Does OSHA address lightning as a workplace hazard?

The OSHA standards do not explicitly call out lightning as a citation and we are unaware of any letters of interpretation that address lightning. However, we can provide some background on how OSHA addresses lightning.

OSHA considers lightning is a recognized hazard, as noted in bold in the OSHA publication excerpt below. In the event of a potential exposure to a lightning strike, OSHA can cite the General Duty Clause from the OSH Act of 1970 Section (5)(a)(1) for not keeping the workplace free from a recognized hazard. However, if employees are working where they could be subject to a lightning strike, the emergency action plan (EAP) should capture the steps to monitor for lightning as well as how and when to take shelter. The general industry standard for an EAP is 1910.38 and the construction equivalent is 1926.35.

In OSHA Publication 3863 Lightning Safety When Working Outdoors, OSHA states: Employers should have a written Emergency Action Plan (EAP), as outlined in 29 CFR 1910.38 or 29 CFR 1926.35. The EAP should include a written lightning safety protocol for outdoor workers.

The same publication includes the following paragraph and lists common at-risk for lightning strike activities: Precautions should be taken to prevent worker exposure to lightning. Employers should recognize lightning as an occupational hazard. Supervisors and workers at outdoor worksites should take lightning safety seriously. Workers whose jobs involve working outdoors in open spaces, on or near tall objects, or near explosives or conductive materials (e.g., metal) have significant exposure to lightning risks.

Worker activities at higher risk for lightning hazards include:

• Logging
• Explosives handling or storage
• Heavy equipment operation
• Roofing
• Construction (e.g., scaffolding)
• Building maintenance
• Power utility field repair
• Steel erection/telecommunications
• Farming and field labor
• Plumbing and pipe fitting
• Lawn services/Landscaping
• Airport ground personnel operations
• Pool and beach life guarding