NECA Director of Safety Explains How to Create an Electrical Safety Policy

Happy Electrical Safety Month, from everyone at the National Electrical Contractors Association (NECA)!

If you’re reading this, there’s a good chance you work in the electrical sector. There’s an even better chance you have questions about safety, or compliance to safety codes.

Electrical safety is definitely something we all need to think about more than once per year. It needs to be in every task we carry out, every single day. Because when we forget about electrical safety, even for a moment, preventable incidents can (and will) happen.

For example, NECA recently took part in a webinar with Brandon Schroeder, owner of Believe in Safety, sponsored by eCompliance. Brandon is an arc flash survivor whose life changed forever in the blink of an eye. He shared his story about how taking a single shortcut can have dire consequences. We encourage you to read his story here.

In my half of the webinar, I walked participants through how to build a safe and compliant workplace in the electrical sector, and that’s what we will be covering here.

How to Build Your Company’s Policy

We really need to understand what the compliance requirements are, and how to provide the guidelines for a safe working environment for our employees. One of the things we need to do is also effectively communicate these policies to our employees and to our potential customers.

Why do we need to do this? Because your policy expresses your company’s commitment towards the rules of safety. If you’re going to develop a policy, it must be written, so it can be clearly understood by those reading it.

In addition to the policies, it’s a good idea to develop best practices for working around doing some of the tasks we commonly do in the electrical industry.

Who is Responsible?

We know employers have responsibilities to the employee. They’re the ones creating the safety programs and policies needed to be implemented.

At the same time, employees have a responsibility to themselves and they should be aware of the risks they are exposing themselves and their coworkers to. These employees also have a responsibility to their families, so they can come home safely every night.

They are expected to know what the safety rules are for the company and have a responsibility to their employers and the organization to follow those rules.

OSHA, NFPA 70E and Electrical Safety

We know the OSHA act says employers must provide employees with a workplace that is free from recognized hazards that are causing (or likely to cause) death or physical harm. The employer shall also comply with occupational safety and health standards promulgated under this Act.

On the employee side, OSHA Act 5 (b) states employees shall comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to this Act which are applicable to his own actions and conduct.

If we look at NFPA 70E as a consensus document, in the 2018 addition (105.3[a]) this new text requires safety-related work practices and procedures required by this standard to be established, documented and implemented by the employer. In addition, the employer shall provide training in safety-related work practices and procedures for employees.

Developing Effective Policies

Policies are clear and simple statements about your company’s services, your actions, and your business. A policy will reflect your values and the approaches and commitment to safety from the management and the owners.

Policies also help to create that safety culture, which is incredibly important to ensure everyone remains safe on the job. If you’re going to develop an effective policy, you need to start by first including key stakeholders; people in management positions, as well as your employees and your customers.

A great place to start is by organizing brainstorming sessions, so people can actually interact, and you can get everybody’s buy-in from the start.

You can identify some of the policies your company will need by looking at the various templates available. You could also look at some organizations who may be doing similar work. You will need to develop an overarching policy, as well as specific ones, as needed, as you identify and include unique elements of your company.

NFPA 70E Company Policy

Let’s take a look at an overall NFPA 70E company policy.

The purpose is to ensure management and employees perform electrical work in a safe, healthful and productive manner. It can also identify and clarify the requirements and expectations for electrical work to be performed in accordance with the current edition of NFPA 70E.

The description this policy includes is: All electrical work shall be performed by qualified persons in accordance with company policies and procedures.

The company intends to follow all the applicable requirements found in the OSHA regulations, all the applicable requirements found in consensus standards such as NFPA 703, and use the best practices identified within the electrical industry.

All persons performing in energized electrical work need to be provided with:

• The initial training they require
• Evaluations to determine competency
• Proper PPE
• Any other required training to successfully complete their task, including any specialized or refresher training

The company will also be responsible to determine who is qualified to perform justified energized work.

The Employee’s Role and Responsibility

Employees will abide by all the rules and regulations created and provided for their protection. They will also be familiar with all safe work practices, take responsibility for their own actions, strive to keep the workplace free of any additional hazards, and of course, wear the proper PPE.

The other thing they are required to do (according to NFPA 70E) is to communicate any additional hazards they may have encountered on the job. We know the situation may change at any time.

Qualified Person Policy

According to the definition, a qualified person is trained in the construction and operation of equipment or specific work method. They will also be trained to recognize and avoid electrical hazards that might be present with respect to a specific piece of equipment, or the work they’re doing.

Additionally, they must be familiar with the special precautionary techniques, PPE (including arc flash gear), insulating and shielding materials, insulated tools, and other equipment they might be using for their job.

They may need to be trained in the following:

• The skills necessary to distinguish exposed energized parts
• The skills and techniques necessary to determine the nominal voltage exposed to live parts
• Figuring out the approach distance, as determined by NFPA 70E, according to arc flash incident energy and the shock risk assessment
• Knowing the decision-making process to determine the degree and extent of the hazard, the PPE, and what job planning is necessary to perform their job safely

An Energized Electrical Work Policy

This policy needs to prohibit any energized electrical work, unless it is justified and signed off by all responsible parties in accordance with the policy.

All energized work on systems of 50 V or more must be justified in accordance with NFPA 70E and OSHA requirements as follows:

• Deenergizing will cause increased or additional hazards
• Or, deenergizing isn’t feasible because of the equipment design or operational limits

All energized electrical work on systems of 50 V or more requires an energized electrical work permit, signed off by all the responsible parties. It’s important everybody from the electrician to the company is authorizing the energized work to be performed.

Teams need to complete job safety meetings or briefings prior to all the work to ensure everybody is familiar with the work being done.

The capacity of the source should also be considered. There are some sources (especially now with photovoltaic) that can have 48 V DC, but you can have a large capacity. So, teams need to look at that individually.

Establishing an Electrically Safe Working Condition Lockout/Tagout Policy

Your lockout/tagout shall be performed as part of the company’s procedures to ensure a safe work condition is established. For additional examples of lockout tagout activities, we encourage you to read NFPA 70E for additional activities that could cause arc flash hazards.

Your policy needs to provide a safe procedure for deenergizing circuits and equipment, while ensuring an electrically safe working condition during a lockout/tagout procedure.

The Real Impact of Strong Policies

Policies and best practices really help to define a company’s safety program. If you’re going to build policies and best practices, use the people who are familiar with the task and the people who are familiar with the control methods. Develop these practices carefully to make sure approval comes from the top level, senior management and the owners of the company.

These policies show commitment and help to create a strong safety culture. Well-thought-out best practices are proven through measured success, time and time again.