In an article that was published in EC&M magazine back in January of 2011, there was a discussion regarding “The Seven Deadly Misconceptions About Arc Flash Labeling.” At that time we (the industry) were using the 2009 NFPA 70E standard, and still developing a better understanding when it came to proper labels for safety. The article discusses the National Electrical Code (NEC) and the National Fire Protection Association (NFPA) 70E 2009 in regards to the requirements for the labels and what needed to be on the labels.
The basic requirement for a label begins with the NEC, article 110.16. This states that, aside from dwelling units, there must be an arc flash label warning “qualified” persons of the danger of arc flash when working on live (energized) equipment. And then the NFPA 70E talks about what those hazards are and the proper PPE to protect those persons. So, the NEC requires what we will call a “generic” label and the NFPA 70E requires a “detailed” label. Remember that this article was written in 2011.
The Seven Deadly Misconceptions About Arc Flash Labeling Outlined in the EC&M Article:
Misconception #1 was, because I have not received any violation then I do not need a label.
Misconception #2, I sub-contract all my work out and therefore I do not need to apply the labels.
Misconception #3, generic labels will work, and engineered labels are not needed.
Misconception #4, the electrical equipment passed its initial inspection and that is good enough.
Misconception #5, rumor was that the NFPA 70E 2009 only applied to “heavy industrial facilities.”
Misconception #6, no need to perform a study, companies can just pick categories based on the tables.
Misconception #7, all I need is an arc flash label and nothing else.
Now, let us fast forward to December 2015.
We are currently using the NFPA 70E 2015 Standard, and there is one major change in the form of labels. The new standard now requires either, available incident energy and working distance, OR the arc flash PPE category from the tables, but not both. Other than the one major change, the arc flash label is still required per the 2014 NEC, and the requirements for what goes on the labels are still found in the 2015 NFPA 70E.
So, now we talk about the counterarguments to each of these misconceptions.
Counterargument #1, The approach of not applying an arc flash label because the company has not been cited or handed a violation, can be interpreted as the company does not care for its employees. The label requirements are needed for employee protection when they are working on exposed energized parts. The employees need to know what to wear to protect themselves against the potential shock and explosion. Why wait on a citation? Applying the labels before an accident/incident goes a long way with employee morale.
Counterargument #2, The responsibility to protect sub-contractors is a two way street. The company that is paying for the services of the sub are required to provide a safe working environment, and the sub is required to notify the host employer of any deficiencies and they are to make sure that there employees are following those safe work practices.
Counterargument #3, Because the way the code is written, arc flash labels are required to illustrate the specific hazard(s) and the proper PPE for that hazard(s). The NEC does not address the “protection” but instead it addresses the need for a “warning of the hazards.” The only way to get labels with the specifics of the equipment will be to hire someone to perform and arc flash risk assessment.
Counterargument #4, True that the equipment did pass an initial inspection of installation requirements. However, some facilities are older and have not gone through the proper permitting and inspections processes through the years.
Counterargument #5, The code addresses in ease, there is a standard within the 2015 NFPA 70E (90.2(A)). Multiple types of facilities are included within this standard and not just “heavy industrial facilities.”
Counterargument #6, This is true, as long as the company can verify that the “parameters” have been met. Using the 2015 NFPA 70E Table 130.7 (C)(15)(A)(b), someone would be able to determine an Arc Flash PPE Category. In the equipment column there are parameters listed and they vary, the first set of parameters are “Maximum of 25kA short-circuit current available; maximum of 0.03 sec (2 cycles) fault clearing time. These will prove harder than one might think to verify and document. Having an engineered study will have all of this listed within the report and the label will be specific to the equipment.
Counterargument #7, There is the basis of the label, yes. But training is also a requirement and needing to be refreshed no more than every three years for the employee(s). And not to mention that the arc flash risk assessment needs to be reviewed on a basis that does not exceed five years.
So, an article that was written four years ago still addresses the same concerns and misconceptions that are still being discussed in 2015. The basics are that the label is a requirement and the only way to ensure a label that is specific to the hazards of each piece of equipment, is to conduct an arc flash risk assessment. The 2015 NFPA 70E had a lot of changes to it and the labeling requirement was just one. The new standard now requires either, available incident energy and working distance, or the arc flash PPE category from the tables, but not both.
Arc flash labels are required.
Don’t wait for OSHA to hand out a citation, be proactive and show your employees that you care about their well-being.