Implementing & Auditing Your Electrical Safety Program - Is it Compliant?

Overview

Both NFPA 70E Article 110.1 Electrical Safety Program and CSA Z462 Clause 4.1.6 Electrical Safety Program advise of the mandatory requirement for an Electrical Safety Program to be developed by the employer: “Employers shall implement and document an overall Electrical Safety Program that directs activity appropriate to the risk associated with electrical hazards. The Electrical Safety Program shall be implemented as part of the employer’s overall Occupational Health & Safety Management System (OHSMS), when one exists.” 

Have you documented and implemented an Electrical Safety Program?

What did you base the content (e.g. framework or Table of Contents) of your Electrical Safety Program on?

Did you reference industry Standards for OHSMSs such as ANSI Z10 for the USA or CSA Z1000 (now CSA Z45001) for Canada?

Did you research and find any recommendations from OSHA for the USA or the Provincial, Territorial or Federal OH&S Regulator for Canada with respect to content they would expect to see in your OHSMS that may be applied to your Electrical Safety Program?

OSHS Recommended Practices for Health & Safety Programs

Does your Electrical Safety Program include a qualitative risk assessment procedure/process with related electrical hazard risk assessment matrix (e.g. 3X#) and risk register table?

Do you know if your Electrical Safety Program is compliant?

How did you develop and implement your Electrical Safety Program?

Have you completed an Internal Electrical Safety Audit or External Electrical Safety Audit of your Electrical Safety Program?

Development

The NFPA 70E and CSA Z462 both require that an Electrical Safety Program be developed. This is a mandatory requirement as noted above. Many employers are actually not aware of this fact. Based on the experience of the author most companies have taken a “bottom up” approach to implementing the hierarchy or risk control methods that are also identified in NFPA 70E and CSA Z462 related to the mandatory risk assessment procedure that will be included with the requirements of the Electrical Safety Program.

The error that has occurred is reactive in nature where the employer has procured arc flash and shock PPE and provided it to their employees (with no specification), Qualified Electrical Workers are provided “arc flash awareness” or “arc flash training” and incident energy analysis studies have been solicited and completed and arc flash & shock equipment labels installed on electrical equipment (that in most cases are not compliant).

The gap that is missing is initially there is no documented roles, policies related to the roles, practices and procedural requirements that the training received and the arc flash & shock equipment labels hazard data can be applied against. The Qualified Electrical Worker is not documenting a Job Safety Plan for their work task specific Shock Risk Assessment and Arc Flash Risk Assessment and then selecting additional protective measures including the arc flash & shock PPE provided to them appropriate to the specific energized electrical work task they are about to execute. The Supervisor who most likely didn’t attend the “arc flash awareness” or “arc flash training” has not documented roles & responsibilities for energized electrical work and has no documented policies, practices and procedural requirements to apply and enforce.

OSHA and OH&S Regulations would sponsor that a company should develop, implement and audit an overall Occupational Health & Safety Management System (OHSMS). In some cases this may be a mandatory regulatory requirement depending on how many employees an employer has working for them.

The Electrical Safety Program identified in NFPA 70E and CSA Z462 would work with the overall OHSMS.

Both NFPA 70E Annex P Aligning Implementation of This Standard With Occupational Health and Safety Management Standards and CSA Z462 Annex A Aligning Implementation of this Standard with Occupational Health and Safety Management Standards actually provide some high level guidance on what the “framework” of an Electrical Safety Program should be.  Annex A in CSA Z462 is unique compared to NFPA 70E Annex P as it provides a cross reference Table of the Clauses of CSA Z462 and how the information supports the requirements of an overall OHSMS Program framework.

For the USA NFPA 70E references the ANSI/AIHA Z10 American National Standard for Occupational Health and Safety Management Systems and for Canada the CSA Z462 currently references the CSA Z1000 Occupational Health and Safety Management Systems Standard. You can look to these Standards for guidance and requirements of the content that your Electrical Safety Program should include.

In Canada Provincial Governments sponsored the development of OHSMS Programs by employers by creating the Certificate or Recognition (COR) program. This program encouraged employers to develop OHSMS programs, implement them and them have them audited. If the employers OHSMS audit scored well the employer would receive a Worker’s Compensation Board (WCB) premium rebate. Depending on the Province they actually provide a “Table of Contents/Framework” of what they would expect to see an employer include in an OHSMS Program was provided. In the USA the OSHA Voluntary Protection Program (VPP) replicates the Canadian COR system.

OSHS VPP

Listed below are two potential frameworks of an overall OHSMS as provided by the Province of Alberta, Canada and Ontario, Canada. Your companies Electrical Safety Program can follow these frameworks, but provide the shock and arc flash specific content and inclusion of the core requirements of NFPA 70E or CSA Z462. As noted above CSA Z462 Annex A does provide guidance of CSA Z462 specific content and how it would fulfill requirements of recognized OHSMSs.

Alberta COR OHSMS recommended framework/Table of Contents:

      i.    Management Leadership, Organizational Commitment.

     ii.    Hazard Assessment.

   iii.    Hazard Control.

   iv.    Joint Work Site Health & Safety Committees (HSCs) and Health & Safety Representatives.

    v.    Qualifications, Orientation & Training.

   vi.    Other Parties At in the Vicinity of the Work Site.

  vii.    Inspections.

 viii.    Emergency Response.

   ix.    Incident Investigation.

    x.    System Administration.

Ontario COR OHSMS recommended framework/Table of Contents:

     i.    Policy Statement.

    ii.    Hazard Analysis.

  iii.    Safe Work Practices.

  iv.    Safe Job Procedures.

   v.    Company Rules.

  vi.    PPE.

 vii.    Preventive Maintenance.

 viii.    Training & Communication.

  ix.    Workplace Inspections.

   x.    Investigations & Reporting.

  xi.    Emergency Preparedness.

 xii.    Statistics & Records.

 xiii.    Legislation.

 xiv.    Occupational Health.

 xv.    First Aid.

 xvi.    Health & Safety Representative / Joint Health and Safety Committees.

xvii.    Workplace Violence & Harassment.

xviii.    Return to Work.

 xix.    Management Review.

Additionally in Canada, ENFORM the oil and gas and pipelines industry association developed an “Electrical Safety Program Development Guide” to promote development and harmonization. You can reference this guide for recommended content to include in an Electrical Safety Program:

ENFORM (Energy Safety Canada) Electrical Safety Program Development Guide 

A good place to start if you don’t have an Electrical Safety Program is to get educated and understand what a compliant Electrical Safety Program needs with respect to content. As noted above the Standards listed, the Regulator or industry association guidelines provide good information.

Get organized and treat the development of the ESP as a formal project. Assign a Project Manager/Electrical Safety Program Manager. Define an Electrical Safety Committee (ESC) with a Management sponsor and relevant Supervision, HSE, and representation of Qualified Electrical Workers, Task Qualified Workers, Qualified Instrumentation Workers, Operations, Mechanical etc.. Schedule ESC meetings and follow a schedule and project execution plan.

Using an Electrical Safety Program Development Checklist is a great place to start. If your company has an existing Electrical Safety Program you could review the checklist to confirm your Electrical Safety Program content is adequate or to consider areas for improvements e.g. PLAN-DO-CHECK-ACT.

Implementation

Implementing an Electrical Safety Program follows the initial development. It is recommended that following the development phase and as a component of implementation the employer provide Electrical Safety Program orientation/roll out training to employees based on their roles & responsibilities as described with the Electrical Safety Program. Providing Electrical Safety Program orientation/roll out training will ensure that the Qualified Electrical Worker can understand and properly apply generic arc flash & shock training received. The Electrical Safety Program can then be transitioned into use for full enforcement of its policies, practices and procedural requirements.

Moving from development to implementation you will need to ensure hardcopies or digital copies of field documentation that is required to be completed by a Qualified Electrical Worker is available to them.

Specifically the energized electrical job work flow requirements for the NFPA 70E’s and CSA Z462’s would require:

1.   Energized Electrical Job Safety Planning to be documented. As noted in NFPA 70E and CSA Z462 the “Qualified Person” shall document the work task description, the work task’s Shock Risk Assessment and Arc Flash Risk Assessment.

2.   When required (remember exemptions apply) an Energized Electrical Work Permit (EEWP) will need to be executed with signatures and retained for audit purposes after the EEWP is closed.

3. The use of an Electrical Safe Work Procedure as a hierarchy or risk control method.

While implementing the Supervisor will be responsible for ensuring the Electrical Safety Program requirements are fully implemented and be available to Qualified Electrical Workers to answer any questions that may arise. While transitioning the Supervisor should ensure they adopt a philosophy of collaboration with the Qualified Electrical Workers they are responsible for. The Supervisor should ensure they complete “Supervisory Level Audit” in real time during and following the initial implementation of the Electrical Safety Program (e.g. policies, practices, procedures and correct pre-use inspection and checks of arc flash & shock PPE, tools and equipment, laundering, etc.). Proactive management of behaviors and beliefs will be required.

Audit

A core requirement of an OHSMS and an expectation of OSHA regulations in the USA and Provincial, Territorial or Federal OH&S regulations in Canada would include that the employer audits their overall OHSMS and specifically the included Electrical Safety Program. Both NFPA 70E and CSA Z462 Article 110.1 H Electrical Safety Program, Auditing and Clause 4.1.6.11 Auditing, require mandatory auditing:

1.   Electrical Safety Program Audit.

2.   Field Work Audit.

3.   Lockout Program and Procedure Audit.

4.   Documentation (audits shall be documented).

A notable quote “YOUR EMPLOYEES DO NOT DO WHAT YOU EXPECT THEY DO WHAT YOU INSPECT!” Assuming compliance and performance without checking the facts is not good safety. Auditing is an important requirement for measurable and sustainable performance of your company’s Electrical Safety Program.

Why perform an audit? As referenced below from Wikipedia a detailed explanation/definition of why you should audit and what is a “Quality Audit?” is provided.

“Quality audits are performed to verify conformance to standards through review of objective evidence. A system of quality audits may verify the effectiveness of a quality management system. This is part of certifications such as ISO 9001. Quality audits are essential to verify the existence of objective evidence showing conformance to required processes, to assess how successfully processes have been implemented, and to judge the effectiveness of achieving any defined target levels. Quality audits are also necessary to provide evidence concerning reduction and elimination of problem areas, and they are a hands-on management tool for achieving continual improvement in an organization.

To benefit the organization, quality auditing should not only report non-conformance and corrective actions but also highlight areas of good practice and provide evidence of conformance. In this way, other departments may share information and amend their working practices as a result, also enhancing continual improvement.”

An audit is a systematic, methodical process implemented to verify and validate that the expected policies, practices and procedures of the Electrical Safety Program have been implemented and implemented correctly. For example was the arc flash & shock training provided to employees understood and put into practice? PLAN-DO-CHECK-AUDIT!

There are three validation and verification techniques you can use to implement an Electrical Safety Program Audit: review of documentation, completion of interviews/discussions, and completing inspections/observations.

The audit of an Electrical Safety Program is ultimately confirming that the expected hierarchy or risk control methods applied in the field to ensure that we eliminate exposure (e.g. Establishing an Electrically Safe Work Condition) or have reduced risk to the Qualified Electrical Worker, Task Qualified Worker or Qualified Instrumentation Worker to as low as reasonably practicable.

You may ask how do you complete an Internal Electrical Safety Audit of your Electrical Safety Program? As noted above follow a systematic and methodical process. Start by assigning a lead auditor, this individual could be a member of your Electrical Safety Committee or Electrical & Instrumentation Maintenance Department or it may be a member of the Health, Safety & Environment Department. You may want to use an audit team of at least two auditors. The key to ensure the audit is effective is the individual(s) completing the audit need to be electrical equipment and electrical work practices knowledgeable. They also need to be knowledgeable of the NFPA 70E’s or CSA Z462’s policy, practice and procedural requirements.

An example of a recommended audit process overview & schedule is:

1.   Internal or External Audit is scheduled. Start date and finish date when audit report will be issued is established.

2.   A Lead Auditor is assigned.

3.   Lead Auditor to confirm specific schedule requirements:

a.   Onsite Day 1 Kick-Off Meeting.

b.   Total required onsite days determined based on anticipated number of interviews, size of facility(ies) that will be inspected, arc flash & shock PPE inspections, and any energized work task observations.

c.    Offsite time to review and analyze documentation, interview sheets, inspection checklists, and/or notes from observations.

d.   Amount of time to draft audit report.

4.   Lead Auditor requests specific documentation for review.

5.   Lead Auditor requests that interviews be scheduled.

a.   Operations & Maintenance Management.

b.   HSE.

c.    Electrical Engineering.

d.   Supervision.

e.   Qualified Electrical Worker.

f.     Task Qualified Worker.

g.   Qualified Instrumentation Worker.

h.   Qualified Operations Worker

i.     Mechanic/Millwright.

j.     Non-Electrical Worker.

6.   Lead Auditor schedules facility inspections or energized work task observations.

7.   Lead Auditor organizes resources they will required while completing the onsite portion of the audit: copy of Electrical Safety Program and related documentation, copy of NFPA 70E or CSA Z462, rubber insulating gloves with leather protectors to use to ask interviewee pre-use inspections requirements, insulated hand tool to test if interviewee can properly identify how it is marked, arc flash PPE for review, copies of OH&S Regulations.

8.   Lead Auditor completes onsite work.

9.   Lead Auditor drafts audit report (e.g. audit basis, findings and recommendations).

10. Lead Auditor issues final audit report for review and is available for discussion.

11. Corrective actions are prioritized to be implemented.

Sustainable, and measurable results are validated for the Electrical Safety Program. The ultimate outcome of an audit it that the workers that will be exposed to arc flash and/or shock hazards are never injured. The expected hierarchy of risk control methods has been field implemented by the QEW, TQW or QIW and non-electrical workers.

Conclusion

Developing, and implementing an Electrical Safety Program following a project based approach that is methodical and thorough, referencing and applying requirements of industry adopted standards will ensure adequate due diligence for the employer and employee to OH&S Regulations.

You will only know if the policies, practices and procedural requirements of the Electrical Safety Program are actually working to eliminate exposure or reducing risk to as low as reasonably practical if you audit the Electrical Safety Program. PLAN-DO-CHECK-ACT!

IF YOU NEED EXPERT LEVEL SUPPORT IN DEVELOPING AN ELECTRICAL SAFETY PROGRAM OR AUDITING YOUR EXISTING ESP, PLEASE EMAIL ME [email protected] OR CALL ME TO DISCUSS 587-433-3777. SEE MY WEBSITE FOR MORE INFORMATION:

TW Becker Electrical Safety Consulting Inc.