A Better Understanding of NFPA 70E: Setting Up an Electrical Safety Program (Part 11 – Electrically Safe Work Condition)

An electrical safety program (ESP) is required by NFPA 70E®, Standard for Electrical Safety in the Workplace® to include an electrically safe work condition (ESWC) policy. The ESP must require, unless justified, that an ESWC be established whenever an employee is within the limited approach boundary or interacting with equipment that has presents a likelihood of an arc-flash occurring. NFPA 70E cannot be the policy or the procedure necessary to comply with this requirement. A requirement in the ESP to establish an ESWC is the first step, but the ESP must detail what is necessary to accomplish this goal. The required ESWC policy cannot be met without filling in the gaps.There are many policies and procedures required in a workplace and several may be used as part of the ESWC policy. Each of those must be detailed to properly apply the policy. For an employee to know when they are within the limited approach boundary requires the knowledge of when an electrical hazard is exposed and if so, where the limited approach boundary is. For an employee to know that there is an increase likelihood of an arc-flash requires them to know what that means for the equipment they are interacting with. The ESP needs to document how an employee is trained to know that.It might be possible to consider that every piece of electrical equipment with a facility is always under the normal operating conditions and an acceptable condition of maintenance. This requires an inspection to determine that fact before an employee approaches any piece of equipment. This then requires the employee who may approach that equipment to be trained on determining an acceptable condition of maintenance. The procedure must detail the steps necessary if the equipment condition is not acceptable. Someone must then be assigned to establish the required ESWC when it is not.Article 120 is not appropriate to use as the procedure for establishing an ESWC. Part 3 of this blog series illustrated the need to develop procedures specific to the employees and equipment within a facility. The ESWC procedure needs to address what to do if a risk assessment has not been conducted on the equipment. An ESWC cannot be safely established without it. Using a contractor does not remove the need to comply with the safety policies of the facility or absolve the facility of enforcing safety requirements. The ESP must include requirements for an ESWC regardless of who is establishing it.             The ESP must provide for a situation when energized work is justified which introduces the potential to cause an injury or fatality. Energized work on 277-volt fluorescent fixtures, 120-volt receptacles, and 13.8 kV transformers have resulted in workplace fatalities. The criteria for greater risk and greater hazard are rarely met. However, tasks such as voltage measurements are infeasible in a de-energized state. The permit must specify the signatures required prior to authorizing energized work. The final authorization should be consistent so that someone is aware of every instance of energized work. That person should be high enough in the organization so it is difficult for them to put pen-to-paper when an employee could become a fatality. Having statements in the ESP that elimination of electrical hazards is the priority and that establishing an ESWC condition is required does not make either happen. It takes more time to properly de-energize equipment then to leave it energized, it is a longer process to don protective gear than work barehanded, and it delays a task to obtain appropriate tools. Without management commitment to the words and the allowance for employees to comply with them, the ESP will be ineffective. Make it clear that the documented electrical safety policies and procedures are not optional for anyone in the workplace.