— Policy Position

Our position, simply stated, is that all electrical workers deserve equal protection from arc flash.

Specifically, we believe the PPE requirements of NFPA 70E: Standard for Electrical Safety in the Workplace provide the appropriate best practices to ensure the safety of industrial electricians, 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 electricians remain unprotected in the USA today.

The electric utility industry in general and Investor-owned Utilities (IOUs) in particular have been providing the appropriate arc flash protection to their workers since 1994, dramatically reducing arc flash injuries and fatalities. The 2014 revision to 1910.269 completed the protection of outside electrical workers in a manner PES fully supports. PES is committed to ensuring industrial electricians are provided the same protection.

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 require appropriate arc flash PPE during all live industrial 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.