Documenting is furnishing written evidence to prove compliance, attendance or other. For example, it is imperative that employees and employers document all safety-related and other training. Documentation can include paper records, digitally stored data, time stamps, emails, text messages and more. 

Without planning for it, building and maintaining required documentation over the course of a year can be difficult. NFPA 70E requires that employers document everything related to electrical safe work practices. Documentation is necessary to prove compliance. Remember the old adage, if it’s not documented, it didn’t happen! 

In the event of OSHA activity, missing documentation could result in serious citations. The maximum penalties for serious and other-than-serious violations increased from $14,502 to $15,625 per violation. When an employer agrees to settle on a serious citation, that agreement opens a five-year period during which a citation issued for the same or  substantially similar condition or hazard will not be considered as serious, but will be categorized as repeat or willful. The maximum penalty for willful or repeated violations recently increased from $145,027 to $156,259 per violation. 

During an OSHA investigation, a compliance officer will ask employees about training provided by the employer as required by OSHA 1926.21(b)(2). Without proper documentation, an employer may be cited, even if the training did occur. The general rule in NFPA 70E 105.3(A) mandates the employer establish, document and implement the safety-related work practices and procedures required by this standard. This is a broad-brush requirement supplemented with multiple, specific documentation requirements throughout the standard. 

Why is this important?

The employer is required to implement and document an electrical safety program (ESP). Many documentation requirements are tied to the disciplines contained in the ESP, including, but not limited to, job safety planning. A job safety plan is required before starting any task involving exposure to electrical hazards. The plan must be documented. The ESP is required to contain elements for auditing every three years, and the field work and lockout/tagout (LOTO) program and procedures annually.

Electrical safety training for qualified and unqualified persons must be documented. The documentation must be made when the employee demonstrates proficiency in the work practices involved; it must be retained for the duration of their employment; and must contain the training’s content, each employee’s name and training dates. 

Where an EC is working for a host employer (e.g., an owner or their designee, construction manager, general contractor or employer) who has knowledge of hazards covered by this standard related to the contract employer’s work, a documented meeting is required between the host and contract employers. This is easily documented with a follow-up email. 

It is important to note that on multi-employer work sites (in all industry sectors), more than one employer can be responsible for identifying hazardous conditions and creating safe work practices. The required LOTO program must be documented and specify an established procedure. This is achieved by combining the six steps to de-energize and four steps to re-energize in OSHA 1910.333(b)(2) with the NFPA 70E 120.5 process for establishing and verifying an electrically safe work condition. 

When an energized electrical work permit (EEWP) is required, it must be documented. There are exemptions to the EEWP including, but not limited to, testing, troubleshooting and voltage measuring. Where the exemptions apply, qualified persons performing these tasks must be provided with and use appropriate safe work practices and PPE in accordance with Chapter 1. Where these tasks will be performed, an EEWP is not required, but shock and arc flash risk assessments are required and must be documented.

Without continuous management oversight, it is typical to see qualified persons perform justified energized work that does not require an EEWP without documentation. The qualified persons will perform a shock and arc flash risk assessment, but in many cases, they have no mechanism to document it. This has a serious impact on auditing work in the field, which is required annually. Without documentation of each energized task, we cannot determine the status of our ESP. 

Where an incident energy analysis is performed, the owner is responsible for documenting, installing and maintaining the marked label. The owner must document and make available to the EC the calculation method and the data to support the label’s information. 

Each ESP and contractor must develop policies and procedures tailored to their work and company. The NECA Safety Meeting app contains many individual apps to help ECs document as required by NFPA 70E. Once an employee uses one of the apps and completes it, it is automatically uploaded to the cloud for auditing and documentation.

Header image: Getty images / Nadezhda Kurbatova