Peggy LaVaque, peggyl@agc-oregon.org

Safety and Loss Control Consultant, East and Southeast Portland Metro Area, Columbia

Gorge to The Dalles

 

Historically, the National Electrical Code (NEC) and other safety codes have been

primarily concerned with protection from fire, electrocution, and shock hazard—arc flash

hazards were not specifically addressed. This is now changing; the 2002 NEC contains

requirements for warning labels, and the National Fire Protection Association (NFPA)

70E—2004 and Institute of Electrical and Electronics Engineers (IEEE) 1584-2002

provide guidance on implementing appropriate safety procedures for arc flash hazards.

 

The ruling is straightforward. Companies are required to make arc flash hazards an

integral part of an ongoing documented safety program. The official ruling from the

Department of Labor states:

 

“Though OSHA does not, per se, enforce the NFPA 70E standard, OSHA considers the

NFPA Standard a recognized industry practice. The employer is required to conduct

hazard assessment in accordance with 29 CFR 1910.132(d)(l), and 1926.28(a).” The

employer is responsible to:

    1.   Assess the hazards in the work place

    2.   Select, have, and use the correct personal protective equipment (PPE)

    3.   Document the assessment

    4.   Train their staff on the hazards

 

“If an arc flash hazard is present, or likely to be present, then the employer must select

and require employees to use the protective apparel. Employers who conduct the

hazard/risk assessment, and select and require their employees to use protective clothing

and other PPE appropriate for the task, as stated in the NFPA 70E standard, are deemed

in compliance with the Hazard Assessment and Equipment Selection OSHA Standard.”

 

In short: Follow NFPA 70E to be in compliance. But even more importantly, follow the

NFPA 70E to protect employees. Don’t confuse what is needed with what is required.

 

What Does OSHA Expect From Me?

OSHA expects quite a bit, actually. Safety is not to be a passive, reactive policy that is

brought out after-the-fact or for show-and-tell. Reviewing some of the major requirements:               

     ●   Employers must know what their employees do. Understand that 1910.296 only

          applies to power generation, transmission, and distribution installations and

          related equipment. Supplementary electric generating equipment (emergency,

          standby, or similar purposes) is only covered in Subpart S. OSHA 20 CFR

          1910.269(a)(2)(iii) states: “The employer shall determine, through regular

          supervision and through inspections conducted on at least an annual basis, that

          each employee is complying with the safety-related work practices required by

          this section.” OSHA would consider that tasks that are performed less often than

          once a year to necessitate retraining before the performance of the work practices

          involved.

     ●   Employees must be trained in their job tasks. OSHA 29 CFR 1910.332 states:

          “The training requirements contained in this section apply to employees who face

          a risk of electrical shock that is not reduced to a safe level by the electrical

          installation requirements.”

(1)   Deenergized parts. Live parts to which an employee may be exposed shall be

       deenergized before the employee works on or near them, unless the employer

       can demonstrate that deenergizing introduces additional or increased hazards

       or is infeasible due to equipment design or operational limitations. Live parts

       that operate less than 50 volts to ground need not be deenergized if there will

       be no increased exposure to electrical burns or to explosions due to electric

       areas.

 

 Note 1: Examples of increased or additional hazards include interruption of

 life support equipment, deactivation of emergency alarm systems, shutdown

 of hazardous location ventilation equipment, or removal of illumination for an

 area.

 

 Note 2: Examples of work that may be performed on or near energized circuit

parts because of infeasibility due to equipment design or operational

limitations include testing or electric circuits that can only be performed with

the circuit energized, and work on circuits that form an integral part of a

continuous industrial process in a chemical plant that would otherwise need to

be completely shut down in order to permit work on one circuit or piece of

equipment.

 

 Note 3: Work on or near deenergized parts is covered by paragraph (b) of this section.

                       ●   In addition, review and consideration of 1926.416(a) {3/K} is a must.

 

                   So where should you focus your attention? It seems logical that safe work practices

                   should be the focus, and you should ensure that you have qualified personnel who

                   understand the hazards involved with the specific tasks they are required to do for their

                   jobs.

 

                  One of the best features of 70E is the tables, specifically Table 130.7. This will assist you

                  in choosing what PPE is required for standard tasks that electrical workers perform.

 

                  What Can You Do?

 

                  Get up to speed on the regulations and the NFPA Standard 70E.

 

                  The real reason we should apply the OSHA regulations and NFPA 70E is because no one

                  wants to see another person injured or killed. If we make decisions based on a lack of

                  knowledge, it can have a negative consequence on our employees’ lives and on our future.

 

                  For a copy of the NFPA 70E Standard, visit www.nfpa.org. For copes of the U.S.

                  Department of Labor Occupational Safety & Health Administration Standard

                  Interpretations, visit www.osha.gov.

 

                 Standard Interpretations: 10/18/2006 – Incorporation of NFPA 70E-2000 into OSHA

                 Standards, and 07/25/2003 – General Duty Clause (5(a)(1) citations on multi-employer

                 worksites; NFPA 70E electrical safety requirements and personal protective equipment.