Yes. If workers at your facility interact with energized electrical equipment, an arc flash study is required by code — not through a single statute using that exact phrase, but through the combined force of NFPA 70E, OSHA’s General Duty Clause and electrical standards, and the National Electrical Code’s labeling rules. Any one of the three would be enough on its own. Together they leave essentially no employer with energized equipment outside the requirement.
What NFPA 70E Requires
NFPA 70E, the Standard for Electrical Safety in the Workplace, is the most direct source of the obligation. The 2024 edition, currently in effect, requires an arc flash risk assessment for any situation where a worker could be exposed to an arc flash hazard. Article 130.5 sets out the substance: before anyone works on or near energized conductors or circuit parts, the employer must assess the arc flash risk, determine the incident energy exposure, and identify the arc flash boundary. That assessment is the arc flash study, whether or not the standard calls it that by name.
The standard also sets a hard shelf life. The arc flash risk assessment must be reviewed for accuracy at intervals no longer than five years, and it must be updated whenever a major modification or renovation changes the electrical system. Equipment swaps, changes to protective device settings, added loads, and utility upgrades all qualify as changes that can shift incident energy levels enough to make an old study dangerously inaccurate.
How OSHA Enforces It
OSHA has never incorporated NFPA 70E by reference into its regulations. That distinction matters legally, but it does not let employers off the hook. Section 5(a)(1) of the OSH Act — the General Duty Clause — requires every employer to provide a workplace free from recognized hazards likely to cause death or serious physical harm. Arc flash is a recognized hazard, so failing to assess and mitigate it violates the General Duty Clause even without a regulation that says “arc flash study” in the title.1OSHA. Protecting Employees from Electric-Arc Flash Hazards
Specific OSHA standards reinforce the obligation. For the electric power utility industry, 29 CFR 1910.269(l)(8)(ii) explicitly requires a reasonable estimate of the incident heat energy to which each employee exposed to electric-arc hazards would be subjected.2eCFR. 29 CFR 1910.269 – Electric Power Generation, Transmission, and Distribution That is as close as OSHA comes to spelling out an arc flash study in plain terms. For general industry, 29 CFR 1910.335(a)(1)(i) requires employers to provide electrical protective equipment appropriate for the specific body parts at risk and the work being performed.3GovInfo. 29 CFR 1910.335 – Safeguards for Personnel Protection Selecting “appropriate” PPE without knowing the incident energy at each piece of equipment is guesswork, which is why OSHA’s own guidance document says the estimate of incident energy determines the arc flash boundary, the incident energy at working distance, and the level of PPE required.1OSHA. Protecting Employees from Electric-Arc Flash Hazards
OSHA has issued willful citations under 29 CFR 1910.335(a)(1)(i) for employers who failed to provide proper electrical PPE for workers exposed to 480-volt and 110-volt hazards, and under 29 CFR 1910.333(a) for failing to employ safety-related work practices to prevent injuries from arc flash.4U.S. Department of Labor. Citation and Notification of Penalty Those citations flow naturally from the absence of a study: without incident energy data, workers end up wearing the wrong PPE or none at all.
How the NEC Adds a Third Layer
The National Electrical Code takes a different path to the same destination. NEC Article 110.16(A) requires that electrical equipment likely to require examination, adjustment, servicing, or maintenance while energized be marked to warn qualified persons of potential arc flash hazards. The rule applies to switchboards, switchgear, panelboards, industrial control panels, meter socket enclosures, and motor control centers in locations other than dwelling units.
NFPA 70E Section 130.5(H) then specifies what those labels must contain: the nominal system voltage, the arc flash boundary, and at least one of the following — the available incident energy with working distance, the minimum arc rating of clothing, or the site-specific PPE level. You cannot fill in those fields without incident energy calculations, which means the labeling requirement effectively mandates a study. A generic “Warning: Arc Flash Hazard” sticker satisfies the bare minimum of NEC 110.16(A), but it does not meet the NFPA 70E labeling requirements that most authorities having jurisdiction expect.
When a Study Is Triggered
Several specific situations require a new or updated study:
- New electrical installations. Any new facility or building with electrical systems where workers will interact with energized equipment needs a baseline study before operations begin.
- Major modifications to existing systems. Adding a transformer, upgrading switchgear, changing protective device settings, or rerouting feeders can all change incident energy levels at downstream equipment, and NFPA 70E requires the assessment be updated to reflect those changes.
- Equipment operating at 50 volts AC or more. NFPA 70E uses 50 volts AC as the general threshold for shock and arc flash hazard considerations. Below that level, the risk of a sustained arc drops significantly. For DC systems, the 2024 edition allows the threshold to be raised to 100 volts in most applications.5NFPA. NFPA 70E Explained: A Breakdown of the Electrical Safety Standard
- The five-year review cycle. Even if nothing obvious has changed, the study must be reviewed for accuracy at least every five years. Equipment ages, utility fault current levels shift, and protective devices degrade in ways that can meaningfully alter incident energy.
- Utility changes. When the electric utility modifies its infrastructure upstream of your facility, available fault current at the service entrance can change, and that ripples through every downstream calculation.
The five-year clock is a maximum, not a target. Facilities with frequent electrical modifications should review more often. Treating the study as a living document rather than a one-time compliance exercise is the approach that actually keeps people safe.
Who Is Qualified to Perform It
NFPA 70E defines a “qualified person” as someone who has demonstrated skills and knowledge related to the specific electrical equipment and tasks involved, along with safety training to recognize and mitigate hazards. Qualification is task-specific, not a blanket credential. A licensed electrician with decades of experience on 600-volt systems is not automatically qualified to analyze equipment rated above 1,000 volts without additional training.5NFPA. NFPA 70E Explained: A Breakdown of the Electrical Safety Standard
State engineering licensing laws add another layer. Every state regulates the practice of engineering, and arc flash hazard analysis is engineering analysis by any reasonable definition. In most states, offering an arc flash study to the public without a licensed Professional Engineer overseeing the work violates state engineering board rules. The PE does not personally inspect every breaker, but the final report with its calculations and recommendations should be under the responsible charge of a PE licensed in the state where the facility is located. Employers who use in-house staff instead of a licensed engineering firm take on full liability for the accuracy of the work.
What Noncompliance Costs
OSHA’s penalty structure gives real teeth to the requirement. As of January 2025, the maximum penalty for a serious violation is $16,550 per violation, and a willful or repeated violation can reach $165,514 per violation. Failure to correct a cited hazard by the abatement deadline adds up to $16,550 per day.6Occupational Safety and Health Administration. OSHA Penalties These amounts adjust annually for inflation.
The willful classification is where costs escalate quickly. OSHA has classified failures to provide appropriate electrical PPE as willful violations, meaning the employer knew about the hazard and failed to act.4U.S. Department of Labor. Citation and Notification of Penalty A facility with multiple pieces of unanalyzed equipment could face separate violations for each one. Penalties are the easy part. An actual arc flash incident with injuries triggers workers’ compensation claims, potential wrongful-death lawsuits, and an OSHA investigation that can disrupt operations for months.