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Is my company required to have an arc flash risk assessment?

Many times over the years, I've been asked , "Is my company required to have an arc flash risk assessment completed?"  Technically, the answer is “No."  In reality, though, the answer is "Yes."

That’s a frustrating answer. Like many of you, I am a black-and-white-kind-of guy. Gray areas frustrate me. When I ask a question, I want an answer. The answer to the question above sounds more like a political answer than a real answer. I wish it were more straight forward, but, unfortunately, it is not. Let me explain.

Let’s start with the regulations, standards, and laws of the OSHA (Occupational Safety & Health Administration) and NFPA (National Fire Protection Association).

OSHA was formed in 1971 to ensure safe and healthy working conditions for workers and enforcement of standards through training, outreach, education, and assistance. OSHA is the law and it applies to most private sector employers.

Next, there is the National Fire Protection Association (NFPA) which was formed in 1896 to address the design and installation of fire sprinkler systems. Soon after its formation, NFPA created the National Electrical Code. Since that time, NFPA has expanded guidance in other areas and there are currently over 300 NFPA codes and standards on topics such as electrical installation and safety, healthcare, life safety, emergency backup systems.....

What is the difference between OSHA and NFPA?

The primary difference is that OSHA is the law and NFPA is not. OSHA was created as an act of Congress, and is, therefore, enforceable by law. NFPA is not the law, but is a private organization whose standards are recommendations on how to apply the law (OSHA standards).

OSHA is the law while NFPA is the road map
OSHA is performance based while NFPA is prescription based
OSHA is the "shall" while NFPA is the "how"

How does this apply to electrical safety?

The NFPA standard that addresses electrical safety is NFPA 70E - The Standard for Electrical Safety in the Workplace.  NFPA 70E addresses all areas of electrical safety for the worker, including Lockout - Tagout, Electrical Safety Programming, Personal Protective Equipment, Shock Prevention and Arc Flash Protection.

NFPA 70E compliance requires that an arc flash risk assessment be performed that includes calculating the level of arc flash hazard within the electrical equipment and ensuring awareness of the risk in the form of a warning label that contains the incident energy and arc flash boundary on all electrical equipment over 50 volts.

As mentioned above, NFPA is technically not the law and is not enforceable as such.  OSHA, however, is the law, and requires the employer to protect the employee from recognized hazards.  Arc flash is a recognized hazard.  OSHA leans on NFPA 70E to satisfy this requirement.  So the question becomes....

If you are not using NFPA 70E arc flash requirements to protect workers from the recognized hazards of arc flash, then what are you doing?

According to OSHA’s website, while OSHA does not enforce NFPA 70E, OSHA may use NFPA 70E to support citations relating to OSHA standards. Remember, OSHA is the “shall” and NFPA 70E is the “how”. As of the current time, NFPA 70E has only been the “how” when it comes to OSHA enforcing electrical safety for workers and protection against arc flash. Therefore, the technical answer to the question, “Is an Arc Flash Risk Assessment required by OSHA?”, is “no”. The reality, however, is that NFPA 70E provides the only true road map for satisfying OSHA requirements for protecting against the recognized hazard of arc flash.

Future articles will explain the objectives of an arc flash risk assessment and the steps involved. In the meantime, thank you for taking the time to read this article. If you have any questions or comments, I can be reached at the email or phone number below.

Mitchell & Lindsey is a nationwide company who performs arc flash risk assessments, provides training, implements safety programs, inspects and tests electrical equipment and evaluates NFPA 70E compliance. If we can be of service to you in any or all of these areas, please reach out to me via the phone number or email below.

Thank You and Be Safe!

Bobby Lindsey – CESCP
Mitchell & Lindsey – President
M: (502) 836-4217