OSHA and NFPA 70E: A History of Powerful Protection for Employees on the Job
This is how OSHA became the “what we have to do” and NFPA 70E became the “how we accomplish what OSHA requires.” I often am asked exactly how these two critical components of electrical safety in the workplace play off one another. Helping employers make heads or tails of these two separate but related entities is critical for the protection of employees especially in today’s world where electrical infrastructure and technology is evolving so rapidly. A firm understanding of this relationship is instrumental in an employer’s ability to keep up with the hazards present in this ever-expanding electrical landscape.
First, we must examine exactly what the requirements around electrical safety are when it comes to OSHA. This involves a deep dive into OSHA standards. For this blog, we can limit our deep dive to two of the more important standards for electrical safety: 1910 for general industry and 1926 for construction workplaces. When it comes to electrical safety, we first need to understand that the general duty clause of OSHA requires an employer to provide their employees a place of employment that is free from known and recognized hazards. Then specific standards, such as 1910 subpart S give shape to OSHA’s electrical safety requirements. 1910.331 lays out that subpart S requirements apply to both qualified and unqualified workers. This same section shows exactly what type of work is covered and what is not covered. This helps us understand exactly who will be following the requirements laid out in Subpart S. In 1910.333, we find that it requires safety related work practices to prevent electric shock or other injuries resulting from either direct or indirect electrical contacts. There is also a requirement that all live parts to which an employee might be exposed be placed in a deenergize state before the employee works on or near them. However, there are some exceptions for when the employer can demonstrate that deenergizing creates additional hazards or an increased risk to personnel or if they can demonstrate that deenergization is infeasible due to the equipment design or certain operational limitations. An example of infeasibility might be a task that requires a current reading to be taken - it needs the power on in order to make that measurement. For instances that fall under these two reasons for permitting energized work, OSHA also states that other safety related work practices must be used to protect employees who are going to be exposed to the electrical hazards involved with this type of work.
So, where does it say in Subpart S what those work practices are? This is where NFPA 70E comes into the picture. The relationship of 70E to these two requirements in OSHA is critical. First, by requiring all energized parts to be placed in a deenergized state, we need a process for what that state looks like. This is what 70E refers to as an “electrically safe work condition.” Article 110 in NFPA 70E states that an electrically safe work condition shall not be established until all the requirements of Article 120 have been met. Section 120.5 spells out multiple requirements that must be met to accomplish an electrically safe condition to work on equipment. The important thing to remember is that the major steps here are to deenergize the circuit, implement provisions to prevent reenergization, and verify that the voltage has indeed been disconnected and apply any temporary grounds, if needed to prevent accidental reenergization or induced voltages.
What do we do when we don't have a deenergized state? Again, OSHA doesn't spell out what safe electrical work practices employees must follow, and we find ourselves falling back on NFPA 70E to spell out what these work practices entail. In NFPA 70E, we find requirements performing risk assessments for both shock and arc flash hazards. The results of these assessments help employers and employees develop a plan for mitigating the risk to the employee during work. Risk being defined in NFPA 70E as the combination of likelihood of occurrence and the severity of injury resulting from an incident. Once we have the results of the risk assessments, we can take the appropriate steps based on the hierarchy of risk control methods to reduce risk to a more acceptable level. It is important to note that this may entail employees selecting and wearing the appropriate personal protective equipment (PPE) level based on the severity of the hazard involved. However, as the hierarchy shows, PPE must be used as a last resort.
On the construction side, we find OSHA’s electrical safety requirements in 1926 subpart K. Like 1910.333, 1926 requires employers to prohibit work in such a proximity to electric circuit parts such that an employee could come in contact with these parts unless the employee is protected from shock by deenergization or by effective guarding such as insulation. However, who defines what this proximity entails? Once again, we look to NFPA 70E for guidance. 70E spells out what this proximity is since Article 100 defines the limited approach boundary as the distance from exposed energized parts at which a shock hazard exists and the restricted approach boundary as the distance from live parts at which an increased likelihood of shock exists. The restricted approach boundary is thereby the distance at which qualified people must be insulated from the shock hazard and the limited approach boundary is the distance at which 70E requires an electrically safe work condition, unless one cannot be established.
This relationship between what we must do and how we do it has been an area of discussion almost since the beginning of OSHA. Having a firm understanding is paramount to keeping employees safe. This is one of the reasons that I am so looking forward to hearing about how this relationship has developed over the years when NFPA kicks off our 125th Anniversary Conference Series on May 18 with an entire day dedicated to electrical safety! One of the sessions during our “Empowering Electrical Design, Installation, and Safety” program centers around using 70E to help stay compliant with OSHA requirements. It’s being presented by none other than the retired OSHA Director of Engineering Standards, Mr. David Wallis. You won’t want to miss this session! Join us as Mr. Wallis explains the development of what we now have come to expect as a certain level of electrical safety in the workplace.
Learn more about our one-of-a-kind 125th anniversary conference series and register today to participate in the full-day electrical program on May 18. I look forward to seeing you there!
