SAFETY SOLUTIONS: Compliance with 70E Electrical Standards

Are you in compliance with 70E electrical standards? This is the question being asked by OSHA compliance officers when they visit your facility. The Department of Labor (OSHA) estimates that there are, on average, 9,600 serious electrical shock and burn injuries each year. OSHA also estimates approximately one fatality per day due to electrocution.

The main reasons for employees being injured on the job is lack of a good safety program and training employees in the requirements of NFPA 70E. Another reason is employers have not conducted an arc flash analysis of their equipment and have failed to mark/placard their electrical systems accordingly.

Workers must be trained in what the labeling means and how to apply the information on the equipment. One of the first things OSHA does during a site inspection or an accident investigation is to review the training records for the company. Lack of training often is cited as a reason for large fines. Who needs training? Virtually everyone. Unqualified workers must be trained on the hazards of electricity and how to avoid them and qualified workers must meet the above requirements and other specific requirements given in 29 CFR 1910.332 and 29 CFR 1910.269.

Some companies that provide on-the-job training do a poor job of documenting that training. If you don’t document it, it never happened. Include the training date, the employee’s name and the topics covered, and have the attendee initial or sign saying he actually took the training.

What is 70E?

Parts of 70E have been around since 1979. NFPA 70E: Standard for Electrical Safety in the workplace is one of many industry consensus standards developed by the National Fire Protection Association (NFPA). The NFPA, an international nonprofit organization, develops voluntary codes and standards using an open consensus process. The Occupational Safety and Health Administration (OSHA) adopted new regulations on safe electrical work practices in 1990. However, 70E is a topic of interest now because the NEC and OSHA are referring to it in their documents, and citations are now being written based on 70E.

Remember, OSHA only allows work on live electrical parts under two special circumstances: (1) when continuity of service is required, and (2) when de-energizing equipment would create additional hazards. In all other cases, lockout/tagout is the law.

NFPA 70E provides specific information to help companies prevent or minimize exposure to all widely recognized electrical hazards. Safety practices, such as those recommended by NFPA 70E, help minimize employees’ risk of burns, blindness, electrocution, electric shock and associated falls. A decrease in employee injury and death rates can reduce workers’ compensation costs and help companies avoid noncompliance penalties.

Ten Steps to Success:

1. Develop a zero-tolerance policy toward energized work. Get serious about no “hot work.” Troubleshooting, infrared scans and the like are not considered to be energized “work,” nor is operating electrical equipment in a manner for which it was designed. However, this does not eliminate the need for conducting an electrical hazard analysis. Some tasks, such as racking circuit breakers, even though they don’t seem to have a hazard associated with them, actually do. Racking circuit breakers in and out of their cubicles involves making and breaking electrical connections (their stabs), which has the danger of arc flash. Therefore, some level of arc flash PPE is required when racking breakers.

2. Get out in the field or plant and see what your workers are doing. Develop checklists or other methods for tracking who is qualified to perform which tasks. Some companies have gone so far as to conduct job task analysis. While they can be somewhat expensive and time-consuming, they help provide a blueprint of your employees’ activities.

3. Train your employees. To be qualified to perform any task, they must know the construction, operation and hazards associated with certain types of equipment. Workers may be qualified to do certain tasks, but unqualified to do others. It is up to supervisors to know what employees can do safely.

4. Develop safe work practices and procedures. Energized electrical work permits, clearance procedures, switching orders, etc., are not called for in the regulations, but help document that the correct steps were taken. This can be especially important if there is an accident.

5. Perform periodic safety audits. If your workers know they will be subject to random safety audits, they will try to keep up with safe work practices and procedures.

6. Implement job briefings. If the job scope changes significantly, introducing new or different hazards than what were first anticipated, conduct another job briefing.

7. Be very careful how you implement any safety awards program. OSHA has issued numerous citations when they believe the awards program discourages accident reporting. Even if the program is designed in good faith, make certain it cannot be misconstrued.

8. Get up to speed on the regulations and the NFPA Standard 70E, as well as the IEEE 1584- 2002, Guide for Performing Arc Flash Hazard Calculations. What you don’t know could kill you.

9. Document, document, document, everything. If you don’t have it in writing, you never did it.

10. Show good faith effort. This is one thing OSHA really keys in on. If OSHA doesn’t think you’re serious or, worse yet, thinks you’re trying to put one over on them, watch out!

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