Steven J. Owen, Electrical Consultant
4662 Burningtree Lane, Pelham, AL 35124 / 205-987-2502 Bus /
205-982-9613 Fax / necexpert@aol.com

Have you completed your workplace hazard assessment?

It is the responsibility of employers to determine any hazards that exist or may exist
in their respective workplaces or jobsites. What is a hazard? A hazard is defined as
“a potential source of harm.” What are employers required to do per OSHA requirements?

Whether you are concerned with responding to the possibility of chemical emergencies in the workplace, or working with hazardous waste at a treatment, storage, and disposal facility, you must do a careful determination of the hazards and potential hazards that workers may be exposed to. This means all possible hazards that exist or may exist.

This onsite survey should include a complete survey of your facility, inside and outside, compiling information as to the presence and concentration of chemicals, the location of entries and exits, the availability of emergency equipment, and potential trouble spots – just to name a few items. An effective program includes provisions for the systematic identification, evaluation, and prevention or control of general workplace hazards, specific job hazards, and those potential hazards, which may arise from foreseeable conditions.

At a minimum, you must do a survey of the presence of any of the hazards listed later in in this article. What may seem to be an annoying situation at present may be greatly magnified in the presence of an emergency situation. Take the time and effort to fix those small, annoying items quickly so they cannot become major items. For example, the electrical equipment that has not been maintained, has numerous unused openings, which have allowed a dust build-up internally, may now be a hazardous situation at any given time.

Although compliance with the law, including specific OSHA standards, is an important objective, an effective program looks beyond specific requirements of law to address all hazards. It will seek to prevent injuries and illnesses whether or not compliance is at the issue.

The extent to which the program is described in writing is less important than how effective the program is in practice. This does not mean that the documentation can be taken lightly or given anything less than a fine effort. As the size of a worksite or the complexity of a hazardous operation increases, the need for written guidance increases to ensure clear communication of policies and priorities, and consistent and fair application of rules.

The scope of your self-inspections should include at least the following:

  • Emergency Action Plans. 09-11-02 is a very good reason for this requirement.

  • Fire Prevention Plans.

  • Processing, Receiving, Shipping and Storage. You know – potential back injuries.

  • Building and Grounds Conditions.

  • Housekeeping Program. Prevention of slips, trips and falls.

  • Electricity, including your written Control of Hazardous Plan, i.e., Lockout-Tagout.

  • Lighting.

  • Heating and Ventilation.

  • Machinery. Pay attention to machine guarding. Lack of, or improper guarding is normally in the top 5 OSHA violations for general industry.

  • Personnel, including the appropriate training for the job task(s). Don’t forget the definitions of “competent” and “qualified.”

  • Hand and Power Tools.

  • Chemicals. Don’t forget that 3 of the top 5 most common OSHA violations for general industry fall under the scope of hazard communication.

  • Maintenance. Maintenance and servicing of machines and equipment is the reason for lockout-tagout (control of hazardous energy).

  • Personal Protective Equipment. If you are working with energized electrical parts and equipment, you had better have a copy of NFPA 70E, and be prepared to follow those guidelines.


Conclusion:

The employer’s hazard assessment will determine, in large part which Standards shall be used in the workplace to provide safe and healthful working conditions. Therefore, it will be incumbent for the employer, and / or all persons involved in the hazard assessment to know which Standards will apply to any given situation.

Here are some common sense tips on how to perform a facility audit / job hazard analysis.

  • Use the team approach. Solicit the help of your employees.

  • Rotate members of the audit team; new and different perspectives may be helpful.

  • Be thorough in your assessments. Check every nook and cranny in your facility carefully.

  • Do this analysis frequently. Conditions may change daily.

  • Be comprehensive. Do not overlook the little things. Little thing can create big problems.

  • Set up a system for corrective action to be followed after an audit(s).


References:

NFPA 70B-1998, Recommended Practice for Electrical Equipment Maintenance, (Quincy, MA, National Fire Protection Association).

NFPA 70E-2000, Standard for Electrical Safety Requirements for Employee Workplaces, (Quincy, MA, National Fire Protection Association).

OSHA (Construction Standard), 29CFR 1926.

OSHA (General Industry Standard), 29CFR 1910.


Steven J. Owen, electrical consultant, has been active in the electrical industry for over 27 years. Owen is certified as a master electrician/contractor in 46 states; as a National Electric Code instructor for continuing education in 29 states; as an OSHA authorized trainer for Construction and General Industry; as an electrical inspector by BOCA, CABO, IAEI, ICBO & SBCCI; as a Chief Code Analyst by SBCCI; as a lightning protection designer, inspector, installer by LPI; as a Power Distribution Engineering Technician by NICET; Principal voting member of CMP-3 of NFPA 70 – NEC; as a member of ABC, ASCET, ASSE, IAEI, ICBO, NETA, NFPA, NICET, RSES and SBCCI.

 
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