ELECTRICAL POLICY

[hawkeye23]

If a company has a electric work policy and they say that it is following 70e as part of its policy and if the company does not include doing a arc flash study would that be considered not complying with the rules of nfpa 70e ?
When having a arc flash survey / study is the contractor performing this service required to update , change or install a new electrical work policy for the employees ? Should he not address this area would this be a red flag ?

 

[WorkSafe]

It would seem the company is not complyign with OSHA or 70E if they are not conducting arc flash studies. How could the company know if the employees are wearing the appropriate PPE if they haven't done a arc flash study (besides the tables).

I wouldn't think a contractor is responsible to update the clients policy, unless that was specifically written into the contract. It would be the clients responsibily to take the contractors assessments and make the necessary changes.

My opinion.

 

[pfalcon]

NFPA70E:2009:130.3
An arc flash study shall be performed and updated every 5 years.

OSHA will consider a declaration of conformance to the 70E and a failure to comply with 130.3 as a violation.

An outside contractor that provides arc flash data is responsible only for reporting that data.

Presumably if the company is having a contractor perform the hazard survey then they are attempting to move into compliance. Even OSHA recognizes that compliance doesn't magically appear. They may warn and watch but will probably not act as long as progress toward compliance is made.

 

[oregonshooter]

OSHA will consider a declaration of conformance to the 70E and a failure to comply with 130.3 as a violation.

Will they consider it a violation if the employer declares they are not trying to follow 70E?

Is it a foul only if you are trying and fail or if you are not trying and fail also? Serious question.

 

[pfalcon]

Will they consider it a violation if the employer declares they are not trying to follow 70E?

Is it a foul only if you are trying and fail or if you are not trying and fail also? Serious question.

I rewrote this reply four times. I'm down to this simple explanation.

OSHA treats the 70E as the default standard for most industries. If you don't adopt a different standard then they will judge compliance by the 70E. They will also hit you for additional violations for not having a written policy. Declaring no policy or denying the 70E won't help. You either have a policy or it's the 70E by default. If you do have a different policy then you're probably in for a longer audit. They'll judge compliance by the 70E and you'll have to explain how your policy works and how it's as effective as the 70E. As to trying, that only helps in negotiating a reduction in the fines.