LEGAL NEWS & UPDATES Navigating OSHA’s Focus on Electrical Safety: What EGSA Members Need to Know
E lectrical safety has always been at the core of OSHA’s mission, but in recent years, the agency has sharpened its enforcement lens on electrical work—particularly in in- dustries that design, install, and ser- vice power generation systems. For members of the Electrical Generating Systems Association (EGSA), that fo- cus has direct implications. Whether your employees are wiring a standby generator, maintaining switchgear, or servicing a transfer switch in the field, OSHA inspectors are paying closer attention to how employers identify and control electrical hazards. Across the country, OSHA compli- ance officers are citing more em- ployers under the General Industry Electrical Safety Standards (29 CFR §§ 1910.331–1910.335) and the Control of Hazardous Energy Standard (§ 1910.147). These pro- visions are foundational to prevent- ing arc flash injuries, electrocutions, and unexpected energization during maintenance. A Growing Enforcement Priority In particular, OSHA’s recent inspec- tion data shows heightened enforce- ment in three areas: 1. Failure to De-Energize Before Work Begins – OSHA expects equipment to be placed in an elec- trically safe condition whenever possible. Too often, inspectors find that “live work” is performed out of convenience rather than ne- cessity. 2. Lockout/Tagout Deficiencies – Many employers have LOTO programs that exist on paper but are outdated, incomplete, or not followed in practice. 3. Arc Flash and PPE Violations – OSHA increasingly references
NFPA 70E as the industry bench- mark, even though it’s not a reg- ulation. Lack of documented arc flash risk assessments and inad- equate PPE continue to drive cita- tions. Common Pitfalls for EGSA Employers Employers in the electrical gener- ation and service industries face unique challenges. Jobsites often in- volve a mix of electrical and mechani- cal work, rapidly changing conditions, and contractors working side-by-side. Common pitfalls include: • Improperly rated tools – Tools designed to be used around en- ergized lines are often confused with tools certified for work on energized equipment (so-called “live-line tools”). • Incomplete training documen- tation – OSHA requires proof that employees are qualified for the specific voltage and tasks they perform. • Failure to coordinate safety with host employers or cus- tomers – When your employees perform work at a customer site, both parties have shared obliga- tions under OSHA’s multi-employ- er worksite doctrine. These are the kinds of details OSHA scrutinizes in post-incident investiga- tions, often with the benefit of hind- sight. Best Practices for Strengthening Compliance A proactive safety and compliance strategy not only prevents injuries—it also protects your organization’s legal and financial interests. Here are key steps to consider: 1. Audit Your Electrical Safety Program Annually
Karen F.Tynan Shareholder, EGSA Member Ogletree Deakins
Robert C. Rodriguez Shareholder, EGSA Member Ogletree Deakins
12 | Winter 2025 POWERLINE
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