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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If you had to give an elevator pitch for electrical safety, the kind of pitches that sales people make all the time,  what is that thing that you would tell the prospective client before the elevator ride ends to sell them on your product or service? This is my elevator pitch for electrical safety. A client or somebody asks what do we have to do in our company, to comply? It’s pretty simple and if you boil it down to its smallest fundamentals, the elevator pitch would be each employee has to be qualified for the electrical task they are performing and/or the electrical hazard that they are exposed to. This applies to unqualified people as well; even though an unqualified person won’t necessarily be doing electrical tasks, they are going to be exposed to electrical hazards. Hazards like from extension cords to working around or in the vicinity of qualified people opening cabinets. So they’re going to be exposed, so they have to be trained for that exposure, whatever it is.

So saying each worker has to be qualified for the tasks that they’re performing, under the word “qualified” comes 1,000 things. It comes knowing the training, knowing the equipment, being trained on the safety of that equipment and that exposure, the voltage, the arc flash potential. It includes knowing the proper PPE to wear, the proper tools to use, being able to understand the equipment, the operation, construction and operation of that equipment. So there’s a lot to it, there’s a lot more that goes into it.

So simply put, each employee has to be qualified, which means trained, can demonstrate that they know what you’re doing on the electrical task they are performing and the electrical hazard they are exposed to. That’s the minimum, that’s where you gotta start. So if you’re in charge of safety at your facility, if you’re a plant manager or whatever your job is, how would you answer that question? Are your people qualified for the task and the hazard. A simple question put as an elevator pitch.

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Critical Electrical Safety Targets

Make sure these get done!

• De-energize. Unless the employer can justify live work, it is not permitted. Live testing and troubleshooting are allowed, but altering the circuit live is difficult to justify.
• Workers must be qualified for each electrical task they perform, and the electrical hazard they are exposed to.
• Workers must know how to perform a risk assessment, and how to reduce the associated risk.
• A worker must have access to and utilize the appropriate PPE for the electrical hazard.
• Employers need to ensure the worker has access to arc-rated PPE throughout the range of incident energy indicated by their incident energy analysis.
• Test-Before-Touch. A qualified worker must verify zero energy before contacting de-energized parts by performing the Live-Dead-Live test.
• While verifying zero energy, the qualified worker must utilize appropriate PPE and insulated tools.
• All PPE, as well as all tools and equipment with electrical insulation, must be inspected daily before each use.
• The owner of the electrical equipment is responsible for providing labels that include nominal voltage, arc flash boundary, and a method of determining the appropriate arc flash  PPE to be worn.
• Rubber insulated gloves must be electrically tested every six months.
• Arc-rated clothing and insulated gloves must fit the user, and provide full coverage.

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Based on the number of questions I get from clients, the electrical safety-related OSHA training requirements can be confusing. In simple terms, a company has to provide electrical safety-related work practices and train employees on them. A worker has to be qualified, trained and can demonstrate skills, on any task they are to perform when exposed to electrical hazards. How much training is required? Enough to accomplish that.

Below in OSHA’s words:

1910.332

1910.332(a)
Scope. The training requirements contained in this section apply to employees who face a risk of electric shock that is not reduced to a safe level by the electrical installation requirements of 1910.303 through 1910.308.

Note: Employees in occupations listed in Table S-4 face such a risk and are required to be trained. Other employees who also may reasonably be expected to face comparable risk of injury due to electric shock or other electrical hazards must also be trained.
1910.332(b)
Content of training.
1910.332(b)(1)
Practices addressed in this standard. Employees shall be trained in and familiar with the safety-related work practices required by 1910.331 through 1910.335 that pertain to their respective job assignments.
1910.332(b)(2)
Additional requirements for unqualified persons. Employees who are covered by paragraph (a) of this section but who are not qualified persons shall also be trained in and familiar with any electrically related safety practices not specifically addressed by 1910.331 through 1910.335 but which are necessary for their safety.
1910.332(b)(3)
Additional requirements for qualified persons. Qualified persons (i.e. those permitted to work on or near exposed energized parts) shall, at a minimum, be trained in and familiar with the following:
1910.332(b)(3)(i)
The skills and techniques necessary to distinguish exposed live parts from other parts of electric equipment.
1910.332(b)(3)(ii)
The skills and techniques necessary to determine the nominal voltage of exposed live parts, and
1910.332(b)(3)(iii)
The clearance distances specified in 1910.333(c) and the corresponding voltages to which the qualified person will be exposed.

Note 1: For the purposes of 1910.331 through 1910.335, a person must have the training required by paragraph (b)(3) of this section in order to be considered a qualified person.

Note 2: Qualified persons whose work on energized equipment involves either direct contact or contact by means of tools or materials must also have the training needed to meet 1910.333(C)(2).
1910.332(c)
Type of training. The training required by this section shall be of the classroom or on-the-job type. The degree of training provided shall be determined by the risk to the employee.

1910.333

1910.333(a)
“General.” Safety-related work practices shall be employed to prevent electric shock or other injuries resulting from either direct or indirect electrical contacts, when work is performed near or on equipment or circuits which are or may be energized. The specific safety-related work practices shall be consistent with the nature and extent of the associated electrical hazards.
1910.333(a)(1)
“Deenergized parts.” Live parts to which an employee may be exposed shall be deenergized before the employee works on or near them, unless the employer can demonstrate that deenergizing introduces additional or increased hazards or is infeasible due to equipment design or operational limitations. Live parts that operate at less than 50 volts to ground need not be deenergized if there will be no increased exposure to electrical burns or to explosion due to electric arcs.
Note 1: Examples of increased or additional hazards include interruption of life support equipment, deactivation of emergency alarm systems, shutdown of hazardous location ventilation equipment, or removal of illumination for an area.
Note 2: Examples of work that may be performed on or near energized circuit parts because of infeasibility due to equipment design or operational limitations include testing of electric circuits that can only be performed with the circuit energized and work on circuits that form an integral part of a continuous industrial process in a chemical plant that would otherwise need to be completely shut down in order to permit work on one circuit or piece of equipment.
Note 3: Work on or near deenergized parts is covered by paragraph (b) of this section.
..1910.333(a)(2)
1910.333(a)(2)
“Energized parts.” If the exposed live parts are not deenergized (i.e., for reasons of increased or additional hazards or infeasibility), other safety-related work practices shall be used to protect employees who may be exposed to the electrical hazards involved. Such work practices shall protect employees against contact with energized circuit parts directly with any part of their body or indirectly through some other conductive object. The work practices that are used shall be suitable for the conditions under which the work is to be performed and for the voltage level of the exposed electric conductors or circuit parts. Specific work practice requirements are detailed in paragraph (c) of this section.
1910.333(b)
“Working on or near exposed deenergized parts.”
1910.333(b)(1)
“Application.” This paragraph applies to work on exposed deenergized parts or near enough to them to expose the employee to any electrical hazard they present. Conductors and parts of electric equipment that have been deenergized but have not been locked out or tagged in accordance with paragraph (b) of this section shall be treated as energized parts, and paragraph (c) of this section applies to work on or near them.
1910.333(b)(2)
“Lockout and Tagging.” While any employee is exposed to contact with parts of fixed electric equipment or circuits which have been deenergized, the circuits energizing the parts shall be locked out or tagged or both in accordance with the requirements of this paragraph. The requirements shall be followed in the order in which they are presented (i.e., paragraph (b)(2)(i) first, then paragraph (b)(2)(ii), etc.).
Note 1: As used in this section, fixed equipment refers to equipment fastened in place or connected by permanent wiring methods.
Note 2: Lockout and tagging procedures that comply with paragraphs (c) through (f) of 1910.147 will also be deemed to comply with paragraph (b)(2) of this section provided that:
[1] The procedures address the electrical safety hazards covered by this Subpart; and
[2] The procedures also incorporate the requirements of paragraphs (b)(2)(iii)(D) and (b)(2)(iv)(B) of this section.
1910.333(b)(2)(i)

Checkout Our Practical Guide To Arc Flash And NFPA 70E

“Procedures.” The employer shall maintain a written copy of the procedures outlined in paragraph (b)(2) and shall make it available for inspection by employees and by the Assistant Secretary of Labor and his or her authorized representatives.
Note: The written procedures may be in the form of a copy of paragraph (b) of this section.
..1910.333(b)(2)(ii)
1910.333(b)(2)(ii)
“Deenergizing equipment.”
1910.333(b)(2)(ii)(A)
Safe procedures for deenergizing circuits and equipment shall be determined before circuits or equipment are deenergized.
1910.333(b)(2)(ii)(B)
The circuits and equipment to be worked on shall be disconnected from all electric energy sources. Control circuit devices, such as push buttons, selector switches, and interlocks, may not be used as the sole means for deenergizing circuits or equipment. Interlocks for electric equipment may not be used as a substitute for lockout and tagging procedures.
1910.333(b)(2)(ii)(C)
Stored electric energy which might endanger personnel shall be released. Capacitors shall be discharged and high capacitance elements shall be short-circuited and grounded, if the stored electric energy might endanger personnel.
Note: If the capacitors or associated equipment are handled in meeting this requirement, they shall be treated as energized.
1910.333(b)(2)(ii)(D)
Stored non-electrical energy in devices that could reenergize electric circuit parts shall be blocked or relieved to the extent that the circuit parts could not be accidentally energized by the device.
1910.333(b)(2)(iii)
“Application of locks and tags.”
1910.333(b)(2)(iii)(A)
A lock and a tag shall be placed on each disconnecting means used to deenergize circuits and equipment on which work is to be performed, except as provided in paragraphs (b)(2)(iii)(C) and (b)(2)(iii)(E) of this section. The lock shall be attached so as to prevent persons from operating the disconnecting means unless they resort to undue force or the use of tools.
..1910.333(b)(2)(iii)(B)
1910.333(b)(2)(iii)(B)
Each tag shall contain a statement prohibiting unauthorized operation of the disconnecting means and removal of the tag.
1910.333(b)(2)(iii)(C)
If a lock cannot be applied, or if the employer can demonstrate that tagging procedures will provide a level of safety equivalent to that obtained by the use of a lock, a tag may be used without a lock.
1910.333(b)(2)(iii)(D)
A tag used without a lock, as permitted by paragraph (b)(2)(iii)(C) of this section, shall be supplemented by at least one additional safety measure that provides a level of safety equivalent to that obtained by use of a lock. Examples of additional safety measures include the removal of an isolating circuit element, blocking of a controlling switch, or opening of an extra disconnecting device.
1910.333(b)(2)(iii)(E)
A lock may be placed without a tag only under the following conditions:
1910.333(b)(2)(iii)(E)(1)
Only one circuit or piece of equipment is deenergized, and
1910.333(b)(2)(iii)(E)(2)
The lockout period does not extend beyond the work shift, and
1910.333(b)(2)(iii)(E)(3)
Employees exposed to the hazards associated with reenergizing the circuit or equipment are familiar with this procedure.
..1910.333(b)(2)(iv)
1910.333(b)(2)(iv)
Verification of deenergized condition. The requirements of this paragraph shall be met before any circuits or equipment can be considered and worked as deenergized.
1910.333(b)(2)(iv)(A)
A qualified person shall operate the equipment operating controls or otherwise verify that the equipment cannot be restarted.
1910.333(b)(2)(iv)(B)
A qualified person shall use test equipment to test the circuit elements and electrical parts of equipment to which employees will be exposed and shall verify that the circuit elements and equipment parts are deenergized. The test shall also determine if any energized condition exists as a result of inadvertently induced voltage or unrelated voltage backfeed even though specific parts of the circuit have been deenergized and presumed to be safe. If the circuit to be tested is over 600 volts, nominal, the test equipment shall be checked for proper operation immediately after this test.
1910.333(b)(2)(v)
“Reenergizing equipment.” These requirements shall be met, in the order given, before circuits or equipment are reenergized, even temporarily.
1910.333(b)(2)(v)(A)
A qualified person shall conduct tests and visual inspections, as necessary, to verify that all tools, electrical jumpers, shorts, grounds, and other such devices have been removed, so that the circuits and equipment can be safely energized.
..1910.333(b)(2)(v)(B)
1910.333(b)(2)(v)(B)
Employees exposed to the hazards associated with reenergizing the circuit or equipment shall be warned to stay clear of circuits and equipment.
1910.333(b)(2)(v)(C)
Each lock and tag shall be removed by the employee who applied it or under his or her direct supervision. However, if this employee is absent from the workplace, then the lock or tag may be removed by a qualified person designated to perform this task provided that:
1910.333(b)(2)(v)(C)(1)
The employer ensures that the employee who applied the lock or tag is not available at the workplace, and
1910.333(b)(2)(v)(C)(2)
The employer ensures that the employee is aware that the lock or tag has been removed before he or she resumes work at that workplace.
1910.333(b)(2)(v)(D)
There shall be a visual determination that all employees are clear of the circuits and equipment.
1910.333(c)
“Working on or near exposed energized parts.”
1910.333(c)(1)
“Application.” This paragraph applies to work performed on exposed live parts (involving either direct contact or by means of tools or materials) or near enough to them for employees to be exposed to any hazard they present.
..1910.333(c)(2)
1910.333(c)(2)
“Work on energized equipment.” Only qualified persons may work on electric circuit parts or equipment that have not been deenergized under the procedures of paragraph (b) of this section. Such persons shall be capable of working safely on energized circuits and shall be familiar with the proper use of special precautionary techniques, personal protective equipment, insulating and shielding materials, and insulated tools.
1910.333(c)(3)
“Overhead lines.” if work is to be performed near overhead lines, the lines shall be deenergized and grounded, or other protective measures shall be provided before work is started. If the lines are to be deenergized, arrangements shall be made with the person or organization that operates or controls the electric circuits involved to deenergize and ground them. If protective measures, such as guarding, isolating, or insulating, are provided, these precautions shall prevent employees from contacting such lines directly with any part of their body or indirectly through conductive materials, tools, or equipment.
Note: The work practices used by qualified persons installing insulating devices on overhead power transmission or distribution lines are covered by 1910.269 of this Part, not by 1910.332 through 1910.335 of this Part. Under paragraph (c)(2) of this section, unqualified persons are prohibited from performing this type of work.
1910.333(c)(3)(i)
“Unqualified persons.”
1910.333(c)(3)(i)(A)
When an unqualified person is working in an elevated position near overhead lines, the location shall be such that the person and the longest conductive object he or she may contact cannot come closer to any unguarded, energized overhead line than the following distances:
1910.333(c)(3)(i)(A)(1)
For voltages to ground 50kV or below – 10 feet (305 cm);
1910.333(c)(3)(i)(A)(2)
For voltages to ground over 50kV – 10 feet (305 cm) plus 4 inches (10 cm) for every 10kV over 50kV.
..1910.333(c)(3)(i)(B)
1910.333(c)(3)(i)(B)
When an unqualified person is working on the ground in the vicinity of overhead lines, the person may not bring any conductive object closer to unguarded, energized overhead lines than the distances given in paragraph (c)(3)(i)(A) of this section.
Note: For voltages normally encountered with overhead power line, objects which do not have an insulating rating for the voltage involved are considered to be conductive.
1910.333(c)(3)(ii)
“Qualified persons.” When a qualified person is working in the vicinity of overhead lines, whether in an elevated position or on the ground, the person may not approach or take any conductive object without an approved insulating handle closer to exposed energized parts than shown in Table S-5 unless:
1910.333(c)(3)(ii)(A)
The person is insulated from the energized part (gloves, with sleeves if necessary, rated for the voltage involved are considered to be insulation of the person from the energized part on which work is performed), or
1910.333(c)(3)(ii)(B)
The energized part is insulated both from all other conductive objects at a different potential and from the person, or
1910.333(c)(3)(ii)(C)
The person is insulated from all conductive objects at a potential different from that of the energized part.

..1910.333(c)(3)(iii)
1910.333(c)(3)(iii)
“Vehicular and mechanical equipment.”
1910.333(c)(3)(iii)(A)
Any vehicle or mechanical equipment capable of having parts of its structure elevated near energized overhead lines shall be operated so that a clearance of 10 ft. (305 cm) is maintained. If the voltage is higher than 50kV, the clearance shall be increased 4 in. (10 cm) for every 10kV over that voltage. However, under any of the following conditions, the clearance may be reduced:
1910.333(c)(3)(iii)(A)(1)
If the vehicle is in transit with its structure lowered, the clearance may be reduced to 4 ft. (122 cm). If the voltage is higher than 50kV, the clearance shall be increased 4 in. (10 cm) for every 10 kV over that voltage.
1910.333(c)(3)(iii)(A)(2)
If insulating barriers are installed to prevent contact with the lines, and if the barriers are rated for the voltage of the line being guarded and are not a part of or an attachment to the vehicle or its raised structure, the clearance may be reduced to a distance within the designed working dimensions of the insulating barrier.
1910.333(c)(3)(iii)(A)(3)
If the equipment is an aerial lift insulated for the voltage involved, and if the work is performed by a qualified person, the clearance (between the uninsulated portion of the aerial lift and the power line) may be reduced to the distance given in Table S-5.
1910.333(c)(3)(iii)(B)
Employees standing on the ground may not contact the vehicle or mechanical equipment or any of its attachments, unless:
1910.333(c)(3)(iii)(B)(1)
The employee is using protective equipment rated for the voltage; or
..1910.333(c)(3)(iii)(B)(2)
1910.333(c)(3)(iii)(B)(2)
The equipment is located so that no uninsulated part of its structure (that portion of the structure that provides a conductive path to employees on the ground) can come closer to the line than permitted in paragraph (c)(3)(iii) of this section.
1910.333(c)(3)(iii)(C)
If any vehicle or mechanical equipment capable of having parts of its structure elevated near energized overhead lines is intentionally grounded, employees working on the ground near the point of grounding may not stand at the grounding location whenever there is a possibility of overhead line contact. Additional precautions, such as the use of barricades or insulation, shall be taken to protect employees from hazardous ground potentials, depending on earth resistivity and fault currents, which can develop within the first few feet or more outward from the grounding point.
1910.333(c)(4)
“Illumination.”
1910.333(c)(4)(i)
Employees may not enter spaces containing exposed energized parts, unless illumination is provided that enables the employees to perform the work safely.
1910.333(c)(4)(ii)
Where lack of illumination or an obstruction precludes observation of the work to be performed, employees may not perform tasks near exposed energized parts. Employees may not reach blindly into areas which may contain energized parts.
..1910.333(c)(5)
1910.333(c)(5)
“Confined or enclosed work spaces.” When an employee works in a confined or enclosed space (such as a manhole or vault) that contains exposed energized parts, the employer shall provide, and the employee shall use, protective shields, protective barriers, or insulating materials as necessary to avoid inadvertent contact with these parts. Doors, hinged panels, and the like shall be secured to prevent their swinging into an employee and causing the employee to contact exposed energized parts.
1910.333(c)(6)
“Conductive materials and equipment.” Conductive materials and equipment that are in contact with any part of an employee’s body shall be handled in a manner that will prevent them from contacting exposed energized conductors or circuit parts. If an employee must handle long dimensional conductive objects (such as ducts and pipes) in areas with exposed live parts, the employer shall institute work practices (such as the use of insulation, guarding, and material handling techniques) which will minimize the hazard.
1910.333(c)(7)
“Portable ladders.” Portable ladders shall have nonconductive siderails if they are used where the employee or the ladder could contact exposed energized parts.
1910.333(c)(8)
“Conductive apparel.” Conductive articles of jewelry and clothing (such a watch bands, bracelets, rings, key chains, necklaces, metalized aprons, cloth with conductive thread, or metal headgear) may not be worn if they might contact exposed energized parts. However, such articles may be worn if they are rendered nonconductive by covering, wrapping, or other insulating means.
..1910.333(c)(9)
1910.333(c)(9)
“Housekeeping duties.” Where live parts present an electrical contact hazard, employees may not perform housekeeping duties at such close distances to the parts that there is a possibility of contact, unless adequate safeguards (such as insulating equipment or barriers) are provided. Electrically conductive cleaning materials (including conductive solids such as steel wool, metalized cloth, and silicon carbide, as well as conductive liquid solutions) may not be used in proximity to energized parts unless procedures are followed which will prevent electrical contact.
1910.333(c)(10)
“Interlocks.” Only a qualified person following the requirements of paragraph (c) of this section may defeat an electrical safety interlock, and then only temporarily while he or she is working on the equipment. The interlock system shall be returned to its operable condition when this work is completed.
[55 FR 32016, Aug. 6, 1990; 55 FR 42053, Nov. 1, 1990; as amended at 59 FR 4476, Jan. 31, 1994]
Go to www.OSHA.gov for full text of the OSHA regulations.

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Introduction

This control panel is like thousands of control panels out in facilities today, and maybe even many in your facility. It controls a machine on the factory floor. It has four motor starters, individual circuit breakers for those motor circuits, ice cube relays, small fuses, and a control transformer. And on the door there are pushbuttons, indicating lights, rotary switches. In the lower right

corner of the panel is the main circuit breaker. With the door closed, we can still operate the breaker through the hole in the door. Pretty typical of many control panels. The question is how do we de-energize this panel to establish an electrically safe work condition.

Circuit Breakers

Circuit breakers have a line and load side. The line side is where the incoming power is connected. The load side is where the downstream loads are connected. In this case, the downstream loads are everything else in this panel and all of the motors and other components in the control circuit outside the panel. Everything downstream from this main breaker is being protected from over-currents by this breaker.

The question is, does this circuit breaker de-energize this panel? The answer is no. Opening this breaker de-energizes everything in this panel as well as the downstream loads, everything except for the line side of the breaker itself. When this circuit breaker is opened, turned off, the line side of the breaker is still hot. With the line side still energized by the incoming power, the panel has to be considered energized because the main breaker still has a shock and arc flash hazard. You could not use this breaker to establish an electrically safe work condition for this panel.

Electrically Safe Work Condition

To properly de-energize this panel to establish an electrically safe work condition, you would need to locate the circuit breaker or disconnect that feeds power to your control panel. Your lockout tagout procedures should indicate the location of this breaker or disconnect. Once that is found you would open that disconnect or circuit breaker and apply your locks and tag. Return to the control panel and follow through with all of the required lockout tagout procedures. The most important of which is the live-dead-live test to verify zero voltage. Always Test-Before-Touch. And of course, always wear the required PPE while verifying zero volts. Every circuit has to be considered energized until you’ve proven it’s not.

Troubleshooting Example 1

As a troubleshooting example, let us use a situation in which the operator of this machine reports that one of its four conveyors stopped running. You show up and ask the operator what led up to this problem, and they state that that conveyor has been making a lot more noise than usual. A squealing sound. You suspect a mechanical problem, and on an inspection of the conveyor pulleys, it is evident that a bearing has failed thus causing too much load on the motor. Next, we go to the control panel and see that it has an arc flash label that states an arc flash rating of 11 cal/cm2 and a voltage of 480. We must don the appropriate PPE to protect you from such an arc flash and voltage. Because we are only going to do a visual inspection and we are wearing the proper PPE we can proceed. We do an orderly shutdown of everything the panel controls then open the main breaker. We then open the control panel door and see that the motor starter has tripped for that motor. Everything else in the panel appears fine, we reset the motor starter, and close the door. We place our lock and tag on the main breaker, and we perform all other procedures required by our lockout tagout procedures and proceed to repair the bearing.

Troubleshooting Example 2

In the next example, the operator reported the conveyor wouldn’t turn on. There was no mention of a squealing noise. During our initial troubleshooting, we attempt to turn on that conveyor manually and we hear the motor starter turn on, or pull-in as we say,  inside the cabinet. But, the conveyor is still not moving. We don the appropriate PPE, open the control panel door and begin our visual inspection of the panel. We immediately notice the motor starter for conveyor four is showing signs of heat damage. A  dark smoke-like film is on the area covering the motor starter contacts. This, we know from experience, is an indication of poor contact being made by the starter contacts. The other starters don’t show this damage. Now we know we are going to have to remove and replace the starter or at least disassemble it for inspection and repair. In either case, we’ll need to completely de-energize the panel. At this time we’ll need to close the control panel door and open the main breaker. We then must go to the upstream circuit breaker for this panel, turn it off and apply our lock and tag. Upon returning to the control panel, wearing the appropriate PPE we open the control panel door. Using an appropriate volt-meter, we test that meter on a known live circuit, then measure incoming line leads phase-to-phase and phase-to-ground and do verify that we indeed have zero volts. We then retest the meter on a known live circuit to confirm the meter is still working. That is the Live-Dead-Live test. Now we can remove the PPE and begin our repair work. We find the contacts badly damaged from not making proper contact and the carbon buildup inside the starter is preventing the contact assembly from moving freely. We replace the motor starter, and now all conveyors are working fine.

A Shield May Not Work

Some people have suggested that if you add a plastic or metal shield to the main breaker that covers the energized line leads that should solve the problem. It actually can create a whole new problem. OSHA requires electrical equipment to be “accepted, or certified, or listed, or labeled, or otherwise determined to be safe by a nationally recognized testing laboratory.” Underwriters Laboratory is such a lab. If you add a plastic or metal shield to your breaker, it is no-longer UL Listed because it didn’t have your shield when tested. The shield could cause the breaker to operate differently than when it was manufactured and tested, resulting in an unsafe situation.

Control Panel Design

This next piece of advice doesn’t help you with existing control panels but could make your future panels safer and easier to work with where 70E is concerned. That advice is to ask the OEM of your new panels to put this main breaker in a separate box on the side of the panel. Putting the main circuit breaker in a separate enclosure is becoming quite common now, and manufacturers of these boxes are offering this option. Hoffman’s SEQUESTR line of enclosures is one such offering.

Circuit Breaker Panel Boards

I used a control panel as an example here, but all of this applies to circuit breaker panel boards as well, not just control panels. Opening the main breaker of a circuit breaker panel does not establish an electrically safe work condition. If you’re going to add a circuit breaker, for example, turning off the main breaker for the panel board is not sufficient. You will need to open the circuit breaker that feeds this panel to establish an electrically safe work condition.

Conclusion

In conclusion, it is essential that we know what does and what does not make an electrical panel electrically safe. It must be spelled out in your lockout/tagout procedures which disconnect, or circuit breaker removes power from the equipment that will enable us to create the electrically safe work condition. We will wear the appropriate PPE any time the equipment has an energized circuit component above 50V.

Relevant courses

The post The Main Circuit Breaker For This Control Panel Doesn’t De-energize The Panel appeared first on ElectricalTrainingPro.com.

Practical Guide To Arc Flash and NFPA 70E

By: Daryn Lewellyn

I began my first job in electrical maintenance when I was hired in at Terre Haute Malleable and Manufacturing Company in 1984; a long-since-closed iron foundry in Terre Haute, Indiana. It was a one-hundred-year-old facility, dark, with dirt floors made of sand and coal dust and known by the workers as The Malleable. Some of my most memorable work experiences happened in the four short months I worked there. I remember not receiving any electrical safety training.

I remember when an older electrician named Bill gave me the arc flash training. It wasn’t called arc flash training because none of us had ever heard that phrase before. We didn’t know what happened when panels blew up or that it had a name. The information was given as somber advice while we were standing in front of a large disconnect. Bill said, “When you open or close one of these big disconnects don’t stand in front of it. Stand off to the side, use your left hand, turn your head and it might not hurt to duck a little.” I asked why and he said, “sometimes these things blow up.” That was good advice then and is still relevant today.  The problem was that in 1984 that advice was the entire arc flash class. That was all we knew. Several years later I was repairing a variable frequency drive when part of it exploded when I closed the breaker. I was standing off to the side and was not injured. Thanks, Bill.

Thirty years ago we wrapped electrical tape around screwdrivers and called them insulated. We thought the plastic dipped handles on our Klein lineman’s pliers made them safe. Channel locks were fuse pullers. We wore polyester shirts and gold chains, and our only PPE was a hard hat, steel-toed shoes and safety glasses.

A lot has changed in regards to electrical safety and electrical safety training in the decades since. Arc-rated clothing has replaced our polyester shirts, voltage-rated insulated tools have replaced electrical tape, and most importantly, awareness of electrical hazards has replaced our ignorance. We can no longer work as we did back then, and we have to receive training on electrical hazards. In the ten years, I worked in factories, my employer never gave me formal electrical safety training. The first electrical safety class I was a part of I was the instructor.

In this Practical Guide To Arc Flash and NFPA 70E, I hope to simplify parts of the standard. This guide is not going to answer every question you have, and it doesn’t address every article in 70E. What I am hoping to accomplish with this guide is to help you understand the standards’ most impactful sections and to give you guidance on whether your facility needs more work on your overall electrical safety program.

As I travel the country providing 70E training and consulting for my clients, I have recognized a need for a guide like this. I wrote this guide for qualified workers, managers, and supervisors to assist them in making people safer while working around electrical hazards. Whether you call the training electrical safety training, 70E training, or arc flash training, it is a good idea to read this guide first as it may generate some good questions to have clarified during your training.

Access To The 70E Standard

Every facility, company or organization needs an easily accessible copy of 70E. I like the pdf version because it’s searchable and you can access it over a network.

I also think the 70E Handbook is a handy tool. It has interpretations, explanations and added material, not in the 70E standard. The Handbook can be purchased as an eBook and read on a tablet, Kindle or your phone. Wherever I am, I have 70E and the handbook on my phone. I also keep the OSHA regulations 1910.301 – 308, 1910.331 – 335, and 1910.399 at my fingertips, and all searchable.

Electrical Safety Responsibilities

Both OSHA and 70E agree on what the employers’ and the employees’ responsibilities are when it comes to electrical safety. Both require the employer to establish, implement, and document electrical safe work practices and procedures. And to train their employees on them. The employee’s responsibility is to comply with these work practices. These work practices will include many things, such as de-energizing equipment, PPE, risk assessments, approach boundaries, etc. The priority of these work practices must be the elimination of the hazard. De-energize the circuit, use the live-dead-live test to verify that it is de-energized.

Using arguments like we can’t afford the downtime, production won’t let us shut it down, and the boss or client say’s we have to work live, do not work anymore. These things are money issues and have no place in the decision-making process when we are de-energizing equipment. When a facility decides to work energized because it might save money they needlessly put workers in a possibly fatal situation. The world will not end if you experience a short downtime.

Exposure To Electrical Hazards

If a worker is about to begin a task that will be exposing them to electrical hazards a few things need to be clear. First, the worker has to be qualified for the work they are about to undertake. They must be able to demonstrate that they understand the equipment operation and construction, have received training on the hazards present, and have been trained on how to reduce the associated risks. The employer must document when the qualified worker received electrical safety training and the contents of that training when they demonstrated their proficiency with the work practices, and retain the documentation for the duration of their employment.

A helpful way to prepare for this is to imagine OSHA walking into your facility and asking if the worker they see using a voltmeter is qualified for the work they are doing. How would you answer and what documentation would you be able to provide to make your case?

Next, assuming we have determined the worker is qualified, we need to look at the task they are about to perform. Let us use as an example of adding a circuit breaker to a 480/277 volt panel-board labeled “Panel-A.” OSHA and 70E agree that we can’t do this work energized. Thirty years ago we may have inserted or removed a circuit breaker while the panel was live. But not today.

OSHA and 70E both require circuits above 50 volts be de-energized before work proceeding. Unless de-energizing would cause increased or additional hazards, such as life support systems at a hospital, or alarm systems. We are also allowed to work energized if it is infeasible to de-energize the circuit. I can tell you OSHA doesn’t believe many things are infeasible. Measuring voltage during the commissioning and startup equipment, measuring voltage and current during troubleshooting, for example, are allowed because it is infeasible to measure voltage and current if the circuit is de-energized. Just because it is acceptable doesn’t mean you have to permit it. Many companies do not. We may also have to work de-energized on circuits below 50 volts if they present a potential arc flash hazard.

OSHA requires you to work energized in one critical task. Lockout/Tagout. One of the steps of LOTO is verifying you have zero volts on the circuit you just de-energized. You must consider every conductor energized until you verify zero energy. When you are validating zero voltage, we have to regard this as live work. What if you opened the wrong disconnect. That happens all of the time. Perhaps the most important things we preach to our clients is, “Test Before Touch,” and, of course, wear PPE while you’re doing it. Every circuit has to treated as energized until we have proven it is not.

Job Safety Planning

Before a task has begun that will expose workers to electrical hazards, such as our example of adding a circuit breaker to a 480/277 volt panel, a qualified person must create a job safety plan(JSP). The JSP has to include a description of the job and tasks, shock and arc risk assessments, and work procedures, special precautions, and energy controls. Once you have the plan created a job briefing needs to take place. Annex I of 70E has a helpful job briefing and planning checklist.

Approach Boundaries

Your electrical safety training must stress these boundaries, so every qualified fully understands what they mean. Approach boundaries operate as their name implies; as you approach a piece of electrical equipment with exposed energized circuit parts, there is a point at which the risk of injury becomes great enough that additional rules apply. Two shock-protection approach boundaries will be a central part of your shock protection; those are limited and restricted. They each have their own rules. There is also an arc flash boundary that marks where a second-degree burn is likely to occur on bare skin if an arc flash occurs. Each of these boundaries marks a spot where an increase in awareness, blocking access, work permits and PPE are going to be required. These boundaries mark the line where the likelihood of an injury and it’s severity increase. Barricades, an attendant, or tape are needed to identify the first encountered boundary.

The Limited Approach Boundary

The limited approach boundary is a distance from the employee to an exposed energized circuit part within which a shock hazard exists. The typical nominal AC voltages that a maintenance person would be working on of 120, 208, 220, 240, 277, 380, and 480 all have a limited approach boundary of 42 inches. For higher voltages, please refer to the latest edition of 70E. No unqualified person is allowed inside the limited approach boundary unless a qualified person is escorting them. Crossing this invisible boundary triggers the need to establish an electrically safe work condition.

Electrically Safe Work Condition (ESWC)

You have established an ESWC when you have disconnected the equipment, locked and tagged the disconnect, tested to verify an absence of voltage, and, if necessary, temporarily grounded the equipment. The temporary ground is something typically used in circuits above 1000 volts.

Restricted Approach Boundary

This boundary triggers the need to insulate the worker from the exposed circuit parts by utilizing insulated rubber gloves, insulated tools, sleeves, shields, etc. Unqualified workers are not allowed within the restricted boundary or to take any conductive material or tool within this boundary. There is no listed restricted boundary for 120 volts AC, 70E says to avoid contact. You must wear insulated gloves, use insulated tools when contacting live 120-volt circuits. The earlier mentioned voltages of 208, 220, 240, 277, 380, and 480 volts AC have a restricted boundary of 12 inches.

Arc Flash Boundary

This boundary is a distance at which a worker could suffer a 2nd-degree burn in 1 second to exposed bare skin. We must utilize proper PPE for arc flash protection when inside this boundary. The arc flash boundary is independent of the shock protection boundaries. Where your restricted and limited shock boundaries are 12 inches and 42 inches respectively, the arc flash boundary might be 50 feet, or it might be 1 inch.

Shock risk assessment

We have to perform a shock risk assessment, starting with identifying the shock hazard, which in the example of adding the circuit breaker will be 480 volts. We know our limited approach boundary will be 42 inches and the restricted 12. We will need to de-energize the upstream circuit breaker that feeds “Panel A.”

Turning off the main circuit breaker of “Panel-A” de-energizes all of the circuit breakers in “Panel-A,” but it does not de-energize “Panel-A.” A common misconception. The line side, the side of the breaker with the incoming power, normally the top of the breaker, will still have 480 volts even when turned off. A shock and arc flash hazard would still be present. To de-energize “Panel-A”, we will need to go to the upstream circuit breaker that feeds “Panel-A.”

At this point we have every breaker in the panel opened, including the main. We’re not ready to remove the front cover yet because the line side of the main circuit breaker is energized. The line side of the breaker is the incoming power, and a label on the panel indicates it is fed from MDP-3” and off we go to find “MDP-3.”

We go to the upstream main distribution panel “MDP-3” and find a circuit breaker labeled “Panel-A” and open the circuit breaker and put on our lock and tag.

Upon returning to “Panel-A” to begin removing the cover, we must first put up our barricades. The arc flash label indicates that the arc flash boundary for “Panel-A” is 72 inches. The barricades have to be set at least that far from the equipment to prevent workers from wandering into our work area. Instead of using a barricade a second worker can be employed as an attendant to warn others to stop them from approaching too closely. Ideally, use both a barricade and an attendant. If our arc flash boundary was less than the limited approach boundary, which is 42 inches, your barrier could be set as close as 42 inches. Always set the barricade at the first encountered boundary.

You might be thinking we’re not going to need barricades because “Panel-A” is de-energized. “Panel-A” is not de-energized because we haven’t proven it yet. All we know for sure is we have moved the handle on a circuit breaker in the “MDP-3” panel from the on to the off position. You must treat every circuit, wire, panel or piece of equipment as energized until we have proven it isn’t. Always test before touch.

Now, as we are readying ourselves to open the cover of “Panel-A,” we must address what the PPE requirements for this panel are. Part of our job safety plan would be to read the label on the equipment to determine the PPE needed for this panel. We know it is a 480 volt AC panel and we will be crossing the restricted boundary as we verify zero voltage. Therefore Class 00 gloves, which are rated at 500 volts AC, would be needed. They will also be required as we remove the cover as we likely will be within the restricted boundary at that time as well. Many times, as we remove the cover our tools are still in our hands, so we must use insulated tools rated for the voltage.

The tools and gloves have to be inspected daily before each use. In fact, any piece of equipment you use that has insulation, such as power-tool cord, extension cord, meter leads, tools, and the PPE you wear as a garment has to be inspected by you daily before each use. You must remove them from service if they show any sign of damage. The gloves must be electrically tested every six months. As with all PPE, it is essential that they fit the wearer. Don’t make the mistake of buying only one set of gloves for everyone to share. The companies that manufacture or sell gloves have sizing instructions on their websites. Don’t use gloves that are rated for a much higher voltage than you will ever need. If your workers are only going to be working on 480 volts, don’t buy them 1,000-volt gloves.

For arc flash protection we see that “Panel-A” has an incident energy of 13 cal/cm2 with an arc flash boundary of 72 inches.

The Live-Dead-Live Test

We will be performing a “live-dead-live” test. OSHA and 70E require us to verify zero energy at the panel. You must choose an appropriate voltmeter, test it on a known live circuit to verify the meter is functioning correctly. Then, check the circuit we want to work on to ensure it is de-energized, and then retest the meter. If the meter worked properly before and afterward, it was probably working during the test.

Non-Contact Voltage Detector

Non-contact voltage detectors, although very useful for a lot of things, cannot be used for the verification of 0 volts during lockout/tagout. OSHA and 70E both require us to measure the voltage between all phases, that is L1 to L2, L1 to L3, & L2 to L3, and each phase to ground. A non-contact device cannot do that. They work on the principle of capacitive coupling and require a complete current path from your hand holding it through your body to ground.

PPE Required

What Is An Arc Flash

An arc flash occurs during a short circuit in which current flows through an air gap. It could be started by the accidental dropping of a tool, a worker making a connection between an energized conductor and ground or another phase, or with a bad connection in your electrical system. Anytime current is flowing through an air gap it creates tremendous heat that can quickly burn a worker or ignite their clothing. When the initial shorting of the circuit occurs, the current flows through, in this example, a dropped tool. A dropped tool is a sufficient conductive path to cause the short circuit, but it is not a path that can withstand the available fault current. As thousands of amps of current begin to flow through this bad connection, an air gap is created as the tool melts away. The current is now flowing through what is known as plasma, and plasma is a great conductor. As the plasma ball grows, it begins to short out more of the circuit parts. What might have started as a short to ground is now a short circuit of all phase conductors. All of this takes place in milliseconds. The energy from this event is what engineers calculate during an arc flash incident energy analysis. The amount of available fault current, clearing time of circuit breakers and fuses, and other factors determine what this incident energy will be.

Arc Rated Clothing

All arc rated clothing is flame resistant but not all flame resistant gear is arc rated. Clothes made for flash fire, for use in the petrochemical industry, for example,  are flame resistant but not arc rated. Electrical workers must have arc-rated clothing.

On the label of arc rated gear, it will have an Arc Thermal Protection Value (ATPV) or an Energy Breakopen Threshold (EBT). ATPV and EBT are both evaluated in the same test, ASTM F1959. The first one to be reached is the reported arc rating. To the end user, it just doesn’t matter which it has. One is not better than the other. The thing you want off the label is the incident energy value or the Category number, regardless if it is ATPV or EBT.

Two Methods For Determining The Arc Rated Clothing Needed

The two methods are the Incident Energy Method and the PPE Category Method. Arc-rated clothing is labeled with both because the manufacturer doesn’t know which you will be using.

You must use one or the other, and you can’t mix them on the same piece of equipment. That is you can’t have equipment with an arc flash label that says it has 19 cal/cm2 incident energy and call it a category two panel. If you have the incident energy on the panel it means you have done an arc flash incident energy analysis and your panel is a 19 cal/cm2 panel and the clothing system worn while exposed will need to have a minimum value of 19 cal/cm2. The clothing category doesn’t play into it at all.

Incident Energy Analysis

This method is one in which electrical engineers have calculated an arc flash energy for your panels based on real data collected from the field. It is typically thought to be the more accurate method, although, because of many factors, predicting arc flash energy is not an exact science. The engineers are relying on your over-current protective devices, your fuses and circuit breakers, to operate as designed. The people collecting the real data from your facility have no way of knowing if the circuit breakers have been appropriately maintained over the many years of operation.

PPE Category Method

This method uses a set of tables to determine what the estimated arc flash energy and arc flash boundary are going to be. This method does not use real-world field data from your facility. It estimates all panels of a particular type to be the same no matter what facility they’re in. To use these tables, you must know the kind of equipment, voltage, clearing time of the over-current protective device, and the maximum available fault current. Finding the voltage and equipment type is easy. Clearing time and fault current are going to require electrical engineers to get involved. The data that will need to be collected, such as wire length, wire size, transformer data, and the calculations the engineers will have to make to arrive at your clearing time and available fault current is essentially the same for doing a full incident energy analysis.

For years many employers have used the tables and ignored the requirements for knowing the clearing time and available current.

When to wear PPE

We are required to use Table 130.5 in 70E 2018 for estimating the likelihood of an arc flash event in the equipment that we will be servicing. The table lists equipment and tasks and indicates the likelihood that an arc flash might occur.  This table gives specific tasks, such as Thermography and visual inspections, a pass and says during these tasks there isn’t a likelihood of an arc flash. And further protective measures are not required, including PPE. It also states there are times when the equipment is in the “Normal Operating Condition” that there won’t be a likelihood of an arc flash. Myself, some colleagues in the field, and many of my clients are ignoring this. In our opinion, if the equipment has an arc flash incident energy of 1.2 or above, and you are within the arc flash boundary, PPE should be a requirement no matter what you are doing. And, if an employee is interacting with the equipment, even if the equipment is closed, such as opening or closing breakers, PPE will be utilized. The “Normal Operating Condition” includes a requirement that the equipment is properly maintained and has been used in accordance with the manufacturers’ instructions. How would any employer be able to verify that on a piece of equipment that has been around for many years? In my opinion, you should utilize arc flash PPE indicated by the equipment label any time the equipment doors are open, and you are within the arc flash boundary, and anytime you are interacting with the equipment even if doors are closed.

Your arc flash training needs to include when your facility requires arc flash PPE.

We see the equipment label on “Panel-A” indicates 13 cal/cm2 of incident energy which requires us to wear PPE of at least that arc rating. From table 130.5(G) we see we will need a face shield, hard-hat, balaclava, hearing protection, safety glasses, leather footwear, and because we’ll be within the restricted approach boundary, insulated gloves with leather protectors. We must ensure we aren’t wearing any conductive jewelry and that our undergarments are made of non-melting fabric. The t-shirt you wear under your arc rated clothing has to be made of natural fibers such as cotton. They make arc rated long and short sleeve t-shirts which are ideal for use as an undergarment.

You need to make it clear during your arc flash training, what your PPE procedures are. Does everyone get their own hard-hat, face-shield, and balaclava? Are we using arc rated PPE that we rent or do we own it? Do the employees have to launder it at home and what are those laundering instructions. What about arc flash suits for the high incident energy levels. Where are they kept? One size doesn’t fit all. If one worker is 6 ft 4 inches tall and weighs 250 pounds is going to wear the same arc flash suit as another worker who is 5 foot 7 inches and weighs 130 pounds. No, that won’t work. When a worker is going to exposed to energized work as during verification of zero energy they need to be fully aware of what to wear and where to find it and be comfortable in the knowledge that it is going to be appropriate for their body.

Resources for more information on PPE

Salisbury , Westex, Bulwark, Ariat, Oberon

Your Training

As I’ve said, the employer must provide electrical safe work practices, practices like those in 70E, and then train employees on them. That training needs to be a classroom, instructor-led training that encourages and answers questions. A test of some type and a certificate of completion. Online training should only be used as a refresher course. Your electrically qualified need to be retrained at least every three years.

Document when the training occurred, who was in attendance, and who the instructor was. The contents of this electrical safety training must be documented for future OSHA visits or company safety audits.

Our NFPA70E/Arc Flash Training

Summary

Electrical safety is quite simple. The employer provides safe work practices, trains the employee, and the employee follows them. The employer as well must follow these practices and insist workers priority will always be de-energizing the equipment. The employer also needs to provide proper PPE for the tasks involved. Hopefully, the only energized work, anyone, does at your facility is verification of zero energy during lockout tagout.

This Practical Guide To Arc Flash and NFPA 70E does not cover every detail of the 70E standard. But, hopefully, it will help simplify the standard for those using it in the field.

1. Provide electrical safe work practices.
2. The centerpiece of those work practices must be the elimination of the hazard. Establishing an Electrically Safe Work Condition.
3. Train your people on those work practices. Your electrical safety training, arc flash training is the glue that holds your electrical safety program together.
4. Ensure your employees are qualified for the electrical tasks they are about to perform and the hazards for which they are exposed.
5. Provide proper PPE for the hazards your people will face. Make sure that PPE fits the individual.
6. A qualified worker must conduct a job safety plan and there must be a job briefing prior to work beginning.
7. Conduct proper risk assessments prior to work beginning.

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This new one-hour online 70E for managers class covers those things that a manager needs to know to effectively manage an electrical safety program. If your direct reports include electrically qualified workers this class can help you comply and create a safer working environment. We’ll cover the topics that managers and safety professionals have to be diligent about when managing workers around electrical hazards.

Link to Online 70E For Managers

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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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Electrical safety in an R&D facility or laboratory can be challenging. The rules for R&D labs have been broadened in the 2018 edition of NFPA 70E. R&D labs face special challenges due to one-of-a-kind equipment and the need to do things that are sometimes out of the ordinary. The lab must follow all requirements of 70E except as amended by article 350. Let’s look at how article 350 changes things for areas designated for research and development or laboratories.

Electrical Safety Authority (ESA)

To ensure proper safe work practices and controls each lab is permitted to assign an Electrical Safety Authority or ESA. The ESA could be an electrical safety committee, engineer or equivalent qualified individual. The ESA is permitted to delegate authority to individuals or organizations within their control.

ESA Responsibility

The ESA has the responsibility to act in a manner similar to an Authority Having Jurisdiction (AHJ). NFPA defines an AHJ as an individual responsible for enforcing the requirements of a code or standard, o

r for approving equipment, materials, an installation, or a procedure. AHJ’s are referenced throughout many NFPA documents and could be a fire marshal, building inspector, insurance inspector, commanding officer, etc.

ESA Qualifications

The ESA must be competent in the requirements of NFPA 70E and the electrical system requirements of the lab.

Specific Measures And Controls For Personnel Safety.

A competent person is still required for the lab as in years past. The standard change calls for the lab to designate a competent person rather than having one assigned. The standard defines a competent person as someone who meets all the requirements of qualified person and who, in addition, is responsible for all work activities or safety procedures related to custom or special equipment and has detailed knowledge regarding the exposure to electrical hazards, the appropriate control methods to reduce the risk associated with those hazards, and the implementation of those methods.

Job Briefings

Job briefings must be conducted as required by chapter 1 of 70E with an exception: Prior to starting work, a brief discussion shall be permitted if the task and hazards are documented and the employee has reviewed applicable documentation and is qualified for the task.

Personnel Protection

As elsewhere in 70E it is necessary to use safety-related work practices for employees exposed to electrical hazards. For special lab equipment where the personnel need to calibrate and adjust sensors, motor controllers, control hardware and other devices that are installed inside equipment or control cabinets the ESA shall define the required PPE based on the risk and exposure. Insulating blankets, covers, or barriers are permitted and insulated tools are required where feasible.

Approval Requirements

Field evaluation is required of all equipment that is not labeled as listed by a listing organization such Underwriters Laboratories. Because in a lab setting one-of-kind equipment may be built for a one-time use it being listed is not likely or practical.

Custom Built Non-Listed Research Equipment, 1000 Volts or Less AC Or DC

Equipment markings, documentation, shutdown procedure, specific hazards, and approvals are required for custom built equipment. They are normally provided with equipment that is purchased off the shelf but for custom equipment, it has to be created on-site.

Equipment Marking

Voltages entering and leaving the control cabinets of the equipment are required to be marked on the exterior of the equipment. Caution, Warning, or Danger labels shall be affixed to the exterior describing specific hazards and safety concerns. ANSI Z535 is a good reference for safety signage.

Equipment Documentation

Sufficient documentation must be provided for the installation, maintenance, and operation of custom built equipment that also describes any safety concerns, shutdown procedure, and non-standard installations. Schematics, drawings, and description of power feeds, voltages, currents, and parts used for construction, maintenance, and operation shall be provided.

Shutdown Procedures

A simple on/off switch doesn’t work for a shutdown procedure for much of the equipment in a laboratory. A detailed shutdown procedure and emergency shutdown procedure that allows for a safe shutdown are required. If equipment-specific lockout/tagout is required, these procedures shall be readily available.

Specific Hazards

Hazards other than electrical shall be documented and readily available.

Approvals: Drawings, Procedures & Equipment

Drawings, procedures, and equipment shall be approved by the ESA prior to startup. The equipment must comply with national standards unless research requires exceptions. Proper shutdown procedures and PPE requirements shall be considered in the absence of grounding and bonding.

Tools, Training, & Maintenance

Sometimes it may be necessary to use special tools and unusual PPE. Documentation is required in such cases and the ESA will determine appropriate training and qualifications required.

Custom Built Non-Listed Research Equipment, > 1000 Volts AC Or DC

Shall comply with everything required for under 1000 volt equipment. If the equipment requires PPE beyond what is commercially available the ESA will determine safe work practices and PPE to be used.

Energy Thresholds

If the energy exposure levels exceed those below, the ESA shall determine appropriate controls.

1.       AC: 50-Volts and 5 Milliamps
2.      DC: 100-Volts and 40 Milliamps
3.      Capacitive Systems:
   1. 100-Volts and 100 Joules Of Stored Energy
   2. 400-Volts and 1.0 Joules Of Stored Energy
   3. 0.245 Joules Of Stored Energy

Taken from the Department Of Energy Electrical Safety Handbook.

Establishing an Electrically Safe Work Condition

Just like elsewhere in 70E a circuit needs to be de-energized prior to work being performed. In the lab there are exceptions:

The ESA is permitted to determine alternative methods of ensuring worker safety for the following conditions.

1. Minor tool changes and adjustments, and other normal production operations that are routine, repetitive, or sequential and integral to the use of the equipment for production
2. Minor changes to the unit under test and other minor servicing activities, to include the activities listed under 350.10Exception condition (1), that take place during research and development
3. Work on cord-and-plug-connected equipment for which exposure to the hazards of unexpected energization or startup is controlled by the following:
   1. Unplugging the equipment from the energy source
   2. The employee performing the work maintaining exclusive control of the plug

Conclusion: Electrical Safety In An R&D Facility or Laboratory

Electrical safety in an r&d facility or laboratory has special challenges that are caused by special equipment and people performing work that goes beyond what the original creators of  70E had in mind. Article 350 does a great job in providing guidance by allowing for an Electrical Safety Authority working with the designated competent person(s) to provide the safest environment for these very challenging areas.

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A great article from our friends at Westex.

Last year, a Los Angeles County jury found Qualcomm liable for $7.1 million[1] in damages as a result of a burn incident. Qualcomm, a telecommunications equipment company, was found negligent in an electrical fire incident, where a third-party contractor suffered third-degree burns while servicing electrical equipment on the company’s premise. The incident, which resulted in catastrophic injury, provides an opportunity to assess contractor safety and the liability incurred when contractors step foot on company property.

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www.westex.com
1 See CASE NO. 37-2014-00012901-CU-PO-CTL SUPERIOR COURT STATE OF CALIFORNIA FOR THE COUNTY OF
SAN DIEGO – CENTRAL.
Last year, a Los Angeles County jury found Qualcomm liable for $7.1 million1 in damages as a result of a burn incident. Qualcomm, a telecommunications equipment company was found negligent in an electrical fire incident, where a third-party contractor suffered third-degree burns while servicing electrical equipment on the company’s premise. The incident, which resulted in catastrophic injury, provides an opportunity to assess contractor safety and the liability incurred when contractors step foot on company property.

A Case Study Review
Understanding Your Liability In Arc Flash Incidentsin third-party contractor situations

1. The injured contractor was a contract employee, not a direct employee of Qualcomm.
2. The contractor’s clothing ignited – indicating he was not wearing flame resistant (FR) apparel, which was later confirmed in his declaration to the court.
3. The contractor was not wearing his PPE because he was advised that the equipment would be de-energized. As part of a planned system upgrade, a third-party contractor visited Qualcomm to inspect the on-site generators. He was told the entire system would be turned off while he and others inspected the equipment, so without his personal protective equipment (PPE), he approached a 4,160-volt circuit breaker. What the contractor did not realize was that the system was still live. When he approached the circuit breaker, after Transpower personnel removed it, a sudden arc flash occurred and his clothes immediately ignited. The resulting fire caused severe burns on 35% of his body, and the contractor spent a month in the hospital recovering from his injuries. When the contractor brought suit, he claimed that Qualcomm and others were negligent and failed to provide a safe work environment. Qualcomm pushed back, arguing its employees turned off the main breaker on the property and followed appropriate safety procedure before opening the site to the contractor. Further, the company alleged that Transpower and the contractor did not heed safety warnings and did not have permission to remove the circuit breaker cover – contending he contributed to the arc flash incident. The jury ultimately found Qualcomm 46% negligent, contractor Transpower Testing, Inc. 45% negligent, and the injured contractor himself 9% negligent.

Background For Liability In Arc Flash Incidents This unfortunate incident has a number of implications, but for those in the safety community, there are three critical points to note:

Key Takeaways from Liability In Arc Flash Incidents Under NFPA 70E, safety onus is on both the host company and the contract employer. Below are specific responsibilities each party should take to provide for electrical worker safety under NFPA 70E:
• A host employer’s responsibilities include:
ₒ Informing contract employers of known hazards covered by NFPA 70E, which are related to the contract employer’s work, and might not be recognized by the contract employer or its employees. ₒ Informing contract employers about any instances where the contract employer will need to make assessments required by Chapter 1 of NFPA 70E.
ₒ Reporting observed contract employer-related violations of this standard to the contract employer.

Liability In Arc Flash Incidents

Applying the Takeaways Electrical employee safety is a system of checks and balances. The NFPA standard outlines both preventative and mitigating measures to ensure the safety and livelihood of those working with electrical systems and equipment. The Qualcomm incident, we think, does a good job of emphasizing the impact of FR personal protective equipment (PPE) as a safety hazard mitigation tool. While nothing is ever certain, it can be assumed that the lingering clothing-burn caused by arc flash ignition compounded the severity of the contractor’s injuries. It seems that if he had been wearing appropriate guaranteed flame resistant arc-rated FR garments, his clothing would have self-extinguished after the arc flash, which could have substantially reduced his burn injuries. When created with reputably branded FR fabric, FR apparel helps to mitigate and reduce injury in the event of an arc flash. FR fabrics are engineered to self-extinguish once a thermal source is removed, so garments do not continue to burn post-exposure. This then allows for an employee to quickly remove his or herself from the hazard, without having to deal with post-flash clothing fires. An arc-rated flame resistant (AR/FR) apparel program comes in many different forms and should be tailored to the specific electrical hazards employees face. Arc-rated fabrics are tested in accordance with F1506 protocol to determine arc rating, and NFPA 70E outlines the necessary arc ratings FR apparel should have when working around various electrical hazards.
• A contract employer’s responsibilities include:
ₒ Ensuring each of the contract employer’s employees is instructed in the hazards communication by the host employer, in addition to providing the basic training required by NFPA 70E.
ₒ Ensuring each employee follows work practices required by NFPA 70E and safety-related work rules required by the host employer.
ₒ Advising the host employer of unique hazards presented by the contract employer’s work, hazards identified during the course of work that were not communicated by the host employer, or measures a contractor took to correct any violations reported by the host employer under NFPA 70E 110.3(A)(2) and to prevent such violations from reoccurring. Chapter 110.3 of NFPA 70E provides full language to understand your responsibilities as either a contract employer or a host employer. This is important information that should be assessed with your entire safety team at regular intervals to make sure you are fully adhering to the standard. When working with third-party contractors, it is critical to use an overabundance of caution. As seen above, and underscored by the jury’s verdict in the Qualcomm case, the employers – both the host and the contractor – shoulder the considerable majority of the safety burden as compared to the employee performing the actual work. Understanding the Impact of FR Apparel in Protecting Employees

The information in this Case Study represents our analysis of the Qualcomm case. It is not intended to substitute for any testing that may be unique and necessary for your facility for you to determine the suitability of our products for your particular purpose. Because we cannot anticipate all variations in end-user conditions, Westex, Inc. makes no warranties and assumes no liability whatsoever in connection with any use of this information. All sales are exclusively subject to our standard terms of sale posted at www.milliken.com/terms (all additional/different terms are rejected) unless explicitly agreed otherwise in a signed writing. While we have made every attempt to ensure that the information contained in this Case Study has been obtained from reliable sources, Westex is not responsible for any errors or omissions, or for the results obtained from the use of this information. All information in this Case Study is provided “as is”, with no guarantee of completeness, accuracy, timeliness or of the results obtained from the use of this information, and without warranty of any kind, express or implied, including, but not limited to warranties of performance, merchantability and fitness for a particular purpose. In no event will Westex and/or its related entities, or the partners, agents or employees thereof be liable to you or anyone else for any decision made or action taken in reliance on the information in this Case Study or for any consequential, special or similar damages, even if advised of the possibility of such damages. The information contained in the Site is general information and should not be construed as legal advice to be applied to any specific factual situation. Westex by Milliken can be a helpful resource as you walk through the review, creation, and implementation steps to create a well-rounded FR program, designed to protect those who come into contact with electrical hazards. Our knowledgeable team of experts can help educate you and your leadership on what an FR program means. To learn more, visit Westex.com as the AR/FR garments – typically a shirt and pants – are worn throughout the day as their standard “uniform.” When AR/FR clothing is worn during the entire workday, employees are more likely to be protected from unforeseen hazards. Comfort is a key component of a daily wear AR/ FR clothing program. With numerous FR fabrics on the market, it is important to specify which FR fabric is used to make your AR/FR clothing. There are some AR/FR fabrics offering a similar look and feel to everyday street clothing. Westex® brand FR fabrics are designed with both the wearer’s protection and comfort in mind, and have been specified for decades by end users globally. AR/FR fabric forms the foundation of an AR/FR garment, so it is necessary to build your program on a solid base – in this instance, a reliable fabric specification. Understanding the Impact of Task-based vs. Daily Wear Arc-Rated Flame Resistant (AR/FR) Apparel One final takeaway, which can be drawn from the Qualcomm case, is the importance of daily wear AR/FR apparel. We infer that, because the injured contractor was able to leave his PPE at home, it was likely task-based PPE. Task-based PPE is just as it sounds – the PPE is only worn for a certain task or in certain situations. While in theory task-based AR/FR clothing programs seem like a cost-effective solution, the reality is it relies too much upon the user. The user must bring and wear AR/FR clothing – typically a coverall – at the correct time, and often, they can be subject to incorrect risk assessments or human nature. Many times, task-based AR/FR clothing, for whatever reason, is not utilized when a situation requires it most. With daily wear AR/FR clothing programs, the burden on the user is lessened considerably,

Liability In Arc Flash Incidents is a great article for anyone trying to understand the attitudes of courts when it comes to injuries from electrical hazards.

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