September 4, 2019SAFETY AND INSPECTIONS
OSHA Electrical Safety Requirements to Pass Inspection
Many people who work in maintenance know that the Occupational Safety and Health Administration (OSHA) is a federal agency that operates under the authority of the Department of Labor. It functions under a mandate which not only develops regulations set forth by the Occupational Safety and Health Act (OSH Act) but to also enforce them.
OSHA electrical safety is just one of the many sections under the Act that requires electricians to meet a number of requirements.
We will discuss what those requirements are, how the OSHA enforces them and why they should matter to you.
Let’s dive in.
OSHA Electrical Safety Requirements
Do you have employees who work with electricity? Then according to the Act, you have a responsibility to provide safe working conditions.
There are many fields where workers work directly with electricity, not just electricians. Engineers, HVAC Mechanics, and many more. These are potentially dangerous jobs which can include, but is not limited to, working on a variety of:
- motorized equipment
- overhead power lines
- circuit assemblies
- cable harnesses
Are the dangers of electricity limited to these types of workers? No. Even people who work in the following jobs could be indirectly exposed to the inherent dangers of electricity:
- office workers
- machine operators
It doesn’t really matter which of the two lists above that your employees fall into, they are due a safe workplace. In accordance with that, the OSHA’s electrical standards have been designed with a view of protecting employees who have jobs that expose them to explosions, electrocution, and electric shocks.
Depending on your industry, there are a number of set electrical standards. They are as follows:
› 29 CFR 1910 General Industry OSHA Electrical Standards
This standard has 3 subsections:
- (Subpart I) Personal protective equipment (PPE)
- (Subpart R) Special industries
- (Subpart S) Electrical
These are covered by 1910.137 (Electrical Protective Equipment)
› 29 CFR 1915, 1917, and 1918 Maritime Industry Electrical Standards
- (Subpart L) Electrical machinery
- (Subpart G) – Related terminal operations and equipment
These are covered by Standard Number 1915.181 and 1917.157. (Electrical Circuits and Distribution Boards and Battery Charging and Changing respectively).
› 29 CFR 1926 Construction Industry Electrical Standards
- (Subpart K} – Electrical
- (Subpart V) – Electric Power Transmission and Distribution
It’s imperative you understand these are just a fraction of the requirements, as this is just the Federal component. On top of these, there is a list of other rules which depend upon your state.
At the time of writing this, there are 28 other states in the US that currently maintain OSHA approved state-level plans, so you need to check and see if any apply to you.
To assist both employers and employees, the OSHA requested the National Fire Prevention Association (NFPA) to produce the National Electrical Code, standard 70, and Electrical Safe Work Practices, standard 70E.
The purpose of the NFPA 70E is to help avoid accidents and fatalities in the workplace caused by arc flashes, shock electrocution, and arc blasts. This also aids compliance of the above-mentioned OSHA 1910 Subpart S and OSHA 1926 Subpart K.
Electricians that maintain their responsibilities of their individual trades by adhering to both the NFPA 70 and 70E will, for the most part, also be OSHA compliant.
However, all trades, whether in the General Industry segment of the Construction Industry segment will have additional responsibilities to meet and adhere to.
› States That Maintain Full OSHA Plans
The following states are authorized to oversee inspections and enforcement:
- North Carolina
- Puerto Rico
- South Carolina
› States That Maintain Partial OSHA Plans
- New Jersey
- New York
- The Virgin Islands
It should also be noted that often times state plans are even more stringent than OSHA rules, and they will sometimes differ as well.
How OSHA Electrical Safety Requirements are Enforced
There are two ways in which the OSHA can and will enforce its requirements.
- It enforces the OSH Act’s general duty clause.
- Through the enforcement of regulations requiring employers to implement health and safety precautions.
With regards to the first, the Act’s clause states that all employers must “furnish to each of its employees conditions of employment and a place of employment free from recognized hazards that are causing or are likely to cause death or serious injury or harm to its employees.”
What are the ramifications of violating these OSHA clauses?
Obviously, the health and welfare of your employers are put in jeopardy but there are significant monetary fines levied as well.
- Non-serious violations: to a maximum of $7000
- Serious violations: to a maximum of $7000
- Willful violations: to a maximum of $70000
- Repeated violations: to a maximum of $70000
- Failure to abate: to a maximum of $7000 per day
However, the OSHA is within their rights to reduce any penalty they see fit depending on the circumstances.
Working in Line with OSHA Electrical Safety Requirements
So what can you as an employer do to help prevent any kind of electrical accident in the workplace?
Here are some general guidelines that support the OSHA Electrical Safety Program:
- All electrical equipment should pass a visual inspection before use
- Use equipment properly and for its intended purpose only
- Never use defective—or unapproved—equipment
- Always make sure all power supply systems, electrical equipment, and electrical circuits are properly ground
- Don’t use portable electric tools in wet areas or around exposed wires
- Follow lockout/tagout procedures
- When working near power lines only use non-conductive materials such as wood or fiberglass
Passing an OSHA Electrical Safety Program Inspection
In order to pass an OSHA Electrical Safety Program inspection, you need to be ready to answer some questions that will likely—if not certainly—come up during an inspection.
In the following ,I’ll cover some of the typical questions an OSHA Inspector will ask, what they mean to you, and what you need to do be prepared and in compliance if and when an inspection happens.
First, it’s interesting to note that the OSHA has changed what they focus on. They used to look at process changes but now they’re more focused on is arc flash safety. So it’s important that you stay up to date on what’s expected of you, and what they could be looking for during an inspection.
Here are some typical questions:
Q. Do all job locations have a description of the circuit or equipment?
A compliance officer will expect you to know your workplace. And that will include you providing either drawings or written descriptions of equipment or circuits for your workers.
If these descriptions are not available at the job site, they may conclude that you haven’t assessed a facility for electrical hazards.
Q: Have you provided a detailed job description of all planned work?
Having such a description means workers are able to refer to which procedures much be used to complete the job.
The OSHA has a publication called 29 CFR 1910 which informs employers as to their responsibilities around protecting their employees from all electrical safety hazards. Part of that is they must train their workers on safe practices for each job.
Q: Can you justify why certain equipment can’t be de-energizes or work deferred until a scheduled outage?
OSHA regulations state that live parts should be de-energized before an employee works on them. However, if the employer can prove that doing so would increase or add additional hazards—or it simply isn’t feasible to de-energize—this regulation can be nullified.
Simply put, your workers should never be working on live circuits unless it’s absolutely necessary.
Can you prove that’s the case?
A shortlist of other possible questions include:
- Do you have all safe workplace procedures in place?
- Have you established detailed work procedures?
- Do you have a job briefing checklist and is that checklist completed before each job?
Need help creating mandatory job-specific checklists? Consider software like MaintainX that can create them with ease.
The Necessity of Meeting OSHA Electrical Safety Requirements
Despite these standards and requirement being in place, there are still a shocking number of accidents. Unfortunately, the majority of them were fatal electrocutions.
For the past several years the OSHA has sited the same 3 electrical standards as being commonly violated:
- Control of hazardous energy (lockout/tagout), general industry
- Electrical, wiring methods, components and equipment, general industry
- Electrical systems design, general requirements, general industry
You can be sure these will be closely inspected should you get a visit from an OSHA inspector, so be prepared. For your sake, and for the health and safety of your employees.