Electrical safety programs cover the intersection of NFPA 70E and OSHA. The written program is what OSHA asks for first — before they even look at the actual electrical work.
What The Written Program Must Include
- Purpose and scope
- Qualified worker training program
- Task-based risk assessment procedure
- Energized work permit procedure
- PPE selection method (Table method or incident energy analysis)
- Job briefing requirements
- Lockout/tagout tie-in
- Emergency response
- Program audit procedure (3-year cycle per NFPA 70E)
Qualified Worker Training
OSHA 1910.269(a)(2) and 1910.332 define a qualified worker as someone who has:
- Received training on hazards of live parts
- Skill and technique to distinguish live parts from other parts
- Skill to determine nominal voltage of exposed live parts
- Knowledge of clearance distances and required PPE
- Training on specific work practices
Training must be documented — name, date, topics covered, instructor. This is one of the most commonly missing compliance elements.
Energized Work Permits
NFPA 70E requires an energized electrical work permit for work above 50V when de-energization isn't feasible. The permit must document:
- Justification for energized work
- Risk assessment
- PPE requirements
- Personnel involved
- Approval signatures (typically management + safety)
What's In The Forbes Electrical Safety Pack
- Written electrical safety program
- Qualified worker training program and records
- Energized electrical work permit
- Arc flash risk assessment template
- PPE selection matrix
- Electrical LOTO procedure
- Job briefing template
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Frequently Asked Questions
Is NFPA 70E mandatory?
NFPA 70E is a consensus standard, not federal law. However, OSHA uses NFPA 70E as the recognized industry standard for electrical safety and cites it under the General Duty Clause. In practice, compliance with NFPA 70E is functionally required.
Who is a 'qualified person' under NFPA 70E?
Someone with skills and knowledge related to the construction and operation of electrical equipment and installations, trained to recognize and avoid the hazards involved. Training must be documented. Unqualified persons cannot perform electrical work above 50V.
Do I need an energized electrical work permit for every task?
For any work on exposed energized parts above 50V, yes, per NFPA 70E 110.1(H)(1). Some tasks are exempt: testing, troubleshooting, and voltage measuring when de-energization is infeasible. Even these tasks require qualified persons and proper PPE.
What's the difference between OSHA 1910.269 and 1910.333?
1910.269 covers electric power generation, transmission, and distribution work. 1910.333 covers general electrical safety. If you're a utility contractor doing T&D work, 1910.269 applies. If you're a general contractor doing building electrical, 1910.333 applies. Both reference NFPA 70E.
How often does the electrical safety program need audit?
NFPA 70E 110.5(M) requires audit at least every 3 years. Audit should verify program implementation, training documentation, PPE adequacy, and worker knowledge. Missing audit records = compliance failure.
Do I need arc flash labels on my equipment?
NEC 110.16 and NFPA 70E 130.5(H) require field-marked labels on electrical equipment operating at 50V or more. Labels must include arc flash boundary, incident energy or PPE category, and voltage. Missing labels are a common OSHA citation.