)), employees should be encouraged to suggest improvements to the procedure anytime they find the procedure lacking. The ESP principles that are used as the basis for procedures typically do not change. A procedure should not be as rigid. Increased electrical safety depends on continuous improvement throughout the entire ESP. Do not let your ESP become stagnant.