Findings in plain language, each tied to the requirement it answers to, and a corrective roadmap ordered by exposure rather than by ease. Most employers hold more compliance than their paperwork can prove — the audit finds both halves of that gap.
| Requirement area | What is expected | What is typically found missing |
|---|---|---|
Written electrical safety program 70E 110.3 · Annex E |
A document naming who owns electrical safety, stating the policy, and directing everything beneath it — written for this operation. | A purchased template with another company’s equipment in it, no revision date, no named owner, prior-edition article numbers. |
Qualified persons and training records 70E 110.4 · 1910.333 |
A defensible definition of qualified applied task by task, with dated records of who was trained, on what, and how competence was demonstrated. | Attendance sheets treated as proof of qualification, no retraining interval tracked, a roster never reconciled against the current crew. |
Electrically safe work condition 70E 110.2, Art. 120 · 1910.147 |
A documented policy putting hazard elimination first, and a de-energisation sequence carried through to a verified absence of voltage. | A generic lockout procedure that never names a disconnect, verification treated as optional, nothing written for a second or concealed supply. |
Energised work permits 70E Art. 130 · Annex J |
A permit recording why de-energising was infeasible or more hazardous, the risk assessment behind it, and a signature from someone able to refuse. | Permits raised after the work, justification completed as “production,” approval delegated to the person doing the job. |
Personal protective equipment 1910.132, 1910.137 · Annex H |
Selection traceable to the incident energy or method used, plus issue, inspection, care, storage, test intervals and retirement records. | Arc-rated clothing bought correctly then never inspected, gloves past their test interval still in the van, no written task-to-PPE link. |
Equipment labelling 1910.303, 1910.305 · 1926.416 |
Field labels that agree with the study behind them, disconnects identified by what they control, and re-labelling when the system changes. | Labels printed from a superseded study, schedules that no longer match the panel, equipment added since the study carrying no label at all. |
Direct current systems 70E Art. 310, 360, 380 (2027) |
Battery rooms, UPS plant, PV arrays and storage handled on their own terms — dc has its own thresholds and its own work logic. | No dc content at all, or a battery procedure written as though the plant can be de-energised. Under the 2027 edition that is an article-level finding. |
Most employers need the first two. Sites with a construction footprint need the third. The fourth is a document review of engineering work someone else performed — the audit clients are most surprised to learn they need.
The written program, its procedures, its training records and its audit cycle, read against the 2027 edition — safe work condition policy, risk assessment method, permit process, qualified-person definitions, host and contractor coordination, and the Chapter 3 articles that apply to your plant.
Subpart S — design safety, wiring methods and safety-related work practices — alongside the standards an electrical incident always drags in: hazardous energy control at 1910.147, general PPE at 1910.132, electrical protective equipment at 1910.137. Read in the order a compliance officer opens the file.
Subpart K, including the general electrical requirements at 1926.416. For capital projects, plant expansions, contractor-heavy shutdowns, and anyone whose crews move between general industry and construction work in the same week — the standard that applies follows the activity, not the badge.
Three questions about the study you already own. Is it current, or has your change history overtaken it? Is its coverage complete, or does equipment exist the model never saw? Is dc addressed, or does it stop at the ac switchgear while battery plant, UPS and PV carry no analysis?
29 CFR 1910.147, Control of Hazardous Energy, ranked fourth on OSHA’s Top 10 Most Frequently Cited Standards for fiscal year 2025, and third the year before. Establishing an electrically safe work condition runs straight through it — which makes it the most-tested part of an electrical safety program, and the part most often written once and never revisited.
OSHA also records General Duty Clause citations, Section 5(a)(1), as a discrete line item in its own enforcement data — code 5A0001, appearing as its own row rather than folded into a standard.
| Violation type | Maximum, per violation |
|---|---|
| Serious | $16,550 |
| Other-than-serious | $16,550 |
| Repeat | $165,514 |
| Willful | $165,514 |
| Failure to abate | $16,550 per day |
These are per-violation figures. An electrical incident rarely produces one violation — it produces a lockout finding, a training finding, a PPE finding and a work-practice finding from the same facts.
| Employer & date | What OSHA cited | Proposed penalty |
|---|---|---|
Eversource Energy Service Co. Beacon Hill, Boston, Massachusetts Release 12 January 2023 |
Two willful and three serious violations after a fatal arc flash and blast: failure to fully de-energise equipment or follow manufacturer maintenance recommendations; failure to estimate heat energy exposure from a potential arc flash; inadequate training; missing rescue equipment; no oxygen testing before vault entry. | $333,560 |
MTD Products Inc., operating as Stanley Black + Decker Willard, Ohio Release 28 May 2024 |
One willful and four serious violations after a 29-year-old maintenance electrician suffered severe burns in an arc blast while replacing fuses on an industrial oven. OSHA found the company failed to provide PPE as required for work around energised equipment, and lacked safe work practices and training for electrical maintenance and for required lockout/tagout procedures. | $222,392 |
Taylor Farms New Jersey Inc. Swedesboro, New Jersey Release 24 November 2025 |
Sixteen safety violations tied to lockout/tagout deficiencies, after a worker was fatally injured in May 2025 while cleaning and sanitising a machine. The staffing firm supplying the worker was cited separately with three serious violations, taking the combined proposed total to $1,158,584. | $1,125,484 |
In a Letter of Interpretation dated 4 November 2004, OSHA stated that it “does not enforce NFPA 70E” and “enforces its own standards that relate to electrical hazards,” and in the same letter that it “may, however, use NFPA 70E to support citations for violations relating to certain OSHA standards.”
In a Letter of Interpretation dated 14 November 2006, OSHA stated that “the General Duty Clause is not used to enforce the provisions of consensus standards, although such standards are sometimes used as evidence of hazard recognition and the availability of feasible means of abatement,” and recommended employers “consult consensus standards such as NFPA 70E… to identify safety measures that can be used to comply with or supplement the requirements of OSHA’s standards.”
OSHA’s Field Operations Manual states in its chapter on violations that where “the relevant industry participated in the committees drafting national consensus standards such as the American National Standards Institute (ANSI), the National Fire Protection Association (NFPA), and other private standard-setting organizations, this can constitute industry recognition.”
In its 2024 arc flash publication OSHA wrote that “OSHA standards follow NFPA 70E… but OSHA has never incorporated that consensus standard by reference.” On its arc flash topic page OSHA describes NFPA 70E as “originally developed at OSHA’s request” and as assisting “in complying with OSHA 1910 Subpart S and OSHA 1926 Subpart K.”
That is the whole of what OSHA says on the point. We report it and stop there.
Every audit finding is an abstraction until it is attached to something that actually happened. This one is investigated, published and public — and it fails on documentation as much as on practice, which is why it belongs on an audit page rather than a training slide.
A 32-year-old maintenance worker at an assisted living facility set out to replace a broken metal halide bulb in a ceiling fixture. He turned the wall switch off and taped it in the off position, then went into the attic to remove the fixture. Holding the fixture in one hand, he touched the bulb base with an uninsulated multi-tool, completed a circuit and received a fatal shock.
The fixture was still energised. It belonged to an emergency lighting system fed from a separate circuit — a circuit that did not appear on the facility’s as-built electrical plans.
Four of the seven contributing factors are documentation failures — and every one is visible from a desk, before anyone goes near a panel.
Led by a Certified Safety Professional (CSP) with 35+ years in EHS and electrical safety. We walk your site, write the findings and sit in the debrief defending them ourselves — no junior auditor with a checklist, no report assembled from a template library.
About the practiceIt produces a dated record of what you knew and what you decided to do about it. An employer holding a findings register with a plan being worked stands somewhere different from one who never looked. The specifics are a conversation for your counsel.
No. We do not perform incident energy analysis and produce no labels — that is engineering work. We review the study you hold for currency, coverage and dc treatment, audit whether field labelling matches it, and write the procedures around it.
Then the audit is worth more, not less. It records the competence you already have informally — most sites have a good deal that was never written down — and produces the specification for the program that follows.
Yes, and the interface is usually where the findings are. NFPA 70E 110.5 places responsibilities on both the host and the contract employer, and the failure mode is symmetrical: each assumes the other assessed the hazard. We review what passed in each direction, in writing.
Duration follows the number of sites and crews, settled on the scoping call. Most document review happens off-site and the onsite portion is built around production. Fixed scope, quoted up front — no hourly meter.
What a compliance engagement covers, where its boundary sits, and how to tell procedural work from engineering work.
Read the article →Why the maintenance history of a breaker changes what an arc flash study can be relied on to tell you.
Read the article →The host and contract employer interface, and what has to pass in each direction before a crew starts work.
Read the article →Fixed scope, quoted up front. Procedural and auditing work only — no incident energy analysis studies, no arc flash labels.