If your electricians completed their apprenticeship in a NECA-IBEW training program within the past several years, they should be familiar with NFPA 70E-2004, Standard for Electrical Safety in the Workplace. It has become increasingly important for contractors and their customers to learn about this standard, too.
The Occupational Safety and Health Administration (OSHA) is primarily concerned with safe working environments. Several OSHA regulations are written in general terms, leaving compliance details up to the employer, but they require employers to train workers to recognize and avoid potential hazards and that employers look to accepted industry standards for compliance how-tos.
When OSHA was developing its electrical safety regulation, the agency appointed a committee of experts and stakeholders to prepare a supporting standard directly related to employee safety. The National Electrical Code could not meet this need because it does not address the employer-employee relationship and because it is updated so frequently it could soon create conflict with existing OSHA standards, which are revised only after a long lead time.
The result was the first edition of NFPA 70E, released in 1979. Since then, it has been revised several times, with the eighth edition due out this fall. In the interim, OSHA has regularly cited employers who fail to abide by NFPA 70E under the OSH Act’s “general duty” clause or provisions in other OSHA standards that require employees to be trained on hazards. The OSHA standards might not spell out precisely what those hazards are and how to mitigate or avoid them—but NFPA 70E does. Thus, NFPA 70E has become the template OSHA officers use to determine whether safe practices are followed.
A revised OSHA general industry electrical standard is scheduled to take effect in August (the first revision of this standard in 25 years), and it reflects both the 2002 NEC and NFPA 70E-2000. Older editions are referenced because of the slow OSHA regulatory process, which, in this case, began in April 2004, but was completed just recently.
NFPA 70E-2000 introduced tables specifying what type of personal protective equipment (PPE) should be used, depending on the risk involved with the task at hand. Thus, it is likely that ignorance or neglect of the NFPA rules will generate even more fines from the government once the revised OSHA standard becomes law. The issue of who pays for PPE has become controversial, with a major lawsuit filed by construction unions, and workers have become more assertive in complaining about employers whom they perceive as providing inadequate protection.
It is in the contractor’s best interest to make customers aware of NFPA 70E and especially its connection to OSHA enforcement, and I applaud the NECA chapters and member companies that conduct seminars for customers on this issue. Raising customers’ awareness of NFPA 70E is particularly important in light of the fact that the primary message of NFPA 70E is to turn off the power before working on electrical equipment, verify that it is off and ensure that it stays off until the work is done.
If a contractor asks for the power to be disconnected and the customer insists this is too great a burden, a little education can go a long way in changing the customer’s mind. It also makes it easier to get customers who absolutely require the work be done live to sign a statement to that effect (shifting liability to the customer in the event of an accident) and to understand why the additional PPE required to work safely may increase job costs.