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NFPA 70E General Requirements — Part 3

Jan. 7, 2022
Is your electrical safety program based on rules or responsibility?

It seems logical to base an electrical safety program on rules. You make a list of rules so people know what to expect. People also know that if they are caught breaking the rules, they will be punished. This was, in fact, the dominant model in the electrical industry.

But comparing the results to other models showed this wasn’t such a good model. For example, DuPont created its STOP program. No longer would employees worry about getting caught (and thus play the catch-me-if-you-can game). Instead, supervisors seeing a dangerous act would ask the employee to stop what they were doing. And then a conversation would ensue, with the emphasis being on having the employee say what they were doing wrong and then explaining how they could do the same task more safely.

In Europe, safety programs centered on personal choices made by employees produced remarkable reductions in close calls, injuries, and deaths compared to the old rules-and-punishment model. This idea of making the employee the primary practitioner of safety, assisted by concept-based training, soon became the standard in much of Europe.

The Technical Committee on Electrical Safety in the Workplace (NFPA 70E’s equivalent to the code-making panels of the NEC) subsequently adopted this into NFPA 70E. The adoption was helped by the fact that several committee members worked for companies that had already implemented this model.

The requirements for an electrical safety program are in 110.3(A) through (M). Let’s look at a few of these.

The section begins by requiring the employer to implement and document a program that directs activity appropriate to the risk associated with electrical hazards [110.3(A)]. This necessarily requires a risk assessment, which is covered in 110.3(H) and makes up almost 25% of the entire text of 110.3.

The three functions that you can see immediately after the general requirements are performed by the individual worker, albeit with a framework provided by the safety program:

  1. Inspect to ensure the equipment complies with the applicable codes and standards [110.3(B)].
  2. Consider the condition of maintenance [110.3(C)]. Is it complete per applicable standards? Was it performed by a qualified person? What is the work date, and is it recent enough for the maintenance to still be valid?
  3. Be aware of the potential electrical hazards, and have the self-discipline to address them [110.3(D)].

To facilitate this, the electrical safety program must identify the principles on which it is based [110.3(E)] and the controls by which it is measured and monitored [110.3F]. Quite a bit of thought went into which requirements should be in 110.3 and in what order. Can you see the logic behind, and the message underneath, the 110.3 we have today?

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