NFPA 70 E requires an audit of the electrical safety program at intervals not to exceed three years [110.1(K)]. The purpose of the audit is to verify the program complies with the principles and procedures provided in NFPA 70E.
The inclusion of “principles” in that requirement make the audit far from cursory. Any kind of “dog and pony show” or “check off the box” compliance does not satisfy the audit requirements. The whole point of NFPA 70E is “to provide a practical safe working area for employees relative to hazards arising from the use of electricity” [90.1]. That means looking closely at how your program helps employees make themselves safe.
In some company cultures, the company makes the rules to avoid OSHA fines and employees try to see what they can get by with to avoid being written up. Both the company and the employees fail when this happens. And ultimately, people get hurt (or killed). A bedrock principle of NFPA 70 E is the individual employee must identify and protect against the likely hazards. If your electrical safety program promotes the former instead of the latter, it has already failed the audit.
Consider making a two-stage audit. In the first stage, you review the electrical safety program for deficiencies relative to NFPA 70E. The auditor(s) will need a solid understanding of the principles, and that comes only through structured study of the standard.
In the second stage, you review the electrical safety program for its practicality of application. Is it written in clear, accessible language? Is extraneous information cluttering the message, or is it stripped to what people need to understand and apply? Does it proscribe actions that are reasonably achievable or is non-compliance built into it? Does it have a feedback mechanism that will alert management to deficiencies not spotted during the audit?
