When it Comes to Electrical Safety, OSHA Standards can be Technical and Confusing

What requirements do safety managers need to know?

Wouldn’t it be nice to know exactly what OSHA is training its inspectors to look for during an inspection that includes electrical safety, including surprising new areas of emphasis based on national OSHA directives? This article covers some of the typical electrical safety questions that OSHA inspectors will ask during a field investigation.

For electrical safety in the workplace, OSHA relies on expert consensus bodies such as the National Fire Protection Association (NFPA) and its standards published in NFPA 70E. To ensure that employers are following NFPA and OSHA guidelines, OSHA trains its inspectors and compliance officers to ask specific questions in the event of an electrical safety incident. Some typical questions are as follows:

Is there a description of the circuit or equipment at the job location?

OSHA expects employers to know their workplaces. If an employer cannot provide a written description or drawing of the circuit or equipment, then the compliance officer may assume that the employer has not assessed the facility for electrical hazards.

Is there a detailed job description of planned work?

In order to know which safety procedures to use, the employee must be provided with a description of the job task. OSHA publication 29 CFR 1910 lays out employer responsibilities for protecting their employees from electrical safety hazards. It states that the employer must train employees to use safe work practices that are designed to avoid injury.

Can you justify why equipment cannot be de-energized or the job deferred until the next scheduled outage?

As stated in 29 CFR 1910.333(a)(1), live parts to which an employee may be exposed must be de-energized before the employee works on or near them, unless the employer can demonstrate that de-energizing introduces additional or increased hazards or is not feasible due to equipment design or operational limitations.

The message is clear: never work on live circuits unless it is absolutely necessary. OSHA allows work on live circuits in some cases, but the reason cannot be simply that turning off the power is inconvenient or will interrupt production. Nor can employees use the excuse that they didn’t have the authority to shut off power.

When it is necessary to perform work on energized equipment, 29 CFR 1910.333(a)(2) requires safety-related work practices to be used and NFPA 70E Article 110.8(B)(1) requires an Electrical Hazard Analysis before work is performed on live equipment operating at 50 volts and higher.

OSHA wants employers to make electrical safety procedures and practices part of regular work processes. Several annexes to NFPA 70E offer guidelines for lockout/tagout procedures, checklists and approvals. For example, Annex E covers Electrical Safety Programs, Annex F covers Hazard Risk Evaluation Procedures, Annex I covers Job Briefing Checklists and Annex J covers Energized Work Permits.

NFPA 70E annexes are not strictly “enforced” by OSHA, as they are appendices to the NFPA standard. However, OSHA inspectors and investigators will ask if the content and information contained in these annexes was followed and adhered to.

If an OSHA inspector came knocking on your door, would you know the answers to the following questions?

• Were required electrical safety analyses performed?
• Was an arc flash hazard analysis performed?
• Were flash protection boundaries established?
• Were all other potential electrical hazards identified?

OSHA regulations state that every employer must furnish a place of employment free from recognized hazards that are causing or likely to cause death or serious physical harm, and that the employer must assess the workplace to determine if hazards are present and select PPE to protect employees.

When it comes to electrical safety, OSHA refers to NFPA 70E, which requires employers to conduct an electrical hazard assessment consisting of a shock hazard analysis and an arc flash hazard analysis before work is performed on live equipment operating at 50 volts and higher. These requirements may be fairly complex, as they involve calculating the potential fault current at each piece of equipment, understanding the characteristics of the over current protective devices and how they are coordinated for each circuit, and creating or updating one-line electrical drawings. Complex or not, OSHA inspectors are trained to ask if these analyses were performed, because they are essential to reducing the number of electrical shock and arc flash-related deaths and injuries.

When the safety of any job task involves electricity or electrical equipment, ask yourself these questions:

• Could the equipment be locked out and de-energized?
• Was a hazard analysis performed?
• Were proper tools and equipment used, including insulated tools?
• Was the necessary PPE determined?
• Were insulated blankets and/or sheeting used to properly cover live parts?
• Were the employees performing the tasks qualified to do so?

For more information, call 908-442-8599, email at contact@TotalEnviron.com.