Issue #7   Are you prepared, should an OSHA representative come walking into your facility?

Osha Representative

OSHA standards can be technical and confusing when it comes to electrical safety. A good place to start is to learn how OSHA approaches to electrical safety. OSHA’s ultimate goal is to prevent accidents from happening by enforcing certain safety precautions. Although OSHA and its requirements are often dreaded and their fines can be pretty heavy, they are actually a very valuable asset to every company in the U.S. OSHA’s regulations prevent accidents that would likely result in serious injury or even death. This in turn also prevents lawsuits that would occur as a result of such accidents, which can cost a business well over $30 million in medical costs, litigation, lawyer fees, lost business, and damaged equipment costs.


To stay within OSHA’s requirements an employer must identify all electrical hazards that could possibly happen and those that are likely to happen.


Prior to 1970 OSHA’s focus was on process changes, encouraging companies to de-energize circuits before any work be done. Perform and enforce lockout/tagout procedures and develop safety programs that include worker training and regular updating. However, accidents were still occuring, therefore more detailed regulations were needed to be developed and enforced. So, OSHA then adopted the NEC’s (National Electrical Code) and the National Fire Protection Association’s (NFPA) electrical safety standards (published in NFPA 70e) to now be used as the consensus standard.


A more recent area of emphasis is electrical arc flash safety, which means electrical safety professionals, such as Industrial Training University, must analyze the workplace for arc flash hazards, establish safe protection boundaries, post ANSI approved arc flash warning labels on every electrical panel (category 1 or above, ITU labels all panels), and define what personal protective equipment (PPE) must be used within these boundaries. OSHA trains their inspectors and compliance officers to ask specific questions in the event of an electrical incident.

Some of the following questions are what you might expect an OSHA representative to ask during a field investigation.

  • Is there a description of the circuit or equipment at the job location?
  • OSHA expects employers to know their workplaces. If an employer cannot provide a written description or a one-line drawing of the circuit or equipment, then the OHSA Representative will assume that the employer has not assessed the facility for possible electrical hazards and therefore is not in compliance. A one-line drawing (both hard copy and digital version) is included with ITU’s Arc Flash Analysis.
  • Is there a detailed job description of planned work? In order to know which safety procedures to use, the worker must be provided with a detailed description of the job task. OSHA 29 CFR 1910 publication lays out the employers responsibilities for protecting their employees from electrical related accidents. It states that the employer is required to properly train workers on electrical equipment and how to apply safe work practices that are designed to avoid or prevent potential hazards.
  • Can you justify why equipment cannot be de-energized or the job deferred until the next scheduled outage? Per OSHA 1910.333(a)(1), de-energize live parts to which employees may be exposed. This must be done before any work can be done on or near live parts, unless the employer can demonstrate that de-energizing introduces additional or increased hazards or is not feasible due to equipment design or operational limitations. Therefore, OSHA will allow work on live circuits in some cases but it must be for good reason and an electrical hazard analysis is to be done before work can be performed on equipment that operates at 50 volts or higher. NFPA 70E Article 110.8(B)(1)

Other questions you might get from an OSHA representative include:

  • Do you have an established safety program in place and are safety procedures enforced?
  • Do you have records or jobs performed?
  • Was a job briefing checklist performed and completed before the job was started?
  • Did proper management approve and sign off on the job before it was started?
  • OSHA’s goal is to make electrical safety procedures and practices part of the daily work processes. NFPA 70e 2004 & 2009 offers several annexes to use as guidelines for various procedures.
  • Annex E covers Electrical Safety Programs
  • Annex F covers Hazard Risk Evaluation Procedures
  • Annex I covers Job Briefing Checklists
  • Annex J covers Energized Work Permits
  • An OSHA representative may even ask if these annexes were followed when the procedures were developed.

Other questions may include:

  • Has an arc flash analysis been performed and if so were flash protection boundaries established?
  • Has the proper Personal Protection Equipment (PPE) been acquired?
  • Have the proper insulated tools been made available to the workers?
  • Have Arc Flash Warning labels been posted on all electrical panels category 1 or above and if they have are they ANSI approved warning labels?
  • Were the workers doing the job qualified to do so and can you provide proof of training?
  • Has your staff been through an up to date Electrical Safety Training class? If yes: can you provide certificate of completion?
  • Were insulated blankets and/or sheeting used to properly cover all of the live parts?

OSHA regulations state that every employer shall furnish a place of employment free from recognized hazards that are causing or likely to cause death or serious physical harm, and that the employer must assess the workplace to determine if hazards are present and select PPE to protect employees.


Industrial Training University provides Arc Flash Analysis which covers everything you need to be in compliance with OSHA and NFPA as well as an online Arc Flash Supply store where you can acquire your Personal Protection Equipment (PPE) as well as all the tools and supplies you might need at an affordable price.
The Analysis also includes ITU’s NFPA 70e Electrical Safety Training class which will educate you on electrical safety procedures, such as how to apply the proper PPE, and make it easier for you to confidently answer any question an OSHA representative may ask.


OSHA’s requirements are very complex and detailed. Therefore, interpreting OSHA and NFPA 70e’s requirements can be a very confusing task. Call ITU at 866-851-9993 or go to ArcFlashEngineering.com and find out how ITU can help getting into compliance easy and affordable.