Complex rules from OSHA and NFPA 70E have to be incorporated into even more complex workplace roles and responsibilities (job descriptions). The aim of this short article is to simplify these requirements in an easy-to-digest manner. This is aimed at persons new to electrical safety.
More specifically, look at 1910 Subpart S – Electrical. These rules focus on industrial (stamping, vehicle manufacturing, airports, food processing, packaging, general manufacturing, hospitals, etc.) and light commercial operations (administration buildings, warehouses, hotels, entertainment areas, etc.). Utilities and residential are largely excluded from the rule set.
Before delving into training, take a step back and think about the following:
Anyone who may interact with energized electrical equipment (e.g., switching a disconnect or breaker, performing maintenance work close to energized parts, troubleshooting, testing, installing, decommissioning, measuring, etc.).
OSHA 1910.332(c) provides a list of who should be trained. We recommend that you start with electrical engineers, electricians, electrical technicians, then move onto training maintenance, operations. Don’t forget management. If getting started or budgeting is a problem, or if support is lacking, try reading up on “Get the Boss on Board”.
Training should be performed once every three years in order to align with the major changes in NFPA 70E. Annual refresher training and the on-the-job coaching should supplement the three yearly cycles.
OSHA uses the language “close enough to energized parts”. This means that the risk of injury is influenced by proximity.
OSHA does not allow unprotected workers to be closer than one foot (12 inches) from an energized part at low voltage (< 600V). NFPA 70E states that the risk of shock is still present at 3’6” (42 inches) and that the risk of burn injury should be quantified and could be (and in certain cases will be) greater than 42”.
Training varies based on risk exposure. Electrical engineers, electrical technicians, and electricians have the highest exposure rates. Their training should be a comprehensive NFPA 70E class that covers the relevant parts of OSHA (1910 Subpart S for work practices and 1910 Subpart I for Personal Protective Equipment).
Operators and mechanics will require a basic class that makes the workers aware of their responsibilities and safety limits (i.e., tasks they are allowed to perform and tasks that are prohibited). They should also understand the hazards and be able to interpret the safety signs and warnings.
OSHA may issue citations or possibly close down operations until safety concerns are addressed. Training the workforce shows the employer’s commitment to the workers’ success. Finally, safety risks transcend worker injury and can easily spill into business risk due to reputation (brand) damage and insurance premium adjustments.
To take advantage of a great resource based on the Plan, Do, Check, Act model (Deming model, Ishikawa examples), refer to the e-Hazard Safety Cycle™.
Training is by far the quickest return on investment since it is cheap, requires little time away from work, and most importantly, provides all the information required to make the next big decisions. Students leave with an idea of what PPE they would need for shock protection and arc flash.
The second stage should be an estimation of the arc flash incident energy (arc flash engineering study). This will quantify the need for higher rated arc protection and provide labels on equipment so that workers can easily identify high energy (higher risk) types of equipment.
Establish work practices by developing a Written Electrical Safety Program. Hugh Hoagland provides a guideline on the typical contents of a written program. Read Electrical Safety Program by Hugh Hoagland.
After a defined period, typically after the roll out of PPE and appointment of qualified persons, perform a high level electrical safety audit. This may be performed in-house, or you can partner with an expert. We generally recommend that companies self-audit different areas and involve our team once every three to six years to provide the third party audit.
More information can be found on our website at the e-Hazard Learning Center.
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