NFPA 70E: Employer’s Responsibilities for Establishing an Electrically Safe Work Condition

You must establish an electrically safe work condition through lockout/tagout. There is no other way, so NFPA 70E, Art. 120 “Establishing an Electrically Safe Work Condition” is all about lockout/tagout. The employee performing the work also performs the lockout/tagout. But the employer has specific responsibilities to ensure that job gets done right every time. Those responsibilities are in Sec. 120.1(B):

1. Provide the equipment necessary to execute lockout/tagout procedures. This means it’s the employer — not the employee — who buys the locks and tags. Since proper execution also requires a means to verify the absence of voltage, the employer is also required to provide test equipment that can reliably verify the absence of voltage. The ability to verify the absence also means the ability to verify the presence, so the equipment must be properly maintained at the employer’s expense.
2. Provide lockout/tagout training to workers. This must comply with 110.6(B). Meeting the requirement means going well beyond a single safety lecture where simply showing up for it means you got the training. There’s detail in 110.6(B), but the gist of it is this. The training must be thorough enough that employee’s managers will have total confidence that the employee can isolate the energy sources. How confident should they be? Confident enough to (in theory) hold the conductors in their own hands. If you would not trust your own life to an employee based on the training they got, the training isn’t adequate.
3. Audit the lockout/tagout program. The audit must comply with Sec. 110(M)(3). There are three kinds of audits (electrical safety program, field work, and program/procedure) plus documentation requirements. As with the training, a cursory effort is not sufficient.
4. Audit the execution of lockout/tagout procedures. Is each individual doing it correctly? The only way to know is for a qualified person to watch the execution and document that it was done correctly.

Poor execution means electrocution. At each step of the way, management must ensure employees know what to do, have the tools to do it, and have the demonstrated ability to do it correctly. Don’t try to do someone a favor by “passing” them when they didn’t do it right. A failure during training or practice means more training and practice. A failure due to inadequate training and practice will usually mean a dead employee.