Commonly asked questions and answers regarding Electrical Safety Standards for the Work Place.
(NFPA 70E, OSHA, and other electrical safety Programs)
Does OSHA enforce the NFPA70E regulations?
No. OSHA enforces its own standards. In the United States, only the U.S. Department of Energy requires compliance with NFPA70E. Otherwise, NFPA 70E is an American National Standard. As such, the standard describes normal and reasonable measures to prevent injury from electrical hazards. NFPA 70E is a voluntary standard for everyone except employees and contractors under the jurisdictions of the U.S. Department of Energy.
However, OSHA has several comparable standard requirements that are enforceable. Such as:
29 CFR 1910.132 (d)(1): Requires employers perform a personal protective equipment (PPE) hazard assessment to determine necessary PPE.
29 CFR 1910.269 (l)(8)(i): Requires estimate of incident energy be determined.
29 CFR 1910.332 (b) Content of training. (1): Practices addressed in this standard. Employees shall be trained in and familiar with the safety-related work practices required by 1910.331 through 1910.335 that pertain to their respective job assignments.
29 CFR 1910.333 (b)(2)(iv)(B): A qualified person shall use test equipment to test the circuit elements and electrical parts of equipment to which employees will be exposed and shall verify that the circuit elements and equipment parts are deenergized…”
29 CFR 1910.335 (a)(1)(i): Employees working in areas where there are potential electrical hazards shall use electrical protective equipment appropriate for the specific parts of the body for the work being performed.
29 CFR 1910.335 (a)(1)(iv): Requires employees wear nonconductive head protection whenever exposed to electric shock or burns due to contact with exposed energized parts.
29 CFR 1910.335 (a)(1)(v): Employees shall wear protective equipment for the eyes or face wherever there is danger of injury to the eyes or face from electric arcs or flashes or from flying objects resulting from an electrical explosion.
29 CFR 1910.335 (a)(2): Employees shall use insulated tools or handling equipment when working near exposed energized conductors or circuit parts.
29 CFR 1926.28 (a): Employer shall require employees wear appropriate personal protective equipment (PPE) during construction work.
Although OSHA may not specifically enforce NFPA 70E, they can and have cited electrical safe work practice hazards with existing OSHA standards. The best practice is to protect and safe gaurd your employees by performing an electric arc flash study; train qualified employees in electrical safe work practices including arc flash hazards; and provide arc rated clothing as well as voltage-rated gloves and tools.
Who enforces the NFPA70E?
As noted, NFPA 70E is an American National Standard. NFPA 70E is not enforced until an organization elects to enforce it. If an organization adopts NFPA 70E, the adopting organization becomes the enforcing agency. Note, however, that NFPA 70E defines reasonable and normal protective measures, rather than exceptional or unusual protective measures.
Who writes the NFPA 70E?
Members of the public write NFPA 70E. The process for generating the standard is guided by the NFPA Regulations Governing Committee Projects, available on the NFPA Web site (www.nfpa.org). The NFPA Regulations Governing Committee Projects meets or exceeds requirements defined by the American National Standards Institute (ANSI). One characteristic of the process s is that a technical committee of people expert in the subject being considered discuss public proposals and comments submitted by members of the public. As described in the NFPA Regulations Governing Committee Projects, the technical committee includes representatives from all sectors of general industry, chosen through an application process.
Does NFPA 70E have an economic benefit?
An electrical safety program is a sound economic investment. Studies conducted by the Construction Industry Institute report an annual return on investment of between four and eight times. In addition, common sense tells us that preventing injuries means preventing incidents that result in damaged equipment, lost production, medical expenses, additional training expense, legal expenses, insurance expenses, and similar negative results. NFPA 70E discuss requirements that prevent injuries and associated incidents, which means that following NFPA 70E does have an economic benefit.
What is so important about the notes that follow the tables in the NFPA standards?
A table establishes a default condition for very complex process. The limiting characteristics of the complex process are defned by the information contained in the notes. If the limit defined in the noted is exceeded, the table does not apply. For example, Note 1 to NFPA 70E 2012, Table 130.7(C)(9)(a) indicates short circuit current of 25 kA and a clearing time of 2 cycles. If the short circuit current exceeds 25 kA or the clearing time exceeds 2 cycles, the table does not apply and a flash hazard analysis is necessary.
Knowing the limiting conditions of the complex process means knowing when additional information or analysis is necessary. The table notes tell what information is needed for the default condition to apply. If the situation is different, the default information should not be used.
What is a basic electrical safety program?
An electrical safety program is a concrete manifestation of a company’s philosophy about the safety of its workers. It is a set of documents that guide actions and reactions for an employer. The documents define policies, procedures, training, and auditing.
An electrical safety program should develop a standard way to communicate by defining all terms used in that workplace. For example, the term hot work is often used for two different meaning: It might refer to work done on an energized circuit or to work that is thermally hot. The term has no consensus meaning. If a workplace uses that term, then the workplace’s electrical safety program should define how that term is used.
A specific person or persons should be responsible for maintaining and updating a company’s electrical safety program. The person or persons responsible should review and revise the program regularly, taking into account new equipment and machinery, new procedures, and new employees as necessary.
What is the role of an employee in developing an electrical safety program?
Both OSHA and consensus standards assign the responsibility of providing an electrical safety program to employers. The same documents assign the responsibility of implementing defined requirements to employees. However, for the program to be effective, employees should participate in developing procedures and practices. Employees should have hands-on experience with particular equipment, and are frequently familiar with exposure, or of ways of reducing exposure. Electrical safety programs reach maximum effectiveness when employees and employers work together to develop the content of the program
Why is safety auditing important?
Auditing provides information about the condition of the electrical safety program. An effective audit will indicate the state of training and whether defined requirements are adequate. Audits provide information to employers and employees. After the electrical safety program is in place, auditing is the only viable method to determine if the program is effective without monitoring injuries or incidents.