NFPA 70E: Electrical Safety Procedure Identification

NFPA 70E says that an electrical safety program shall identify the procedures employees must use before they can start work if they are expected to be exposed to electrical hazards [Sec. 110.5(G)].

This requirement is very easy to meet if all you want to do is check off the box. However, meeting it in a way that ensures employees use the correct procedures for a given set of tasks is not so easy.

The main obstacle is the procedures themselves. It’s traditional to write procedures in a verbose and unclear manner, tossing in complicated phrasing and peripheral ideas that reduce the readability and usefulness of those procedures. In especially bad cases, employees will not even use the procedures; They will give up in frustration and try to follow what they see as the essence of what’s there.

A way to reduce, if not solve, this problem is to write each statement in a short verb-noun followed pattern by an example:

“Verify the circuit is de-energized”. For example, use the DMM three-step method to test for voltage.”

“But,” the counterargument goes, “we are leaving out important information!” As you should. These procedures are not intended to substitute for proper training, but to supplement it. A qualified person already knows how to perform lockout/tagout, so does not need to get mired down in a 13-page set of instructions on how to perform it.

A basic outline of the major steps is all that is required. If you provide that, it is almost certain people will read it and follow it. If you provide the verbose version, it is almost certain people will neither read nor follow it.

Always test procedures in the field. Testing with a dry run for the first two or three iterations is a good practice. Testing under real circumstances with the users being able to suggest corrections is how you honey these to be the most effective they can be.

Another obstacle is in how the procedures are stored, referenced, and retrieved. The more friction there is in this process, the more likely people will be to wing it rather than locate the procedure. The justification is often, “I’ve used that procedure before, so I don’t need to see it again anyhow.” But this justification confuses the purpose of training with the purpose of a procedure; the same kind of confusion that leads to writing unusable procedures.

If procedures can be stored on the device (eg, tablet or laptop) with some kind of synching (automated or manual) when the device is back at the shop (to ensure the latest version is on the device), that solves several problems including the need to print out all procedures before heading out to the job.

If each work order (WO) lists the relevant safety procedures (perhaps populated by a dropdown on the WO user interface as the WO is being written), that solves another problem. But that solution can’t be implemented unless the electrical safety program first identifies each procedure and its purpose.

The question you have to answer as you go through each is this: “What barriers are there to effective use of safety procedures at this step and how can I eliminate them?” Nobody that question will ever write procedures in a way that would make even a lawyer cringe, but that is typically what happens. Ask the question.

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