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 Post subject: 70e compliance questions
PostPosted: Tue Oct 26, 2010 11:40 am 
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Joined: Tue Oct 26, 2010 10:48 am
Posts: 1
I am new to the form and before I ask my questions I should give you a bit of info about my company. We a a medium sized electrical and HVAC contractor employing around 80 people and are looking to become OSHA VPP in the near future. We do work in large industrial manufacturing plants all the way down to small residential work. We have a active Safety Committee and sometime the Board of directors and the Safety Committee do not see eye to eye( just like every other place).

Right now there seems to be some struggle on the 70e compliance. The Safety Committee believes that we need to have a written ESP in place before we can be considered 70e compliant and the board believes that all we have to do is issue the correct PPE and use table 130.7(c)(9) to be compliant.

At this time we have all the PPE that is required and would like to start using it thinking that will make us 70e compliant.

At some of the larger facility's we work at they have done the Arc Flash Hazard Analysis but equipment (robot cells, lasers, punch presses) moves all the time changing the analysis.

Do we need to train our employees how to use the calculations for incident energy and flash protection boundary's? Dose anyone know what the steps to become 70e compliant are? What needs to be in our ESP? What type of training do we need to do? Should we hire an outside company to do our training and write our ESP (please remember that we are all electricians or HVAC tec's not teachers and Lawyers)?

Your thoughts would be helpful. Thank you in advance.


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PostPosted: Tue Oct 26, 2010 11:56 am 
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Joined: Mon Jun 02, 2008 11:58 am
Posts: 1103
Location: Charlotte, NC
huntcrazy wrote:
I am new to the form and before I ask my questions I should give you a bit of info about my company. We a a medium sized electrical and HVAC contractor employing around 80 people and are looking to become OSHA VPP in the near future. We do work in large industrial manufacturing plants all the way down to small residential work. We have a active Safety Committee and sometime the Board of directors and the Safety Committee do not see eye to eye( just like every other place).


Yep, sounds liek just about every other place.

huntcrazy wrote:
Right now there seems to be some struggle on the 70e compliance. The Safety Committee believes that we need to have a written ESP in place before we can be considered 70e compliant and the board believes that all we have to do is issue the correct PPE and use table 130.7(c)(9) to be compliant.


Safety commitee is right, if you do nto have a written ESP in place, OSHA will see that as nto having any ESP's at all. Article 110.7 in the 70E specifically requires "documentation"

huntcrazy wrote:
At this time we have all the PPE that is required and would like to start using it thinking that will make us 70e compliant.


Being 70E compliant is a lot more about not working on energized equipment than it is about wearing PPE.

huntcrazy wrote:
At some of the larger facility's we work at they have done the Arc Flash Hazard Analysis but equipment (robot cells, lasers, punch presses) moves all the time changing the analysis.


That requires the analysis and label if affected, to be updated. Article 130.3

huntcrazy wrote:
Do we need to train our employees how to use the calculations for incident energy and flash protection boundary's? Dose anyone know what the steps to become 70e compliant are? What needs to be in our ESP? What type of training do we need to do? Should we hire an outside company to do our training and write our ESP (please remember that we are all electricians or HVAC tec's not teachers and Lawyers)?

Your thoughts would be helpful. Thank you in advance.


The requirements for training are outlined in detail in 110.6. I suggest you hire a outside vendor to help you with becoming compliant. Your company may have created a huge problem by doing the study and issuing PPE before establishing any written ESP or training thier people.

I caution you, there are a bunch of Yahoos out there offering training and compliance services, do your homework. Our host at this forum can help you out and I highly recommend his company.

The attached checklist will get you started on the right path.


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