A written electrical safety program (ESP) is a key part of the e-Hazard Safety Cycle™. Moreover, it is required by law. Yet even though OSHA requires them, ESPs are often missing from companies’ safety plans. A written ESP clarifies policy for training and enforcement of safe electrical practices; without one, training and auditing are hampered before you start.
For industrial sites, an electrical safety-related work practices program using OSHA 29 CFR 1910.331 - 335 and 399 is a minimum. If the industrial site has generation, transmission or distribution of electricity, it must also have a program complying with OSHA 1910.269. Many companies use NFPA 70E® and/or the NESC® to comply with the OSHA standards, but having a written program based on the documents is more cost effective and practical (from a copyright perspective) than directly training to specific standards. The standards are program-guidance documents rather than program documents. Many companies choose to train directly from NFPA 70E® due to its practical nature, but a written electrical safety program using ALL the standards (NFPA, NETA®, OSHA, and NESC®) for reference can be more practical when company policy differs from the standards (for example, by allowing exceptions, or by requiring MORE than any given standard). While it may take time to write the ESP, it is required. If it is thorough, the ESP can essentially become your standard and can be more effective than using a standard program guide without interpretation.
According to OSHA and NFPA 70E®, training must be provided to employees whose work might expose them to a risk of electrical shock while working on or near to exposed live parts or other electrical equipment. The content of the training shall include all work practices addressed in the standard. Also, written lockout/tagout procedures must be provided for work on the electrical systems. If all these elements are present in your ESP, that document could be adequate for your training program.
So how does your ESP fit into the electrical safety cycle?
1. Designate a core team to develop the electrical safety program. This team should include representatives from management, the engineering and electrical trades, and the safety department.
2. Because the initial development of the written ESP can be difficult, e-Hazard provides templates with the “bones” of an ESP in our Electrical Safety Compliance Strategies Class. (This program has been used by several Fortune 500 companies and also by many companies with fewer than 50 employees.) Don’t get hung up on this process and put off purchasing PPE, training, equipment labeling or completing an arc flash study while trying to get your ESP perfect. That is why we have developed the e-Hazard Safety Cycle™; throughout the cycle, you will keep improving your ESP by adding and revising parts with best practices.
1. Engage the workforce in training and awareness, and launch the ESP. Consider involving both management and the labor workforce. Many incidents have been related to middle-level management overriding safety rules due to lack of a written program for employees to point to or a lack of awareness of the new program.
2. Be open to changing elements that receive pushback. However, stay firm on critical elements; you may need to consider educating everyone on “why we are doing this”.
1. NFPA 70E® requires an audit review of your electrical safety policies at a minimum of every three years. This helps ensure your ESP meets the current version of that document and the OSHA standards. Review is an important part of the e-Hazard Safety Cycle™ because it can quickly identify problem areas before you are out of compliance.
1. When there is a failure in the system presented in the form of a near miss incident, accident, internal or external audit, or change in a reference standard, this is an opportunity to REVISE.
2. Sometimes challenges in the written electrical safety program may be resolved internally. In other cases, OEMs and SMEs may be brought back into the program to resolve difficult issues.
To make this part of your electrical safety cycle, contact us for our written electrical safety program (ESP) consulting service or attend our Electrical Safety Program Compliance Strategies class. We can assist in helping you complete your written electrical safety program or by auditing your current program.