Bulletproof Your Safety Documentation

CSA Z462, Clause 4.1.7.1, requires employers to “implement and document an overall electrical safety program”, while 4.1.7.6 states “this program shall identify a hazard/risk evaluation procedure”. Note (1) to this clause references Annex F, where an explanation of the intent and processes involved can be found. In addition, Figure F.1 provides a procedural flow chart and F.2 a figure of the logical steps, while Figures F.3 and F.4 give an example of an evaluation procedure form.

These should be integral to your Job Briefing meetings mandated by Clause 4.1.7.7, and should include Figure I.1 from Annex I and Figures J.1 and J.2 from Annex J.

These documents may look foreign, but note that Z462 is a standard—meaning you can create your own ‘standard’ or elements thereof. Should an accident occur, all that will matter is whether the standard or elements you used prove you had been duly diligent? The answer in the case of documents: “Yes”.

Common documents used within safety programs are the: Job Hazard Analysis (JHA); Safe Work Procedure; Safe Work Practice; and Code of Practice.

Job Hazard Analysis (JHA)
The JHA is a specific tool for a relatively simple task, and can be filled out very quickly. This is a minimum practice, and you don’t want your crews to miss it. Train them thoroughly in completing a JHA during safety meetings, and insist that it be done prior to every job.

In my classes, I ask: “How many people fill out JHAs in the truck when you’re leaving the job?”, and I always get confirmation that this is happening. This puts your crew, yourself and your company at risk. Should an accident occur and this activity is discovered during the investigation, the report will label your company as having a poor safety culture.

The JHA typically has a section at the top for identifying the work location, workers, task, etc., and the remainder of the document is divided into three columns. In the left column (#1), you break down the task into a series of steps. In the centre column (#2), you identify hazards associated with a particular step, and in the right column (#3), you identify control methods for mitigating each hazard.

Some organizations create JHAs ahead of time. These may be generic and modified at the time, or specific, then double-checked for accuracy. Most JHAs are specific and created by the crew as part of pre-job planning. Once one is completed, it becomes part of the safety program for future use. Put whatever is created into your files so you can prove years of correct practice if you’re ever investigated.

Safe Work Procedure (SWP)
A Safe Work Procedure (a.k.a. Standard/Safe Operating Procedure) is a detailed instruction for a more complex task; it expands on JHA’s #1, outlining one method of performing a task and is generally done beforehand. It may not be the only way to accomplish the task, but when done in this manner, it is highly unlikely that an accident or an injury will occur.

There is no definitive layout to an SWP; each organization will have its own distinct style, but each SWP identifies the work location, workers, task, etc., and lists a sequence of statements describing exactly what to do. The hazards and control methods are also identified, either separately or within the steps. A JHA is not required when an SWP is used. The SWP must include sign-off dates and revision numbers.

Within both a JHA and an SWP, the intent of Annex F (including Figures F.1-F.4, as well as Annex I, Figure I.1, and Annex J, Figure J.2) can be achieved. What cannot be achieved is Annex Figure J.1, the Sample Energized Electrical Work Permit.

A permit needs to be completed when energized work is performed. The Annex I Note states: “This Annex is not a mandatory part of this Standard”. That just means you do not necessarily have to use this exact form, but you do need some kind of form, and it better include everything that is shown in J.1. Therefore, you may as well use J.1 as it is shown, in addition to a JHA or SWP. (Troubleshooting and diagnostics do not require an Energized Work Permit, but you should still complete a JHA.)

Safe Work Practice
In your Electrical Safety Program, include Safe Work Practices: generic safety statements that, when followed, help prevent accidents, and preserve health and safety. For example: “Capacitors - Electrical workers must be aware of the substantial energy and subsequent arcs that can be produced in equipment that includes capacitors; these may cause electrocution or burns to workers or ignite material”.

Code of Practice (CoP)
A Code of Practice is a collection of related Safe Work Practices. For instance, you might create a “CoP for Outdoor Substations”, and your safety program could grow to include many CoPs. (There will be repetitive statements in your “CoP for Indoor Substations”, but that’s okay; having them individually allows you to focus on them during training and job planning.)

Your safety documentation is Risk Management 101 for your people and the equipment on which they work, but it needs to be done properly.

Until next time, be ready, be careful and be safe.