When looking at critical codes and standards across the electrical industry such as NFPA 70E, documentation is consistent. We pay lip service to the concept that any good attorney will tell you: “If it isn’t documented, it never happened.” But have you spent the time to understand what needs to be documented? This question kept me up late after delivering a training session to a group that had several side conversations about the unwritten procedures they are required to follow. So, at 1 a.m., I did what any code nerd does: I hit the books.

Let us focus on NFPA 70E and the rules around documentation as it applies to electrical safety, since this is a safety-­focused publication and NFPA 70E is a major document brought into litigation. 

First, let’s look at what documentation NFPA 70E requires. Chapter 1 mentions a requirement for documentation for no less than a dozen items. Topics requiring documentation include employee trainings, overall electrical safety programs (ESPs), risk assessments and energized electrical work permits, the meeting(s) between host and contract employers, ESP audits, lockout/tagout, work procedures and job safety plans. 

To focus this discussion, let’s discuss the ESP, field work audits, risk assessments and the importance of documenting.

Importance of the ESP

Let’s start with the ESP. It might seem obvious why having the ESP documented is important, yet several instances exist where the practiced ESP was not the written one. 

The general rule is the employer must implement and document an overall ESP to direct activities appropriate to the risk of injury from electrical hazards. However, the question I hear is, “Why can’t we just refer to NFPA 70E as our electrical safety program?” After all, NFPA 70E tells us when to create an electrically safe work condition, how to perform risk assessments, how to select personal protective equipment and other important items. 

You’re right, but show me what NFPA 70E says about your specific situation. In other words, NFPA 70E provides the broad brush strokes, whereas the documented ESP is needed to add the details to the painting.

Field Work Audits

Next, let’s examine the requirement to document field work audits. This speaks right to one of the major problems in the industry where a company builds a great ESP but the work doesn’t follow it. NFPA 70E requires that employers audit field work to the ESP at least annually. Documenting these audits helps change the culture of safety in a facility over time. 

This documentation can be used to show a history of improvement and inform safety management where training must be focused. If several employees are having difficulty performing the daily air test on rubber gloves, for example, now it is documented and this task can be emphasized in the next training effort. Also, the paper trail is tracked over time to show skills improving from information gathered during the audits. This is a win-win situation.

Risk Assessments

The risk assessment is arguably the most important item that needs documentation. Why must this be documented when it can be found on equipment labels or in NFPA 70E tables? There are several reasons. 

For one, an employer’s risk tolerance level is typically defined in the ESP, and documenting risk assessments helps track how work is being performed in accordance with the program’s directives. Writing information down is a significant benefit during job planning. It helps the worker interpret and remember the information better, and if the documentation is part of a form such as a job safety plan/job safety analysis or energized electrical work permit, the form ensures that needed information isn’t overlooked.

Why Does It Matter?

All too often we see an indifferent attitude toward documentation. The message needs to be in every discussion on documentation that the requirement exists in one way or another to help ensure a safer work environment. In most instances, documentation required by NFPA 70E is aimed at improving employees’ conditions. In extreme cases, this documentation might be the only thing that helps the employee plead their case in court since, “If it isn’t documented, it didn’t happen.” Take the time to fill out the paperwork as it is intended and stop the pencil whip. 

Until next time, stay safe and always test before you touch. 

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