Safety remains a critical consideration for those working in the field of electrical testing and maintenance. For members of the InterNational Electrical Testing Association (NETA), whose work often focuses on electrical systems analysis, commissioning, and maintenance, each task is governed by the highest standards of technical accuracy and safety.
However, despite rigorous attention to protocols, the industry continues to be exposed to significant risks associated with arc flash. In the fall of 2024, the Occupational Safety and Health Administration (OSHA) released new guidance focusing on arc flash hazards that has the potential to significantly impact safety across the electrical industry, including the work performed by NETA professionals.
While OSHA’s guidance does not currently establish any new mandatory regulations, it signals a growing emphasis on addressing worker exposure to arc flash risks. For NETA members, this guidance underscores the importance of aligning testing and maintenance practices around worker safety by incorporating critical safety standards, such as NFPA 70E®, Standard for Electrical Safety in the Workplace®, and NFPA 70B®, Standard for Electrical Equipment Maintenance®.
NETA professionals occupy a unique role in the electrical industry, tasked with independently verifying equipment performance and ensuring compliance with electrical safety standards. By understanding how OSHA’s guidance applies to mitigating arc flash risks, NETA members can deepen their role in promoting safer work environments for their clients as well as for themselves.
UNDERSTANDING ARC FLASH RISKS IN THE CONTEXT OF NETA’S WORK
An arc flash, which occurs when electricity discharges through the air, creating temperatures hotter than the sun’s surface, represents one of the most severe hazards in the electrical industry. While electric shock is more common, the risk associated with exposure to an arc flash event presents a significantly lower likelihood of survival for the worker.
NETA’s members regularly interact with energized electrical systems during testing, troubleshooting, and certification of electrical equipment, in turn exposing them to potential arc flash hazards. OSHA’s guidance emphasizes the critical importance of safety measures such as conducting proper risk assessments and, when required, utilizing proper personal protective equipment (PPE), both in accordance with NFPA 70E safe work practices. These same principles apply to NETA professionals whose line of work requires constant awareness of these hazards.
KEY TAKEAWAYS FROM OSHA’S ARC FLASH GUIDANCE
OSHA’s guidance on arc flash primarily aims to address widespread safety gaps and educate both employers and employees on recognizing these hazards and mitigating the associated risk. While this information from OSHA states that it does not create new legal requirements, it does provide recommendations that look to align with existing standards such as NFPA 70E. Think of it this way: OSHA outlines what employers must do to keep their employees safe, while NFPA 70E provides guidance on how to accomplish it.
Central to OSHA’s efforts in their guidance is the debunking of two myths in the electrical industry.
MYTH 1: Your Work Is Not Energized
Many workers incorrectly assume that lockout/tagout (LOTO) automatically establishes equipment as being de-energized and therefore eliminates the need for arc flash PPE. However, OSHA emphasizes that until the absence of voltage has been confirmed, equipment should be treated as energized. Testing for the absence of voltage is a critical step in establishing an electrically safe work condition (ESWC), as outlined by NFPA 70E. Due to the exposure to energized equipment, until the absence of voltage has been confirmed, appropriate arc-rated PPE (AR PPE) must be worn.
This stage represents one of the most vulnerable points for workers performing testing and maintenance; therefore, it introduces a considerable amount of risk. For NETA members conducting absence of voltage verification, OSHA’s guidance reinforces the necessity of treating this step with the highest level of caution and ensuring proper arc-rated (AR) PPE is donned during testing.
It is also worth noting the difference between AR PPE and flame-resistant PPE (FR PPE) to assist in proper selection, as they do not provide the same level of protection in the event of an arc flash incident. FR PPE is designed to resist ignition and self-extinguish when exposed to flames, offering protection against general fire-related hazards, but is not specifically tested for arc flash hazards. AR PPE, however, is tested and rated to protect against the intense thermal energy of an arc flash, making it a more specialized form of protection that meets both flame-resistant and arc flash requirements. In short, AR clothing is FR, but not all FR clothing is AR.
MYTH 2: My Work Is Justified, So It’s Electrically Safe
OSHA reiterates to employers and workers that energized work should never be justified out of convenience or cost-saving measures, such as preventing downtime during business operations. NFPA 70E specifies that energized work is only permissible in exceptional cases, such as when de-energizing equipment is infeasible due to design or operational requirements (e.g., troubleshooting live systems) or when removing power introduces a greater hazard (e.g., disabling safety-critical ventilation).
OSHA’s emphasis on this point is particularly relevant to NETA professionals, who may work in facilities where clients push for minimal disruptions to their normal processes. NETA-certified employers and their workers must be diligent in aligning their work practices with NFPA 70E and OSHA guidance and advising their clients on the importance of worker safety over business operations convenience.
THE POTENTIAL ROLE OF OSHA’S GENERAL DUTY CLAUSE
OSHA’s arc flash guidance references the General Duty Clause found within Section 5(a)(1) of the Occupational Safety and Health (OSH) Act of 1970. This clause requires employers to:
…furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.
In evaluating the arc flash guidance as it could be interpreted within the General Duty Clause, the information provided by OSHA seems to establish arc flash risk as being a recognizable hazard to employers.
While OSHA’s arc flash guidance states that it does not establish new mandatory regulations for employers, the combination of the responsibility of meeting the General Duty Clause and the recognition of arc flash risks as a known workplace hazard would seem to place responsibility on employers to adapt their work practices to better align with this guidance. This includes aligning with safety standards, such as NFPA 70E and NFPA 70B, to help ensure workplace safety and compliance. Failure to do so could result in OSHA citations or even more severe consequences, such as additional litigation, if an incident occurs that leads to workplace injury or death.
HOW CAN NETA MEMBERS UTILIZE OSHA’S ARC FLASH GUIDANCE?
While each company needs to take in all of the information provided and determine its next steps based on its specific business model, here are some actionable steps NETA members can consider to better align their business practices with OSHA’s recommendations.
Perform Thorough Arc Flash Risk Assessments
NETA professionals should routinely conduct arc flash risk assessments for each specific work task where there is known exposure to energized electrical equipment. Properly calculating incident energy and arc flash boundaries, while utilizing that information to determine the appropriate level of PPE, when necessary, sets the foundation for safe interaction with electrical systems and equipment. It is important to keep in mind that, although arc flash risk has been the discussion point thus far, NFPA 70E also requires electric shock risk assessments to take place along with arc flash risk assessments.
Ensure Workers Have Access to Proper PPE
Having properly rated PPE on hand and accessible is an important first step for NETA companies to ensure that workers utilize it. Arc flash PPE should be arc-rated, not solely flame-resistant (FR), and should be rated for the level of incident energy that is available at the particular piece of electrical equipment being serviced. This may mean that workers need access to different rating levels of PPE while on the job. Workers should also be trained to properly determine when PPE is needed and at what rating level, as well as how to don, inspect, store, clean, and utilize the PPE that has been provided.
Reinforce Proper Absence-of-Voltage Verification
Employers should ensure that workers are properly trained on how to test for the absence of voltage as a critical step in establishing an electrically safe work condition (ESWC), in accordance with NFPA 70E. It is essential to reinforce that simply turning off a circuit breaker or disconnect switch and applying a lockout/tagout (LOTO) procedure does not guarantee that equipment has been deenergized. Until the absence of voltage is verified as part of establishing an ESWC, workers must assume the equipment is still energized and wear the appropriate level of personal protective equipment (PPE).
Educate Clients on Justified Energized Work
By educating customers on the risks of energized work, NETA professionals can facilitate more effective conversations with clients who request energized work to be performed out of convenience to their business operational needs. Clients should understand that workplace injuries not only increase risks for the contractors that they hire but also pose significant risks to their own business. Additionally, an injury could lead to other challenges, such as production downtime, long lead times for replacement parts, and the potential for being named as a defendant in any litigation related to the injury.
CONCLUSION
NETA professionals hold a significant responsibility in the electrical industry, balancing technical expertise with safety leadership. OSHA’s guidance highlights how crucial arc flash prevention measures are to ensuring workplace safety. Aligning testing and maintenance practices with these recommendations is not just about compliance; it’s about fostering a culture of safety across the many touchpoints of the electrical industry that so many NETA members have.
By embracing OSHA’s guidance and relevant standards like NFPA 70E and NFPA 70B, NETA members can protect their own business interests and serve as a trusted resource for their clients in mitigating risk for all parties involved. Through a relentless focus on safety and effective communication, NETA professionals can reinforce their role in shaping an industry that prioritizes worker safety as much as it values performance and reliability.
Important Notice: Any opinion expressed in this column is the personal opinion of the author and does not necessarily represent the official position of NFPA or its Technical Committees. In addition, this piece is neither intended, nor should it be relied upon, to provide professional consultation or services.
Corey Hannahs is a Senior Electrical Specialist at the National Fire Protection Association (NFPA), where he serves as an electrical subject matter expert, contributing to the development of products and services that support NFPA codes and standards, as well as its stakeholders. A third-generation electrician, Corey holds multiple licenses in Michigan, including Master Electrician, contractor, electrical inspector, and plan reviewer. His professional experience spans various roles as an installer, business owner, and executive, along with over 15 years as an electrical apprenticeship instructor. Corey contributes to industry standards as a member of technical committees for UL 2272, Electrical Systems for Personal E-Mobility Devices, and UL 2849, Electrical Systems for E-Bikes. Twice appointed to Michigan’s Electrical Administrative Board by former Governor Rick Snyder, Corey has also been recognized with United States Special Congressional Recognition for founding the B.O.P. (Building Opportunities for People) Program, a training initiative that equips homeless and underprivileged individuals with construction skills.