Occupational Safety and Health Administration 29 CFR 1910.331-.335, "Electrical Safety-Related Work Practices" regulation has been in force for over 20 years. And yet, surprisingly, many Army units still do not have a written electrical safety program or an electrical safe work practice procedure in place.

One question that is continually asked is: "is this a new requirement?" The answer is: "No, this is not a new requirement; the final rule has been around since Aug. 6, 1990."

So the question that must be asked is: "Why are there so many who are not even aware of these electrical safety procedure requirements?" In addition, why are there so many, who are aware of the requirements, not in compliance? Some believe that they do not need to comply. Compliance is not an option because OSHA and the Army require it; besides, it is the right thing to do.

During a recent visit to a major U.S. Army installation, OSHA representatives issued electrical safety notices for several safety and health violations. Violations found at the installation included, lockout/tagout procedures were not developed, training on hazardous energy sources was not provided for employees performing maintenance on electrical pop-up targets, and employees servicing mechanical targets were not trained on recognition of hazardous energy sources.

Electrical hazards included a power strip attached to a wall and used for multiple outlets, markings missing from electrical panels, a ground plug missing from an extension cord, junction boxes missing covers, flexible cords substituted for fixed wiring and a lack of personal protective equipment for employees exposed to electrical panels. Employees also were not trained in safe work practices associated with electric arc flash protection, and a qualified person did not test equipment to ensure electrical circuits were de-energized before an unqualified employee worked on them.

Federal OSHA is responsible under the Occupational Safety and Health Act for inspecting federal agency sites. Under Executive Order 12196, federal agencies must comply with the same safety and health standards as private sector employers covered under the OSH Act. OSHA's federal sector authority is different from that in the private sector in several ways. The most significant difference is that OSHA cannot propose monetary penalties against another federal agency for failure to comply with OSHA standards. Instead, compliance issues unresolved at the local level are raised to higher organizational levels until resolved.

The federal agency equivalent to a private sector citation is the Notice of Unsafe and Unhealthful Working Conditions, commonly called "the notice." The OSHA notice is used to inform establishment officials of violations and OSHA standards, alternate standards and 29 Code of Federal Regulations citable program elements. The notice becomes a final order if the U.S. Army installation does not request an informal conference with OSHA's area director within 15 business days.

In recognizing the need for a proactive approach to improve safety and health for Soldiers, Civilian and contract workers at all installations/sites, the secretary of defense tasked the Department of Defense with reducing the number of occupational injuries and illnesses at all 400 DoD installations nationwide. DoD selected OSHA's Voluntary Protection Programs safety and health management system model to help them accomplish this task. So far, OSHA has recognized VPP Star participants, and by the end of September 2011, the Army plans to have additional participants approved in the program.

Attaining an excellent safety and health management system takes hard work and dedication and may seem a little overwhelming at first. The VPP program is a start to assist in establishing your Electrical Safety Program at your installation. The VPP is a proven program across industry that began in 1982. It encourages companies to voluntarily go above and beyond promoting effective safety and health programs with the overriding objective of making safety a fundamental part of our culture. VPP is built on four elements: (a) management leadership and employee involvement, (b) worksite analysis, (c) hazard protection and control, and (d) safety and health training. VPP is considered as a method to measure the success of programs such as electrical safety with the view that the two programs complement each other.

For additional information concerning VPP go to https://vppcx.org/.

Establishing an effective electrical safety program is vital to the safety of everyone. The organization is required to develop and implement an electrical safety program that addresses employee exposure to each specific hazard that exists.

Page last updated Thu October 6th, 2011 at 00:00