Providing training on NFPA 70E
As an employer am I legally obligated to provide NFPA 70E training and, if so, are there specific documentation requirements for the training?
Responding is Craig Howell, director of clothing sales, Magid, Romeoville, IL.
OSHA 1910 Subpart S mandates training for any employee who might come into contact with an electrical hazard. NFPA 70E is considered the consensus industry standard for electrical safety practices, so even though OSHA does not call for NFPA 70E training specifically, it remains the best option for worker safety and compliance.
Training should include both “qualified persons” trained to work directly with electrical equipment and “unqualified persons,” such as maintenance or janitorial staff who operate around a hazard. It could also include outside contractors or visitors to the facility. NFPA 70E Article 110.2(A) states:
“The training requirements contained in this section shall apply to employees exposed to an electrical hazard when the risk associated with that hazard is not reduced to a safe level by the applicable electrical installation requirements.”
As with any workplace safety issue, an employer’s first priority should be to eliminate or neutralize the hazard. This could include de-energizing, disconnecting, grounding or locking out the hazard, among other means. If that’s not possible, employees must be trained to work safely around the hazard. Article 110.2(B) states:
“The training required by this section 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.”
Training can include hazard recognition, PPE requirements, risk assessment and control, safe work practices, injury risks, and emergency response. Employees must be retrained at least once every three years in safe work practices and in any changes to the NFPA 70E standard. Training is also required after failed inspections, when new equipment has been added or after a temporary change in job duties.
NFPA 70E requires employers to document any safety training employees receive. The documentation can include a course curriculum, outline, table of contents, training objectives or employment records showing that an employee received training. Article 110.2(E) states:
“The employer shall document that each employee has received the training required by 110.2(D). This documentation shall be made when the employee demonstrates proficiency in the work practices involved and shall be maintained for the duration of the employee’s employment. The documentation shall contain the content of the training, each employee’s name, and dates of training.”
Training can be administered by qualified internal safety personnel or external safety consultants. In many cases, a PPE provider or risk assessment consultant will offer safety training as a “value-added service” on top of their core program. This can be a good cost-saving option for companies lacking the ability to administer training internally.
Although OSHA will issue citations for failure to properly train employees, this shouldn’t be a prime motivator when designing an electrical safety training program. NFPA 70E training protects employees from injury, creates a more ordered workplace and builds a culture of safety within the company.