Over the past years, the NFPA 70E standard has been a topic of discussion for many safety and health professionals. Often the discussion leads to a debate about whether or not the NFPA 70E is a standard enforceable by OSHA. The NFPA 70E has not been officially adopted by OSHA — but most would agree that the consensus standard is being used by enforcement to determine if an employer acted reasonably in protecting employees from an arc flash.
Consequently, safety professionals have been quick to develop policies and procedures for their employees and purchase thousands of dollars of PPE to obtain compliance. Compliance, however, is more than just having written policies and procedures. Even the best safety programs are not worth the paper they are written on without adequate employee training.
New NFPA requirements
Employee training is the most important part of your electrical safety program. Employees must be aware of the hazards associated with arc flash, be capable of reading warning labels and understand the limitations of their tools and equipment.
The 2009 edition of NFPA 70E has some additional requirements about employee training. The goal of the extended requirements is to reduce potential accidents through increased knowledge and awareness. The following changes have been made:
- Article 110.6(C) states employees who are likely to be exposed to shock hazards be trained in methods to release victims from live electrical conductors or circuit paths, and be able to respond in first aid and CPR. The new 2009 edition further requires employers to certify employees’ training in CPR annually.
- Article 110.6(D)(1)(d-e) states that job tasks that are performed less often than once a year require employees performing the task to be retrained before the work begins. Employees must be trained on how to select the appropriate voltage detector and demonstrate their proficiency with verifying the absence of voltage and the interpretation of the indicators used by the device. Employees must also understand all device limitations associated with a particular voltage detection device.
- Article 110.6(D)(3) (a-c) states that if employees are found to be noncompliant with proper safetyrelated work practices or if changes have been made to the employer’s safetyrelated work practices, additional training and/or retraining is required. This is also true when new equipment is installed or newer technologies are added to existing equipment that may require different procedures when using safety-related work practices.
- Article 110.6(E) requires that employers document the training that each employee has received with each employee’s name and the date of training. The training documentation should be made once employees can demonstrate their understanding of the work practices involved and shall be maintained for the duration of the employee’s employment.
- Article 110.5 addresses the relationship with outside contractors. The Host employer is responsible for informing the Contract employer of any known hazards associated with the work, including any information necessary to make the assessment. However, the duty of training clearly falls on the Contract employer to instruct the employees of the known hazards made aware by the Host employer and to train the employees to follow the safety-related work practices of the standard and those specific to the Host employer.
The development of your training program or choosing an outside consultant for training is key to maintaining employee safety and program compliance. Few employers will have the expertise, resources and experience to develop their own program, so choosing the correct trainer will be necessary.
The training program should include the following elements:
- Overview of NFPA 70E standards and its importance as it relates to your facility.
- Identification of electrical safety hazards and how to protect against shock and arc flash. _ Control of hazardous energy and review of lockout/tagout procedures.
- Identification and labeling of electrical panels, disconnects and other affected equipment.
- Safety procedures needed to work safely while exposed to live circuits (including the determination of limited approach boundaries for shock and flash protection boundaries).
- Use of Personal Protective Equipment (PPE) and its limitations.
- Procedures to follow in case of emergency (including first aid and CPR).
- Demonstration of employee ability to use tools and follow work procedures.
