Question: The new requirement for the Job Safety Plan is that it needs to be documented. How long are we required to keep this documentation? For the duration of the job? Monthly?
Answer: NFPA 70E – 2018® requires that the Job Safety Plan (JSP) be documented.
In order to understand the duration of the documentation retention, it is important to firstly understand what a JSP actually consists of. The standard requires that the following information be present:
- Details of the scope of work and activities related to the scope,
- Details of the shock and arc flash hazard identification, risk assessment, and risk control measures,
- Associated Standard (Safety) Operating Procedures (SOPs)
In most industries, the SOP covers all of the above and is usually documented. In addition, gaps are addressed through the Energized Electrical Work Permit (EEWP). If this is the case, such procedures are retained for the life of the process. The arc flash engineering study will definitely cover item 2 on the list above. The study is valid for a five year period or until changes to the power system take place.
In certain cases, a JSP may have to be drafted due to the absence of a management procedure or SOP. In this case, requirements of the standard outside of section 110.1(I) must be considered. More specifically, section 110.2(5)(2) requires “on the job” training. Such documentation can serve as evidence of the company meeting these requirements. In cases such as these, documentation must be retained for the duration of the employee’s service or at minimum over a three cycle until new documentation can serve as evidence. It serves as a good indicator (and proof) of the employee’s understanding of electrical safety. As a long-shot, it can also prove useful in an incident investigation – investigations are now required as per 110.1(J).
Finally, if none of the above are applicable, then 110.1(K)(4) comes into effect and requires annual auditing of the Electrical Safety Program and its constituents. The documented JSP can be part of this audit, thus requiring retention for at least one year or until that audit cycle is met.