Page 34 - OHS, June 2021

TRAINING: ELECTRICAL SAFETY
Managing day-to-day operations of a facility requires having your finger on the pulse of everything going on in a single building or full medical campus.
“Live parts to which an employee may be exposed shall be deenergized before the employee works on or near them, unless the employer can demonstrate that deenergizing introduces additional or increased hazards or is infeasible due to equipment design or operational limitations.”
While some decisions that facility managers need to make lie within a gray area, this one is pretty black and white. If a manager is considering energized electrical work being done within their facility, they must: ensure that they can clearly demonstrate that by deenergizing, there would be an increased risk to the individual who is working on the system or show that it would be infeasible to deenergize based on equipment design or operational limitations. If either item cannot clearly be demonstrated, then continuing to allow energized work to be done on the system is, simply put, breaking the law.
What’s Next?
If we review the OSHA requirements and determine that we do indeed have justification to perform energized work, what are the next steps? Reading further into OSHA standard number 1910.333, section 1910.333(a)(2), it says that if the work is to be done energized, as determined after considering section 1910.333(a)(1), then “other safety-related work practices shall be used to protect employees who may be exposed to the electrical hazards involved.”
Section 1910.333(c)(2) further states that work on energized equipment shall only be done by qualified persons. Where in OSHA standards does it say what the safety-related work practices that we must utilize are when exposed to electrical hazards? It doesn’t. That is where a document such as NFPA 70E Standard for Electrical Safety in the Workplace comes into play. The purpose of NFPA 70E is to provide a practical safe working area for employees relative to the hazards arising from the use of electricity.
From a safety-related work practices standpoint, OSHA standards tell you what needs to be done and NFPA 70E tells you how it should be accomplished. OSHA standard number 1910.333 contents can be seen as a nearly mirror image within NFPA 70E section 110.4 dealing with energized work with both documents only allowing for energized work only where deenergizing would pose and increased risk or infeasibility. NFPA 70E section 110.5(H) provides a Risk Assessment Procedure as follows:
1. Identify hazards
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