NFPA 70E says, “An electrical safety program shall identify the controls by which it is measured and monitored” [110.5(F)].
This traditionally meant employees would receive a barely comprehensible safety manual in all but the most forward-thinking companies. If their supervisor caught them doing something clearly unsafe, they would be written up.
Of course, the supervisor wasn’t familiar with that manual, so it was things like horseplay or not wearing safety glasses. An employee could skip hearing protection, lounge around energized equipment for no job-related reason (conducting bull sessions or eating lunch in the switchgear area wasn’t considered foolish), or commit 21 ladder safety violations and not get written up.
This “get caught by an unqualified person” control method isn’t the best way to control for safety. Fortunately, NFPA 70E, Annex E, provides eight examples of typical controls for companies where the concept has gotten proper attention from management and employees. These are paraphrased as follows:
- The employer develops the programs and procedures, then trains the employees, applying what they learned.
- Employees are trained to be qualified for the electrical environment they are working in.
- Employees and managers use procedures to identify electrical hazards and eliminate or control the risks.
- Every electrical conductor or circuit part is considered energized until proven otherwise. (This particular example has extensive implications for how work is performed. Take a few minutes to think about what those are).
- Deenergizing is considered a hazard in itself.
- Tasks to be performed within the limited approach boundary or flash boundary are identified and categorized.
- Management and employees identify and take the precautions needed for a given working environment.
- The associated risk of each task is determined with a logical approach.
These are just examples. But do you see how not among them is anything about being caught violating some rule? The emphasis is on empowering employees to identify hazards and protect themselves against those hazards.
Under this model, you don’t see employees snapping on their safety glasses when the supervisor is spotted coming their way. What you are more likely to see is an employee consulting with his or her supervisor on the best way to address an identified hazard.
How familiar are you with the controls of your electrical safety program? Do they make sense for the hazards you encounter or is something missing? How many years has it been since they were revised? Is your supervisor able to specify several of them from memory? Are you?
The controls are not something written down for posterity or to check off a box. They are meant to be integral to how you work. Take the time to understand them. If they are not adequate, then take the time to improve them.
