When electrical incidents occur, insurance carriers immediately demand documentation, The Office of Safety and Health Administration (OSHA) opens investigations, and attorneys begin building cases. The facility’s electrical risk assessment, or lack thereof, often becomes pivotal evidence that might determine liability, claim payments, and regulatory sanctions totaling millions.
In 2023, 147 workers died from electrical exposures and 3,260 non-fatal electrical injuries occurred. The total cost of all workplace injuries in 2023 reached $176.5 billion, with electrical incidents representing a significant portion of severe injury claims. Claims managers, risk managers, and litigation attorneys require comprehensive electrical risk assessment documentation to establish defensible positions and help reduce liability exposure.
Compliance Foundations
NFPA 70E Section 110.5(H) requires electrical safety programs to include hazard identification, risk assessment, and risk control implementation per the hierarchy of control methods. Documentation standards are designed to meet litigation defensibility requirements.
Key standards and responsibilities:
- Employers bear primary responsibility per NFPA 70E Article 110.5(H)
- Qualified workers execute assessments per OSHA 1910.333
- Electrical engineers provide incident energy analysis per IEEE 1584-2018
- Risk assessment methodology follows ISO 31010
Prerequisites: Current one-line diagrams, equipment labels, incident history (five years), maintenance records.
7 Step Checklist for an Electrical Risk Assessment
This seven-step process provides a systematic approach to electrical risk assessment that meets NFPA 70E requirements. Following these steps helps create documentation that may help support both safety objectives and regulatory compliance.
Step 1: Identify electrical hazards
Electrical hazard identification involves comprehensive facility walk-throughs examining all electrical equipment for :
- Arc flash (thermal energy release from electrical faults)
- Electric shock (current flow through body from energized conductors)
- Arc blast (pressure wave and projectile hazards).
According to OSHA guidance, arc flash produces temperatures exceeding 35,000°F.
Include maintenance personnel, safety officers, and insurance representatives in walk-throughs to help avoid blind spots. Use infrared thermography to detect hot connections (>40°F differentials) and insulation-resistance testers to identify degraded cables before failure.
Step 2: Define electrical work and failure modes
Compile comprehensive task inventories documenting routine maintenance, commissioning activities, troubleshooting procedures, and emergency response protocols. Use Failure Mode and Effects Analysis (FMEA) tables to document equipment failure scenarios, their effects on personnel safety, and detection methods. For each task, identify what can fail (breaker contact failure during racking), how it fails (arc flash during insertion), and consequences (thermal injury to operator).
Lock the task inventory before risk scoring begins to help prevent scope creep from delaying control deployment. Organizations experiencing continuous task additions should establish a separate Phase 2 assessment.
Temporary power installations present elevated hazards from weather exposure, physical damage, and frequent reconfiguration. OSHA guidance identifies faulty extension cords, improper grounding, and overhead power line contact as leading electrocution causes.
Step 3: Evaluate severity and likelihood
The 5×5 risk matrix methodology assigns numerical ratings for both dimensions, producing risk scores that could help guide control decisions.
Severity Scale (1-5):
- 5 (Catastrophic): Fatality or permanent total disability
- 4 (Critical): Severe injury requiring hospitalization
- 3 (Moderate): Injury requiring medical treatment beyond first aid
- 2 (Minor): First aid injury only
- 1 (Negligible): No injury anticipated
Likelihood Scale (1-5):
- 5 (Very High): Expected to occur frequently under normal conditions
- 4 (Likely): Probable during equipment lifetime
- 3 (Possible): May occur occasionally
- 2 (Rare): Unlikely but conceivable
- 1 (Negligible): Extremely unlikely even with prolonged exposure
The matrix multiplies these values: a task with Catastrophic severity (5) and Likely occurrence (4) produces Risk Score = 20, demanding immediate intervention. Example calculation: A qualified electrician replacing a circuit breaker in an energized 480V panel without proper arc flash PPE: Severity = 5 (potential fatality), Likelihood = 3 (possible during breaker removal), Risk Score = 5 × 3 = 15 (High Risk).
Risk assessment matrix (likelihood x severity)
| Likelihood / Severity | 1 – Negligible | 2 – Minor | 3 – Moderate | 4 – Critical | 5 – Catastrophic |
| 5 – Very High | 5 | 10 | 15 | 20 | 25 |
| 4 – Likely | 4 | 8 | 12 | 16 | 20 |
| 3 – Possible | 3 | 6 | 9 | 12 | 15 |
| 2 – Rare | 2 | 4 | 6 | 8 | 10 |
| 1 – Negligible | 1 | 2 | 3 | 4 | 5 |
Step 4: Prioritize and assign risk levels
Convert risk scores to action levels using NFPA 70E Annex F definitions:
- High Risk (15-25): Immediate controls required, de-energization per NFPA 70E Article 120
- Medium Risk (8-14): Mitigation within 30 days using engineering or administrative controls (Articles 110, 130)
- Low Risk (1-7): Standard procedures with five-year reassessment
Insurance tip: Cross-reference risk scores with workers’ compensation loss data to strengthen premium negotiations. Historical loss data combined with documented risk reductions may provide quantifiable evidence for carrier discussions.
Step 5: Implement control measures
NFPA 70E Articles 120 and 130 establish a six-level hierarchy ranked by effectiveness. Prioritize controls at the top of the hierarchy as they typically provide greater risk reduction than lower-level measures.
- Elimination: De-energize equipment through lockout/tagout
- Substitution: Replace 480V systems with 120V alternatives
- Engineering Controls: Remote racking systems for circuit breaker operation outside arc flash boundaries
- Awareness: Arc flash labels displaying calculated incident energy and required PPE categories
- Administrative Controls: Energized work permits requiring documented justification, plus qualified worker training on arc flash boundaries and PPE selection
- PPE: Arc-rated clothing and voltage-rated gloves as last-resort protection
Reference specific NFPA 70E articles for each control measure to help demonstrate standards-based implementation.
Step 6: Document, verify, communicate
Legally defensible electrical risk assessments require comprehensive documentation meeting both OSHA recordkeeping and litigation discovery standards.
Required Records:
- Risk Register: Complete hazard inventory with pre- and post-mitigation risk scores
- PPE Plans: Equipment specifications tied to calculated incident energy levels
- Updated Drawings: One-line diagrams reflecting current system configuration
- Training Logs: Documentation maintained for the duration of employment
Chain-of-Custody: Construction litigation requires signed transfer logs, photographic documentation before equipment removal, secure storage with access logs, and documented handling procedures meeting Federal Rules of Evidence requirements for physical evidence admissibility.
Step 7: Monitor, review, improve
The 2024 NFPA 70E specifically states that an incident energy analysis shall be reviewed for accuracy every five years and updated when electrical distribution system changes occur.
Leading Indicators: Near-miss reports, PPE inspection rates, and pre-job briefing attendance can provide early warning.
Performance Metrics: Track recordable incident rates per 200,000 hours, incident energy reductions (kJ/cm²) following system upgrades, downtime hours avoided through proactive maintenance, near-miss report frequency, and PPE compliance audit scores.
Common Issues Overlooked
Scope Creep During Assessment: Task lists expand continuously as workers identify additional activities, delaying control implementation. Organizations should lock the task inventory before risk scoring begins. Organizations experiencing continuous additions should establish a separate ‘Phase 2’ assessment rather than postponing critical control deployment.
Underestimating Incident Energy: Generic arc flash labels specifying “PPE Category 2” without calculated incident energy values fail NFPA 70E Article 130.5 requirements. Incident energy calculations per IEEE 1584-2018 must precede label application.
Documentation Gaps: Risk registers lacking pre-mitigation and post-mitigation scores prevent demonstrating risk reduction effectiveness. Maintain both baseline and current risk scores with implementation dates for each control measure.
Training Documentation Deficiencies: Training logs without competency verification (written tests, practical demonstrations) fail OSHA 1910.333 qualified worker requirements. Document both attendance and demonstrated proficiency.
Insurance, Risk, and Legal roles
Insurance Claims managers: Documented assessments with implemented controls might demonstrate policyholder due diligence. Pre-loss documentation can establish proactive risk management timelines.
Corporate Risk managers: Use electrical risk scores in enterprise risk matrices to justify safety investments. OSHA research shows $6 saved per $1 invested in safety programs.
Construction Litigation attorneys: Expert testimony requires documented methodology meeting Daubert standards. Following the 2023 amendments to Federal Rule of Evidence 702, expert witnesses must demonstrate specific qualifications in the electrical system types involved in the incident. Generic electrical engineering credentials no longer suffice; Daubert challenges now require documentation of prior experience with voltage levels, equipment types, and system configurations matching the incident.
Pre-incident electrical risk assessments with documented incident energy calculations, PPE specifications, and control implementation timelines could help establish baseline conditions designed to withstand cross-examination regarding foreseeability and standard of care.
Why Rimkus? Authority Under Pressure
Rimkus electrical engineers help to provide pre-energization verification, incident energy calculations, and NFPA 70E compliance audits. The multidisciplinary approach from the Rimkus team combines electrical engineering analysis with construction defect investigation and regulatory compliance expertise.
Contact Rimkus for additional support in electrical risk assessments.
This article aims to offer insights into the prevailing industry practices. Nonetheless, it should not be construed as legal or professional advice in any form.