Arc Flash Training Requirements
Article 110.2 of NFPA 70E 2012 specifies the safety training requirements when working on equipment that presents an electrical hazard. The introduction to this section provides a summary of the arc flash training requirements:
"Such employees shall be trained to understand the specific hazards associated with electrical energy. They shall be trained in safety-related work practices and procedural requirements, as necessary to provide protection from the electrical hazard associated with their respective job or task assignment. Employees shall be trained to identify and understand the relationship between electrical hazards and possible injury." The article then provides specifics on what is required, including specifying the requirements for qualified person training and unqualified person training. There are also requirements for training documentation.
Although the NFPA code only mentions employees as needing training, you should be providing arc flash training to vendors, contractors and anyone else who may be exposed to an arc flash hazard. Recent OSHA decisions include anyone within your workplace as being within the workplace owner's (or the workplace operator's) scope of responsibility for safety. So these arc flash training requirements apply to everyone, without regard to whether they are your employee.
Real-world advice and insight into preventing arc flash accidents.
Does OSHA have arc flash training requirements?
The answer is no, not specifically. There is no OSHA standard that mentions arc flash training. Does OSHA enforce the NFPA 70E requirements for training? In 2006 ORC Worldwide wrote to OSHA and asked them to clarify OSHA's position on enforcement of NFPA 70E. Here is OSHA's answer:
Does OSHA issue Section 5(a)(1) General Duty Clause violations to companies who do not follow the new NFPA 70E requirements?
OSHA's Reply: A violation of the General Duty Clause, Section 5(a)(1) of the Act, exists if an employer has failed to furnish a workplace that is free from recognized hazards causing or likely to cause death or serious physical injury. The General Duty Clause is not used to enforce the provisions of consensus standards, although such standards are sometimes used as evidence of hazard recognition and the availability of feasible means of abatement. In addition, the General Duty Clause usually should not be used if there is a standard that applies to the particular condition, practice, means, operation, or process involved. See §1910.5(f).
Does that mean you are free to not provide the training specified by NFPA 70E?
In a July 12, 2010 press release OSHA announced a $272,000 fine against the US Postal Service for exposing workers to electrical hazards at their Capitol Heights, MD., facility. Concerning this citation Dr. David Michaels, the Assistant Secretary of Labor for OSHA, stated: "These citations and sizable fines reflect the Postal Service's failure to equip its workers with the necessary knowledge and skills to safely work with live electrical parts. The Postal Service knew that proper and effective training was needed for the safety of its workers but did not provide it."
If you do not meet the NFPA arc flash training requirements, you are subject to being fined by OSHA. Although not required by OSHA standards, OSHA considers arc flash training to be required.
An important part of your arc flash training should be training concerning arc flash labels. Everyone who might be in an area in which there is an arc flash hazard should be familiar with arc flash labels and the information they contain. NFPA 70E provides some flexibility in label design and content, so don't count on training provided at other facilities or workplaces as being adequate for your workplace.
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