I am a new member of the Arc Flash Forum. My goal here is to find a resource and to be a resource where I may. I have been in the electrical field for 21 years and an Electrical Engineer for the past 9 years. I have created an ESWP Policy and program for an international mfg.

My question is what percentage of the electrical workforce do you think complies with OSHA 1910 subpart s by practicing NFPA 70E?

First off, welcome to the forum.

As far as your question goes, that varies regionally and by what part of the electrical workforce you are asking about. (I.E. Resi EC or Industrial Maint Electrician. HV testing tech or Utility worker)

I think that the answer varies a lot depending on the region of the country. Without trying to sound prejudice and just to state my own observations, I see FR more common on the East and West Coasts than in the South. It will also change with the employer. Large multinational organizations tend to conform to OSHA and NFPA codes sooner than the smaller privately owned firms. There are also a lot of residental and light commercial electrical contractors out there that don't comply.

But if I had to venture a guess, that included all of the Lower Continental 48 States, my guess would be 4% to 6%.

Compliance

We have been guiding many companies down the NFPA 70E compliance road. It is difficult to say how many actually comply. I can say with a high degree of confidence that the larger the company, the more sensitivity to the issue exists. If you are looking at statistics, this is a regulatory driven program. As OSHA focuses more and more on electrical safety (and they are) you will see the compliance numbers go up. This is still in its beginning stages, similar to the control of hazardous engergy (LOTO) 10 years ago.

John,
I'm not sure I would agree with you about compliance. Arc Flash is only enforceable under the OSHA General Duty Clause. That means that no OSHA audit can capture the lack of an Arc Flash program. There is no requirement in OSHA that references or requires an Arc Flash program. The only way it would be enforceable would be if there was an accident, then OSHA could fine the employer for lack of compliance to the General Duty clause. But I would think this is only possible as a reactive action, and not as a pro-active action.

OSHA requirement for Arc Flash Programs

Thank you for the reply several of you made. I'm new to this so I hope I am approaching continuing a thread the right way. My original question was regarding what percentage of the electrical workforce is in compliance with NFPA 70E Standard for Electrical Safety in the Workplace. I agree the percentage is low, and I also agree from activity on my web site each coast, Texas, Ohio, and Pennsylvania are active.

One reply indicating that OSHA would only be reactive to an incident is a topic I would like to follow up on. I think in general OSHA is forced to be reactive. They are undermanned and do not have the inspectors to proactively inspect for general compliance. The target industries and target regulations, which change from year to year, are less engaged then OSHA would like.

That being said, I do believe OSHA has clearly stated they would like to see compliance with NFPA 70E. What do you think?
From a historical perspective you all have probably seen the time line where OSHA requested NFPA to create 70E.

The argument is 70E has been referenced only, as opposed to incorporated by reference, until last August when the installation guidelines from 70E where incorporated by reference.

Regardless, here are some of the OSHA Regulations I believe show clearly NFPA 70E is expected to be followed.

29 CFR OSHA 1910 Subpart I – Personal Protective Equipment
§1910.132 (d) (1) Employers Shall Asses the Workplace to Determine Hazards
The employer shall asses the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of PPE. If such hazards are present, or likely to be present, 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;

Communicate selection decisions to each affected employee;

Select PPE that properly fits each affected employee.

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29 CFR OSHA 1910 Subpart S – Electrical

§1910.332 Training
Employees who face electrical hazards are required to be trained.

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§1910.332 (b) (1)
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.

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§1910.332 (c)

Type of training. "The training required by this section shall be of the classroom or on-the-job type. The degree of training provided shall be determined by the risk to the employee."

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§1910.332 (b) (3)
Qualified persons (i.e. those permitted to work on or near exposed energized parts) shall, at a minimum, be trained in and familiar with the following:

The skills and techniques necessary to distinguish exposed live parts from the other parts of electric equipment.

The skills and techniques necessary to determine the nominal voltage of exposed live parts.

The clearance distances specified in 1910.333 (c) and the corresponding voltages to which the qualified person will be exposed

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1910.333 (a) (1)

De-energized parts. Live parts to which an employee may be exposed shall be de- energized before the employee works on or near them, unless the employer can demonstrate that de-energizing introduces additional or increased hazards or is infeasible due to equipment design or operational limitations.
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29 CFR OSHA 1910 Subpart S – Electrical

§1910.333 (a) (2)

When working on energized parts other safety-related work practices shall be used to protect employees who may be exposed to the electrical hazards involved.
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§1910.333 (C) (2)
Only Qualified persons may work on electric circuit parts or equipment that have not been de-energized. Such Persons shall be capable of working safely on energized circuits and shall be familiar with the proper use of special precautionary techniques, Personal protective equipment, insulating and shielding materials, and insulated tools.
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§1910.335 (a)(1)(i)

Employees working in areas where there are potential electrical hazards shall be provided with, and shall use, electrical protective equipment that is appropriate for the specific parts of the body to be protected and for the work to be performed.
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§1910.335 (a)(1)(iv)
Employees shall wear nonconductive head protection wherever there is a danger of head injury from electric shock or burns due to contact with exposed energized parts.
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§1910.335 (a)(1)(v)

Employees shall wear protective equipment for the eyes or face wherever there is danger of injury to the eyes of face from electric arcs of flashes or from flying objects resulting from electrical explosion.

29 CFR OSHA 1910 Subpart S – Electrical

§1910.335 (a)(2)(ii)

Protective shields, protective barriers, or insulating materials shall be used to protect each employee from shock, burns, or other electrically related injuries while that employee is working near exposed energized parts which might be accidentally contacted or where dangerous electric heating or arcing might occur. When normally enclosed live parts are exposed for maintenance or repair, they shall be guarded to protect unqualified persons from contact with the life parts.
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§1910.335 (b)
The following altering techniques shall be used to warn and protect employees from hazards which could cause injury due to electric shock, burns, or failure of electric equipment parts:

Safety signs and tags. Safety signs, safety symbols, or accident prevention tags shall be used where necessary to warn employees about electrical hazards which may endanger them, as required by §1910.145.

Barricades. Barricades shall be used in conjunction with safety signs where it is necessary to prevent or limit employee access to work areas exposing employees to uninsulated energized conductors or circuit parts. Conductive barricades may not be used where they might cause an electrical contact hazard.

Attendants. If signs and barricades do not provide sufficient warning and protection from electrical hazards, and attendant shall be stationed to warn and protect employees.

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Subpart S - Appendix A
“The following references provide information which can be helpful in understanding and complying with the requirements contained in Subpart S:â€

NFPA 70E Standard for the Electrical Safety Requirements for Employee Workplaces

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Arc Flash Enforcement

As far as OSHA and enforcement goes, electrical safety is a focus area. Ken Mastrullo from Region 1 is driving this - and actively training the OSHA field force. As an example, during the recent VPPP Region 1 show, approximately 25% of the breakout conference sessions revolved around electrical safety.

The "Electrical Safety Program Book" written by Ken Mastrullo is my favorite. I would like to meet Ken some day to thank him for his works. How is the enforcement being driven? I drive Electrical Safety by speaking at safety conferences and providing the Electrical Safety Managers Position for my division in my place of employment. I also own http://www.eswpco.com. What would you recommend for me to attend to become involved in driving Electrical Safety.

I don't mean to dampen your proactive approach, but it is your question.

As a general rule in this country our government agencies can NOT assume power or authority not specifically granted to them in law. If OSHA is going to fine you, they have to cite the regulation being violated. An employer can meet all the above cited regulations without having an Arc Flash program. The inspector can tell you how much the industry needs more electrical safety awareness, but that's like Obama telling me I am selfish because I don't want to pay more taxes. If there is an accident, the investigator can not cite you under a Arc Flash regulation that doesn't exist - he can only do it under the general duty clause.

The reference I have seen by OSHA to NFPA70E is that OSHA would NOT fine you after an accident for lack of compliance to the general duty clause if you were conforming to 70E. This is a big difference from what you are saying.

Thank you Haze10. I'm glad I found a forum with others this knowledgeable on the subject. We may disagree on the term Arc Flash Program used as the sited regulation, however the components of the program are detailed in the regulations. 1910.132 (d) (1). To assess the hazards of the workplace which necessitate the use of PPE I think specifically says, do an arc flash analysis. 1910.333 (a) (1) Do not work on energized equipment unless necessary. If you do, you must be qualified, §1910.332 (b) (3), and trained,§1910.332 (b) (1). If you are trained and qualified then you will use safe work practices, §1910.333 (a) (2), and protection for specific parts of the body,§1910.335 (a)(1)(i). Shock and burns are specifically identified as electrical hazards §1910.335 (b). All of the major components of a Arc Flash Program are listed, and at the end of 1910 subpart S it says use NFPA 70E to help understand and comply.

Sorry to be long winded and repeat my earlier list, but placed in one paragraph, it looks like an Arc Flash Program to me.

In the end I am glad the emphasis and study is taking place. Compliance will come over time.

To this group, my next question is why electricians don’t want to use Arc Flash Clothing. I have a list. Grant it some do want to use the equipment.

Go to new Thread. "Resistance to using arc flash clothing"