Application Note

2 Fluke Corporation Who sets the rules for electrical testing and safety?
In other words, OSHA sets and
enforces the rules, while NIOSH
provides helpful information on
workplace safety. Here are some
examples:
Several OSHA regulations have
an impact on electrical work-
place safety. For instance:
•
29 CFR (Code of Federal
Regulations) 1910 Subpart
I sets standards for Personal
Protective Equipment (PPE),
including eye and face protec-
tion, footwear and protection
for electrical workers, such
as insulating blankets, gloves
and sleeves.
•
The key electrical safety rules
are part of 29 CFR 1910
Subpart S, including design
safety standards for electrical
systems, safe work practices,
maintenance requirements
and safety requirements
for special equipment. This
regulation also covers training
requirements, sets guide-
lines for work on energized
parts, outlines lockout/tagout
procedures and provides rules
for use of PPE in electrical
work. The OSHA web site
provides other electrical safety
resources at http://www.
osha.gov/SLTC/.
While OSHA sets the broad safety
agenda, it leaves some details to
others. For example, the OSHA
electrical safety rules in 1910
Subpart S specifically refer the
reader to NFPA and ANSI codes
and standards for help in com-
plying with OSHA. These include
NFPA 70E (Standard for Electrical
Safety in the Workplace), ANSI/
NFPA 70 (National Electrical
Code) and others. Subpart S was
updated in August 2007 and fur-
ther amended in October 2008.
Here’s an example of how the
standards work together. OSHA’s
safety-related work practice
standards in Subpart S do not
currently address flame-resistant
(FR) clothing. However, OSHA
standard 29 CFR 1910.335 (a)
(2)(ii) requires use of protective
shields, protective barriers, or
insulating materials to protect
employees from shock, burns or
other electrically related injuries
while working near exposed
energized parts or where dan-
gerous electric heating or arcing
might occur. Chapter 1 of NFPA
70E-2009 contains specific
requirements and methodology
for hazard assessment and selec-
tion of protective clothing and
other personal protective equip-
ment. Employers may follow
NFPA 70E flash-hazard require-
ments as a way of meeting the
OSHA standard.
The key distinction is this:
OSHA 1910 Subpart S and other
OSHA safety and health stan-
dards are law. Failure to follow
these standards could result in a
citation, a work shutdown, fines
or other sanctions. The NFPA,
ANSI and other standards OSHA
refers to, on the other hand, are
intended as guidelines to safety.
“We’re pointing employers
and employees to these docu-
ments as sources for additional
information,” said David Wallis,
director of the OSHA office of
engineering safety. “For safe
work practices there are some
general-type requirements in
OSHA 1910 related to protection
from electric shock and elec-
tric arc hazard. Employers can
look toward NFPA 70E for more
specific information about the
kind of equipment they need to
protect their employees.”
“There is another caveat I
might explain,” Wallis continued.
“Sometimes OSHA will have a
specific requirement not con-
tained in NFPA 70E, or where
the 70E provision might not be
quite as stringent. In that case,
OSHA would expect employ-
ers to comply with the OSHA
standard. Compliance with NFPA
70E would not automatically be
considered adequate.”
Key Points:
•
Both employers and employees are responsible
to know and follow OSHA standards.
•
Citations and penalties may be imposed if
standards are not observed.
•
Other safety standards, including NFPA 70E,
provide guidance on safety measures and
procedures. They do not supplant OSHA.
In case of conflict, follow OSHA standards.