A question that comes up often in training classes on NFPA 70E is “Who enforces these requirements?” Many believe that OSHA will enforce them, but that is not true—OSHA will implement its own regulations. In accordance with the OSHA Field Operations Manual, guidance is provided on how to cite OSHA violations. This document does permit citing an alternate standard such as 70E. However, when this is done, the agency must first cite the OSHA standard that was violated. 

It is the employer’s responsibility to enforce electrically safe work practice requirements in accordance with 70E. The driving force to create 70E was a request from OSHA to NFPA to develop a standard with prescriptive requirements to address electrically safe work practices. 

While OSHA will not typically cite 70E requirements, it will use the standard to (1) prove a hazard existed, and (2) prove the impact of that hazard could have been eliminated or mitigated through the implementation of 70E requirements. 

OSHA recently published a document providing guidance to protect employees from arc flash hazards. It is long overdue. It is not a regulation, but it does give employers recommendations and describes existing OSHA regulations that apply to arc flash hazards. It is well understood that obtaining empirical data to quantify the yearly number of arc flash occurrences and injuries in the United States is difficult. However, we know they occur every day. 

Misperceptions

The guidance provided does illustrate misperceptions many electrical workers have. The first myth is that if equipment is de-energized, it is safe. That is incorrect. De-energizing is just one step in the creation of what 70E designates as an electrically safe work condition (ESWC). The act of de-energizing alone does not eliminate electrical hazards; an ESWC in accordance with 70E must be created to eliminate the hazard while the ESWC is maintained. 

The second misperception is that justified energized work is inherently safe. Again, this is incorrect. Justified energized work includes, but is not limited to, tasks where the equipment is in a normal operating condition, the employer demonstrates infeasibility or the employer shows that de-energizing introduces additional hazards or increased risk. It is imperative to note that while there may be justification for energized work, the potential severity may preclude that task. 

Informative material

When applying 70E, note that half of this standard is informational material in the form of annexes. Informative Annex Q deals with human performance and workplace electrical safety. Anyone involved in electrical safety or safety in general should read and implement the material in this annex; it is that important. We are all fallible and all make mistakes. Work conditions may be challenging, but they are usually manageable.

Informational Annex Q points out that individual performance is influenced by organizational processes and values. The guidance OSHA provides emphasizes worker participation mirroring the information in Annex Q. Employers need to create a culture where workers feel comfortable sharing safety concerns and will step forward to report hazards and near-misses. Training in electrically safe work practices is imperative and must include processes and procedures. 

It is interesting to note that in the guidance provided, OSHA recognizes its regulations require assessing the workplace for hazards but include no prescriptive components on what needs to be in the assessment or how it is to be performed and documented. This is an excellent example of the adage commonly used in electrically safe work practice training: “OSHA is the shall, and NFPA 70E shows the employer how.” 

Prescriptive requirements for shock risk assessments exist in 70E 130.4 and arc flash risk assessments in 130.5. The OSHA guidance mirrors 70E requirements for normal operating conditions and the likelihood of arc flash incidents. See the definition of “hazard, arc flash” (arc flash hazard) and the informational notes that follow. The guidance recognizes the 70E boundaries and limited, restricted and arc flash as triggers that invoke requirements in 70E. 

PPE requirements

The incident energy analysis and the arc flash PPE table method are discussed by OSHA as permitted methods to determine exposure, arc flash boundaries and necessary PPE. OSHA recognizes that due to the nature of electrical work in existing buildings and structures, it is difficult or impractical to implement risk control methods such as substitution. Where justified energized work is to be performed, shock and arc flash risk assessments must be done to determine the necessary PPE. 

It is important to note that in almost every case, more than one risk control method can be applied. This includes, but is not limited to, engineering controls such as an arc energy reduction maintenance switch. 

OSHA notes that most arc flash burn injuries come from flammable clothing being worn instead of arc-rated PPE. If employees are not wearing arc-rated clothing, they are wearing fuel.

Shahid/stock.adobe.com