When workers performing maintenance or repairs on energized electrical equipment, they could be exposed to an arc flash hazard. Where this situation is likely, the industry standard NFPA 70E requires a marking on the equipment that warns the workers about that specific hazard. However, OSHA's regulations don't directly address arc flash hazards. Does OSHA require companies to follow the industry standard?
Does OSHA Enforce NFPA 70E's Requirements?
In 2006, OSHA published a letter of interpretation responding to this question. The answer: technically, no. But that's not the whole story.
As the OSHA representative said, "OSHA has no specific requirement" for arc flash labeling. However, OSHA does have regulations requiring employers to "mark electrical equipment with descriptive markings, including the equipment's voltage, current, wattage, or other ratings as necessary." This rule can be found in 29 CFR §1910.303(e).
Additionally, the representative pointed out, a separate OSHA regulation requires employers to use alerting techniques such as safety signs to "to warn and protect employees from hazards which could cause injury due to electric shock, burns or failure of electric equipment parts." This rule, §1910.335(b), makes it clear that employers need to warn their employees about any electrical hazards that exist in the workplace.
NFPA 70E: A Good Approach
While OSHA has not incorporated NFPA 70E into law, and no OSHA regulation specifically requires arc flash labels, the letter indicates that arc flash hazards are a recognized threat to worker safety. Known hazards in the workplace must be addressed, and the NFPA 70E standard describes a widely-accepted approach for this particular hazard.
Richard S. Terrill, the Regional Administrator for OSHA in Seattle, stated that "though OSHA does not, per se, enforce the NFPA standard... OSHA considers [it] a recognized industry practice."
Terrill also pointed out here is also a general OSHA regulation for workplace hazards that require Personal Protective Equipment (PPE). The NFPA 70E process for assessing arc flash hazards and selecting appropriate PPE for them offers a good way to meet OSHA's requirements in this area.
"The employer is required to conduct an assessment in accordance with 29 CFR §1910.132(d)(1). If an arc flash 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."
This illustrates an important fact about OSHA and industry standards. Often, OSHA regulations will require employers to provide for the safety of their workers, but will not specify exactly how that must be done. Another organization, like the NFPA, will create a voluntary standard for the issue, using expert opinion and industry consensus. As these voluntary standards become popular, OSHA will use them as benchmarks to determine if employers are taking appropriate steps to protect their employees.
The regulations tell employers what they need to do; the industry standards tell employers a good way to do it.
What Does OSHA Require?
OSHA's regulations in 29 CFR 1910 Subpart S, part of OSHA's General Industry regulations, discuss electrical safety. These regulations state that "Safety related work practices shall be employed to prevent electric shock or other injuries resulting from either direct or indirect electrical contacts...." In general, employers have a number of responsibilities under this regulation:
- Creation and documentation of a facility electrical safety plan with defined responsibilities
- Documented training in electrical and arc-flash safety, for both electrical workers and any other workers who might be affected
- Identification and analysis of arc flash hazards
- Provision of adequate personal protection equipment
- Placement of warning labels on equipment
- Provision of proper tools for safe electrical work
- Verification, through annual inspections, that individual employees are complying with established safe work practices
OSHA regulations usually don't establish specific safety practices (for instance, detailed rules for selecting PPE). Instead, relevant industry standards such as NFPA 70E may be used as "how-to guides" for reaching the goals set out by the OSHA requirements.
What Does NFPA 70E Require?
First, NFPA 70E requires an arc flash risk assessment to be conducted. This will determine the degree of danger posed by given equipment under expected circumstances. If the assessment determines that there is a significant risk of arc flash, then a more in-depth analysis is called for. This analysis will determine the information that needs to be on the arc flash label, such as the Arc Flash Boundary and the kind of PPE that will be required to work within that boundary.
NFPA 70E (2015 edition) requires arc flash labels to include:
- Nominal System Voltage
- Arc Flash Boundary
- At least one of the following:
- Either the Available Incident Energy and the corresponding Working Distance, or the Arc Flash PPE Category for the equipment, but not both
- Minimum Arc Rating of Clothing
- Site-Specific Level of PPE
These details will be different for different pieces of equipment in different installations, and may even change for different types of maintenance work. In order to be accurate, the labels need to be applied in the field, based on an assessment that considers the actual installation and the work that will be performed. As a result, an on-site custom label printer may be an important part of your NFPA 70E compliance plan.