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Employer Responsibilities Under OSHA
| OSHA regulations were developed to mandate that employers provide a safe workplace for their employees. The following sections of standard CFR Part 1910 promote the safety of employees working on or near electrical equipment, and clearly define employers' responsibilities: |
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- Equipment must be deenergized before work is performed!
In addressing work on electrical equipment, 1910.333(a)(1) states:
Live parts to which an employee may be exposed shall be deenergized before the employee works on or near them, unless the employer can demonstrate that deenergizing introduces additional or increased hazards or is infeasible due to equipment design or operational limitations.
- Lockout/tagout procedures must be used
In Note 2 of 1910.333(b)(2), it states:
Lockout and tagging procedures that comply with paragraphs (c) through (f) of 29 CFR Part 1910.147 will also be deemed to comply with paragraph (b)(2) of this section, provided that:
[1] The procedures address the electrical safety hazards covered by
this Subpart; and
[2] The procedures also incorporate the requirements of paragraphs
(b)(2)(iii)(D) and (b)(2)(iv)(B) of this section
- If equipment cannot be deenergized prior to work:
- Employees must be properly protected
When employees are required to work where there is a potential electrical hazard, 29 CFR Part 1910.335 calls for the employer to provide:
...electrical protective equipment that is appropriate for the specific parts of the body to be protected and for the work to be performed.
The appendix to Part 1910 Subpart S references NFPA 70E as providing information that "can be helpful in understanding and complying with the requirements contained in Subpart S."
- Employers are responsible for performing a hazard assessment
29 CFR Part 1910.132(d)(1), hazard assessment and equipment selection, states:
The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). If such hazards are present, or likely to be present, the employer shall:
1910.132(d)(1)(i) 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;
1910.132(d)(1)(ii) Communicate selection decisions to each affected employee; and,
1910.132(d)(1)(iii) Select PPE that properly fits each affected employee.
This is the section referred to in the OSHA standard interpretation that discusses NFPA 70E. The remainder of 1910.132 outlines the requirements for the design, application, proper selection, training and documentation required for the use of personal protective equipment.
Other Regulations Relating to Arc Flash Hazards
OSHA 29 CFR Part 1910 contains many other sections that pertain to electrical safety and arc flash hazards:
- Subpart S: Paragraphs 1910.301 to 1910.399 address electrical safety requirements, particularly sections 1910.331 through 1910.335, which concern electrical safety work practices
- Subpart I: Paragraphs 1910.132 to 1910.139 cover personal protective equipment
- Subpart J: Paragraphs 1910.141 through 1910.147 discuss general environmental controls, including lockout/tagout
In addition, 29 CFR Part 1926, Safety and Health Regulations for Construction, Subpart K, contains requirements for electrical safety in paragraphs 1926.400 through 1926.449.
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