by Kerry Fikes
Electrical Safety Project Manager
Unfortunately, a definitive “Yes” or “No” answer to this question is not easy to come by. When I first started in the electrical safety field, I had the same question. Who is required to have an arc flash risk assessment? After some time in the industry, along with doing my own research, I realized the answer is pretty clear, though it takes some code research and understanding of how the codes and standards work together to come to that conclusion. With that said, I’m going to try to break down the code requirements to their simplest form. My hope is that after reading this, you will be able to answer the question: “Is an arc flash risk assessment required for my facility?”
First of all, we need to clearly define what we are actually assessing the risks of. “Arc Flash” is kind of like the buzz word or catch-all term for electrical safety. In regard to electrical systems, the two known hazards are: 1) arc flash; and 2) shock and electrocution. The two hazards require two assessments: 1) Arc Flash Risk Assessment; and 2) Shock Risk Assessment. In my mind, a better term for what we all call “Arc Flash Risk Assessment” would be “Electrical Hazard Risk Assessments.”
Does your facility need to have an electrical hazard risk assessment? In my opinion, the answer is going to most likely be a resounding “YES!” I have yet to come across an industrial or commercial customer where the answer was “No.” Here’s why:
OSHA 1910.132 requires that the employer assess the workplace to determine if hazards are present or likely to be present, which necessitates the use of PPE. If such hazards are present, the employer shall provide PPE to protect the employee from the hazards identified in the hazard assessment. In regard to electrical systems, OSHA 1910.132 requires arc flash and shock hazard assessments to be done so that the employer can determine what PPE is required to protect their employees from these two hazards.
The big question you should be asking at this point, and the one that I asked, is what if the equipment is deenergized before we do any work? Do we still need to do these assessments? And the answer is “YES.” Here’s why:
OSHA 1910.333 requires that the circuits energizing the equipment, that is about to be worked on, shall be locked out, tagged out (LOTO) or both. This section also clearly states that electrical equipment that has been deenergized, but has NOT completed the LOTO process shall be treated as energized. Energized work requires the following:
NFPA 70E Article 130 requires all energized electrical work (greater than 50 volts) to comply with the following requirements:
- Workers shall be qualified.
- Energized electrical work permit shall be completed (exception: permit not required for visual inspection, metering, thermography, etc.)
- Shock risk assessment shall be performed.
- Arc flash risk assessment shall be performed.
As you read through OSHA and NFPA 70E, there are sections, other than the ones I mention above, which require arc flash and shock risk assessments. However, the ones above are the most defining and supportive of the requirement.
Is it a true statement to say that every industrial and commercial electrical distribution system has some level of electrical hazard, which in turn requires Arc Flash and Shock hazard assessments? My answer to this question is: “YES, they do.” The only way to eliminate electrical hazards completely is to deenergize. And the only code compliant way to deenergize is to complete the LOTO process. One of the steps in the LOTO process is to test for absence of voltage. Based on what I have said above, testing for absence of voltage is considered energized work. And energized work requires an arc flash and shock risk assessment.
How We Can Help
The EI Group, Inc. has performed electrical hazard assessments
for virtually every type of facility from manufacturing to healthcare to commercial buildings and are capable of customizing the onsite evaluation, modeling, analysis drawing, fault current and coordination studies you require. If you are in need of an arc flash or shock hazard assessment or have other electrical safety concerns, please contact Kerry Fikes at (919) 725-2703 or kfikes@ei1.com.