Introduction

The devastating effects of electrical shocks and burns have long been of concern to employers and many significant improvements have been in Engineering designs and Safe Work Practices over the last 30 years. Despite these improvements, accident investigations often revealed that causal factors of electrical accidents included that key protective systems were either missing or dysfunctional in some way. In response, OSHA and the National Fire Protection Administration (NFPA) require that employers develop and implement comprehensive and effective Electrical Safety Programs (ESP) (NFPA 70E, 2004). This paper will provide substantive guidance on how to develop and implement effective ESPs.

"Compliant" Versus "Effective" Programs

One important distinction needs to be made between "Compliant" and "Effective" ESPs. For this discussion, we will define a "compliant" ESP as a program where all of the OSHA minimum Electrical Safe Work Practices outlined in either Subpart S (29 CFR 1910.331-.335) or Subpart R (29 CFR 1910.269) have been met such that the employer could not be cited by OSHA.

The term "Effective" means that the ESP has been analyzed using appropriate Hazard Analysis techniques and will actually protect employees from electrical hazards. OSHA is often depicted as being overly protective of workers but this is simply not the case with Electrical Safety. Although the OSHA regulations provide excellent guidance in many respects, difficulties in revising the regulations have left them "out of date" in many important areas of Electrical Safety. Also, the use of "performance-based" language in the Code of Federal Regulations (CFR) has left many employers unable to determine whether or not their ESP even meets OSHA minimum standards.

Due mostly to the need for "up to date" information on Electrical Safety, most employers (and even OSHA in many cases) have turned to consensus standards to provide the current "best thinking" in Electrical Safety. Two consensus standards must be consulted when developing effective ESPs and they include the National Electrical Code (NFPA 70) and the Standard for Electrical Safety in the Workplace (NFPA 70E). As the citations suggest, the NFPA 70E is a subset of the NFPA 70. The National Electrical Code (NEC) is a Design and Installation standard and relates to the "how to build it" part of electrical work. The NFPA 70E is the "how to work on it" part of electrical safety and, taken in concert with the NEC, comprises the best sources of information on Electrical Safety to date.

Although OSHA is silent regarding specific guidance for developing ESPs, the NFPA 70E-2004 does a bit better by providing a general outline in Annex E (page 106). The italics statement at the top of Annex E clearly suggests that the ESP outline is purely for informational purposes only and is not even formally part of the NFPA 70E document itself. Therefore, the reader can accurately ascertain that no one would be required to use this outline as a standard for what must be included in an ESP.

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