In NFPA 70E 2021, the requirements for an electrical safety program (ESP) are relocated from Section 110.1 to 110.5. This revision in no way diminishes the importance of the ESP. It was part of a logical reorganization of existing requirements to the front of Article 110. The general requirement in 110.5(A) is modified for clarity and requires the employer to implement and document an overall ESP directing activity that is appropriate to the risk associated with electrical hazards.
The previous text—which mandated the ESP be part of an overall occupational health and safety management system, if one existed—was removed, along with an associated informational note (IN) that referenced safety management systems. The ESP must contain the elements identified in 13 first-level subdivisions as a coordinated outline of safety-related measures. The goal is to provide a comprehensive plan, with principles, policies, procedures and processes to create practical, safe working conditions with respect to electrical hazards.
Several significant changes in the 2021 edition of 70E impact the ESP. Two INs that were at the end of 110.5(H) are relocated to follow 110.5(H)(1), Elements of a Risk Assessment Procedure, for clarity. The first IN explains that the risk assessment procedure required in the ESP could include elements to identify when a second person may be required and the training and equipment that this person should have. Many questions arise with respect to when a second person is required where justified energized work is performed. This reference to considering a second person is informational only, and the employer must make that determination. It would be nice if 70E came with an easy button that identified each task or exposure requiring a second person.
Remember that 70E is the Standard for Electrical Safety in the Workplace, and there are many different workplaces. We cannot begin to identify and categorize tasks or exposures that may or may not require a second person.
The second IN relocated following 110.5(H)(1) sends the standard user to Annex F for information on the required risk assessment procedure. The information provided in Annex F, Table F.3, The Hierarchy of Risk Control Methods, lists examples of each risk control method and may be referenced in the employer’s ESP. For example, Table F.3 clarifies that an example of the first risk control method—elimination—is placing conductors and circuit parts in an electrically safe work condition (ESWC).
Also new in 2021 is 110.5(K), which mandates the ESP include a policy to comply with 110.3 that requires an ESWC be created before an employee gets within the limited approach boundary or interacts with equipment where conductors or circuit parts are not exposed, but an increased likelihood of injury from an exposure to an arc flash hazard exists.
This policy can mirror the standing NECA safety policy by requiring zero energy work environments as the normal and best practice whenever achievable. It is important to note that this ESWC policy is a set of general guidelines that outline your plan for keeping employees safe in accordance with the requirements of 110.3. This is not a procedure that would provide prescriptive steps to achieve a specific goal.
A new 110.5(L) now requires elements in the ESP for a lockout/tagout (LOTO) program. It is important to note that there is an existing requirement for a LOTO program in 120.1(A). The ESP is now required to include a LOTO program structured in accordance with 120.1(A), or simply reference the employer’s individual LOTO program that meets the requirements of 120.1(A).
Requiring that the ESP include or reference the LOTO program is significant. This program must be applicable to the experience and training of the employees, must meet all of the requirements of Article 120 and will apply to fixed, permanently installed equipment, temporarily installed equipment and portable equipment. This correlates with the newly relocated requirement in 110.2 that mandates and clarifies that electrical conductors and circuit parts cannot be considered to be in an ESWC until all of the requirements of Article 120 have been met.
Many in the electrical industry try to implement an ESWC by applying only the process for establishing and verifying an ESWC laid out in 120.5. Much more needs to be done. Requirements for employee involvement, interlocks, coordination, LOTO equipment requirements, procedures in 120.4 and much more must be met. Every employer’s ESP is a work in progress.
Changes occur with every 70E revision cycle. The required ESP audit (at intervals not exceeding three years) may reveal deficiencies or areas for improvement, and field work audits (at intervals not exceeding one year) will provide the employer with insight to ensure that the ESP policies and procedures are effectively contributing to safe working conditions.