By Daryn Lewellyn
President & Founder
Lewellyn Technology
(printable version)
The following list of citations for electrical hazards is real. These citations happened recently and they will be eye-opening for some. I wrote this with the hope that it might help facility personnel better evaluate their facilities. If OSHA is looking for these kinds of hazards, you should be looking for them also, well ahead of an OSHA visit. Finding these kinds of hazards will help prevent injuries and at the same time avoid a costly OSHA citation. I thought the best way to show you what to look for in your own facility was to share with you, in OSHA’s own words, actual violations written up by OSHA field personnel. You don’t have to have a vast knowledge of electrical equipment to recognize these hazards.
Lack Of Hazard Assessment
1910.132(d)(2) The employer did not verify that the required workplace personal
protective equipment hazard assessment was performed through a written certification
that identified the workplace being evaluated; the person certifying the evaluation
had been performed; the date(s) of the hazard assessment; and which identified the
document as a certification of hazard assessment.
Hazard assessment for shock and arc are required by OSHA. You won’t have any idea what PPE to utilize if an assessment is not done. NFPA 70E includes hazard assessment methods.
Lack of FR Clothing and Insulated Gloves
1910.335(a)(1)(i) Employees working in areas where there were potential electrical
hazards were not provided with, and did not use, electrical protective equipment that
was appropriate for the specific parts of the body to be protected and for the work to be
performed.
Facility Wide – maintenance personnel who performed electrical work… were not
provided with and did not wear flame-resistant clothing (FRC) or insulated gloves.
FR clothing seems to be what everyone thinks of first when they think of NFPA 70E. People have told me they won’t implement 70E until it is the law. OSHA doesn’t seem to be waiting. They don’t have a problem with penalizing companies now. NFPA 70E includes PPE selection methods. Employees need protected now.
Unused Opening in Electrical Enclosures Left Open
1910.303(b)(7)(i) Used openings in boxes, raceways, auxiliary gutters, cabinets,
equipment cases or housings were not effectively closed to afford protection
substantially equivalent to the wall of the equipment.
Knock-outs left open, circuit breakers removed and not properly covered, offer a place where dirt, moisture, conductive articles and fingers can access the live conductors inside. It doesn’t take an electrical engineer to figure out you have a hole in your electrical enclosure. These are easy to spot and easy to fix, and very costly if you don’t, because OSHA will hit you for every occurrence.
Breakers and Disconnects Not Labeled
1910.303(f)(2) Each service, feeder and branch circuit, at its disconnecting means or overcurrent device, was not legibly marked to indicate its purpose, unless located and
arranged so the purpose was evident.
Neither the busway, nor the bus plugs were marked or labeled as to what electrical
equipment, installations or apparatus they supplied.
None of the circuit breakers located inside of electrical panel were marked or labeled…
All circuit breakers and fuses feeding loads must be correctly labeled as to what they feed. This is easy for non-electrical people to spot and easily rectified.
Plugs Without Ground Prongs
1910.334(a)(3)(ii) Attachment plugs and receptacles were altered in a manner which
prevented proper continuity of the electrical equipment grounding conductor at the point where plugs were attached to receptacle.
In order to make the three-prong plugs on each of the lighting fixtures fit into twoconductor electrical receptacles, the grounding pins were cut off and/or removed from each of the plugs.
This was a common thing to see thirty years ago when people were just getting used to those new three pronged plugs. It’s inexcusable now and beyond words how this could still be happening. Do you have some old lighting fixtures that have been plugged in for thirty years and the ground prong removed? Easy to spot. Easy to fix.
Lockout/Tagout Failure
1910.333(b)(2) While any employee was exposed to contact with parts of fixed electrical
equipment or circuits which had been de-energized, the circuits energizing the parts
were not locked out or tagged out or both.
…maintenance employees did not apply locks and/or tags on all of the electrical disconnects, electrical circuits or shut-off points prior to performing electrical work.
The employer must develop proper lockout/tagout procedures and train the employees on those procedures. The employer must also provide the locking and tagging devices as well as other equipment for the employees to carry this out.
Lack of Electrical Safe Work Practices Training
1910.332(b)(1) Employees were not trained in and familiar with the safety-related work
practices required…
Maintenance employees who performed electrical work…were not provided electrical
training on topics such as…potential hazards associated with electrical work (including
arc flash or arc blast.)
“Safety-related work practices shall be employed to prevent electric shock or other injuries.” Employees must be trained on those practices. All training must be documented, including the contents of the training.
All of these citations, as well as the potential injuries that might result are easily avoidable. Use these citations to learn what it is OSHA might be looking for and make sure your plant is current with all of the latest OSHA and NFPA 70E requirements. Take a walk through your plant and look for these hazards. If you aren’t comfortable doing this, bring in an outside company to do the inspection. Just get this done before OSHA shows up and looks for themselves.
View Workplace Safety Show Episode “Electrical Safety in OSHA’s Words”: