Electrical Utility Q&A: Emergency Response Requirements

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Electrical Utility Q&A: Emergency Response Requirements
Updated January 2024

Emergency Response at a Utility: When CPR/First Aid is Required

We hear often about the need for electrical personnel to have at least a basic level of CPR and First Aid training. In addition, proper use of an Automated External Defibrillator is sometimes the only proven method of saving the life of an electrical shock victim. This article explains the standard requirement from NFPA® 70E®, as well as the applicable OSHA regulations in electrical applications.

Training For Those Responsible for Emergency Response

NFPA 70E covers the requirements for training for those responsible for emergency response to electrical incidents. 110.2(C) (1), 2018 edition, requires training in contact release for two groups of people:

(1) Those exposed to shock hazards, and

(2) Those responsible for the safe release of victims from contact with energized conductors or circuit parts.

Annual training is required for locations complying with NFPA 70E requirements.

Training Over First Aid, Emergency Procedures, and Resuscitation

The second requirement in this vein is 110.2 (C)(2), which stipulates first aid, emergency response, and resuscitation training requirements. As we will see in a few paragraphs, OSHA’s wording for electrical response training differs from NFPA’s wording. NFPA 70E states that “Employees responsible for responding to medical emergencies” must be trained in first aid, emergency procedures, cardiopulmonary resuscitation (CPR), and automated external defibrillator (AED) training if the site has AEDs available. Keep in mind the words in quotation marks, that this training applies to those responsible for such response activities.

Also, notice that 70E makes no mention of requiring electrical incident response training for qualified electrical personnel.

Shock release method training, however, is required for electrically-qualified personnel, as they are certainly “exposed to shock hazards” on a routine basis. It’s part of the job as an electrician, electrical technician, electrical engineer, or those performing similar tasks.

Specific Requirements for Utility Electrical Workers

OSHA has specific requirements for electrical incident response. We find specific requirements for employees working in the electrical utility environment in 1910.269 Electrical Power Generation, Transmission, and Distribution.

1910.269(b) is entitled, “Medical Services and First Aid.”  Section (b), (b)(1), (b)(1)(i)-(b)(1)(ii) states,

The employer shall provide medical services and first aid as required in §1910.151. In addition to the requirements of §1910.151, the following requirements also apply:

First-aid training. When employees are performing work on, or associated with, exposed lines or equipment energized at 50 volts or more, persons with first-aid training shall be available as follows:

For field work involving two or more employees at a work location, at least two trained persons shall be available. However, for line-clearance tree trimming performed by line-clearance tree trimmers who are not qualified employees, only one trained person need be available if all new employees are trained in first aid within 3 months of their hiring dates. For fixed work locations such as substations, the number of trained persons available shall be sufficient to ensure that each employee exposed to electric shock can be reached within 4 minutes by a trained person. However, where the existing number of employees is insufficient to meet this requirement (at a remote substation, for example), each employee at the work location shall be a trained employee.”

Breaking It Down

As we break this down, we simplify the rules by saying this:

(1) At a FIELD work location, two people must be trained in first aid and proper medical services.

(2) At a FIXED work location, one of the following is required:

(a) Have a trained response team that can guarantee a 4-minute or less response time to an electrical incident.

(b) Train each employee at the work location.

In 1910.151, the specific MINIMUM requirements are very vague. This standard simply says that personnel must be trained in rendering first aid, and that first aid supplies must be available. There is no mention of CPR or AED training, nor is there mention of appropriate electrical-specific response to electrical incidents.

However, in true OSHA fashion, we must keep digging. 1910.269(x) DEFINES first aid as the following:

“Training in the initial care, including cardiopulmonary resuscitation (which includes chest compressions, rescue breathing, and, as appropriate, other heart and lung resuscitation techniques), performed by a person who is not a medical practitioner, of a sick or injured person until definitive medical treatment can be administered.”

So, we MUST provide training, including CPR and other techniques. This certainly should include AED training if these units are available on the worksite.

One last note: Remember that these rules not only apply to electrical utilities, but to other sites that use similar equipment (e.g. industrial substations, backup generation, etc.) Non-compliance can always be cited under the OSHA General Duty Clause.

Here is some good reading from an OSHA interpretation letter regarding the same subject matter.

Q: Does the OSHA [1910.269, Electric Power Generation, Transmission, and Distribution Standard] require, at all shifts, that an employee in a generating station be reached by another employee or a second person, trained in cardio-pulmonary resuscitation (CPR) and first aid, within 4 minutes?

A: No, not in all circumstances. OSHA Standard 29 CFR 1910.269(b)(1)(ii) requires that for fixed work locations such as generating stations, the number of trained persons available shall be sufficient to ensure that each employee exposed to electric shock can be reached within 4 minutes by a trained person. 

However, where the existing number of employees is insufficient to meet this requirement (at a remote substation, for example), all employees at the work location shall be trained. In the rulemaking, OSHA clarified that this provision was required only for employees exposed to the hazards of electrical shock when they perform work on or associated with exposed lines or equipment energized at 50 volts or more. This does not pertain to employees working near insulated electrical equipment, as the exposure to electrical shock hazard is minimal.

Can e-Hazard Training Meet Your Company's Needs?

e-Hazard provides training to personnel on electrical shock and arc flash immediate medical response, available upon request.

Also, our Low Voltage Qualified class contains some medical response training.

Call our office at (502) 709-7235

Have a question about electrical safety and standards?   

NFPA 70®, National Electrical Code®, NEC® , 70E®, and Standard for Electrical Safety in the Workplace® are registered trademarks of the National Fire Protection Association, Quincy, MA.

Ken Sellars

Ken Sellars is an instructor of electrical safety, NEC, Grounding/Bonding and Arc Flash Safety courses nationwide. Read more about Ken.

This Post Has 2 Comments

  1. Griffin Avin

    Ken, I have a question about 2021 NFPA 70E 110.6(C)(2) Informational note. See it is the same in the 2024 update. For my staff that may respond to provide first aid or CPR as the standby person but are not responsible to be the “First Responder” shouldn’t they also receive first aid and CPR/AED training?

    1. Ken Sellars

      The reference to emergency response in 110.4(C)(2) in 2024 does address first aid, emergency response, and resuscitation as you state. The idea is that a site may have certain personnel that are set up as emergency responders to electrical scenes. These responders must be trained in the required methods of rescue, including AED if provided by the employer. No matter how the site policy is set up, “responders” must be trained. This statement does not exactly match OSHA however, especially if your facility has generation, distribution or transmission, even if you are an industrial site. The rules in these areas require a specific response time of 4 minutes or less (see 1910.269(b)(1)(ii)) if the site is a “fixed work location.” On these sites, if 4 minutes cannot be guaranteed, then “each employee at the work location shall be a trained employee.” Field work requires at least two employees be trained in first aid. This would be working on a distribution line, for example, in an oil field.

      An OSHA interpretation letter expands this 4 minute concept outside of specific electrical response. It states:

      “Medical literature establishes that, for serious injuries such as those involving stopped breathing, cardiac arrest, or uncontrolled bleeding, first aid treatment must be provided within the first few minutes to avoid permanent medical impairment or death. Accordingly, in workplaces where serious accidents such as those involving falls, suffocation, electrocution, or amputation are possible, emergency medical services must be available within 3-4 minutes, if there is no employee on the site who is trained to render first aid. OSHA exercises discretion in enforcing the first aid requirements in particular cases. OSHA recognizes that a somewhat longer response time of up to 15 minutes may be reasonable in workplaces, such as offices, where the possibility of such serious work-related injuries is more remote.”


      In my opinion, it is imperative that every electrical worker be trained in first aid, CPR, and the use of an AED. This is not exactly regulatory, but a best-practice approach. As for your question specifically, that person or persons that are the ones to provide immediate assistance do require training in first aid, CPR, and AED usage if the AED is provided.

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