If we have our electrical panels [mcc] labeled with the hrc labels do electrical contractors working at the plant on mcc, have to follow the rules of 70e and use the correct ppe?

If they do not then I would think their employer is at risk, but just because it is labelled and they do not comply, I would not assume that your company is off the hook if there is an incident.

Company policy/contracts should require them to comply, but I would audit them as well to be sure.....just as with your own employees.

Yes they do, the 70E is very specific about that in 110.5

Many companies require thier contractors to be pre-qualified, the attached form is commonly used.

Yes they do as mentioned see 110.5
(B) Contract Employer Responsibilities.
(1) The contract employer shall ensure that each of his or her employees is instructed in the hazards communicated to the contract employer by the host employer. This instruction is in addition to the basic training required by this standard.
(2) The contract employer shall ensure that each of his or her employees follows the work practices required by this standard and safety-related work rules required by the host employer.
(3) The contract employer shall advise the host employer of: a. Any unique hazards presented by the contract employer’s work,

Seems pretty clear to me!

OSHA and OH&S Regulations

Whether you are in the USA or Canada the applicable Occupational Health & Safety Regulations apply to employees and contractors. The owner is accountable for "worker" safety when the "worker" is on their property working on their electrical equipment.

Your Electrical Safety Program should have Contractor Management section that outlines your policies with respect to contractors:

1. Pre-qualification orientation to your Electrical Safety Program.
2. Validation of contractor competency.
3. Contractors don't use owner's Electrical Specific PPE, Tools & Equipment.
4. Contactors must follow the requirements of your Electrical Safety Program.

Unfortunately in my audit work I interview Supervisors that don't understand their roles, responsibilities and accountabilities to OSHA or OH&S Regulations.


Terry Becker, P.Eng.
ESPS Electrical Safety Program Solutions INC.
terry.becker@espsi.ca
403-465-3777