— Policy Position

We believe that the PPE requirements of NFPA 70E: Standard for Electrical Safety in the Workplace provide the appropriate best practices to ensure worker safety, and should be broadly adopted and enforced for substantially all live industrial electrical work in the United States. NFPA 70E first addressed arc flash in 2000; despite 20 years of experience, about 40% of affected American industrial electrical workers remain unprotected.

We believe that the March 19, 2010 Occupational Safety and Health Administration Standard Interpretation, “Enforcement Policy for Flame-Resistant Clothing in Oil and Gas Drilling, Well Servicing, and Production-Related Operations,” provides a relevant example of how OSHA’s interpretations can dramatically and positively improve safety for workers facing similar hazards to those in the electrical industry.

We encourage OSHA to adopt a similar Interpretation, citing the general industry standard for personal protective equipment, to requiring appropriate arc flash PPE during all live electrical work performed in the United States.

We believe this will have a dramatic impact on the reduction of worker injury from electrical hazards, and provide a net cost savings to society.