A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program (Part 12 – Program Controls)
NFPA 70E®, Standard for Electrical Safety in the Workplace® Section 110.5(M)(1) requires auditing of your electrical safety program (ESP) to determine if the ESP continues to comply with current NFPA 70E requirements. Section 110.5(F) requires that the ESP identify the controls by which it is measured and monitored. Electrically safety in the workplace will stagnate without this step where improvements for safety are implemented.
Controls are the electrical safety metrics for determining if an ESP is effective and efficient. To evaluate a system, you need to know where you started and how far you have come. Controls must be both measurable and actionable. Metrics are measurable points to determine performance. They are used to determine if improvements to the safety program are required and, if so, what needs to be changed. NFPA 70E requires controls but it is the documented ESP that details what they are and how they are used. It is necessary to identify who is responsible for analyzing the data and incorporating necessary changes.
There are two common metrics used to determine the effectiveness of something: lagging and leading. Lagging metrics provide a reactive view of an ESP. Lagging metrics might include the time lost to injuries, the money spent on worker compensation, or the amount of training an employee has received. Under this metric, an injury occurs, and the ESP is changed to address it. A shock is reported, and a change is made. Leading metrics identify and correct contributing factors before an incident occurs. Leading metrics might include the number of hazards identified and eliminated, the reduction in the number of authorized energized work permits, or the number of work procedures altered for de-energized work. Under this metric, a decrease in electricity injuries might be evident after hazard elimination was instituted or after every employee had been trained on the proper use of with extension cords. A combination of these metrics can enhance a safe work program. The next step is determining where further improvements could be made to the system.
The ESP must detail what controls are implemented, how they are evaluated, how data is collected, how changes are incorporated, and who is responsible for maintaining the control system. The process should address how much change may occur at one time. Incremental steps are easier to monitor than whole scale changes. If the system heads in the wrong direction it is easier to correct its course, then try something else. Make sure that your ESP has appropriate controls to keep electrical safety progressing in your workplace.
This concludes the 12-part series on an ESP. NFPA 70E requirements cannot be used as appropriate procedures or for training for any specific task. A well-developed ESP is critical to achieving electrical safety in the workplace as well as for complying with NFPA 70E and OSHA regulations. Without it there are no policies and procedures available for employee training and there can be no qualified persons without proper training. Review your ESP to make sure all requirements and safety issues are properly addressed.