More commercial and industrial facilities are developing an Electrical Safety Program (ESP) their employees can follow to reduce shock and arc flash exposure working about electrical equipment. However, many of those same facilities (owners) believe that since the electrical equipment has general labeling i.e. WARNING ARC FLASH AND SHOCK HAZARD Appropriate PPE and Tools Required when working on this equipment, affixed to the equipment that it would be the worker(s) and/or another contractor(s) responsibility to identify what depth of PPE is needed to satisfy that work. Even though worker(s) and/or contractor(s) have responsibility to wear the appropriate PPE to reduce their exposure to electrical hazards, the owner, or the owner’s designated representative, is accountable for defining the depth of the electrical hazards that may cause or are likely to cause death or serious harm to those workers.

In general, owner/employer accountability goes back to the Occupational Safety and Health Act (OSHA) of December 29, 1970, which states “An Act: To assure safe and healthful working conditions for working men and women…’’ Section 5 of the Act goes on to state that an employer “shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees”. OSHA 1910.132 General Requirements, under Subpart I, Personal Protective Equipment: Section 1910.132(d)(1) states “The employer shall assess the workplace to determine if hazards are present, or likely to be present, which necessitate the use of personal protective equipment (PPE)”. Section 1910.132(d)(1)(i) states the “employer shall select, and have each affected employee use, the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment”.

Since the 2002 edition of the National Electrical Code (NFPA 70) Article 110.16 Arc Flash Hazard Warning has identified electrical equipment, in other than dwelling units, that is likely to require examination, servicing or maintenance while energized shall be field marked to warn workers of potential arc flash hazards. Informational Note 1 to 110.16 refers to NFPA 70E (Electrical Safety in the Workplace) for assistance in determining the potential exposure, safe work practices, and PPE requirements.

OSHA recommends that employers consult consensus standards such as NFPA 70E-2015 to identify safety measures that can be used to comply with the requirements of OSHA’s standards for protecting employees from the severity of arc flash hazards:

NFPA 70E-2015 Article 130.5 identifies that an arc flash risk assessment (arc flash study) shall be performed to determine if a hazard exists. If an arc flash hazard exists, the risk assessment (arc flash study) shall determine the arc flash boundary where the arc flash ‘incident energy’ is no greater than 1.2 cal/cm2; a.k.a. Arc Flash Boundary. For any worker inside the arc flash boundary and exposed to energized electrical equipment, or any workers verifying the electrical equipment is at a ‘zero energy state,’ those workers shall wear the appropriate arc flash and shock PPE as required based on their working distance. Also, the results of the arc flash risk assessment (arc flash study) shall be documented and maintained by the equipment owner/employer.

NFPA 70E-2015, Article 110.5(D) Equipment Labeling states “The owner of the electrical equipment shall be responsible for the documentation, installation, and maintenance of the field marked label’. The article also states the field-marked label shall contain: (1) Nominal system voltage; (2) Arc Flash Boundary; (3) At least one of the following: a) Available incident energy and corresponding working distance…, b) Minimum arc rating of clothing, c) Site-specific level of PPE.

The Occupational Safety and Health Act has been in place for some 45 years as law defining employer (owner) accountability for worker safety in the workplace. This accountability includes defining (calculating) the available ‘incident energy’ at the electrical equipment and labeling that equipment so the worker(s) know what type and depth of PPE will be required. For those employers who say “arc flash labeling does not apply to their commercial or industrial facility because their employees don’t work on energized electrical equipment“, BE CAREFUL… OSHA considers the verification of a zero energy state to be ‘live’ electrical work requiring the worker(s) to wear appropriate PPE, and that PPE is defined from completing a risk assessment (arc flash study) by the owner or the owner(s) designated representative.