A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program (Part 4 – Lockout)
Does your electrical safety program (ESP) lockout program require that employees follow NFPA 70E®, Standard for Electrical Safety in the Workplace® Article 120? That ESP does not comply with NFPA 70E and employees are being improperly trained if it does. NFPA 70E requires that a lockout program be established and procedures to be developed. It provides requirements that must be addressed but does not provide a procedure for any specific equipment lockout. A lockout program in the ESP must comply with the minimum NFPA 70E requirements even if it refers to an employer’s lockout program.
NFPA 70E cannot detail the requirements referenced in Article 120. It is not typical for every employee to have the same experience or training. Does the documented procedure cater to the least experienced or a higher level? The lockout procedure must be applicable to the experience and training of the employee and the conditions in the workplace. It is probable that different lockout conditions are encountered at various locations in the workplace. A mechanical lockout procedure might be different than an electrical one. It is possible for a basic lockout procedure to be developed and a standardized procedure mitigates the potential for human error. A specific lockout procedure could be necessary for a given piece of equipment which in turn requires additional training. Equipment installed before the NEC requirement for a permanent locking means could require additional locking mechanisms which alter the basic procedure. The program must address the use of simple and complex lockout procedures.
An ESP could permit a contractor to use their own lockout procedure or contractors could be trained on the facility lockout program. Whose program will be followed and who is responsible for training employees affected by a different lockout procedure? If contractor procedures are permitted, an employee must be assigned to review those procedures to determine that safety standards of the facility are being met. Without a review, it is possible that the contractor does not have one, or that their program is less stringent than the facility’s lockout program. There could be situations when multiple contractors from various trades are affected further complicating the lockout procedure to be used and the training required.
Remember that the lockout process is only one necessary step in establishing an electrically safe work condition. A well-developed lockout program is not as simple as it appears. A generic lockout procedure could address most equipment. A detailed lockout procedure might be necessary to fill in the gaps when using it on specific equipment. Affected people might include facility employees as well as contract employees. Sections 110.5(M)(3) and (M)(4) require a documented annual audit of the lockout program and procedures including witnessing their use in the field. The ESP must address more issues than this blog points out. Make sure your lockout program and its procedures cover all the bases.
