How to determine the best electrical safety practices for your plant

Dec. 23, 2013
Objective and measurable techniques to determine best safety practices on electrical systems.

Frequently asked questions

I hire qualified electricians, why do I need to monitor their every move?

You likely were diligent to hire technically competent electrical workers. Qualification ensures they can recognize and avoid injury from electrical hazards. It is the employer’s responsibility to train workers on specific facility hazards, ensure understanding, and monitor compliance after training has been given. These three steps must be effective, timely, and documented to keep workers safe and for you to comply with regulations and standards.

You won’t be monitoring their every move all the time. NFPA 70E establishes “periodic monitoring” as at least once a year. That may not be enough to satisfactorily know they will work according to your electrical safety program. The employer’s electrical safety program must direct electrical activity where the electrical hazard exists. Do your work procedures include steps on working safely and have pre-work checks on all protective equipment? What documentation do you have to show this process and worker proficiency?

I provided my workers with the PPE. What more do I need to do?

How do you know these workers can inspect the PPE on a daily basis to determine its condition? Do you have a process in place to track any required re-testing or re-certification of PPE? Who is responsible and accountable for this?

Who can do this monitoring of electrical work practices?

First things first. Do you have written work procedures that your workers will follow to perform work on or near energized electrical conductors or parts? If so, then anyone who has been trained on how to watch for certain actions and how to conduct an objective interview in a non-threatening way should be able to monitor and audit.

It’s best to have specific persons, not always electrical persons, but employees trained to do this monitoring, so that it may occur on a more timely or consistent basis.

Along with the in-house observers, an independent outside party is useful in monitoring not only specific work tasks, but in auditing the entire process in an unbiased objective format. In this way a company is assured of compliance, unbiased reporting, and monitoring of the overall electrical safety program, all conditions prescribed by NFPA 70E.

Companies must acknowledge hazards that exist in their facilities and operations and agree upon the safe work practices employees will employ when working on or near them. Training then follows to ensure employee knowledge and monitoring processes established to ensure compliance. Variations of this model exist worldwide.

The mandate, problem, and solution techniques can be used on electrical safe work practices. It should be recognized that this model could be adapted for any aspect of an employer’s workforce.

If employees are a company’s most valuable asset, a natural follow-up would be to prepare, preserve, and protect the human asset with the same vigor that is afforded the mechanical equipment those humans work with on a daily basis. Both the human and hardware must be correctly selected for an intended outcome and maintained for optimal performance. Where humans are involved, optimal performance begins and ends with safety.

The basis for monitoring safe work compliance is rooted in the Occupational Safety and Health Act with techniques described in NFPA 70E. These two documents become the operating manuals for the human asset, the employee, in which every supervisor must be well versed. They provide both the requirements and compliance processes for safe and efficient operation and outcome. Workers must first be qualified for the task and then monitored to ensure their daily work habits reflect the training elements used to determine their qualification status while following company-provided work procedures.

The benchmark of effective training and workforce development must meet three interconnected requirements:

  • targeted to the topic (equipment and work practice)
  • measured for understanding
  • monitored for compliance.

In recent years, training models have evolved by adapting to client’s scheduling and budgeting restraints with a diligent eye on the effects on the company’s overall financial health. Training providers, whether in-house or outsourced, continue to develop new delivery models that ensure training effectiveness and the best return for the investment.

The employment process determines a worker’s ability to perform employer-directed tasks or the need for initial training so that the worker may achieve the necessary level of documented independent work performance. Technical competence is a foundational aspect to consider when determining the qualification of any worker.

In a previous position, I was tasked with staffing outages, or turnarounds, in an electrical generating plant. These are very work-intense and time-constrained projects endured by many large industrial-type facilities, and they require great planning and preparation to achieve a safe, successful, and reliable result. These annual projects typically occur in low electrical load times of the year, spring and fall, throughout the industry. After a particularly negative result the previous year, I’d decided to give a basic-level electrical test to all applicants, even though they may have had extensive experience performing this work in the past. To my chagrin, or maybe not, it was discovered that only 22% of the temporary workers could pass this basic test. To ensure some level of fairness, I also gave the test to the full-time company employees, half of which had less than five years’ experience. Only one of the 23 tested individuals possessed an electrical license or had experience in taking similar type testing. Licensing of electrical workers within a company maintenance environment is not a mandate in many states as was the case with the state in which this occurred. All of the company employees passed the test.

What was revealed was actually a factor of basic human behavior and performance. People work to their areas of strength but, when confronted with areas of weakness, often will remain silent for fear of reprisal. The temporary workers I had hired previously were specialists. They were very good at certain aspects of their work but extremely weak in others. As an employer, the responsibility of determining the readiness of the workforce to perform any requested task and the preparation for that task rested firmly on my shoulders. What became painfully clear was that a safe, efficient, and valuable workforce is not hired; it is developed.

A company must use all diligence to hire qualified candidates for its electrical workforce but with full awareness must consider these new hires, or those in their existing workforce that have neither been tested nor been measured for understanding, are just that, qualified candidates. Qualification requires a process of answering key questions to determine baseline factors upon which to act.

  • What is the existing level of expertise and understanding of the workers for the task they are expected to perform?
  • Where deficiencies are noted, how can these be addressed best to ensure effectiveness of any required training?
  • How will I be alerted when additional training is required to best spend the training dollars available and, more importantly, ensure the safety of the worker while doing the tasks expected?

Frequently asked questions

Is this monitoring only for electrical work practices?

Yes and no. Begin with the electrical practices since this is a mandate of both OSHA and NFPA 70E, but the same format and procedure can be applied to all work, especially work considered a hazard risk to employees.

Where do I begin? With the monitoring or writing the electrical safety program? They both seem important but isn’t the monitoring based upon the electrical safety program?

You are correct. The electrical safety program determines work procedures and policies, and this is usually a long process to get agreement within a company, especially one with many work sites and local plant management, on what will be the conditions of working while the electrical system is energized. Safety consultants can do a gap analysis and advise plant management where there are gaps or discrepancies with applicable regulations and recommended practices. This process can take months to work through all the parties within your company to attain a document that all agree to enforce.

In the meantime, your workers may be using work practices that are more about being comfortable than in compliance to electrical safe work practices. Have an initial overview audit taken of both your electrical safety program and your workforce. In this way, the needs of your electrical safety program, training, and development can be determined and a plan put in place to manage and budget the results.

Let’s attack these questions one at a time. The definition of “qualified electrical worker” by OSHA and the recommendations of 2012 NFPA 70E both reference the mandate that a qualified worker have understanding of construction, operation, and maintenance of the electrical equipment to which that worker intends to interact.

The employer must audit the workforce to first determine the level of qualification and compliance that exists. After this determination is made, processes must then be put in place to raise any level that falls short of the electrical safe work practices (ESWP). For the level of work practices to remain at this high level of expectation, further processes are required to monitor compliance and immediately unleash a predetermined action plan to regain the ground that has been lost.

The new O&M

Often plant managers examine work tasks to properly place them in either the operations or the maintenance category. They must further audit performance to ensure this separation remains.

An audit is a systematic process for objectively obtaining information and evaluating, or measuring, the data against a known foundation. Two very key words emerge that are often missing in most cursory examinations: “objective” and “measurable.”

Often these assessments become subjective in nature, accompanied by statements such as, “I think he knows,” or, in exasperation, “With all the training they’ve received, surely they understand.” To be considered objective the results should conclude at least one of the following:

  • “I heard him say the proper thing.”
  • “I see the correct answer was marked.”
  • “I observed the worker doing it correctly.”

For an objective conclusion to be made, it must be measured against an accepted standard. The standards for the qualification are determined by regulations, by industry best practices, and most importantly by applicability to the requested task. These expectations must first be given in the form of training and then followed up with a means to measure understanding. With a goal of 100% demonstrated proficiency this then becomes a baseline upon which to measure the need for refresher training as time goes by.
Employees work under a mindset of consent. “My employer consents to my employment because I am a recognized valuable asset to the company.” Often consent is assumed in the absence of guidance. Companies often view the bottom line of the financial statements as the measurable outcome in determining success. Internal processes ensure honesty, integrity, and fairness to have confidence in the result. In the same way, workers view the successful completion of a task as their goal and measure. Too often the emphasis and acknowledgement is on the end goal; and little time, effort, or thought is given on how it was achieved. The worker is rewarded for exceeding expectations when in fact the worker may have cheated, in the sense that safe work practices were ignored or guidelines altered to complete what the worker thought was the goal of work performance and success. To the worker, success is keeping the plant running or getting the power back on as quickly as possible, which in the worker’s mind justifies the work practices used. Success cannot be measured by a decrease in lost-time incidents or accident reports alone. True success can only be achieved by comparing the results with the practices that achieved those results.

Even with this essential determination of qualification, the employer cannot assume a worker will interact with electrical equipment safely, unless given the company’s expectations of how to work with energized and de-energized equipment, show proficiency in demonstrating skills and techniques necessary to safely perform the work task, and be periodically monitored for compliance and understanding. Objective tools must then be utilized to measure this level of qualification. There can be no hint of subjectivity in the process, as employee understanding and compliance is being measured against this minimal safe standard.

Additionally the employer must audit its electrical safety program to ensure compliance with current standards, measure against industry best practices, and identify any shortfall in providing a safe work environment. Processes must be in place to track these benchmarks and immediately formulate a plan to regain compliance.

These ongoing processes involved procedures that are both equipment- and system-specific. The electrical safe work practices are incorporated into the task-specific procedures and utilized as the work practice norm. Each task is thoroughly examined and written as the road map a worker will follow in performance of the task. Milestones are identified along the road with points assigned for successful achievement. After the task is completed, a total score is determined by adding up the milestones achieved and compared against the predetermined score goal. Action plans are put in place to immediately remediate the milestones missed. The result is a document whereby observable compliance is not only measured, but reasonable employer response can be ensured.

These new processes are a definite change from what has been the established norm. Employers seek to hire the most technically competent workers. Assumptions are made that the terms “technically competent” and “qualified” are synonymous, when in fact they are two entirely different processes an employer must undertake. The employer must ensure technically competent workers understand the hazards encountered in the performance of their work and how to remain safe while doing it. This has been one of the most radical shifts in employer duties in the past decade.

To embrace change from the boardroom down to the plant floor, a progression of steps must be followed:

  • acknowledge the need
  • own the culture
  • establish the guidelines
  • acquire the knowledge
  • train for the expectations
  • provide positive mentoring
  • apply the solution
  • monitor the process
  • document the effectiveness.

Change can’t be driven from the top down, nor is it driven from the bottom up. Real change, lasting change, is driven from the inside out. Workers need a mirror in which to examine work practices against expected behaviors and be rewarded more for the process than the end result. The days of electrical heroes who are rewarded for work efficiency, regardless of the means utilized, must come to an end. This culture must be confronted head-on with established guidelines and expectations, which are then monitored for understanding and compliance.

The workforce is any company’s greatest asset and like other assets must be well constructed and appropriately maintained. Equipment maintenance requires gathering baseline and operational data to make prudent decisions on any necessary action. So also the workforce, when it is regarded as the most critical of company assets, requires being given the guidelines around which electrical work is to be performed and measurable tools put in place to monitor operational effectiveness.

Robert S. LeRoy is an electrical safety and compliance consultant. Contact him at [email protected] or 863-944-3369.

Some employers are well on their way to achieving workplace safety. They may request industry experts to review their electrical safety programs, provide a gap analysis should any gaps exist, and advise them on training and tools monitoring worker compliance. Others are just beginning to walk down this road and need a guide to recommend which pathway will obtain their desired results expending the least amount of time, effort, and training dollars. The vast majority of companies find they’re somewhere in the middle and formulate a plan from a list of benchmarks meeting the unique circumstances and need to which they find themselves today.

Developing a safe and efficient workforce requires more than yesterday’s training models. The days of providing disconnected courses driven by an immediate need or worker request with hopes that somehow employees will get some of what they need or find a resource from which to get it are over. World-class employers know that to provide the level of safely delivered expertise required to succeed, nothing can be left to chance.

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