One of the more common questions that I am asked pertains to “arc flash”. Employers and supervisors want to know….. (1) What does the law say? …..and (2) what do I need to do?
A short answer to question 1, as far as what is mentioned specifically about arc flash in the 1910 General Industry regulations is not very much. If you read the Electrical sections in Subpart S, you’ll see it is briefly mentioned at 1910.335 (a)(1)(v) where it talks generically about PPE and protecting a person’s eyes and face. This lack of detail in my opinion is because the last amendment to this standard was written in the early 1980’s. Changes to any law are hard to legislate and but this one is long overdue. The 1910 standard was taken from the National Electric Code (NEC). Technological advancements in electrical equipment hardware and flame resistant (FR) clothing are just a few of the items that should be mandatory for a safe work environment. The NEC standard that is most often referenced is also referred to as NFPA 70E. A major take away from these two standards is that OSHA has not adopted 70E, but rather considers compliance to it as a best practice. 70E is considered an industry consensus standard. If you are still concerned about compliance, a November 14, 2006 Letter of Interpretation further explains in detail about how the 1971 OSHA General Duty Clause applies to violations by companies to the 70E requirements.
For question 2, I start off by referring them back to 1910.132 where you must assess the work place. This is where you must first identify the hazard in the workplace. Then you assess the identified hazard(s). Lastly, you then create and implement a plan to eliminate the hazard risk. To most employers at this point this is where having the proper PPE comes into play. Unfortunately engineering and administrative (labels and signs) controls are bypassed to go straight to the last line of defense….the PPE. For an example of what they need to do besides PPE, I mention, that while 70E arc flash is not required, there are labeling and marking requirements that are required (1910.333). Additionally with the hazard assessment, which by the way should be a written signed document, any PPE also requires specific training of that equipment. As always, it goes without saying, if you don’t also document the training, OSHA looks at that as if it never happened.
John Sutton CSP, CHMM
NIBCO of Virginia, Inc.