Arc flash studies and compliance: What’s legally required—and what’s best practice in 2025?

Note on scope:
What follows is Patrick Council’s professional engineering interpretation of NFPA 70E, OSHA rules, and related standards, based on his experience as a licensed Professional Engineer in electrical power systems.
It’s not legal advice—Elevation Power Engineering isn’t a law firm—but it is his clear recommendation that every facility with energized electrical equipment should maintain an up-to-date arc flash risk assessment. It’s one of the ways to protect workers, simplify PPE requirements, and avoid the dangerous extremes of overprotection or non-compliance.

Equipment Owner Responsibilities Under NFPA 70E

Primary Safety Program Requirements

Establish and document safety-related work practices as required by NFPA 70E
Implement comprehensive electrical safety programs that include:
- Employee training programs
- Lockout/tagout (LOTO) procedures
- Risk assessment procedures
Prioritize hazard elimination as the first line of defense in safety planning

Documentation and System Maintenance

Maintain updated and verified one-line diagrams (Article 205.2, 120.2(F)(1)(a)) – This is one of the most critical yet neglected aspects of electrical safety
Ensure equipment duty verification (Article 400.5, 400.6) – Proper application and rating of equipment for available short circuit duty
Commission arc flash hazard analyses and ensure they’re updated every 5 years or after system/equipment changes

Labeling and Marking Requirements

Install and maintain arc flash labels on electrical equipment per NEC 110.16(B) and NFPA 70E 130.5(H)
Use ANSI Z535.4-compliant, weather-resistant labels that include:
- PPE requirements
- Arc flash boundary information
- Review dates and system information
Update labels when they become unreadable, after system modifications, or when a review reveals different information

Training and Communication

Provide required training to all affected employees, regardless of their role
Ensure contract/host employers communicate hazards and enforce work rules
Maintain documentation of completed training programs
Build safety culture that emphasizes understanding the “why” behind safety procedures, not just compliance

Ongoing Compliance

Review and update safety programs regularly
Ensure all employees comply with established safety practices
Coordinate with contractors to maintain consistent safety standards
Document all safety-related activities for audit and insurance purposes

A Critical Message for Landlords & Property Managers

Your NFPA 70E responsibilities don’t end with your tenants’ lease agreements.

As the property owner or designated representative, you remain legally responsible for:

Ongoing Electrical Safety Obligations

Maintaining all common area electrical systems – lobbies, hallways, parking garages, and shared mechanical rooms
Ensuring building-wide electrical infrastructure meets current safety standards
Coordinating with tenant electrical contractors to prevent conflicts and maintain system integrity
Providing updated electrical documentation to tenants and their contractors when requested

Liability Protection Through Compliance

Insurance requirements – Many commercial property insurance policies now require documented electrical safety programs
Due diligence documentation – Proper arc flash studies demonstrate proactive risk management in litigation
Tenant safety obligations – You have a duty to provide a safe working environment, which extends to electrical hazards
Regulatory compliance – OSHA can hold property owners accountable for workplace electrical safety violations

The Hidden Risk

Many landlords assume electrical safety is solely the tenant’s responsibility. This is a dangerous misconception. When electrical incidents occur, investigators look at the entire chain of responsibility – and property owners are rarely exempt from liability.

Don’t let an electrical incident become a property management crisis. Proactive compliance protects both your tenants and your investment.

NFPA 70E is not law—but it matters

NFPA 70E, Standard for Electrical Safety in the Workplace, is a voluntary consensus standard published by the National Fire Protection Association (NFPA). It contains widely recognized best practices for electrical safety, including how to assess arc flash hazards.

NFPA 70E places the responsibility of an arc flash risk study onto the owner of electrical equipment. Equipment Owners are required to assess electrical hazards, document the findings, and:

NFPA 70E-2024, Article 130.5(G) effectively states:

“An arc flash risk assessment shall be updated when a major modification or renovation takes place and shall be reviewed for accuracy at intervals not to exceed five years, to account for changes in the electrical distribution system that could affect the results of the arc flash risk assessment.”

However, NFPA 70E is not law on its own. There’s no agency or “NFPA inspector” who enforces it directly.

So how does NFPA 70E get enforced?

NFPA 70E becomes enforceable indirectly because:

✅ OSHA uses it as a benchmark.

The Occupational Safety and Health Administration (OSHA) enforces the Occupational Safety and Health Act (OSH Act), which includes the General Duty Clause [29 U.S.C. § 654(a)(1)].
The General Duty Clause requires employers to provide a workplace “free from recognized hazards.”
Arc flash hazards are well-established as “recognized hazards.”

OSHA frequently references NFPA 70E as the de facto standard for how employers should protect workers from electrical hazards. While OSHA does not require employers to follow NFPA 70E verbatim, failing to follow it can make it much easier for OSHA to cite you for violations under the General Duty Clause.

Enforcement typically happens after an incident

OSHA usually does not proactively inspect arc flash labels or demand proof that a study was done every five years. Instead, enforcement is usually reactive:

A serious arc flash incident occurs.
OSHA investigates.
They request documentation:
- When was the arc flash assessment last performed?
- Has it been reviewed in the past five years?
- Have there been changes to the electrical system that could affect arc flash hazards?

If your study is outdated—or if conditions have changed and the study wasn’t updated—OSHA may cite you for failing to identify and mitigate known hazards.

What about the five-year review?

Is an arc flash study legally required every five years?

This question comes up often—and the answer is more nuanced than a simple “yes” or “no.”

To be clear:

✅ NFPA 70E requires that your arc flash risk assessment be reviewed at least every five years to confirm it still accurately reflects your electrical system.

🚫 Labels themselves do not automatically expire every five years. Labels only need updating if:

The electrical system changes.
The calculated hazard levels change.
Personal protective equipment (PPE) requirements change.

Even if your system hasn’t changed, you still need to review your study every five years to confirm it’s still valid.

Bottom line for facility owners and managers

OSHA does not mandate a five-year arc flash study interval as a regulatory requirement.
NFPA 70E establishes five years as the maximum interval for reviewing your arc flash risk assessment.
OSHA uses NFPA 70E as the benchmark for determining whether you’ve fulfilled your obligation to protect workers from electrical hazards.
If your arc flash study is older than five years—or if your system has changed significantly since your last assessment—you could face serious legal and financial risk in the event of an incident.

This is why most facilities treat the five-year review as effectively mandatory.

References

Occupational Safety and Health Act, 29 U.S.C. § 654(a)(1) – The General Duty Clause
OSHA 29 CFR 1910.132(d) – Hazard Assessment and Equipment Selection
NFPA 70E-2024, Article 130.5(G) – Incident Energy Analysis Method

Elevation Power Engineering helps facilities stay compliant and safe. Whether you need a new arc flash study or a review of an existing one, we’re here to help ensure your facility meets the highest standards of electrical safety.

Disclaimer: This content reflects Elevation Power Engineering’s professional engineering interpretation of applicable electrical safety standards and requirements. It is provided for informational purposes only and does not constitute legal advice. Elevation Power Engineering is not a law firm and does not employ attorneys. Clients should consult qualified legal counsel for advice on legal rights and obligations.

Common Arc Flash Questions

Understanding risk assessment requirements can be complex. Here are some answers to frequently asked questions to help clarify your concerns.

What is included in our arc flash study?

Our arc flash study includes short circuit analysis, protective device coordination, equipment duty analysis, and incident energy analysis analysis outlined in standard IEEE 1584-2018. Results are documented and new labels are printed.

Can I perform energized work if I’m wearing adequate personal protective equipment (PPE) indicated on the label?

In most cases NFPA 70E requires you to fill out an "Energized Electrical Work Permit" outlined by your organization. (This may be called something different at your organization) PPE helps reduce the severity of injury in the event an arc flash even occurs. Energized work requires justification, a job hazard analysis, and written approval in most cases—even if the gear is adequate.

Why is a short circuit study necessary?

A short circuit study helps calculate potential fault currents, ensuring your equipment can withstand the stresses of a fault and operate safely under fault conditions.

What is the benefit of device coordination?

Proper device coordination minimizes downtime and protects equipment by ensuring that protective devices operate in the correct sequence during a fault. Device coordination can be adjusted to reduce arc flash incident energy hazards by reducing fault clearing times, but the primary purpose of device coordination is system reliability. In some cases, "Maintenance Mode" or other engineered safety solutions may be recommended during a device coordination review.

How often do I need to update my arc flash study?

NFPA 70E requires reviews at least every 5 years, or whenever major electrical changes occur. If you’ve done renovations, replaced equipment, or adjusted breaker settings, it’s time to revalidate your study.

Is having arc flash labels enough for NFPA 70E or OSHA compliance?

No. Labels are just one piece of the puzzle and they are not always required. True compliance also requires up-to-date system documentation, personal protective equipment policies, documented work procedures, and proper employee training. Labels alone won't protect your team or your business. You need an actual written electrical risk assessment for your facility.

Do I need one label or multiple labels per piece of equipment?

For most equipment, a single “worst-case” label is recommended. Adding more can confuse workers and increase liability if someone chooses the lower-rated label without understanding the risk.

My equipment is already labeled. Why do I need my system modeled?

Labels don’t tell the full story if they're generic. NFPA 70 and NFPA 70E have specific requirements for labels for electrical equipment. A complete system model identifies equipment duty problems, verifies protective device coordination, calculates arc flash incident energy results, supports safe decision-making, and generates the information needed to create NFPA required labels. It’s the foundation for both safety and operational planning.

Is an arc flash study required by law every five years?

No. There’s no U.S. law or OSHA regulation that explicitly says, “You must perform an arc flash study every five years.”

However, NFPA 70E—the industry standard for electrical safety—requires that your arc flash risk assessment be reviewed at least every five years to ensure it still reflects your current electrical system.

While NFPA 70E isn’t a law, OSHA often uses it as the benchmark for what’s considered safe practice. Failing to follow it can leave employers vulnerable under OSHA’s General Duty Clause.

Are all arc flash labels required to be updated every five years?

Not necessarily. NFPA 70E does not require arc flash labels to be replaced on a five-year schedule.

Labels must be updated if:

Your electrical system changes.
Arc flash hazard levels change.
PPE requirements change.

If your system remains the same and your assessment is still accurate, the labels can remain in place.

Do the five-year review rules apply to both the Incident Energy Method and the PPE Category Method?

Yes. The five-year review requirement applies to all arc flash risk assessments, regardless of whether you use:

The Incident Energy Analysis Method (calculations yielding specific incident energy levels)
The PPE Category Method (table-based approach in NFPA 70E)

Either way, you’re required to confirm that your assessment is still valid at least every five years—or sooner if changes occur.

So, is NFPA 70E required?

Technically, no. NFPA 70E is a consensus standard—not law.

Practically, yes. OSHA relies on NFPA 70E as the recognized standard for electrical safety. In an incident investigation or legal case, failing to follow NFPA 70E can expose employers to significant liability.

What’s the safest practice?

Best practice is:

Review or have a qualified person review your arc flash study at least every five years. Be sure to date your reviews to help with auditing.
Update your study any time your electrical system changes significantly.
Keep clear records proving your assessments are current.

Following NFPA 70E helps protect your workers and demonstrates due diligence if OSHA ever investigates.