Video Transcript

Let’s talk about arc flash labels. As I travel around the country teaching 70E classes, refresher and awareness classes and what have you, I see a lot of confusion about when the labels need to go on, what needs to be on them, what can’t be on them, things like that. So let’s talk about that.

First. The owner of the equipment is responsible for the label. Now, that’s very simple if you are a manufacturer, own the building you’re in and you own all the equipment in the building, distribution as well as production equipment, that’s very simple. You own all that stuff. Where it gets a little more complicated is in multi-use buildings where maybe it’s several floors of a building, different companies own different floors. There’s a building in Chicago that I know of that gets a little more complicated. Multi-floors, the building is owned by a real estate investment trust, it’s run by a property management company who employs another company who takes care of all the maintenance, several floors of that building are inhabited by companies that have their own maintenance people, there’s three floors that are a data center for a cell phone company, so they have their own maintenance people. Who owns what equipment and who is responsible for those labels gets a little more complicated. Different people have different motivations for wanting to get those labels on.

So the owner of the equipment, 70E says, is responsible for that label. Now what has to be on that label; obviously nominal voltage has to be on there, the arc flash boundary has to be on there and at least one of the following, and this is where it gets a little more complicated.

(a) Is available incident energy and the corresponding work distance or the arc flash PPE category but not both. So you can have incident energy or the PPE category but not both. And that’s where a lot of people stumble there. I used to own a company that did hundreds of arc flash studies across the nation and it was typical back several years ago where we would put incident energy and the PPE category on the same label. Well, starting in 2015, it stopped being allowed. You can’t have incident energy and the PPE category on the same label.

(b) Another thing that you can have on label is minimum arc rating of clothing. Let’s say that your company has done an arc flash study and has found most of your equipment is say anywhere between two calories and nine calories, so maybe you come up with a label that just says minimum arc rating on all this equipment is 10 or 11 or something like that and then you mark all of it accordingly. It makes it a little bit simpler.

(c) Another thing that you can do is site specific level of PPE that would be a level that you create yourself like say A, B or C and you train all of your maintenance folks what A is and what B is and then from that they know what to wear.

The data on the label has to be reviewed every five years. Now, that doesn’t mean you have to have a complete new arc flash assessment done every five years. It means that you need to review what the utility data is to make sure the utility data is correct and utility’s not built a great big new substation that feed your equipment, that you’ve changed nothing. And I’ve never worked at a facility where you’ve never changed anything over five years, so that’s kind of a rarity in my experience, anyway.

So you would have to confirm and review and make sure that nothing’s changed and if nothing’s changed you don’t need to do a complete new study, but if things have changed in your distribution equipment or in your utility, then you need to redo the study.

Christopher Coache works for National Fire Protection Association and put together the handbook for electrical safety in the workplace. This is the 70E hand book, it’s a companion book that goes with 70E. I highly recommend that everyone reads this, I have it in an e-book, and I read it all the time, just wonderful stuff in there. It’s got everything that 70E has, but then explains in more detail of how we got there, what these things mean and how you could incorporate that. And I don’t like slides with a lot of words on them but these are good words on this particular slide, the employees should not be expected to calculate the incident energy value or to determine whether a job complies with the arc flash PPE category.

So it’s not the employee’s responsibility to figure out what the incident energy rating of that piece of equipment is. It’s not the employee’s job to figure out what the category rating of that equipment is, it’s the employer’s responsibility. The employee needs to know how to read that label to determine what PPE to wear. It’s on the employer to figure out what that arc rating is or incident energy rating is. It’s on the employer to figure out what should be on that label, not the employee. So 70E says that equipment has to have an arc flash label. A lot of people take that to mean that, and it has for years, and people have taken it to mean this, that you do an arc flash assessment, you do an incident energy analysis, then you get your labels. Well, you need to have labels even if you’ve not had that done, even if you don’t intend to ever have that done. You still need labels so you have to put labels on even for the category method. Because there are things that have to be evaluated to use the category method and have to be evaluated by engineers.

There are maximum fault clearing times and maximum fault current allowance on the PPE tables. For years we’ve ignored those, a lot of people but we can’t now, we have to have someone calculate those to make sure that we’re within the parameters that allow us to use the tables. This is where a lot of people over the years have had to skip this because they just didn’t have this done. But you need to have this done. The National Electric Code now requires that you have maximum available fault current labeled on your service equipment. So we need to get this done. So anyway, Christopher Coache, I’m a big fan, he’s got a blog, makes videos, very good information NFPA, his website NFPA xchange recommend that highly a lot of good interpretive stuff, things I’ve learned from this guy. This is good stuff right here.

What needs labeled. Well, equipment that while energized is gonna require servicing or maintenance or adjusting or inspection. So what is that? Is it a motor? Three-phase motor connection box? No. We don’t open those up while it’s energized, generally we don’t, so we don’t need to label those so, but a disconnect, yeah, we have to open those while they’re energized to verify they’re not energized. We gotta do… At disconnects, we have to verify zero volts at the disconnects, and so when we open up that disconnect to verify it’s turned off we still have to treat it as it’s on, as it’s energized so it gets a label.

What about in this photograph, circuit breaker panel boards? Yeah, those need labels because we’re gonna open those and verify the energization. Those are things we open up while energized sometimes. What about that transformer on the floor? No, no, we don’t open those up to work on those. It’s important that the equipment that while energized is gonna be serviced or maintained gets a label. Raceways, condolets, pull boxes, those kind of things don’t, they won’t need a label, ’cause we don’t open those while they’re energized and if we do there’s insulated conductors in there, so. Things that while energized require service, maintenance, inspection need to have a label.

Now, so when it comes to arc flash labels the owner is responsible for it, you can have incident energy or the PPE category you can’t have both, the labels go on equipment that’s gonna be serviced or maintained while energized. The employee should not be expected to go out and calculate the incident energy for a particular panel and put that label on, the employees should not be expected to go out and figure if they can use the PPE category tables. This is things that have to be done by the employer, it’s the employer’s responsibility, and it needs done prior to the maintenance person going out and working on that equipment.

I hope this video helps to clear up some of those issues that I see out there, so make sure we get our labels in compliance, and get those things done. If you have any other questions, there’s the contacts in the link below, please don’t hesitate to give me a call, drop me a line and I’ll answer any kind of questions you got. Thank you very much.

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NFPA 70E permits either of two methods be used when selecting arc flash PPE. The PPE category method, which relies on tables, or the incident energy analysis method, which calls for an electrical power system analysis to be performed by electrical engineers. What many don’t realize is that because of the parameters in the PPE tables both methods require a power system analysis.

When using the PPE category method for selection of arc flash PPE, you must ensure that your equipment is within the clearing time and fault current parameters listed in the tables. If your circuit is not within these parameters, the standard states you can not use these tables and instead you must use the incident energy analysis method.

An electrical power system analysis involves electrical engineers using engineering software, and data collected in the field, to create a model of the electrical distribution system of your facility. This data includes transformer information, wires sizes, fuses, breaker model numbers and settings, all overcurrent-protection devices, etc. Collecting, modeling and analyzing this data can be time-consuming and costly; which is why many facilities struggle with getting it done. This study would provide you with your available fault current and clearing times that you must have to use the PPE category tables. Just a bit more work by the engineer and you would have a complete incident energy analysis.

From NFPA 70E Table 130.7(C)(15)(a) a 480-volt panelboard calls for category 2 arc rated PPE. The table further states the parameters of 25,000 amps of available fault current and a two-cycle fault clearing time. If your fault current or clearing time is outside of these parameters, it is possible the Cat 2 PPE recommended will fall short of the protection you need. There is no way of knowing these parameters without doing a power system analysis?

Another example would be an upstream current-limiting fuse protecting the panel you are about to open for troubleshooting. The informational note to Table 130.7(C)(15)(a) states that a current-limiting fuse has a typical clearing time of .5 cycles if it is within the current limiting range. This is an informational note and not part of the standard language however someone might be tempted to use this clearing time as their clearing time without knowing if the fault current is within the current limiting range of the fuse. Current-limiting fuses are very fast acting fuses and can reduce arc flash energy but only if there is enough current to drive the fuse into its current limiting range.

When selecting arc flash PPE the standard doesn’t allow us to assume we are at a .5 cycle clearing time. We have to verify we are and we can’t do that without getting electrical engineers involved.

The most important thing to keep in mind is that this is the same information you would have to collect and almost all of the calculations you need to perform an incident energy analysis. Just a little more work by the engineer and you will have a complete incident energy analysis. At this point, you would have no use for the tables. Most often the incident energy analysis recommends less PPE be worn, gives you a chance to mitigate the arc flash energy and is a better method.

Selecting arc flash PPE by either method is never an exact science. There are too many variables and unforeseen circumstances. The more of these variables you can control the more accurate your selection will be. One thing is for sure, wearing arc rated PPE helps reduce injury from arc flash. We need to do all we can to make sure we are wearing the proper PPE.

Relevant ETP Training
nfpa.org

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70E Electrical Safety Calendar Reminders

Mark your calendar, there are things we are required to do on schedule. Training, audits, visual inspections, testing, etc. are required by NFPA 70E to be accomplished on a strict schedule. We have gathered those here to help remind you when these things need to be done.

Electrical Safety Program Audit

Intervals not to exceed 3 years

An audit of your program must occur at least every 3 years to verify the principles and procedures are still in compliance with 70E. Article 110

Field Work Audit

Intervals not to exceed 1 year

Fieldwork must be audited at least once a year to verify that the principles and procedures in the electrical safety program are being followed. Article 110

Lockout/Tagout Program and Procedures

Intervals not to exceed 1 year

Your lockout/tagout program and procedures must be audited at least annually to verify they are in compliance with Article 120 of 70E. At least one LOTO in progress must be covered. This audit must include all of your procedures for all of your equipment. Not just your overall program. The purpose of this audit is to identify and correct deficiencies in your program & procedures, training, and execution of loto procedures. Article 110

Electrical Safety Retraining

Intervals not to exceed 3 years

Many things can trigger retraining or the need for additional training that is not related to a calendar date. Among them are non-compliance discovered during normal supervision or the annual fieldwork audit, new equipment, unfamiliar tasks and work practices and a change of duties. You need to be aware of this complete list in 70E. Otherwise, your qualified electrical workers must be retrained every 3 years. Article 110

Lockout/Tagout Procedures Retraining

Intervals not to exceed 3 years

Retraining is also triggered by a change in procedures or if the annual audit indicates that the employee is not complying. Article 110

Incident Energy Analysis

Intervals not to exceed 5 years

The analysis must be reviewed for accuracy at least every five years. The analysis must be updated when a change is made to the electrical distribution system that could affect the results. Article 130

Equipment Labeling

Intervals not to exceed 5 years

The equipment label includes nominal system voltage, arc flash boundary and arc flash PPE selection information such as incident energy or PPE category. Each label and the supporting data must be reviewed for accuracy at least every 5 years. Article 130

Visually Inspect Protective Equipment & Protective Tools

Interval not to exceed 1 year

Equipment such as grounding equipment, hot sticks, rubber gloves, sleeves, and leather protectors, test instruments, blanket and similar insulating equipment, insulating mats and similar insulating equipment, protective barriers, external circuit breaker rack-out devices, portable lighting units, temporary protective grounding equipment, dielectric footwear, protective clothing, bypass jumpers, insulated and insulating hand tools must be visually inspected before initial use, each use thereafter and as service conditions require. Article 250

Insulation Test Of Protective Equipment & Tools

Interval not to exceed 3 years

The equipment listed in the previous entry that is used as primary protection from shock hazards and requires an insulation system to ensure protection of personnel, shall be verified by the appropriate test and visual inspection to ascertain that insulating capability has been retained before initial use, and at intervals thereafter, as service conditions and applicable standards and instructions require, but in no case shall the interval exceed 3 years. Article 250

Visually Inspect Personal Protective Ground Cable Sets

Intervals not to exceed 1 year

Inspected as service conditions require and at least annually. Article 250

Contact Release Refresher Training,

Shall occur annually

Workers exposed to shock hazards and those responsible for safe release shall be trained on methods of safe release. Article 110

First Aid And CPR

Frequency satisfying the certifying body

Those responsible for responding to medical emergencies must be trained in first aid, emergency procedures, CPR and automatic external defibrillator (AED) if provided. Employees responding might be a second person, safety watch or a craftsperson. Article 110

Verification Of Contact Release & Emergency Response Training

Annually

This training must be verified annually to confirm it is current. Regardless of how often the training is required, it must be verified that each employee is current. Article 110

Test Of Abnormal Battery Conditions Alarm

Annually

Instrumentation that provides alarms for early warning of abnormal conditions of battery operation, if present, shall be tested annually. Article 320

This has been created as a helpful reminder for those managing electrical safety programs. It is not a substitute for NFPA 70E. This piece includes paraphrasing and truncated standard language. You must access NFPA 70E for details and what is required at each of these intervals.

I hope the 70E Electrical Safety Calendar Reminders will be helpful. For more information on dates.

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Arc Flash Incident Energy Analysis Hidden Benefits

Single Line Drawings

Whoever does the assessment of your electrical distribution system will have to find out, in simple terms, what is connected to what. They will follow conductors as they connect to panelboards, circuit breakers, disconnects, control panels, etc. They will follow it all the way from your utility connection point, or points, and continue down to your equipment on the plant floor. Using software they will build a single-line or one-line diagram of your electrical distribution system. A sort of road map of your facility’s electrical system.

Regulations

Chapter 2 of NFPA 70E, Article 205.1 states: A single-line diagram, where provided for the electrical system, shall be maintained in a legible condition and shall be kept current. An incident energy analysis will gill give you a set of single-line drawings. Keep them up-to-date. They will assist maintenance, engineering and contractors in doing their jobs more efficiently and safer. Insist these drawings be updated when changes are made.

Inventory Of Equipment

At the completion of the arc flash risk assessment you should have an inventory of most of your fuses. I say most of your fuses because it depends on how much of your plant is actually surveyed. It is possible that some of your equipment will not be looked at. Certainly fuses inside control panels will not all be recorded. But you should have a good look at most of them in disconnects, motor control centers, combination starters and switchgear. Ask the people doing the arc flash risk assessment specific questions concerning your study.

How To Use The Inventory

If after looking at this inventory you discover you have several fuses that are exactly the same, yet you have none of those in your store room, you might want to order some to have on hand. If a fuse blows and you don’t have one in stock this could create excessive downtime while one is brought in. Or, it could tempt someone to use a fuse that is not an exact replacement. This can cause many problems depending on what they put in. A fuse can only be replaced by a fuse that has all the same specifications as the one it is replacing.

Improper Wiring Conditions

Another unintended benefit of an arc flash risk assessment is that a knowledgable person is going to open all of your panels to collect data. In the process of data collection it is not uncommon that wiring problems become apparent. It isn’t necessarily what the data collector is there to do, and not exactly what they’re looking for but sometimes the issues are just too obvious to miss. You should ask your data collectors to inform you when they find anything like this.

Crazy Things

Some of the crazy things they find are funny, but some could be deadly if not corrected. One I remember was a Tuna can used as a junction box. I don’t remember Tuna cans being allowed by the National Electrical Code. Another is copper tubing or copper bars being used to replace fuses. Granted, a 1/2 inch piece of copper tubbing will last much longer than a fuse, but the building might burn down because of it. Sometimes an electrical panel is opened and it is discovered that the panel is completely full of wood dust, flour, sugar, metal dust, metal shavings, or just what ever it is that the plant processes. I remember shaken data collectors calling the office to report panels full of rat nests, tarantulas, a dead squirrel and snakes. These last problems would indicate unused opening not properly covered. It shouldn’t be hard to keep a squirrel out of your electrical enclosures. They are apparently good conductors. Tarantulas might be a bit harder.

Infrared Survey

Thermal imaging cameras have advanced in the last several years to the point where Flir can turn your iPhone or Android phone into a thermal imaging camera for a couple hundred dollars. Because you are going to open all of your electrical enclosures it makes sense to incorporate as much of an infrared study into your arc flash risk assessment as you can. The data collection will be done while the facility is in operation with equipment running. It makes sense to shoot the cabinet to see if you have issues.

In Conclusion

It is great you are having an arc flash risk assessment done to improve the general electrical safety of your facility. The arc flash incident energy analysis hidden benefits are substantial and can impact electrical safety. To get the best value out of your study take advantage of these hidden benefits to the best of your ability.

You may also like “Properly Labeled Panels”

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http://www.osha.gov
http://www.nfpa.org

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