Review your written procedures for accuracy and alignment with current OSHA standards and NFPA 70E. Make sure each ener- gy source and piece of equipment is covered by a written LOTO pro- cedure. 2. Verify “Qualified Person” Status OSHA requires that anyone work- ing on or near exposed ener- gized parts be properly trained and demonstrate the ability to distinguish live parts, determine voltage, and use proper PPE and tools. Maintain training records and qualification documentation for each employee. 3. Conduct and Document Arc Flash Assessments Even though OSHA doesn’t specif- ically require an “arc flash study,” the agency uses NFPA 70E as a guide when evaluating whether employers have identified and mit- igated electrical hazards.
vere Violator Enforcement Program (SVEP), certain significant willful, re- peat, or failure-to-abate violations— including electrical and LOTO—can qualify an employer for SVEP. A strong electrical safety program demonstrates more than compliance, it reflects a company’s culture of re- sponsibility, technical competence, and professionalism. For EGSA mem- bers, that culture is also a competi- tive advantage. The Bottom Line OSHA’s enforcement focus on elec- trical hazards shows no signs of slow- ing down. For companies in the pow- er generation and electrical systems space, the most effective defense is preparation: know the standards, train to them, and document every step of your compliance process. With the right safety infrastructure in place, your organization can operate confidently — protecting both your workforce and your bottom line. l
4. Coordinate with Host Employers
When your employees perform service work at a facility, clearly document communication with the host employer about energy con- trol procedures, electrical hazards, and coordination responsibilities. 5. Respond Strategically to OSHA Inspections If an incident or complaint triggers an inspection, prepare a plan for the inspection. Proper handling of document requests, interviews, and closing conferences can make a major difference in the outcome. The Legal and Business Impact Electrical safety compliance is not just a regulatory exercise, it’s a busi- ness imperative. OSHA penalties for serious and willful violations can reach into six figures per citation, and a single electrical incident can disrupt operations, harm reputation, and trig- ger civil litigation. Under OSHA’s Se-
PEACE AND QUIET
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P.O. Box 5905 | De Pere, WI 54115-5905 920.494.7411 | www.robinsoninc.com De Pere | Manitowoc
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