What a loaded term is the simple word–audit. When coupled with the acronym IRS, it can strike fear in the hearts of even the most attentive taxpayer. In the the corporate world, the all-to-familiar audit raises images of masses of red tape, reams of columned spreadsheets and exhausted board members with glazed eyes. While the audit is standard practice for many business professionals, it may seem out of place to the electrical safety professional, but it is not!
When the 2009 edition of NFPA 70E was released, electrical safety auditing became part of the electrical industry’s best practices. Certainly, it will be one criterion OSHA will use to judge whether an employer is doing what it needs to provide a workplace that is “free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees;” [OSHA General Duty Clause]
NFPA 70E Article 100.7 (H) says: “An electrical safety program shall be audited to help ensure that the principles and procedures of the electrical safety program are being followed. The frequency of audit shall be determined by the employer, based on the complexity of the procedures and the type of work being covered. Where the audit determines that the principles and procedures of the electrical safety program are not being followed, appropriate revisions shall be made.”
Let’s take a look at some of the implications that arise from this new standard raises for American industry.—implications that must be addressed if a company wants to remain OSHA compliant..
Auditing is mandatory. The little word shall is crucial. The clearest conclusion we can draw from this paragraph is that the NFPA did not intend auditing as an optional exercise. No employer can afford to ignore a regular audit of their electrical safety program. (You do have a documented electrical safety program, don’t you?)
Audit frequency is flexible. With the exception of the need for annual auditing of the lockout/tagout procedure [(NFPA 70E article 120.3 (C) (3)] a company is free to set what it considers to be an appropriate frequency for its electrical safety audit. The frequency of audit is determined by “the complexity of the procedures and the type of work covered.” This seems to beg for a progressive auditing plan. Electrical procedures would be prioritized and scheduled for auditing according to the established priority. Lockout/tagout would be audited yearly, other procedures audited every other year or some other appropriate interval. Still other procedural audits might be triggered by programmed events, such as plant shutdown or the release of new safety standards.
The NFPA 70E itself is revised on a 3-5 year schedule. The release of a new revision of the NFPA 70E standard should automatically trigger an audit of the electrical safety program. Each company should ask itself, “Are our previously compliant procedures now out of phase with the new standard?” Remember that safety standards have no grandfather clause. Just because a procedure was compliant under the 2004 (or earlier) edition of NFPA 70E does not mean that it will remain acceptable under the newer 2009 edition. The changes to NFPA70E must be reflected in corresponding changes to an employer’s electrical safety policy.
As an example of how changes in NFPA 70E can influence your safety policy, the 2009 edition now requires electricians to wear an arc-rated faceshield when working within the flash protection boundary of HRC category 1 equipment. Companies that did their arc flash analysis under the 2004 edition and have included a PPE list on their equipment labels would now find their category 1 labels to be inaccurate and in need of revision. A proper audit would have picked up this discrepancy and promoted compliance with the new standard.
Auditing is focused on behavior. It is important to remember that the electrical safety audit is not intended to investigate the employer’s policy on paper, but to examine whether the electricians and technicians who are doing the work are actually using the policy in practice. It is important that company auditing of its electrical safety policy investigate the controls by which the policy is monitored and enforced.
Auditing profits from independent eyes. Although the bulk of auditing can and should be accomplished in-house, there is a very real need for employers to have an independent auditor periodically examine its electrical safety program. Familiarity may breed contempt, but familiarity also breeds myopia. It is easy to overlook significant gaps in the electrical safety program by being so close to the project. Fresh unbiased eyes will see what may otherwise be overlooked. In addition, it is difficult for a person involved with the day-to-day management of operations to keep abreast of the latest in electrical safety standards and best practices. Periodically bringing in a safety professional to look over your electrical safety policy is simply an effective way to help ensure that a company remains both safe and compliant to the electrical safety standards..
Auditing is not comfortable, nor easy. Yet it is an essential part of an effective electrical safety program. After all, safety is the goal and auditing helps us do the best job we can of providing an electrically safe work place.