NFPA 70E requires three audits related to your electrical safety program:
- Audit the program itself [110.5(M)(1)]. This audit verifies that the principles and procedures of the electrical safety program comply with NFPA 70E. Perform this audit at intervals no greater than every three years. Notice that the audit requirement is in 110.5(M), which is the last subsection of 110.5. So review the program against everything that is 110.5(A) through (L).
- Audit the field work 110.5(M)(2]. The program is pointless if it’s not followed in the field. This audit must be performed at intervals no greater than annually. If deviation is discovered, revise the training program and/or the procedures. Perhaps people don’t follow a procedure because they don’t have sufficient training to do so. Or perhaps people don’t follow a procedure because of one or more flaws in the procedure. The most common flaw is text that is verbose and thus unclear; if you find this, rewrite for directness and clarity.
- Audit the lockout/tagout program and procedures [110.5(M)(3)]. Review these against NFPA 70E Art.120. At an interval of no more than annually, a qualified person should audit one lockout/tagout as it is performed. The purpose of the audit is to identify and correct deficiencies in the procedures, training, or work execution.
Ensure that each audit is documented [110.5(M)(4)]. But simply keeping a record in some secret place doesn’t help the people whose lives your program helps protect. Sharing the findings with them will help them to understand what went wrong, what has changed, and how to be safer.
Once you have the audit completed, review what was documented and determine the key takeaways. NFPA 70E does not require you to do this, but there’s real value gained from doing so. Consider:
- The process of doing this deepens understanding, while the result of doing this is often a short, doable action item list. You want to make sure nothing on that list does an encore in the next audit.
- You may identify a root cause. For example, the procedures are generally not written well and compliance is low because few people read the procedures and even fewer understand them.
- Comparing the key takeaways identified by managers, supervisors, and field workers can reveal deficiencies in perception at all three levels. It will also reveal differences in perception, whether those are deficient or not.
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