REPOST by our valued Associate and Author Ralph Carito, Total Environmental & Safety.
When it comes to OSHA standards, they can be technical and confusing, especially electrical standards. Wouldn’t it be nice to know exactly what OSHA inspectors are trained to ask and look for during an electrical inspection?
A good starting point is to understand OSHA’s approach to electrical safety. OSHA’s goals are to ensure that employers identify electrical hazards, both potential and actual, and have sound procedures in place to eliminate the hazards, such as Control of Hazardous Energy (lockout/tagout) procedures, working with live circuits procedures, energized work permit procedures, and employee training programs. A more recent area of emphasis for OSHA is arc flash safety, which means employers must analyze their workplace for shock and arc flash hazards and establish safe protection boundaries and define required personal protective equipment (PPE).
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 OSHA standards and NFPA guidelines, OSHA trains its inspectors and compliance officers to ask specific questions during an inspection. Below are some typical questions asked during an electrical safety inspection:
Do you have a facility description and/or diagram of the electrical circuits and equipment?
OSHA expects employers to know their workplaces. If an employer cannot provide a written description or drawing of the electrical circuits and equipment, then the inspector will most likely assume that the employer has not assessed the facility for electrical hazards.
Do you have a detailed job procedure for performing electrical work, and have employees been trained on your procedures and applicable OSHA standards?
OSHA wants employers to make electrical safety part of the company culture and regular work process. The only way this happens is if detailed user-friendly procedures have been developed and implemented, and employees have been trained. I’m not saying this is all it will take, but, these are the first steps.
Several NFPA 70E annexes offer guidelines for the development of electrical safety procedures. 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.
Do any employees work on live electrical circuits? If so, can you justify why equipment couldn’t be de-energized or the job deferred until the next scheduled outage?
OSHA says that energized electrical circuits that an employee may be exposed to must be de-energized before the employee works on 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, in which case, other safety precautions must be utilized to protect the worker. Therefore, never work on live circuits unless it is absolutely necessary. If you do allow work to be done on live circuits the reason shouldn’t be simply because turning off the power is inconvenient or will interrupt production. Nor should workers use the excuse that they didn’t have the authority to shut off power.
It’s important to note, that NFPA 70E requires an Electrical Hazard Analysis be completed before work is performed on live equipment operating at 50 volts and higher, as discussed in the next question.
Do you need and have you done an Electrical Hazard Analysis, Shock Hazard Analysis, and Arc Flash Hazard Analysis?
As mentioned earlier, 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 circuit and piece of equipment and understanding the characteristics of the overcurrent protective devices. Complex or not, in the eyes of OSHA, these assessments are essential to reducing the number of arc flash-related deaths and injuries that occur each year.
Did you establish flash protection boundaries?
NFPA 70E has established Shock and Flash Boundaries to reduce the risk of injury to workers due to shock and arc flash hazards. There are four (4) distinct boundaries; limited approach boundary, restricted approach boundary, prohibited approach boundary, and flash protection boundary. The boundaries are determined based on information gathered during the above-referenced hazard analyses, and have different requirements for each. Each boundary is based on the voltage of the energized circuit and/or equipment.
It is important to note that circuits and equipment are considered live when checking for voltage, even if checking to ensure that circuits and equipment have been properly de-energized and, therefore, boundary requirements apply.
Understanding the hazard and the use of appropriate PPE are key to preventing electrical related injuries. OSHA requires employees who work in areas where there are potential electrical hazards to be provided with electrical PPE that is appropriate for the tasks being performed. Of course, the employee must also be made to ware the PPE.
This is no small undertaking, first the employer must facilitate the workers’ understanding of the PPE required for each specific task. Second, employers must select the appropriate PPE to be worn for each potential hazard. Third, the employer must train workers in safety procedures and practices, and in particular, how to match the PPE to the type and magnitude of the electrical hazard. And finally, employers must determine, through regular supervision and inspections conducted annually, that each employee is complying with the employers’ safety procedures and applicable OSHA standards.
Ralph Carito, Total Environmental & Safety, LLC