Navigating Electrical Safety’s Gray Areas
Electrical safety standards provide a framework, but real-world work doesn't always offer clear-cut choices. Five common gray areas show why understanding the hazard, the task and the worker’s qualifications matter when the right decision is not immediately obvious.
- By David Kopf
- Oct 15, 2026
"We can't shut it down." For safety professionals responsible for electrical work, few statements better illustrate the difference between knowing a standard and applying it in the real world. Production demands, maintenance needs and unfamiliar equipment can turn what seems like a straightforward requirement into a difficult operational decision.
Those situations were the focus of a July 29 Occupational Health & Safety Executive Q&A webinar with Derek Vigstol, a licensed master electrician and electrical safety consultant with e-Hazard. Vigstol's background includes construction electrical work, apprenticeship instruction and several roles with the National Fire Protection Association.
Rather than reviewing electrical safety requirements broadly, the discussion examined the gray areas that emerge when employers must decide what constitutes electrical work, whether energized work is justified, who is qualified to perform a task, what PPE is appropriate and how emerging technologies alter familiar hazards.
Where Does Electrical Work Begin?
One deceptively simple question is where routine maintenance ends and electrical work begins.
Consider a maintenance technician troubleshooting a machine that has stopped operating. Opening an electrical panel and taking voltage measurements might seem like an extension of ordinary maintenance. From an electrical safety standpoint, however, the distinction is not based primarily on the employee's job title.
Vigstol recommends starting with the hazard.
"Does this work represent an electrical hazard to the people performing it?" he says. If it does, he explains, the employer should treat it as electrical work. That can include working "on," "with" or "near" electrical equipment when the employee is exposed to an electrical hazard.
Troubleshooting illustrates the point. Intentionally contacting energized components with a meter or test probe while taking voltage or current readings constitutes electrical work, Vigstol says, even if the employee thinks of the activity simply as diagnosing a malfunction.
That shifts the safety question from What is this employee called? to What hazard is this employee encountering?
"We Can't Shut It Down"
The gray area becomes more consequential when work must occur energized. When Vigstol hears that a piece of equipment "can't" be shut down, he challenges the premise.
"Change what you're saying to 'we don't want to shut this off,'" he says. "It's not that you can't shut it off. We don't want to shut this off."
Legitimate situations may justify energized work. Troubleshooting can require voltage to perform diagnostic measurements. Some equipment, such as certain battery or photovoltaic systems, inherently presents energized sources. OSHA also recognizes circumstances involving infeasibility or situations in which de-energizing could introduce additional hazards or increased risk.
But operational inconvenience is a different matter.
Vigstol says safety professionals may need to push back against pressure to keep equipment running while also explaining the broader operational risk. For example, performing energized work to avoid several hours of downtime could cause an incident that damages equipment and creates a much longer outage.
That makes the safety professional both an educator and, at times, the person who must hold the line when energized work is not justified.
Who Is Actually Qualified?
"Qualified electrical worker" can sound like a fixed designation. In practice, qualification is more specific.
"It's not about what your official title is," Vigstol says. "It's about the concept of being qualified for the task that you're going to perform and the hazards that are present in that equipment you're working on."
That means an electrician is not necessarily qualified for every electrical task, while a controls technician, engineer or maintenance employee may be qualified for certain tasks if that person has the necessary knowledge, skills and safety training.
Vigstol uses his own experience to illustrate the distinction. Despite holding a master electrician's license, much of his career involved systems of 480 volts and below. Had he suddenly been assigned to substation work without the corresponding experience and safety training, he says, he would not have considered himself qualified for that work.
Experience must also be relevant. An electrician with 30 years of experience, most of it in residential construction, might be less qualified for a particular industrial task than an electrician with five years of experience working on that facility's equipment.
"It's not just about time spent," Vigstol says. "It's about time spent doing what?"
Employers therefore should look beyond completed classes or licenses. Observation, field audits, hands-on demonstrations and task-specific experience can help determine whether someone can actually perform the assigned work safely.
How Much PPE Is Enough?
PPE also tempts people to replace judgment with a simple rule: if workers wear arc-rated or flame-resistant clothing, they are protected.
The reality is more nuanced. For arc-flash protection, clothing must match the potential exposure. Vigstol also cautions against treating "FR" and "arc-rated" as interchangeable terms.
"All arc-rated clothing is going to be FR clothing," he says, "but not all FR clothing is arc-rated clothing."
Employers can err in both directions. Vigstol describes one organization that required workers to remain in a 40-calorie suit even after they had verified zero voltage because the company did not fully trust its lockout/tagout process. Conversely, he has encountered workers opening equipment while wearing an 8-calorie daily uniform despite labels indicating substantially higher incident energy.
The underlying question again returns to the hazard: What exposure exists during the specific task being performed?
"Do we really fully understand that?" Vigstol asks.
New Technology, New Gray Areas
Emerging technologies are adding another layer to those decisions.
Electric vehicles, lithium-ion batteries, photovoltaic systems and battery energy storage systems can combine familiar electrical hazards with different considerations. Thermal runaway, for example, raises questions that extend beyond traditional arc-flash protection.
Vigstol says those changes are making PPE conversations more difficult. A mechanic working on an EV battery may face electrical hazards while also working in hot conditions where heavier protective clothing introduces practical concerns. Battery energy storage systems can introduce thermal runaway hazards that differ substantially from the chemical-exposure concerns traditionally associated with batteries.
Multiple power sources create another gray area. A facility may disconnect utility power and still have energy supplied by a photovoltaic array or battery system.
"Number one, know what sources are present," Vigstol says. "Number two, know how to verify and make sure that that equipment is truly dead and know where all your isolation points are."
That is ultimately what connects these electrical safety gray areas. Standards establish essential requirements, but applying them depends on understanding the actual task, hazards, equipment and people involved.
And as electrical systems continue to change, those judgment challenges do not go away. They evolve as the equipment evolves.
This article originally appeared in the October 2026 issue of Occupational Health & Safety.