On-Site Data Center Audits Are The Key To Determining Electrical Worker Qualifications
When electrical workers lack the proper training or skills needed to complete their jobs, it can put your business at risk. Research by the Ponemon Institute has found that in data centers, human error is a leading root cause of unexpected downtime, which can disrupt productivity, impact customer service, and take a toll on the bottom line.
Beyond costly equipment failures and unplanned shutdowns, inadequate worker knowledge can also increase the risk of electrical accidents, putting workers in grave danger. In fact, two of the top 10 most frequently cited Occupational Safety and Health Administration (OSHA) violations are related to electrical safety. And in 2016, the U.S. Department of Labor reported 5,190 on-the-job deaths which is the highest fatality rate since 2008. Many of these violations or accidents can be mapped back to insufficient training, which results in failure to follow appropriate procedures or take the necessary safety precautions on the job.
To help safeguard against such costly and potentially deadly consequences, organizations including OSHA and the National Fire Protection Association (NFPA) are beefing up their standards and redefining the qualifications needed to work on or near energized electrical equipment. The latest version of NFPA 70E: Standard for Electrical Safety in the Workplace® also introduces new requirements for determining and validating a worker’s technical proficiency and competence with safety procedures.
Below is an overview of what you need to know to ensure your workers can stay safe on the job and protect themselves, your assets, and your business.
UNDERSTANDING THE DEFINITION OF ‘QUALIFIED’
According to OSHA CFR 1910.269, a qualified worker is one who can demonstrate the skills and abilities to:
- Determine what hazards are faced on the job
- Assess the magnitude of those hazards
- Determine the proper work techniques to avoid the hazards
- Select the proper personal protective equipment (PPE) to mitigate the hazards
“Demonstrate” is the operative word, and the same verbiage appears in the latest version of NFPA 70E. The 2018 standard states that workers must demonstrate skills and knowledge related to the construction and operation of electrical equipment and installations, and not just be familiar with them.
Specifically, to be considered qualified to perform maintenance on electrical equipment and installations, NFPA 70E indicates that workers must demonstrate the ability to use:
- Special precautionary techniques
- PPE including arc flash suits
- Insulating and shielding materials
- Insulated tools and test equipment
The standard also mandates additional training for employees who work within the limited approach boundary of exposed energized electrical conductors and circuit parts operating at 50 Volts or more.
PROVIDING THE NEEDED TRAINING
Both OSHA and NFPA provide guidance on the type and frequency of training required to ensure electrical workers meet the qualifications described above. The NFPA stipulates that retraining (not just refresher training) must occur as least every three years. Additionally, all training must be documented and supplementary training must be provided whenever new procedures or practices are introduced, or when an audit indicates a need.
While training programs must be customized to the specific site and work to be performed, incorporating the following elements into a comprehensive training program is a good place to start. At a minimum, a training program should focus on:
- Imparting an understanding of your organization’s electrical safety policy
- Building knowledge about the existence, nature, and cause of electrical hazards
- Developing the skills to identify electrical and arc flash hazards and assess the associated risk
- Ensuring the employee’s ability to select and use appropriate arc flash personal PPE
- Ensuring the skills needed to read and follow hazard warning labels
- Creating awareness of methods for reducing risks while working on live exposed parts
AUDITING WORKER SKILLS
Organizations today must not only provide the appropriate training to qualify workers, they must also audit individual workers to ensure each employee is complying with safety-related work practices. NFPA 70E 2018 states: “The employer shall determine through regular supervision or through inspections conducted on at least an annual basis that each employee is complying with the safety-related work practices required by this standard.” Such audits provide the ideal opportunity for data center managers to observe and document each worker’s demonstrated qualifications.
Audits are intended to be self-administered. However, many critical facilities are looking to professional electrical engineering or electrical testing service providers to help develop audit programs that ensure compliance with the latest standards. Such a partner can help create a customized audit checklist based on the individual facility’s needs. Third-party partners who are well-versed in the latest standards can also provide assistance and guidance on how to train your auditors and how to properly document the annual audit process per the latest requirements.
Whether you choose to work with a partner, or to develop your audit program in-house, keep the following seven tips in mind:
NFPA 70E is a guideline. The specifics depend on your data center. A detailed, well-written electrical safety policy is critical to protecting workers, assets, and the bottom line. While NFPA 70E offers excellent guidance, it is the facility’s responsibility to add the details specific to its own infrastructure. In other words, your safety policy, training programs, and worker audits should not address only what’s in the latest standards, but also the specific circumstances and conditions that impact worker safety and performance in your unique space.
Know what to look for. Because NFPA 70E is intended to be a guideline, it is somewhat vague in terms of what, specifically, needs to be addressed in annual worker audits. However, your electrical safety policy provides a great place to start. You will want to be sure your employees understand and can carry out the specifics described in your policy so your audit checklist should address these items.
If you work with an electrical engineering or electrical testing service provider to create your audit guidelines, this partner should not only be knowledgeable about the latest industry standards, but should also take the time to thoroughly understand your safety policy and current training program, assess the condition of your electrical distribution system, review site-specific standard operating procedures, and be familiar with each worker’s job scope and responsibilities. This ensures a customized audit program that promotes compliance. It could prevent injuries or shutdowns, and even save a life.
Go where work is performed. It’s difficult to assess a worker’s skills and capabilities in a classroom setting. To determine whether an individual worker is truly able to identify a risk, quantify the magnitude of the hazard, and properly use PPE, it’s important to observe the worker in real-world environments within your own data center.
Build on your existing audit programs. To comply with OSHA and other NFPA requirements, you are likely already auditing other safety-related programs, such as lockout/tagout. To save time and effort, and maximize your resources, you may be able to expand the scope of these existing audit efforts instead of building an entirely new electrical safety audit.
Remember that being qualified for one job does not automatically qualify the worker for another. OSHA and NFPA concur that employees may be qualified for some types of work methods and equipment, but not for others. So it is critical for employees to receive job-specific training and demonstrate learned skills needed for each task to be performed. Furthermore, even if a previous employer has determined a worker’s qualifications, it’s up to the current employer to validate the skill sets and provide site-specific training.
Use your audit results to refine your training program. NFPA 70E 2018 stipulates the need to provide retraining if an annual worker audit identifies skill deficiencies. Such deficiencies could also indicate a need to overhaul portions of your safety training program or policy. Should you choose to work with a partner to develop and implement your initial audit, you will benefit from expert advice on how to improve your current safety training and better prepare your electrical workers.
Maintain as well as train. No matter how skilled your workforce, if you don’t properly maintain your electrical equipment, your employees could still be at great risk. Updates to NFPA 70E address general maintenance requirements, including the need to keep your single-line diagram up to date and to conduct maintenance on all electrical equipment (not just over current protective devices).
ONE TEST YOU REALLY CAN’T AFFORD TO FAIL
The regulatory requirements to qualify employees for electrical work and audit their safety-related skills can seem taxing for some data centers owners to implement, especially when these activities are just a portion of a larger electrical safety compliance program.
Developing and managing an ongoing electrical safety compliance program takes expertise, and in many cases, dedicated resources that aren’t always available internally. Fortunately, a trusted and skilled engineering or testing partner can help do some of the heavy lifting and ensure your audit program or your broader electrical safety program keeps you compliant.
Given the high cost of downtime caused by inadequate worker knowledge, and the even greater toll an injury or fatality could take on a business, investing in a well-defined safety training and worker audit plan is well worth the effort. Interact with our infographic for more on why electrical safety compliance is smart business.