OSHA’s Landmark Update Addresses Arc Flash Myths, Aligns with NFPA 70E 2024

OSHA’s update marks a pivotal moment in electrical safety, aiming to reduce arc flash incidents and align federal guidance with contemporary industry standards.

In November 2024, the Occupational Safety and Health Administration (OSHA) released its first significant update to arc flash safety guidance in two decades. This long-awaited revision addresses persistent misconceptions and critical gaps in electrical safety practices, emphasizes the dangers of low-voltage systems, and underscores the necessity of proper personal protective equipment (PPE) for energized work above 50 V. Coinciding with the 2024 edition of the National Fire Protection Association’s NFPA 70E standard, OSHA’s update marks a pivotal moment in electrical safety, aiming to reduce arc flash incidents and align federal guidance with contemporary industry standards. The update comprises four key documents: a comprehensive employer guide and three concise resources tailored for workers.

Comprehensive Employer Guide: This detailed document provides employers with in-depth information on implementing administrative controls, conducting hazard assessments, and ensuring proper PPE use.

Worker Resources: These three one-page documents are designed to educate workers on arc flash hazards, proper PPE use, and safe work practices. They serve as quick-reference tools to reinforce safety protocols on the job.

Addressing Common Electrical Work Myths (FS OSHA 4473 11/2024)

OSHA’s updated guidance directly confronts two pervasive myths that have contributed to arc flash injuries and fatalities.

Myth #1: De-energized Equipment Is Safe

Many workers assume that once equipment is turned off, it is safe to work on. However, de-energizing equipment is only the first step toward achieving an electrically safe work condition (ESWC). Proper procedures, such as lockout/tagout (LOTO) and verification of de-energization using established methods, must be followed to eliminate electrical hazards. It is important to understand that without LOTO, the risk of electrical shock and arc flash are not eliminated. Failure to adhere to these protocols can leave workers exposed to dangerous conditions.

Myth #2: Low Voltage Is Not Hazardous

A common misconception is that low-voltage systems (e.g., 120/208 V, 277 V) are inherently safe and do not pose arc flash risks. OSHA’s guidance clarifies that low-voltage systems can sustain arc flash events capable of producing molten metal, igniting flammable clothing, and causing severe or fatal injuries. OSHA emphasizes that all energized work above 50 V requires appropriate PPE, including arc-rated clothing.

 

Establishing Boundaries Around Arc Flash Hazards (FS OSHA 4474 11/2024)

Arc flash incidents are one of the most severe hazards in electrical work, capable of producing explosive blasts with temperatures exceeding 35,000 °F—hotter than the surface of the sun. These events can vaporize metal, ignite clothing, and send molten debris flying at supersonic speeds, leading to severe or fatal injuries. In this publication, OSHA has provided a concise document defining the three types of approach boundaries associated with electrical work that are essential for minimizing risk. Two of them, the restricted and limited approach boundaries, protect against electric shock. The third, the arc flash boundary, protects against the hazard of arc flash.

The restricted and limited approach boundaries are determined by the magnitude of the voltage present. These are defined in the 2024 NFPA 70E Table 130.4(E)(a) for AC voltages and the 2024 NFPA 70E Table 130.4(E)(b) for DC voltages. The limited approach boundary is the working distance from an energized conductor where there is a risk of shock hazard. An unqualified worker, as identified by 29 CFR 1910.399 should be supervised by a qualified worker when in the limited approach boundary. The restricted approach boundary is the area with the highest likelihood of electric shock. Only qualified workers wearing the appropriate PPE shall cross the restricted approach boundary and they should not take uninsulated conductive objects or tools into that area.

The arc flash boundary does not follow a fixed pattern like either of the shock boundaries; it can fall inside, outside, or overlap with the other zones depending on the voltage, available fault current, and equipment configuration. It is important to note that if the arc flash boundary extends farther than the shock hazard boundaries, it takes precedence. According to the NFPA 70E, this boundary is the distance from the exposed energized electrical conductor or circuit part where the incident energy equals 1.2 cal/cm2. Qualified workers shall wear the appropriate PPE for the existing hazard. Table 130.7(C)(15)(c) of the 2024 NFPA 70E lists the appropriate PPE for each hazard level. It is important to note that at the arc flash boundary, even while wearing the appropriate PPE, there is still a chance of suffering second degree burns.

 

Being Aware of Arc Flash Hazards (FS OSHA 4475 11/2024)

This publication reemphasizes the definition of an arc flash described in OSHA 4474, but focuses on common causes of arc flashes and prevention strategies for workers. It reminds workers to look for faulty or damaged equipment and dirty or improperly maintained electrical systems and to be aware of the hazards associated with using conductive tools and inadvertent movements while working.

OSHA also describes ways to prevent arc flash incidents. They reiterate the use of LOTO procedures, applying safe work practices to deenergize and test for the absence of voltage, and the use of PPE in compliance with 29 CFR 1910.147 and 29 CFR 1910.133 respectively, as the strongest mitigation methods for all electrical hazards.

Aligning with procedures described in the 2024 NFPA 70E, it reminds workers to conduct arc flash risk assessments before doing work to aid in determining the available incident energy and to select the correct PPE for the task at hand. It also stresses the need for proper worker training as described in 29 CFR 1910.332 and the NFPA 70E.

Both OSHA 4474 11/2024 and 4475 11/2024 have workers’ rights notifications to ensure that employers are adhering to their obligations for workplace safety and training.

 

Protecting Employees from Electric-Arc Flash Hazards (FS OSHA 4472 11/2024)

Electrical injuries are a significant occupational safety concern, especially for workers operating in environments involving live electrical circuits or equipment. This includes professionals in power generation, transmission, and distribution, as well as those in manufacturing and industrial settings. Among the most severe hazards are electric shocks, arc flashes, and arc blasts—events that can lead to serious injury or death. Estimates from NFPA and other industry sources indicate that there are five to ten arc flash incidents daily in the United States.

It is the goal of the agency to assist employers in providing a workplace free from recognized hazards likely to cause death or serious physical harm (General Duty Clause, Section 5(a)(1)). The final publication in the series is a guide for employers that goes into much more depth than the three concise documents for employees and is designed to help move toward safer workplaces. This lays out recommendations from OSHA in a more streamlined fashion than the 2024 NFPA 70E but also contains descriptions of mandatory safety and health standards enforced by the agency.

Employers are encouraged to implement a comprehensive safety and health program guided by seven core elements:

  • Management leadership
  • Worker participation
  • Hazard identification and assessment
  • Hazard prevention and control
  • Education and training
  • Program evaluation and improvement
  • Communication and coordination (especially with contractors and staffing agencies)

A strong safety culture and active worker involvement are key to the program’s success. Workers should be encouraged to report hazards, participate in inspections, contribute to training design, and access up-to-date safety information. The ability for employers to leverage their employees’ knowledge and experience can result in a more robust safety culture.

Existing regulations require assessing the workplace for hazards, including arc flash and shock hazards. These hazards include faulty or malfunctioning electrical equipment, inadequate installation or maintenance practices, operating equipment beyond its rated capacity, unauthorized modifications to equipment, lack of proper labeling, insufficient PPE, inadequate training, poor equipment condition, and negative environmental factors impacting the integrity of the electrical equipment. The 2023 NFPA 70B aligns with mitigating many of these potential hazards by requiring the maintenance and testing of electrical equipment.

Part of the workplace hazard assessments include making an estimate of the available incident energy, often referred to as an arc flash assessment, before work involving arc flash hazards begins. The assessment also requires a shock hazard evaluation. These arc flash boundary and limited and restricted approach boundaries are all utilized in the complete hazard assessment.

Employers are encouraged to utilize the hierarchy of controls when establishing safeguards to protect their workers and prioritize the most effective means of hazard elimination.

  1. Elimination/Substitution – Removing the hazard or replacing it with a less dangerous alternative
  2. Engineering Controls – Isolating workers from the hazard through design
  3. Administrative Controls – Establishing safe work practices, training, and signage
  4. Personal Protective Equipment (PPE) – Providing arc-rated clothing and gear to protect workers when exposure cannot be eliminated

 

Preventive controls (the top three levels) are the most effective but may not always be practical in electrical environments. In such cases, employers must rely on protective controls—administrative measures and PPE—to reduce exposure.

Administrative measures include:

  • Developing detailed procedures for energized work
  • Training workers on arc flash hazards and safety protocols
  • Controlling access to hazardous zones
  • Implementing permit-to-work systems
  • Complying with OSHA standards such as 29 CFR 1910.332 and 1910.335

When other controls are insufficient, PPE becomes essential. This includes:

  • Arc-rated (AR) garments, gloves, and face protection
  • Fire-resistant (FR) and rubber-insulated clothing
  • Proper PPE selection, inspection, training, and maintenance as mandated by OSHA (29 CFR 1910.132 and 1910.335

All PPE must meet specific performance criteria, as outlined in ASTM standards such as F3258 and F1959, to effectively shield workers from thermal energy. The NFPA 70E categorizes PPE into four protection levels, with higher categories indicating more severe hazards that require increased layers and coverage. These are listed in Table 130.7(C)(15)(c) of the 2024 NFPA 70E.

Employers must emphasize correct PPE use, appropriate undergarments, and proper maintenance to maximize effectiveness. However, reliance solely on PPE, without implementing higher-tier controls, can lead to unsafe work environments. It is important for employers and workers to remember that utilizing the hierarchy of controls does not mean that PPE is not utilized, but that it is always the last method added to the process.

In implementing a robust safety program, employers and workers can collaborate to foster a proactive approach to identifying and addressing workplace hazards before they cause injury. These four publications issued by OSHA help to further cement the alignment between OSHA recommendations and regulations and the NFPA 70B and NFPA 70E publications directing electrical maintenance requirements and electrical safety guidelines in the workplace.

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