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Changes to the 2012 edition of this electrical safety standard target training, verification to improve worker safety
More robust training
The updated 70E now calls for worker training in new areas more often with a better paper trail confirming it’s been successfully carried out. Most notably, there’s a new provision that employers must verify that employees comply with 70E’s safety-related work practices on an annual basis through regular supervision or inspection, including the new arena of field work. Before, there was no set verification schedule. New content-specific requirements for training include the use of automatic external defibrillators and in methods of releasing victims from exposed energized parts.
At least every three years, employers must now audit the content of their electrical safety program to ensure compliance with 70E and provide documentation. Generally, if employees fail to demonstrate safe work practices, they must be retrained. In any event, retraining is now required at least every three years. In addition to keeping records of who received training and when, there’s a new provision for documenting the specific content of that training.
These and other related revisions to employer responsibilities for safety are an acknowledgement that vigilance, knowledge, and the workforce aren’t static conditions. Moreover, says technical committee member Dennis Neitzel, director emeritus of AVO Training Institute, Inc., Dallas, with OSHA focused more than ever on training and ensuring that it’s not just an afterthought, employers will want to make sure they’re able to demonstrate that employees are fully trained and qualified, capable, and safety conscious when working around electricity.
“OSHA does enforce documentation, and their attitude generally is that if it hasn’t been documented, it didn’t happen,” he says. “We didn’t make these changes for that reason only; our main objective was to find a way to make sure that these things get done through audits and retraining. The new requirements and time constraints will mean more paperwork, time, and investment, but standards change and revisions and updates need to be accounted for.”
Along the same lines, the new standard also now calls for host employers to have a formal meeting with contractors brought in to work on electrical equipment and systems. The aim, says Tom McCauley, president of Consolidated Consulting Corp., an electrical engineering consulting firm headquartered in Vero Beach, Fla., is to review workplace-specific hazards/risks and the game plan for addressing them.
“The contract between the facility and the contractor can be a tricky thing where each has their own procedures,” he says. “This documented meeting helps make sure that both are on the same page on what’s in the plant and what the dangerous parts of the plant might be. It’s an acknowledgement that accidents can happen when there’s not good communication.”
Clearly, enhanced vigilance of this sort will come at some sort of cost to responsible parties. Whether they’re able and willing to come into compliance on their own or seek outside assistance, employers and other service providers will likely find themselves spending more time building a bigger margin of worker safety into their operations. Ultimately, that amounts to a good investment, says Daryn Lewellyn, president of Lewellyn Technology, a Linton, Ind.-based electrical safety and maintenance training company that’s been ramping up staff and resources to answer calls for compliance assistance.
“I think addressing points like the three-year limit on retraining and the audit of the safety program will make people take more notice of the need to do things properly,” he says. “Hiring an outside consulting firm may be necessary with the need now to look at every aspect of electrical safety — from training and training documentation to plant and equipment walkthroughs to checking on PPE [personal protection equipment] inventories.”