Page 9 - Occupational Health & Safety - eDITION, August 2017
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ELECTRICAL SAFETY PROGRAM
DITION
The e-Hazard Safety CycleTM: ESP
If it is thorough, the ESP can essentially become your standard and can be more effective than using a standard program guide without interpretation.
ABY HUGH HOAGLAND
written electrical safety program (ESP) is a key part of the e-Hazard Safety CycleTM. 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 train- ing and enforcement of safe electrical practices; without one, training and auditing are hampered before you start.
For industrial sites, an electrical safety-re- lated 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 per- spective) than directly training to specific stan- dards. The standards are program guidance docu- ments 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 refer- ence can be more practical when company policy differs from the standards (for example, by al- lowing 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®, train- ing 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 ad- dressed 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 ad- equate for your training program.
An acceptable written electrical safety pro- gram will contain the following elements:
PURPOSE
RESPONSIBILITIES
■ Management
■ Employees
DEFINITIONS
HAZARD CONTROL
■ Engineering Controls (equipment
requirements or standards, etc.)
■ Administrative Controls (energized work
permits, equipment labeling, etc.)
■ Work Practice Controls
ELECTRICAL EQUIPMENT INSPECTIONS PERSONNEL AUDITS
EQUIPMENT REQUIREMENTS OR
STANDARDS
PERSONAL PROTECTIVE EQUIPMENT EMPLOYEE TRAINING & QUALIFICATION ■ Qualified Employees
■ Affected Employees
■ Unqualified Employees
REFERENCES (OSHA, ASTM, IEEE, NETA®,
NFPA, IEC, CSA, EN and other references that are used to build the document for future or fur- ther reference).
Many sites will also require the following: ■ Switching Orders
■ HV Testing and Grounding
■ Field Testing
■ Mobile Equipment
■ Operation and Maintenance requirements
of utilization equipment
So how does your ESP fit into the electrical
safety cycle?
Envision: Develop an ESP.
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 Elec- trical 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 CycleTM; throughout the cycle, you will keep im-
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