My first blog covered why YOU should consider yourself to be an AHJ when it comes to applying the requirements in NFPA 70E®. To refresh your memory, the main reason is that NFPA 70E must be applied proactively not reactively. There is no governmental agency that visits your facility to set up a safe work program for you. No agency audits the work procedures or watches over you while you are performing work. You are left to your own devices until an incident occurs. By then it is too late for the employee who was injured or their family dealing with their death.
Look at the requirements in NFPA 70E. They must be used before an employee is put at risk of an electrical injury. This requires proactive involvement of the entire organization starting at the top. An AHJ is broadly defined as “an organization, office, or individual responsible for enforcing the requirements of a code or standard, or for approving equipment, materials, an installation, or a procedure.” Throughout an organization there are many people responsible for various NFPA 70E requirements. So you are the AHJ in some regard whether you are in upper management, middle management, a supervisor or the employee.
The employer must provide safety related work practices and train the employee. Upper management must set the course for a culture of electrical safety. They must establish policies for protecting the employee which would include allowing an electrically safe work condition to established rather than placing revenue above worker safety. They are responsible for overseeing that the core electrical safety principles are not undermined. They must address contract employees performing work within their facility.
Middle management must allow for time for work to be safely conducted. They must make sure that processes and procedures provide protection for the employee. They are often the one given the responsibility of applying their signature to an energized work permit and must make sure that the work is properly justified. They may need to modify the electric safety work program when conditions at the facility change.
Supervisors must make sure that qualified employees are assigned to conduct the specified tasks. They should confirm that the job briefing is conducted before work is begun. They must verify that the appropriate personal protective equipment (PPE) is issued to or used by the employee. They must understand the safety issues brought to them by a worker who has expressed concerns regarding the assigned task.
The employee is required to implement the employer’s training and practices. They are responsible for their own actions. They must acknowledge the fact that they may not be qualified for the task assigned to them. The employee must be able to recognize that the equipment has not been maintained as expected. They are the only one capable of realizing that pulling a double shift has decreased their awareness to the point that they can no longer work safely and are now at a greater risk of an injury. The employee is solely responsible for final assurance that the work can be and is performed safely.
A single AHJ most often will not be identifiable when it comes to electrical safety in the workplace even if there is an assigned safety manager. These were just some examples of how the requirements in NFPA 70E become the responsibility of various persons thereby making each an AHJ. The main thing to remember is that NFPA 70E is about providing a safe electrical work environment for the employee. Without top to bottom buy in to this fact, the best laid plans are rendered ineffective. Electrical safety is everyone’s job. Where do you fit in?
Next time: The misconception of what a consensus standard is.