We write it for your operation — your equipment, your crews, your contractors, your shift patterns — not from a template with another company’s plant in it. A program that does not describe how work is actually done at your site is worse than no program: it is a signed statement that you know the right answer and do something else.
| Element | Who owns it | What document proves it | What breaks without it |
|---|---|---|---|
Scope and responsibilities 70E 110.3 · Annex E |
A named senior manager, not a job title | The program’s own front matter: what it covers, which sites and which contractors, and who is accountable for each part. | Every other element becomes optional. Nobody can be asked why a requirement lapsed if nobody was ever named against it. |
Electrically safe work condition policy 70E 110.2 · 110.6 · Annex G |
Operations, with EHS holding the standard | A documented policy that puts hazard elimination first, plus the test instrument requirements that make a verified absence of voltage meaningful. | De-energising becomes a preference rather than a default, and the decision to work live moves to whoever is holding the tool. |
Risk assessment procedure 70E Annex F |
EHS, applied by supervision | A written method with a repeatable output — the same task assessed by two people should reach the same control decision. | Risk assessment reduces to individual judgement, which cannot be trained, audited, or defended after an incident. |
Hierarchy of risk control 70E Annex F |
Engineering and maintenance leadership | Evidence that higher-order controls were considered and rejected for a reason — not a PPE selection with the earlier steps left blank. | PPE becomes the whole safety system. The employer ends up protecting people from a hazard it had the option to remove. |
Qualified and unqualified person definitions 70E Article 100 · 110.4 |
The manager who assigns work | A roster naming individuals, the equipment and tasks each is qualified for, and the evidence of demonstrated ability behind it. | Qualified drifts to mean experienced. Work gets assigned by availability, and the maintenance technician takes the electrical job. |
Training and retraining 70E 110.4 · OSHA 1910.333 |
EHS, with budget held by operations | Dated records showing content, instructor, attendees, how competence was assessed, and when each person is next due. | You can prove attendance but not competence — the distinction an inspector draws first, and the one a plaintiff draws hardest. |
Energised work permit process 70E Article 130 · Annex J |
A manager senior enough to stop production | Completed permits held on file, each recording the justification, the assessment behind it, and an approval signature from outside the crew. | Energised work becomes routine and invisible. Nobody with authority to refuse ever sees the request in time to refuse it. |
PPE programme 70E Annex H · OSHA 1910.132, 1910.137 |
Maintenance leadership and stores | Selection traceable from task to garment, plus issue, inspection, care, storage, test intervals for rubber insulating equipment, and retirement. | Correct equipment is bought and then quietly degrades. Gloves stay in service past their test interval because nobody owns the calendar. |
Contractor and host employer coordination 70E 110.5 |
Procurement, jointly with the site | A written exchange in both directions, dated before mobilisation: hazards disclosed by the host, practices and qualifications evidenced by the contractor. | A symmetrical assumption — each employer believes the other assessed the hazard, and the contract crew works to neither program. |
Incident investigation Program-level requirement |
EHS, reporting to the named program owner | Investigation records that reach a program cause, and a documented route from that cause back into a procedure or training revision. | Near misses are closed as individual error. The same event recurs, now with a documented history of it having happened before. |
Audit and review cycle 70E 110.3 · Annex E |
The named program owner | A dated audit record, a revision history on the program itself, and the triggers that force a review between scheduled ones. | The program ages out silently. It stays true to the plant it was written for, which stopped existing three equipment changes ago. |
Not out of fashion — wrong. A citation that points at an article number the standard no longer uses is a finding anyone can verify in a minute, and it is the first thing we look for when a client sends us an existing program.
Buying the right arc-rated clothing is the easy part and the part most sites have already done. The programme is everything after purchase: how a task maps to a selection, who issues and records it, how garments and rubber insulating equipment are inspected and stored, what the test intervals are and who holds that calendar, and the rule for taking something out of service.
Written to OSHA 29 CFR 1910.132 and 1910.137, with selection guidance read against NFPA 70E Informative Annex H. The failure we see most is not the wrong garment — it is the right garment with no record that anyone has looked at it since it arrived.
What happens in the first four minutes, written down before it is needed: how contact is broken safely, who is trained in release and resuscitation and how that currency is tracked, where rescue equipment lives and who checks it, how emergency services are met and directed to a site they do not know.
This is not a theoretical gap. Among the violations OSHA cited against Eversource Energy Service Co. following a fatal arc flash and blast in Boston were missing rescue equipment and no oxygen level testing before vault entry — response failures, cited alongside the work-practice ones. Source: OSHA news release 23-20-BOS, 12 January 2023.
Plant changes, crews turn over, contractors are replaced, editions advance. The review cycle is the element that keeps every other element honest — and it is the one that quietly stops happening once the consultant has left.
Led by a Certified Safety Professional (CSP) with 35+ years in EHS and electrical safety. The people who write your program are the people who stand in front of your crews and teach it — a useful discipline, because a document you have to defend to an electrician in a room gets written differently.
About the practiceSometimes, and we will say so if the bones are sound. More often the template describes an operation that is not yours, and editing it costs more than writing a program that starts from your plant. We tell you which case you are in before you commit.
Not necessarily. If you have no program at all, the baseline phase does the work an audit would. If you have one you are unsure about, an audit is the cheaper way to find out whether it needs rewriting or revising.
You do, outright and editable, with no licence tied to us and nothing to renew. If you never call us again the program still works. It carries your name, not ours, because you are the one accountable for it.
Yes, and the program will name the study as a gap and specify what it must cover, including dc. We do not perform incident energy analysis or produce labels — that is engineering work — but the program should not wait on it.
Duration follows the number of sites, the state of the current documents and how quickly your reviewers turn drafts around. Fixed scope, quoted up front — the quote does not move once scope is agreed, and there is no hourly meter.
The change list read against the standard itself, with the Chapter 3 renumbering set out article by article.
Read the article →The trigger mechanism that decides whether a written program stays true after the plant changes underneath it.
Read the article →What a PPE programme has to cover once the clothing has been bought, and where the records usually stop.
Read the article →Fixed scope, quoted up front. Procedural work only — no incident energy analysis studies, no arc flash labels.