• Parts of 70E have been around since 1979/1981
• OSHA adopted safe electrical work practices in 1990 based on 70E
• NEC and OSHA now using  - OSHA citations being written on 70E

• Sep 1999 - Major U.S. corporation experienced an electrical accident resulting in serious burn injuries to an electrical apprentice employee. 

• OSHA investigation found several citations. 
  • Employer challenged citations
  • Disagreement ended up before the Occupational Safety and Health Review Commission

• Citation
  • Employer didn't provide appropriate PPE
    • Flame-resistant coveralls and insulated gloves
    • Appropriate face protection

• Employer agreed to develop hazard analysis in accordance with the PPE provisions contained in NFPA 70E.

• OSHA agreed the hazard analysis would achieve compliance with their requirements.

• NFPA 70E is a "Natiaonl Consensus Standard"

• OSHA 29 CFR 1910.2(g) - National Consensus Standard is defined as a standard that is developed by the same persons it affects and then is adopted by a nationally recognized organization.

• Examples of organizations that publish national consensus standards include

  • NFPA

  • ASTM

  • ANSI

1. Electrical Shock
   • Electrocution
   • Internal and external burns
2. Arc Flash
   • Potentially severe external burns
3. Arc Blast
   • Pressure and sound waves
   • Shrapnel (in excess of 700 MPH)

• Electrocution is the FOURTH highest cause of industrial fatalities
• The National Safety council estimates 1,000 fatalities each year are due to electrocution (more than half of them while servicing energized systems of less than 600 volts)
• Over 30,000 non-fatal electrical shock accidents occur each year
• Most of the deaths and injuries that occurred could have been avoided

• One of the hottest things on earth
• Size of arc is independent of voltage
• Amount of short circuit current available determines size of arc
• Responsible for about 75% of all industrial electrical injuries
• Arcs on low voltage systems can be just as dangerous as arcs on medium & high voltage systems

• Determines Trip Time for Each Protective Device based on Arcing Fault Current
• Calculates Incident Energy at Working Distance
• Calculates Arc Flash Boundary
• Determines Required PPE
• Is Used to Generate Warning Labels

• The Arc Flash Risk Assessment needs to be addressed to reduce injuries and fatalities in the workplace
• NFPA 70E is an effective approach for addressing the Arc Flash Risk Assessment
• PPE labeling can clarify the protection level of FR daily wear used with Arc Flash suits
• PPE labeling can indicate approaches to reduce the probability of 2nd degree burn injury
• Workforce involvement and Education are key to launching an FR daily wear & PPE Program for the Arc Flash Risk Assessment

Bottom Line:

• Many OSHA regulations are written in general terms leaving the details up to the employer on how to comply. The employer is expected to use consensus standards to help in the selection of the best method to achieve compliance with the OSHA regulations. 
• NFPA 70E is not a Federal regulation, it is a “how to comply” consensus standard for specific OSHA regulations. Compliance with 70E will assure compliance with some OSHA electrical regulations.

• In the event of an injury or death due to an electrical accident, if OSHA determines that compliance with 70E would have prevented or lessened the injury, OSHA may site the employer under the “general duty clause” for not using 70E to protect the employee(s). In a 2003 “Standards Interpretation” letter OSHA stated 70E can be used as evidence of whether the employer acted reasonably.

• Fatality/Injury
• Treatment cost
• Fines
• Litigation
• Insurance

• Perform OSHA mandated analysis

• Should be performed by a registered professional Engineering Firm
• Issue the analysis report with results
• Professional should make recommendations
• Training