Weekly digest #66: OSHA updates

What changed at OSHA this quarter

OSHA's Q1 2026 enforcement memo puts renewed weight on 29 CFR 1910.333 (selection and use of work practices) and 1910.335 (safeguards for personnel protection). Compliance officers are citing more crews for missing arc flash boundary documentation and for energized work without a written permit. If your JHA binder hasn't been touched since 2024, it's time.

The headline item: OSHA is aligning more closely with NFPA 70E 2024, which means the energized work permit requirement is being enforced even on jobs under 50V where induced voltage or stored energy is present. That catches a lot of PV disconnect work and battery storage commissioning.

Second headline: increased scrutiny on temporary power on construction sites, tied back to NEC 590 and GFCI requirements under NEC 590.6. Inspectors are pulling cord caps and checking for missing ground pins.

Energized work permits, actually filled out

The permit is not a checkbox. OSHA wants to see the justification for why the circuit couldn't be de-energized, the shock and arc flash risk assessment, PPE category, and the qualified person's sign-off. "Troubleshooting" alone is no longer accepted as blanket justification on multi-day jobs.

If you're testing voltage, taking readings, or verifying phase rotation, that's permitted energized work and generally doesn't require a separate permit. The moment you open a gutter, land a lug, or pull a conductor hot, the permit applies.

• Justification for energized work (shutdown creates greater hazard, infeasible, etc.)
• Results of shock risk assessment, including approach boundaries
• Results of arc flash risk assessment, including incident energy or PPE category
• Required PPE specified by cal/cm² or category
• Means to restrict unqualified persons from the work area
• Evidence of a job briefing
• Authorized signatures before work starts

If the permit takes longer than the job, the job probably should have been de-energized. Use that as your gut check.

GFCI and temporary power on job sites

NEC 590.6(A) requires GFCI protection on all 125V, 15, 20, and 30A receptacles used by personnel on construction sites. The 2023 cycle extended this to single-phase 125/250V and 250V receptacles up to 50A. OSHA inspectors are now carrying GFCI testers and checking trip times in the field.

The common failures we see: spider boxes with one dead GFCI that nobody reported, extension cords with damaged ground pins taped over, and assured equipment grounding conductor programs that exist only on paper. If you're running the AEGCP alternative under 590.6(B)(2), the written program, tests, and records have to be on site and current.

Lockout/tagout and the NFPA 70E overlap

OSHA 1910.147 is the LOTO standard, but electrical LOTO also has to satisfy NFPA 70E Article 120. The key distinction: verification of an electrically safe work condition requires an adequately rated test instrument, tested on a known source before and after, on every ungrounded conductor. Drive the point home with new apprentices. A proximity tester is not a verification tool.

Group LOTO for crew work is fine, but each qualified person still needs their own lock on the group lockbox. Tags alone, without locks, only satisfy OSHA when the device physically cannot accept a lock, and even then you need a documented equivalent-protection procedure.

1. Identify all sources, including control power, UPS, and stored energy.
2. Notify affected personnel.
3. Shut down using normal stopping procedure.
4. Isolate, lock, and tag each source.
5. Release or restrain stored energy (capacitors, springs, hydraulics).
6. Verify with a rated meter, live-dead-live.
7. Apply grounds where required for the voltage class.

PPE rating, fit, and the paperwork

Arc-rated clothing without a label, or with a label that's been washed off, is not compliant. OSHA is citing this more often. Keep a photo of the label in your phone or crew app if the garment itself is hard to read after a few seasons.

Voltage-rated gloves need a current test date, typically within 6 months of issue per ASTM F496. Leather protectors are not optional on Class 0 and higher. If you're using Class 00 for low-voltage terminal work, the same inspection and storage rules apply.

Stamp the in-service date on your rubber gloves with a paint pen the day you cut the bag. It settles every "are these still good" argument on the truck.

What to do this week

Pull your energized work permit template and compare it against NFPA 70E 130.2(B)(2). If it's missing any of the seven elements above, update it before your next hot job.

Walk your temp power on the next site visit. Test every GFCI with a real tester, not just the self-test button. Flag any cord set with a damaged ground pin or a missing strain relief and take it out of service on the spot.

• Audit one energized work permit from the last 30 days for completeness.
• Confirm glove test dates on every truck.
• Verify your meter's CAT rating matches the highest system you'll touch.
• Review NEC 110.16 arc flash labeling on gear you regularly open.