Shelter-In-Place, Low- to No-Cost 70E Compliance Solutions

What can engineering directors and facility managers do to move their facilities closer to NFPA 70E compliance when spending has all but ground to a halt?

• By Michael Dillard
• Apr 28, 2020

After getting knocked on our rear ends by that COVID-19 sucker punch, we’ve all been scrambling furiously to get back up and regain some sense of balance in our personal and professional lives. In speaking with many of my colleagues across industries, it has become apparent to me that we have all learned some similar lessons the hard way…one of which is managing the fine art of doing more with less. Less revenue. Less manpower. Fewer hours. Less access.

In Hawaii, where a large portion of the economy is based on tourism, the majority of hotels have all but shut down due to COVID-19 efforts. Although these facilities (and other types) are shut down, their engineering plants are not. The equipment is still up and running, and there are still engineering staff (albeit a skeleton crew) maintaining that equipment. My hat’s off to these professionals who are mastering the fine art of doing more with less.

That being said, what can engineering directors and facility managers do to move their facilities closer to NFPA 70E compliance when spending has all but ground to a halt? The very phrase “NFPA 70E compliance” seems to conjure up ghastly visions of complex arc flash risk assessments with $50,000 price tags for many managers. Thus, it may not have occurred to them to work towards 70E compliance at this time. I know that a running joke within the maintenance community (some would say a well-known fact) is that the maintenance budget is always the first to get cut. So, if it was already difficult enough to get maintenance projects approved during normal times, I can only imagine the challenge these managers face now.

The good news is that there are actually some no- to low-cost NFPA 70E compliance measures that can, and should, be performed during all of this shelter in-place craziness. In this article, I will cover three of these strategies.

The first of the strategies is using audits. NFPA 70E Article 110.1(K) covers audits—another word that maintenance workers just love to hate. I know when I was a young submarine Machinist Mate in the Navy, I was horrified to think that the engineer or commanding officer would be watching me screw up some maintenance task that I hardly ever performed. Now that I’m older and wiser, I realize that audits get a bum rep. First of all, audits are a NFPA 70E requirement. Second, they don’t cost any money to perform. Lastly, if at first you do not succeed, you will get to learn from your mistakes and have another shot at it. Let us look at exactly what the 70E requires you to audit:

• Electrical Safety Program Audit: The electrical safety program shall be audited to verify that the principles and procedures of the electrical safety program are in compliance with this standard. Audits shall be performed at intervals not to exceed three years.
• Field Work Audit: Field work shall be audited to verify that the requirements contained in the procedures of the electrical safety program are being followed. When the auditing determines that the principles and procedures of the electrical safety program are not being followed, the appropriate revisions to the training program or revisions to the procedures shall be made. Audits shall be performed at intervals not to exceed one year.
• Lockout/Tagout Program & Procedure Audit: The lockout/tagout program and procedures required by Article 120 shall be audited by a qualified person at intervals not to exceed one year. The audit shall cover at least one lockout/tagout in progress. The audit shall be designed to identify and correct deficiencies in the following:

(1) The lockout/tagout program and procedures

(2) The lockout/tagout training

(3) Worker execution of the lockout/tagout procedure

My second Low to No-Cost compliance strategy is training. The NFPA 70E has training requirements for three types of training:

• Electrical Safety Training: Article 110.2(A)
• Lockout/Tagout Training: Article 110.2(B)
• Emergency Response Training: Article 110.2(C)

OSHA has been known to cite training violations as “Serious Violations”; these carry a maximum fine of $13, 494 per violation! Now depending upon the sort of training you implement, the training could be free of cost or it may cost you a little more. Either way, now is a great time to make sure you have your training ducks all in a neat little row. Training can be accomplished at your facility or, for those workers deemed non-essential, online in the privacy of their homes. Article 110.2(A) states that employees shall be trained with attention to the following:

• Train employees to understand the specific hazards associated with electrical energy.
• Train employees in safety-related work practices and procedural requirements.
• Train employees to identify and understand the relationship between electrical hazards and possible injury.
• Retraining in safety-related work practices and applicable changes in this standard shall be performed at intervals not to exceed three years.
• The training required by 110.2(A) shall be classroom, on-the-job, or a combination of the two. The type and extent of the training provided shall be determined by the risk to the employee.

Article 110.2(B) states that employees involved in or affected by the lockout/tagout procedures required by Article 120.2 shall be trained in the following:

• The lockout/tagout procedures
• Their responsibility in the execution of the procedures

Retraining in the lockout/tagout procedures shall be performed as follows:

• When the procedures are revised
• At intervals not to exceed three years
• When supervision or annual inspections indicate that the employee is not complying with the lockout/tagout procedures

Article 110.2(C) covers training for:

• Contact release
• First aid
• Emergency response, and resuscitation
• Training shall occur at a frequency that satisfies the requirements of the certifying body

Since I’m an electrical consultant, my focus would be on electrical safety training, of course. However, as a quick aside, regardless of your industry or profession, OSHA publication 2254 entitled “Training Requirements in OSHA Standards” is an exhaustive guide that covers all OSHA training requirements. Read the pdf here.

My third no- to low-cost compliance strategy is to create and/or update your Electrical Safety Program. No matter what type of facility—banks, museums, universities, shopping centers, hospitals and astrophysical telescope facilities—invariably, their electrical safety program (ESP) is not up to snuff. Many times, they give me the deer-in-the-headlights stare when I ask about their ESP; this lets me know right away that they are not in compliance in this area. NFPA Article 110.1 covers the ESP requirement and states:

“The employer shall implement and document an overall electrical safety program that directs activity appropriate to the risk associated with electrical hazards. The electrical safety program shall be implemented as part of the employer’s overall occupational health and safety management system, when one exists.”

If you’ve never designed an ESP from scratch, these can be something of an administrative beast to create. The good news is that it won’t cost you any money to sit down and have a go at this. Keep in mind that this document is the best policy, as it covers every aspect of electrical safety at your facility.

Use of the NFPA 70E alone isn’t sufficient to create an effective ESP, though. You will also need to reference articles from other standards (29 CFR 1910, ANSI Z-10, etc.) to say the least. The NFPA 70E Informative Annex “E” provides a sample Electrical Safety Program which lists all of the principles, procedures and controls that go into creating a quality ESP.

In closing, effective NFPA 70E compliance solutions do not always cost money to implement. Even if you, or most of your team, have been relegated to working from home, you can still work towards compliance and make a difference.