Does OSHA require a JHA for electrical panel work?

OSHA does not require a written JHA for panel work. It does require deenergizing, locks and tags, testing and training under 29 CFR 1910.333 and 29 CFR 1910.332, and on construction sites under 29 CFR 1926.416 and 29 CFR 1926.417. This template does not cite NFPA 70E because it is not part of the cached OSHA text; use your company program for arc flash.

What goes in a typical electrical panel work JHA?

Include planning, shutdown, lock and tag, stored energy and testing, the work, any energized work, restoring power and close-out. Add the qualified person, the lock owner and the panel ID.

Who can test whether a panel is dead?

A qualified person must use test equipment to verify that the circuit elements and parts are deenergized, and must also verify that the equipment cannot be restarted (29 CFR 1910.333(b)(2)(iv)(A) and (B)).

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Electrical panel work job hazard analysis (JHA) template

Opening a panel puts a worker within reach of live parts, so shock, burns and arc blast are the main hazards. OSHA requires live parts to be deenergized before an employee works on or near them, unless that creates greater hazard or is infeasible (29 CFR 1910.333(a)(1)). Plan to de-energize, lock out and test first.

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The task

Working in a distribution panel or breaker enclosure to add, replace or troubleshoot a circuit, including shutdown, testing, the work and re-energizing.

Steps, hazards and controls

Controls run from most effective to least. A citation beside a control means an OSHA paragraph requires it; with no citation it is good practice.

Step	Hazard	Controls
1. Plan the job and decide to de-energize	Choosing to work live when it is not necessary	Eliminate: De-energize the panel and everything fed from it before working on or near the live parts. (29 CFR 1910.333(a)(1)) Administrative control: Decide the safe procedure for deenergizing before the circuits are opened. (29 CFR 1910.333(b)(2)(ii)(A)) Administrative control: Train employees who face a risk of shock in the electrical safety-related work practices that apply to their jobs. (29 CFR 1910.332(b)(1))
2. Notify people and locate the sources	A source is missed or someone re-energizes the panel	Administrative control: Review the panel directory and trace the feeder to the source. Administrative control: Tell other trades that a panel will be locked out, and where. Administrative control: Find out whether any part of an energized circuit is close enough to the work to be contacted, by inquiry, observation or instruments. (29 CFR 1926.416(a)(3))
3. Turn off, lock out and tag	Panel is turned back on while you are working	Engineering control: Disconnect the circuits from all electric energy sources; control devices like push buttons are not the sole means of deenergizing. (29 CFR 1910.333(b)(2)(ii)(B)) Administrative control: Place a lock and a tag on each disconnecting means used to deenergize the circuits. (29 CFR 1910.333(b)(2)(iii)(A)) Administrative control: Attach tags at all points where deenergized equipment or circuits can be energized. (29 CFR 1926.417(b)) Administrative control: Write the tag so it plainly identifies the equipment being worked on. (29 CFR 1926.417(c))
4. Release stored energy and verify dead	Capacitors or backfeed leave parts live	Engineering control: Discharge capacitors and short-circuit and ground high capacitance elements where stored energy might endanger people. (29 CFR 1910.333(b)(2)(ii)(C)) Administrative control: Have a qualified person use test equipment to confirm the circuit elements and parts are deenergized. (29 CFR 1910.333(b)(2)(iv)(B)) Administrative control: Test the tester on a known live source before and after. PPE: Wear insulating gloves and eye protection while testing.
5. Open the panel and work	Contact with energized neighboring parts	Engineering control: Guard any live parts left in the enclosure with insulation, barriers or covers, unless they are deenergized and grounded. (29 CFR 1926.416(a)(1)) Engineering control: Keep workspaces and walkways clear of cords and clutter. (29 CFR 1926.416(b)(2)) Engineering control: On a construction site, protect the temporary 120-volt, 15- and 20-amp receptacles that feed your tools with GFCIs, unless an assured equipment grounding conductor program is used. (29 CFR 1926.404(b)(1)(i)) PPE: Wear safety glasses, insulated gloves and non-conductive footwear.
6. Energized work, only if de-energizing is not feasible	Shock or arc blast during live work	Administrative control: Allow only qualified persons to work on parts that have not been deenergized. They must be familiar with the special precautionary techniques, PPE, insulating and shielding materials and insulated tools. (29 CFR 1910.333(c)(2)) Administrative control: Get a written approval from the employer or a supervisor and have a second qualified person standing by. PPE: Use rated insulating tools, gloves, face shield and arc-rated clothing selected for the equipment.
7. Restore power in the right order	Re-energizing on top of someone or a leftover tool	Administrative control: Have a qualified person verify that all tools, jumpers, shorts and grounds are removed, and warn exposed people to stay clear. (29 CFR 1910.333(b)(2)(v)) Administrative control: Have each lock and tag removed by the person who applied it. (29 CFR 1910.333(b)(2)(v)(C)) Administrative control: Make a visual check that all employees are clear before closing the disconnect. (29 CFR 1910.333(b)(2)(v)(D))
8. Close up and record the work	Panel left open or unmarked	Engineering control: Confirm the path to ground from the circuits, equipment and enclosure is permanent and continuous. Then replace all covers and dead fronts. (29 CFR 1926.404(f)(6)) Administrative control: Update the panel directory and note any changes for the next crew.

Required PPE

Safety glasses
Insulated, rated gloves
Non-conductive footwear
Hard hat, class E
Arc-rated clothing and face shield for energized work

What the standard says

Deenergize live parts before working on or near them. (29 CFR 1910.333(a)(1))
“Live parts to which an employee may be exposed shall be deenergized before the employee works on or near them, unless the employer can demonstrate that deenergizing introduces additional or increased hazards”
Place a lock and a tag on each disconnecting means. (29 CFR 1910.333(b)(2)(iii)(A))
“A lock and a tag shall be placed on each disconnecting means used to deenergize circuits and equipment on which work is to be performed”
A qualified person must test that circuits are deenergized. (29 CFR 1910.333(b)(2)(iv)(B))
“A qualified person shall use test equipment to test the circuit elements and electrical parts of equipment to which employees will be exposed and shall verify that the circuit elements and equipment parts are deenergized.”
Only qualified persons may work on energized equipment. (29 CFR 1910.333(c)(2))
“Only qualified persons may work on electric circuit parts or equipment that have not been deenergized under the procedures of paragraph (b) of this section.”
Construction: deenergized equipment must be rendered inoperative and tagged. (29 CFR 1926.417(b))
“Equipment and circuits. Equipment or circuits that are deenergized shall be rendered inoperative and shall have tags attached at all points where such equipment or circuits can be energized.”
Do not work close enough to a power circuit to contact it unless protected. (29 CFR 1926.416(a)(1))
“No employer shall permit an employee to work in such proximity to any part of an electric power circuit that the employee could contact the electric power circuit in the course of work, unless the employee is protected”
Verify that everyone is clear before reenergizing. (29 CFR 1910.333(b)(2)(v)(D))
“There shall be a visual determination that all employees are clear of the circuits and equipment.”

Training

Employees who face a risk of electric shock that is not reduced to a safe level must be trained in the electrical safety-related work practices that pertain to their jobs (29 CFR 1910.332(a) and (b)(1)). Qualified persons must also be trained to distinguish exposed live parts and to determine nominal voltage (29 CFR 1910.332(b)(3)).

Frequently asked questions

Does OSHA require a JHA for electrical panel work?: OSHA does not require a written JHA for panel work. It does require deenergizing, locks and tags, testing and training under 29 CFR 1910.333 and 29 CFR 1910.332, and on construction sites under 29 CFR 1926.416 and 29 CFR 1926.417. This template does not cite NFPA 70E because it is not part of the cached OSHA text; use your company program for arc flash.
What goes in a typical electrical panel work JHA?: Include planning, shutdown, lock and tag, stored energy and testing, the work, any energized work, restoring power and close-out. Add the qualified person, the lock owner and the panel ID.
Who can test whether a panel is dead?: A qualified person must use test equipment to verify that the circuit elements and parts are deenergized, and must also verify that the equipment cannot be restarted (29 CFR 1910.333(b)(2)(iv)(A) and (B)).

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Electrical safety: the free talk and the training kit
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