THE ELECTRICAL SAFETY PROGRAM AND THE VALUE IN PARTERNING

WITH HEALTH & SAFETY PROFESSIONALS

Copyright Material IEEE
Paper No. ESW2020-30

Jeremy Presnal Herb Houston Greg Maberry

Division Safety & Health Manager Safety & Health Leader Safety Supervisor
Georgia-Pacific, LLC Georgia-Pacific, LLC Targa Resources
133 Peachtree St. 133 Peachtree St. 440 I-35
Atlanta, GA 30303 Atlanta, GA 30303 Denton, TX 76207
USA USA USA
jeremy.presnal@gapac.com herbert.houstonIII@gapac.com gmaberry@targaresources.com

Abstract – Managing a compliant and effective Electrical
Safety Program (ESP) can be a challenge in the industrial
workplace. A large contributing factor is that historically,
ownership of the ESP has been assigned to electrical, technical
and / or maintenance capabilities and although electrical
engineers, electrical technicians, electrical craftsmen, etc. are
experienced and knowledgeable about many elements of the
ESP, these individuals are generally not always the most
experienced with all of the compliance aspects and program
ownership responsibilities required for implementing and
managing a sustainable ESP. The intent of Article 110.1 (A) of
the NFPA 70E Standard for Electrical Safety in the Workplace, is
that the ESP should be managed as part of an employer’s
existing Occupational Health and Safety (OHS) management
system (note: pending one exists) [1], along with other
fundamental OHS programs such as Control of Hazardous
Energy (Lockout / Tagout), Confined Space Entry, Hazard
Communication, etc. and should not be segregated away
separately. The intent of this paper highlights the value in
establishing a partnership with the Health & Safety (H&S)
Professionals to help create, manage and sustain an effective
ESP and discusses the comparative advantages that H&S
Professionals have to offer that make this collaboration both
necessary and worthwhile for the organization.
cases of business interruptions, consumers may be without
electrical power or losing power at a facility that results in an
emergency shut down of high-risk operational processes can
result in activating safety systems that may trigger environmental
limit exceedances and warrant additional agency reporting
(Federal or State EPA). This can lead to a financial penalty if a
Notice of Violation (NOV) is levied against the company and
further impacts a company’s reputation in the eyes of the local
agencies and within the community. Additionally, contact with
electrical energy is still a leading cause of fatal workplace injuries
in the U.S., ranking in the top 10 causes for general industry and
within the top 5 for construction and mining industries, as well as
the financial impact of nonfatal electrical injuries are extremely
high compared to other lost time cases [6]. This is where the
importance of a compliant and effective ESP comes into play and
creates value for an organization from a personnel safety,
regulatory compliance and legal standpoints. There are other
obvious operational reliability and sustainability advantages, but
these will not be explored in much detail in this paper. Although
most reputable companies and their respective operating
businesses have an ESP, the variability of effectiveness for
ensuring protection of personnel, assets and the community, as
well as meeting regulatory compliance expectations is impacted
by many different factors.

Index Terms — Occupational Health & Safety (OHS)
Management System, OSHA, electrical safety, electrical safety
program (ESP), training, NFPA 70E, Health & Safety (H&S)
Professional, electrical safety committee, qualified electrical
worker (QEW)
I. INTRODUCTION
It is no secret that in today’s work environment, most industrial
companies have employees as well as contractors that operate,
interact, work on and / or near complex electrical equipment. As
such, the employer has a business and moral obligation to
ensure that the associated risk potential has been identified,
evaluated, controlled and where possible eliminated. The direct
and indirect costs of a significant injury or fatality (SIF) to any
business is very high. Beyond the moral piece of human loss
and tragic suffering, these unfortunate events generally lead to
government interaction (i.e. OSHA or MOL investigations) that
can involve citations / financial penalties, legal costs, equipment
damage / down time and even business interruptions. In some
II. OHS MANAGEMENT SYSTEMS AND THE ESP
One primary factor is the existence of a strong OHS
management system within which an ESP should be owned. As
pointed out in the abstract of this paper, there is specific
language in the current NFPA 70E Standard for Electrical Safety
in the Workplace, which was a technical update formally included
in the 2015 edition. However, this concept was previously
introduced in the 2009 edition of NFPA 70E as a Fine Print Note
(FPN) in article 110.7, which specifically referenced the
ANSI/AIHA Z10-2005 regarding a framework for establishing a
comprehensive electrical safety program as part of an
employer’s OHS program [6]. In his paper, “A System Safety
Approach To Occupational Electrical Safety”, H. Landis Floyd II,
clearly explains “Safety management systems utilize concepts
such as continuous improvement, comprehensive hazard control
measures and engineering design solutions that are not
addressed in NFPA 70E.” He also provided a very compelling
case history of one company’s experience in applying this
approach and further concludes in the paper that “The safety

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management system standards are based on proven principles
that are fundamental and essential for robust safety programs
and sustainable safety performance”[6]. There are both
nationally and globally recognized OHS management systems
out there that an employer may choose to leverage, (i.e. ANSI /
ASSP Z-10, ISO 45001, OHSAS 18001, etc.). Some companies
utilize an OHS management system built internally that are
similar in design and align with the key elements of the
aforementioned OHS management systems. Regardless of
which a company chooses to utilize, the common framework of
these safety management systems generally consists of
leadership commitment, worker participation, risk assessment
(i.e. hazard identification, evaluation and controls), program
ownership, planning, support, auditing, continuous improvement
via the PDCA (plan, do, check, adjust) model, management of
change, training, etc. These key elements are critical to the
success of an effective and compliant OHS program, but
especially the ESP. In the 2018 edition of the NFPA 70E
Handbook, an illustration is included as a visual aid to highlight
the framework in which these crucial elements should exist.
Fig. 1 Occupational Health & Safety Management System,
Article 110.A NFPA 70E Handbook [2]
III. ESP OWNERSHIP / MANAGEMENT AND THE
POTENTIAL PITFALLS OF NOT INVOLVING
H&S
Leadership commitment and program ownership are major
benefits of an OHS management system and where the
ownership of the ESP is not clearly defined, it can unintentionally
fall victim to the tragedy of the commons in which nobody really
owns it or is accountable for ensuring a viable product for the end
users. This gap can happen easily in an organization without a
robust OHS management system in place and even in large
companies where one exists, the ESP oversight and overall
program management responsibilities can get assigned to the
electrical engineering group and / or the electrical maintenance
department due primarily to fact that leadership generally
assume that the electrical experts of the company should own it
and also the technical complexity being overwhelming to the
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H&S professionals. However, excluding the H&S professionals
from leadership of and involvement in the ESP is a crucial
mistake that inhibits improving the electrical safety culture and
application of principles, procedures and controls. The
electrical engineering capability within an organization plays a
very critical role with ensuring that electrical power distribution
and utilization equipment are designed to meet applicable
regulatory code requirements, installation oversight and project
management responsibilities, providing equipment reliability
strategies and that the critical equipment risk analysis have been
completed such as the incident energy analysis and short circuit
/ coordination studies and having familiarity with Prevention
through Design concepts. With inspection, testing and condition
of maintenance being such a critical factor in the reliability of
electrical equipment safeguards, the electrical maintenance
capability also plays an extremely crucial role regarding electrical
safety. They serve as the owners and users of the maintenance
work processes, systems, standards and procedures and as
such, most frequently interact with a facility’s electrical
equipment and have the primary responsibility of understanding
and applying the principles, procedures and controls of the ESP.
With these considerations in mind, it is still important to call out
that the electrical engineering and electrical maintenance
capabilities bring immense value to the table with regards to the
ESP and are usually best at helping business and / or operations
leaders understand and prioritize what changes should or could
be made to further reduce risk to the equipment and hazards to
personnel. However, most do not normally possess the
experience and skills sets conducive to compliance
administration and risk assessment techniques. In their paper
titled, “Changing the Electrical Safety Culture”, authors D. Ray
Crow, Danny P. Liggett and Mark A. Scott explain “Establishment
of an active safety committee within an organization is important
to monitor and continually improve the electrical safety program.
Engage safety professionals in the committee. Too often
electrical safety is delegated to electrical experts. A competent
safety professional is more qualified in risk assessment than
most electrical experts.” [3]. Electrical Engineering and Electrical
Maintenance generally are not trained or experienced with formal
risk assessment processes. The immediate user of an actionable
ESP is not just the Qualified Electrical Worker but also
mechanical maintenance and operational employees.
Overlooking these groups usually leaves a larger pool of
individuals excluded from the scope of the ESP and is
detrimental to the business. Health & Safety Professionals
typically are well versed in the execution of work in both
mechanical maintenance and operational roles and can readily
connect the relationship of multiple work roles with the ESP
scope.
IV. IT TAKES A TEAM… LIMITATIONS OF AN
EXPERT VS. POWER OF A TEAM
“No one can whistle a symphony. It takes a whole orchestra
to play it.” – H.E. Luccock
Having a well-rounded team of capabilities helping to develop
and establish the ESP is invaluable. Electrical engineering,
Maintenance / Reliability, Operations and H&S Professionals
bring multiple perspectives and disciplines to the improvement
process of a thriving and effective ESP.
Typically, the electrical engineering group’s strong suit is the
design of the electrical infrastructure, ensuring it is adequate for
the proposed operational demand and that the design is in a
serviceable configuration for the reliability and maintenance
group.
The operations group is the ultimate customer of an effective
ESP enabling them to achieve the vision for the operation. These
individuals help to connect the ESP with field execution of
operations. Depending on the type of operation these employees
may interact and be more involved in day to day routines directed
and managed by the ESP than historically realized.
The reliability and maintenance group direct how systems are
managed and maintained so they can safely operate. These
individuals must take the content of the ESP and put it into
practice; having their perspective on how the ESP is executed is
essential to ensuring the process is effective for the organization.
The Health & Safety professionals bring a leveling dynamic to
the ESP regarding organizational risk tolerance and help to
connect the groups and capabilities together aligning the ESP
with the other safety programs in an operation. In the conclusion
of their paper “Electrical Safety: State of the Art in Technology,
Work Practices and Management Systems” the authors express
that “The safety professional is best positioned in the general
techniques of hazard analysis and risk assessment to
significantly impact and accelerate changes for improving
electrical safety, serving as the “electrical safety conscience” to
owners, managers, electrical experts and the workers most at
risk to electrical injuries.” [8].
This brings us to another area to consider, which is the ESP
content. The 2018 Edition of NFPA 70E added as a technical
change, “a specific definition providing the pertinent components
of an ESP to enhance clarity and usability of the standard” [2].
However, if the components of an organization’s ESP strictly
mirrors and only contains language of the applicable regulatory
compliance and consensus standards, (i.e. OSHA Subpart S,
K,1910.269, NFPA 70E, etc.) then the ESP is likely ineffective
because there is no clear roadmap for the organization that
illustrates to employees how the company expects them to apply
electrical safe work practices to address unsafe conditions and
at risk behaviors. This is a pitfall that some companies
unknowingly have fallen into, especially those absent of an OHS
management system and / or internal ESP SME resources that
understand both the compliance requirements (i.e. know the rule
and why it is important) and the needs of the end user (i.e.
understand the rule and know how to follow it). A company’s
organizational structure and resources are also related to the
success of the OHS management system and in particular, the
ESP. If a corporate electrical safety capability exists and it
includes an individual or team of SMEs dedicated to owning,
managing and advancing the ESP across the organization by
working with facility teams, the probability of employees being
dialed in on electrical safe work practices is likely good.
However, due to economic challenges in today’s business
climate, this is more of an exception than the norm, for many of
today’s organizations. Some smaller companies that operate
without an OHS management system and / or without on staff
competent H&S professionals have fallen victim of hiring and
retaining online third party safety services vendors that claim to
provide compliant OHS programs, (note: including the ESP, but
instead utilize a generic / boiler plate ESP document for the
respective client that is used for all their customers with the only
major difference being the name of the company on the top of
the ESP. These services are typically retained for the purpose
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of achieving an acceptable grade or score in third-party
contractor selection, evaluation and management programs
prescribed by a hiring client that the small company is doing work
for or wishes to be awarded a work opportunity. A typical reason
this is done by a company is to avoid the cost of hiring and
retaining competent H&S professionals on staff or reputable and
qualified third-party consultants. Unfortunately, at some point
these companies do pay the price in the form of poor H&S
performance or worse, suffer a SIF and then upon incident
investigation it is realized that the necessary elements of an
effective ESP were never in place.
Although there are many reasons why partnering with the H&S
Professionals can help an organization achieve a world class
ESP, another important acknowledgement is the ability to help
navigate the regulatory compliance world. Understanding the
dynamics between OSHA regulations and national consensus
standards like NFPA 70E is necessary and helpful when creating
or revising an ESP. OSHA standards related to electrical safety
and control of hazardous energy (i.e. LOTO) are some of the
most regularly cited by the agency and that is due to the fact that
the regulations mostly communicate general requirements to be
met or followed, but fails to directs employers on how to do it,
which is where a consensus standard like NFPA 70E can be
helpful. There are also times where a relevant OSHA Standard
requirement may differ from NFPA 70E, as in the case of
approach distances listed in Subpart S (1910.333, Table S-5)
related to overhead power lines and what is found in NFPA 70E
(2018 version, Table 130.4 (D) (a)). Since H&S professionals
typically already have a fluency of sorts with these types of
challenges, they should be better able to help drive a team
through the decision making process and land on decisions that
align with the company’s vision for safety and respective risk
tolerance, compared to if they were not involved and the matter
strictly left to only the electrical experts to decide.
Also, with many H&S related efforts, there are often specific
H&S programs that overlap with and mutually reinforce each
other. H&S professionals are usually well engaged with other
company H&S standards and / or facility protocols that closely
dovetail with electrical safety, like the control of hazardous
energy program and process. The corporate ESP (where one
exits) and facility specific ESP should complement other existing
safety protocols and vice versa and should be tailored from the
consensus standards to the specific electrical equipment and
task hazards of an organization, giving employees the needed
detail for what they face and eliminating superfluous information.
This also allows the company to leverage other routine safety
protocols like internal audit process, behavior or people based
safety programs, training and skills evaluation process, process
and equipment based risk assessments, and safe work
permitting efforts as just a few examples. The site-specific ESP
being largely based on the corporate standard is tailored for the
site and the sites specific needs further focusing on the industry
and associated operational / maintenance processes and
equipment that occur at that site. The site ESP should clearly
explain how the site complies with the company standard and
gives specifics of how the systems are managed at the site. The
H&S professionals are also already familiar with other company
specific programs like PPE and Emergency Response, which
are related to the ESP and other site-specific programs.
Employee training is another area that the H&S professionals
typically own or are at a minimum are greatly involved in. Much
knowledge and effort are required by an organization to ensure
that the appropriate level of training is afforded to employees. In many businesses the Health & Safety professionals are well
Traditionally, qualified electrical worker safety training has ingrained in the contractor safety management process. Often
revolved primarily around the electrical, instrumentation and companies have a contractor safety management system with
controls staff at a facility, although many non-electrical, the general expectation that contractors will abide by host
unqualified employees have occupational exposures to electrical employer specific job safety requirements (company standard
hazards and should be covered by the ESP training strategy. In and site standard). This is no different with electrically skilled
their 2017 IEEE paper titled, “Changing the Electrical Safety contractors although some electrical work may go beyond the
Culture” the authors communicated, “Training for non-electrical capabilities of the host employer or contractors that do other
workers is a missing element in today’s electrical safety specialized work that may cross the line into qualified worker
culture”[3]. We propose that to embrace the holistic training tasks like HVAC specialists. Involving the safety professionals in
approach to all the affected employee groups and ensure the the ESP process, enables more help to catch these potential
right people are getting the right content, that companies are far compliance gaps providing an opportunity to reduce both safety
better off when the safety professionals are integrated in the and business risk to the contracted work. In closing, many
process assisting the electrical leaders. experiences and thoughts have been shared to illustrate why and
The training process should be formally outlined in the how the H&S professionals should help own the ESP, but with
company ESP and documented as part of a training matrix. that said, these comparative advantages alone will not get the
Training assignments should be based on the electrical risk organization to the level of success needed. It can be similarly
potential associated with roles and responsibilities and must also compared to the three-legged stool referenced in the 2018 NFPA
include management responsibilities. The H&S professionals 70E Handbook that indicates the fact that NFPA 70E cannot
must be included in the training process the same as managers alone be enough to get you there.
and supervisors, as they largely have overall responsibility to Refer to Fig. 2, which represents the Electrical Safety three-
oversee the Health & Safety Program, of which the ESP is legged stool. It takes more than just the electrical safe work
included [4]. Employees and contractors that work in a facility practices standard, it also takes necessary design, installation
whose roles and responsibilities do not include operating or and maintenance standards. This can be similarly thought of as
maintenance activities are considered electrically unqualified a circle of success that takes three groups for an effective and
and should be trained at an awareness level to be able to identify compliant ESP. The H&S professionals, the Electrical Engineers
and avoid electrical hazards. This generally is incorporated into and the Operations & Maintenance teams are all crucial
site specific safety orientations and includes locations of elements necessary to make it work but must have leadership
overheard power lines, general risk recognition to exposed circuit commitment and support to succeed. Refer to Fig. 3, which
parts, understanding barricade restrictions, access to electrical represents the groups necessary to build and implement an
equipment rooms, etc. Employees whose roles and effective ESP.
responsibilities necessitate operating and interacting with
electrical equipment require a higher degree of electrical safety
training and demonstrate the adequate skills and knowledge to
safely perform the tasks. Employees that work as electricians or
instrumentation and controls technicians also have very specific
electrical safety training requirements and should be assessed
on a frequency not to exceed a year, to demonstrate the core
competencies necessary to identify, assess, control and
eliminate risks associated with electrical shock and arc flash /
blast. This also includes ensuring minimum emergency
response related training (i.e. CPR, First Aid & AED) has been
provided and current in accordance with the training certifying
agency for Qualified Electrical Workers and those fulfilling
electrical attendant duties as well. These are all examples, but
not an inclusive list of training that may be required and related
to electrical safety. A Learning Management System (LMS) is a
very helpful tool that helps an organization manage the training
and compliance deliverables and again, something that the H&S
Professionals should own or where a Learning and Development
capability is in place, at least be heavily involved with.
The last group that should be considered is the contractors
performing electrical work activities at a facility. This is usually
the most at-risk group due to unfamiliarity to a company’s safety
culture, facility specific operations, processes and hazards. Fig. 2 Electrical Safety Three-Legged Stool
Although as a host employer a facility is not required to
electrically qualify contractor employees, there should be due
diligence efforts done to verify that an ESP exists as part of the
contractors H&S Program and that their employees have been
properly trained.

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Fig. 3 Groups Necessary for ESP Success
V. CONCLUSIONS
In closing, much has been expressed related to the importance
of utilizing an OHS management system and establishing an
effective partnership to create, manage and sustain an effective
ESP. In his 2019 paper, “Maintenance Errors As Cause For
Electrical Injuries – What We Can Learn From Aviation Safety”
author H. Landis Floyd II conveys “The opportunity and methods
to establish management commitment, engage a multidiscipline
team and achieve synergy with electrical safety and reliability
improvement can be facilitated using the framework of
management systems standards such as ANSI Z10
Occupational Safety and Health Management Systems and ISO
5500X Asset Management.” Also among the many good
considerations to ponder, he leaves us with the question “How
would you rate the collaboration and synergy among safety
professionals, maintenance professionals, key members of
management, and the electrical experts with respect to driving
improvement in the electrical safety and the reliability &
maintenance programs in your organization?” highlighting the
importance of a team approach for not only electrical safety, but
other critical capabilities.
VI. ACKNOWLEDGEMENTS
The authors would like to express recognition and appreciation
to Rene’ Graves, Lanny Floyd, Ken White, Dennis Hill and other
IEEE ESW Committee Members for their encouragement,
support and patience in writing this paper. Additionally, we would
like to acknowledge the authors of the several great papers
reviewed as part of the development process for this paper (D.
Ray Crow, Danny Liggett, Mark Scott, Dennis Neitzel, Mark
Cross, Mike Doherty, Joseph Andrews, Dr. Mary Capelli-
Schellpfeffer, Thomas Neal, Lynn Saunders and the NFPA 70E
technical committee members). Lastly, a very special thanks to
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Nelson Amy of ISPIC (Industrial Safety & Performance
Improvement Consultants, LLC) who has been an excellent
mentor, teacher, and influential leader in helping H&S
Professionals with building and advancing an electrical safety
culture change across the many businesses he and his
associates have supported over the last decade.
VII. REFERENCES
[1] NFPA 70E, 2018 Standard for Electrical Safety in the
Workplace, Quincy, MA: NFPA.
[2] NFPA 70E, 2018 Handbook for Electrical Safety in the
Workplace, Quincy, MA: NFPA, Exhibit 110.1
[3] D. Ray Crow, Danny Liggett, Mark Scott, Changing the
Electrical Safety Culture, IEEE Publication ESW2017-09,
Pg. 1, 3
[4] Dennis Neitzel, Electrical Safety Training Requirements for
All Personnel, IEEE Publication 978-5386-2582-8, Pg. 5
[5] NFPA 70E, 2009 Standard for Electrical Safety in the
Workplace, Quincy, MA: NFPA, Article 110.7, FPN 2
[6] H. Landis Floyd II, A System Safety Approach To
Occupational Electrical Safety, IEEE Publication 2014-CIC-
0031, Pg. 1
[7] H. Landis Floyd II, Maintenance Errors As Cause For
Electrical Injuries – What We Can Learn From Aviation
Safety, IEEE Publication ESW2019-28, Pages 1, 7
[8] H. Landis Floyd II, Joseph J. Andrews, Mary Capelli-
Schellpfeffer, Thomas E. Neal, Lynn F. Saunders, Electrical
Safety: State of the Art in Technology, Work Practices and
Management Systems, IEEE Publication 360
[9] H. Landis Floyd II, Mike Doherty, Rene Graves, Electrical
Safety Management, 2010 ASSE PDC, Baltimore, MD June
13 – 16, 2010
VIII. VITA
Jeremy Presnal graduated from Indiana State University with
a Bachelor of Science degree in Occupational Safety & Health
Management. He started his career as a Safety Specialist in the
electric utility industry in 2004 and served in various safety
leadership roles supporting power generation plants and major
capital expansion projects. In 2015, he joined a petrochemical
company to lead the refineries field safety and occupational
health teams, OSHA VPP and co-chaired the Electrical Safety
Task Force. In the fall of 2017, he transferred over to the
company’s international Building Products business as a Division
Safety & Health Manager and is a key member of the Corporate
ESWP Technical Committee. He is a member of IEEE and past
speaker at ESW 2019, a professional member of ASSP
(American Society of Safety Professionals) and the Assistant
Administrator of the ASSP UPS (Utilities Practice Specialty). He
is a Certified Safety Professional (CSP), Certified Electrical
Safety Professional (CESCP), Construction Health & Safety
Technician (CHST), OSHA VPP Special Government Employee
(SGE) and holds other board-certified professional safety
designations.
Herb Houston graduated from Embry-Riddle Aeronautical
University in Prescott Arizona with a Bachelor of Aeronautical
Science degree with a minor focus on Airline Transportation. He
started his career in aviation as a flight instructor, teaching pilot
candidates at the university level in 1999. In 2002, he joined a
national airline as a First Officer achieving second in command
status in both the J4100 and CRJ-200 aircraft. In 2007, he joined
an international building products company as a Safety & Health
Manager, serving both site and division corporate needs. In 2018
he was nominated to serve on the organization’s Corporate
ESWP Technical Committee and serves as an ESWP SME for
the Building Products, OSB and CP Divisions. He is a Certified
Flight Instructor for Instrument and Multi engine fixed wing
aircraft and holds numerous other FAA flight ratings. He is
currently a member of IEEE and working to earn his Certified
Safety Professional (CSP) certificate.

Greg Maberry graduated from Texas A&M University as a

double major in Biology & Entomology in 2009 and later
graduated from the University of North Texas Health Science
center, receiving a Master of Public Health in Environmental and
Occupational Health and Safety in 2012. He has been involved
in the application of Safe Working Practices in personal, process
and electrical safety since 2013, starting in upstream oil and gas,
venturing to downstream refining and is currently serving as
Regional Safety Supervisor in the midstream gas industry. He is
a member of IEEE and past speaker at ESW 2019. He is a
Certified Safety Professional (CSP), Certified Electrical Safety
Professional (CESCP) and holds several other board-certified
professional safety designations.

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