Arc Flash Labeling Requirements – Are You Really in Compliance?

Feb. 10, 2012 - PRLog -- Generic arc-flash labels applied before September 30, 2011 are non-compliant per 130.5(C) of NFPA 70E-2012 if they do not inform the in-house or contracted worker about the available incident energy or required level of PPE.  In the event of worker injury due to an electrical accident at your facility, generic labels could be cited as cause for the accident.

NFPA  70®-2011, “National Electrical Code®” (NEC), Article 110.16 “Arc-Flash Hazard Warning” requires that switchboards, panelboards, industrial control panels, meter socket enclosures, and motor control centers which are in other than dwelling units that are likely to require maintenance while energized “shall be field marked to warn qualified persons of potential electric arc flash hazards. The marking shall be located so as to be clearly visible to qualified persons before examination, adjustment, servicing, or maintenance of the equipment.”  This requirement covers electrical equipment in both public and private buildings and structures per Article 90.2.

NFPA 70E®-2012, “Standard for Electrical Safety in the Workplace®” provides requirements for conducting an arc flash hazard analysis to determine where potential arc flash hazards exist throughout the electrical system and what kinds of personal protective equipment (PPE) are required for the task.  Article 130.5 states that “The arc flash hazard analysis shall be updated when a major modification or renovation takes place. It shall be reviewed periodically, not to exceed five years, to account for changes in the electrical distribution system that could affect the results of the arc flash hazard analysis.”

OSHA has no specific requirement for such marking.  However, paragraph (e) of 29 CFR §1910.303 requires employers to mark electrical equipment with descriptive markings, including the equipment's voltage, current, wattage, or other ratings as necessary.  OSHA believes that this information, along with the training requirements for qualified persons, will provide employees the necessary information to protect themselves from arc-flash hazards.

Additionally, in 29 CFR §1910.335(b), OSHA requires employers to use alerting techniques (safety signs and tags, barricades, and attendants) . . . to warn and protect employees from hazards which could cause injury due to electric shock, burns or failure of electric equipment parts.  Although these Subpart S electrical provisions do not specifically require that electric equipment be marked to warn qualified persons of arc-flash hazards, §1910.335(b)(1) requires the use of safety signs, safety symbols, or accident prevention tags to warn employees about electrical hazards (e.g., electric-arc-flash hazards) which may endanger them as required by §1910.145.

After an arc flash hazard analysis has been completed, additional engineering may be required to lower high levels of incident energy to manageable levels. Only a complete electrical system analysis by a qualified professional can identify the level of personal protective equipment required at each location in the system.  Relying upon quick analysis methods can expose you to unexpected liabilities. There are a number of shortcuts being offered by individuals and companies that can have disastrous results. Be sure that your methods will stand up to analysis and peer review.

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McCain Engineering, LLC
3522 Rocky Ridge Road
Oxford, Alabama 36203
www.mccaineng.com
(256) 391-1486