Arc Flash Studies are Easy - NFPA-70E is Hard!

[diakonos1984]

Our company conducts arc flash studies and provides NFPA-70E training for a variety of industries in the central US. I am finding that while conducting a good arc flash study takes some time and money, full NFPA-70E compliance requires a significant culture change.

Unfortunately, in spite of my recommendations to the contrary, many customers bring us in to provide safety training before management really understands the implications of NFPA-70E. This creates some tense situations as lights are coming on for both management and floor level workers at the same time. PPE isn't too hard of a sell; it's the work permit that's the killer. Many plants have no concept of a work permit at all!

I was wondering how others in the industry have dealt with some of these issues:

1) Opening or closing breakers is energized work. Therefore it requires an energized work permit. How do you handle routine breaker operation? I have one customer that uses their 277V breakers as light switches every day! This customer has a lot of production machines fed off of overhead busways. Simply shutting off the machine and opening the 480V box on the side to change fuses appears to me to require an energized work permit. Do you have "standing work permits" for routine operations like this?

2) One customer is a chemical plant, and they are much further ahead, since they use work permits for all maintenance anyway. However, they have operators (non-electrical) who routinely open 480V MCC breakers to allow mechanics (non-electrical) to change belts, filters, and other non-electrical work. While the maintenance is not electrical work and does not involve exposed conductors, it IS electrical LOTO. Do they need to perform the full NFPA-70E six-step LOTO procedure with voltage checks? If so, where do they do their voltage check? The MCC bucket or the motor?

3) One plant has a production line with product testers who routinely connect 480V to "units" for testing. A computer controls a contactor that applies the voltage at the appropriate point in the test. The test personnel do not lockout the test device while moving (dead) leads from one unit to another. In fact, there is no lockout point on this part of the test device. Can they really depend on the computer for their safety, or do lockout points need to be installed? If so, do work permits need to be issued for connecting and disconnecting "units"?

4) The same customer has R&D labs with technicians routinely operating 480V disconnects, troubleshooting live "units", and running test procedures. While the troubleshooting doesn't require a permit (though it does require PPE), what do they do for the disconnects? Some sort of standing work permit, that needs only be renewed every couple days/weeks/months?

As an electrical engineer, it's not my job to dictate my customer's safety policies. But I don't like throwing a 20lb arc flash study on the desk, scaring people with some safety training, and rolling out. I don't have to live with the implications, but I would like to help my customers achieve some workable solutions that ensure safe work practices firstly, but also balance plant productivity with NFPA-70E compliance. How have others in the industry dealt with these things?

Thanks for the input!

 

[jim dungar]

1) Opening or closing breakers is energized work.

Says who? The task tables are not applicable after an arc flash study is done.

Simply shutting off the machine and opening the 480V box on the side to change fuses appears to me to require an energized work permit.

I agree this should be 'permited' work

2) While the maintenance is not electrical work and does not involve exposed conductors, it IS electrical LOTO.

If nothing is exposed how is it electrical LOTO?

NFPA70E is about each company creating their own Electrical Safe Work Practices programs, but like the NEC, it is just a 'guideline' not a 'how to' manual. For example, there is a difference between a residential circuit breaker, like a HomeLine, and an industrial breaker like an I-Line, but they are both built/listed to the same exact standard UL#489.

 

[zog]

I sopent 15 years doing this job, I managed several differnt training and compliance programs for heavy industrial companies (Auto plants, stell mills, stuff like that) I also trained many of OSHA compliance officers on 70E compliance because it was new to them too. Back when the 70E was new to everyone (2000) it was even harder.

Our company conducts arc flash studies and provides NFPA-70E training for a variety of industries in the central US. I am finding that while conducting a good arc flash study takes some time and money, full NFPA-70E compliance requires a significant culture change.

Unfortunately, in spite of my recommendations to the contrary, many customers bring us in to provide safety training before management really understands the implications of NFPA-70E. This creates some tense situations as lights are coming on for both management and floor level workers at the same time. PPE isn't too hard of a sell; it's the work permit that's the killer. Many plants have no concept of a work permit at all!

You should never suprise the management with the requirements of compliance. I always offered a pre-training with myself and management where I would review all the steps to complance with them and tell them what to expect for policiy changes, PPE costs/program recommendations, method of analysis recommendations, and most importantly I gave them a list off all the phrases they expect to hear from thier workers during the "culture change" (You put that well by the way). Most took me up on the offer, some did not and regretted it later. One of your jobs is to not make the management team look stupid or off gaurd.

I was wondering how others in the industry have dealt with some of these issues:

1) Opening or closing breakers is energized work. Therefore it requires an energized work permit. How do you handle routine breaker operation? I have one customer that uses their 277V breakers as light switches every day! This customer has a lot of production machines fed off of overhead busways. Simply shutting off the machine and opening the 480V box on the side to change fuses appears to me to require an energized work permit. Do you have "standing work permits" for routine operations like this?

Not energized work at all and no permit equired for 99% of switching applications. Using breakers for light switches in light industrial is pretty common, that is a prime example of where "Non-qualified" training should be applied for this specific task. Companies that offer one NFPA 70E training couse (Canned crap) never meet the training requirements, last job I offered about 12 different courses as base courses with task specific training for specific groups that was customized for the facilities needs.

2) One customer is a chemical plant, and they are much further ahead, since they use work permits for all maintenance anyway. However, they have operators (non-electrical) who routinely open 480V MCC breakers to allow mechanics (non-electrical) to change belts, filters, and other non-electrical work.

Again, task specific training.

While the maintenance is not electrical work and does not involve exposed conductors, it IS electrical LOTO.

Why do you think that?

Do they need to perform the full NFPA-70E six-step LOTO procedure with voltage checks? If so, where do they do their voltage check? The MCC bucket or the motor?

No, and neither.

3) One plant has a production line with product testers who routinely connect 480V to "units" for testing. A computer controls a contactor that applies the voltage at the appropriate point in the test. The test personnel do not lockout the test device while moving (dead) leads from one unit to another. In fact, there is no lockout point on this part of the test device. Can they really depend on the computer for their safety, or do lockout points need to be installed? If so, do work permits need to be issued for connecting and disconnecting "units"?

I would need to know more about the system to say for sure but does not sound like a problem.

4) The same customer has R&D labs with technicians routinely operating 480V disconnects, troubleshooting live "units", and running test procedures. While the troubleshooting doesn't require a permit (though it does require PPE), what do they do for the disconnects? Some sort of standing work permit, that needs only be renewed every couple days/weeks/months?

Same answer as #1. Your customers must be buried in permits.

May I suggest you attend some training yourself, I can make a couple recommendations of course specifically designed for people that do your job.

 

[zog]

1) Opening or closing breakers is energized work.

Says who? The task tables are not applicable after an arc flash study is done

Right, but the arc flash label still applies for operating a breaker, that is "interacting with equipment" and even with the doors closed the Ei''s and required PPE still apply.

 

[diakonos1984]

Thank you Zog and Jim,

I was hoping to get some responses from you in particular as I have found your other comments/posts on this forum to be very helpful in the past.

"Is operating breakers considered energized electrical work?" appears to be the crux of the matter. As it will be Monday before I am back at the office with the standard in front of me, I can't cite it tonight, but I really don't believe I've ever thought the standard specifically said that anyway. However, I am almost positive that in both the 2004 and in the 2009 NFPA-70E Video Seminar the NFPA reps said that operating breakers IS considered energized work.

Zog, while you don't interpret the standard this way, you did say "...the arc flash label still applies for operating a breaker, that is "interacting with equipment" and even with the doors closed the Ei''s and required PPE still apply." Why would PPE still apply, if it's not energized work??? The only case I have seen in the standard for requiring PPE, but not an energized work permit is the clearly spelled out exception of troubleshooting.

It will be Monday before I can look at the standard again, or address any of the other issues you have raised, but this is at least an explanation of my understanding at this point. If I am wrong, it will be a relief to my customers who are not looking forward to being "buried in permits."

Thank you very much for your thoughts. I will have more questions later. These issues are very important to me to get squared away on. Our company's practice in the past was to provide the study and let the customer deal with the standard on their own, but that is all changing now that we are providing training.

 

[jim dungar]

Right, but the arc flash label still applies for operating a breaker, that is "interacting with equipment" and even with the doors closed the Ei''s and required PPE still apply.

I hope I did not give the impression that proper PPE was not required.

But, there is difference of opinion as to how treat devices that have been tested and listed for breaking the amount of arcing fault current. Also, what PPE is required when the Limited Approach boundary is calculated to be only 2" and the operating handle is 4" away.

No single answer fits every situation.

 

[ron]

Nathaniel,
While contemplating over the weekend, NFPA.org has 70E available for you to review on the website for free. Just like all other NFPA documents.

 

[zog]

I hope I did not give the impression that proper PPE was not required.

.

Just was not sure Jim.

 

[zog]

Zog, while you don't interpret the standard this way, you did say "...the arc flash label still applies for operating a breaker, that is "interacting with equipment" and even with the doors closed the Ei''s and required PPE still apply." Why would PPE still apply, if it's not energized work??? The only case I have seen in the standard for requiring PPE, but not an energized work permit is the clearly spelled out exception of troubleshooting..

Again, not energized work, no permit required, but still an arc flash haard. An EEWP is required when crossing the LAB of exposed live parts to do work (With the exceptions), operating a breaker with covers on is still a task that has an arc flash hazard (Unless the gear is arc rated) and requires PPE, but not really energized work.

For what it is worth, one of my jobs now is an arc flash soulution specialist. I find solutions to those nasty >40cal systems and remote switching has come a long way in the last year and there are now wireless, easy to use remote switiching devices available for alomost every breaker/switch/mcc out there.

 

[cornbread]

I'll hop on my soap box for a few brief statements. Let me be clear I support the efforts of 70E and at our plant we have installed some remote racking, provided extensive training and purchase tons of new PPE and tools. I would estimate we spent apprx. $250K last year. Are we safer? The answer would of course be yes. With that said, here is my beef with 70E, or I should say 70E enforcement. The bean counters keep harping that our plant charge out rate for electrcial services are high. Of course they are comparing us to other plant that have not implenented 70E. I usually relpy the dollars associated if a accident occurs and that the prevention upfront is a real cost saving, but cost are a real concern when our plant is competing for new products lines. It's the same argument about shipping job to Mexico. I want to be safe, but I also want to see our plant continue to grow. Knock on wood our electrcial safety record has been top notch and that fact helps me keep funding our 70E effort but I fear its a matter of time before the cost outweights the benifits (in the eyes of the bean counters). If 70E was enforced nation wide it would help level the playin field.

 

[jim dungar]

... remote switching has come a long way in the last year and there are now wireless, easy to use remote switiching devices available for alomost every breaker/switch/mcc out there.

Zog, we live in two different worlds sometimes. You hear "switching breakers" and think of power circuit breakers. I hear "switching 277V breakers" and think of molded case breakers in 'wall mounted' panels used as light switches.

 

[zog]

Zog, we live in two different worlds sometimes. You hear "switching breakers" and think of power circuit breakers. I hear "switching 277V breakers" and think of molded case breakers in 'wall mounted' panels used as light switches.

When it comes to PPE required for arc flash what is the difference? You still need to follow what the label says, even if it is HRC 0 for the 277V breakers.

I live in the same world as you, the one where we have to wait until August to see if Favre is retiring on not, Skol Vikings!

 

[zog]

I'll hop on my soap box for a few brief statements. Let me be clear I support the efforts of 70E and at our plant we have installed some remote racking, provided extensive training and purchase tons of new PPE and tools. I would estimate we spent apprx. $250K last year. Are we safer? The answer would of course be yes. With that said, here is my beef with 70E, or I should say 70E enforcement. The bean counters keep harping that our plant charge out rate for electrcial services are high. Of course they are comparing us to other plant that have not implenented 70E. I usually relpy the dollars associated if a accident occurs and that the prevention upfront is a real cost saving, but cost are a real concern when our plant is competing for new products lines. It's the same argument about shipping job to Mexico. I want to be safe, but I also want to see our plant continue to grow. Knock on wood our electrcial safety record has been top notch and that fact helps me keep funding our 70E effort but I fear its a matter of time before the cost outweights the benifits (in the eyes of the bean counters). If 70E was enforced nation wide it would help level the playin field.

Even without an accident being prevented you are saving money. The NFPA is run by a bunch of insurance people, including 70E, ask your "bean counters" how much of a savings you are getting on your insurance for providing the documentation that your plant is compliant with the 70E.

 

[jim dungar]

When it comes to PPE required for arc flash what is the difference? You still need to follow what the label says, even if it is HRC 0 for the 277V breakers.

What PPE is required to switch a breaker when the Limited Approach Boundary is only 2"? The person doing the switching is outside of the 'arc flash zone' except for the hand touching the breaker.

There is no single answer, situations like this must be addressed in the company's ESWP program.

 

[zog]

What PPE is required to switch a breaker when the Limited Approach Boundary is only 2"? The person doing the switching is outside of the 'arc flash zone' except for the hand touching the breaker.

There is no single answer, situations like this must be addressed in the company's ESWP program.

LAB applies to electric shock, not arc flash, the 2009 edition clarified that because it was misleading in the 2004 edition. The calulated arc flash boundary or 4" rule applies for arc flash PPE requirements when "interacting" with equipment.

 

[diakonos1984]

Well, I made it back to the office this afternoon after all, so I am reviewing my copy of the standard and the NFPA videos again.

In the 2004 ?Video Seminar on NFPA 70E? Joe Sheehan spends several minutes at the beginning of the second segment emphasizing that establishing an electrically safe work condition is hazardous work. So what you are saying is that while it is ?hazardous work? it is not ?energized work?. I think we would all agree from a practical perspective that it is only ?hazardous? because it is ?energized? (hence my conclusions regarding the EEWP), but you are saying that that is not what the standard intends. I am about 95% convinced you are right, but here are the reasons for my hesitation (convince me!):

Maybe it?s just me, but I think it is painfully unclear in the standard. I don?t find your phrase ?interacting with equipment? in the standard (doesn?t mean it?s not there, you?ll just have to show me where), so I?m left with ?safe work condition?, ?unsafe work condition?, and ?energized electrical work?. In 2009 Article 130 ?Work Involving Electrical Hazards? the requirements regarding Energized Electrical Work are laid out, including our favorite EEWP. 2009 130.1(A)(3) FPN No. 3 recommends remote racking and remote opening and closing of switching devices. Since the context is energized electrical work, I have heretofore assumed that to rack, open, or close a switching device WITHOUT a remote control would indeed be electrically energized work! In addition, 2009 Article 130.1(B)(3) lists types of work ?performed within the Limited Approach Boundary of energized electrical conductors or circuit parts? that may be exempted from the Work Permit requirement. (Since they did not say ?exposed?, I don?t think they are intending to rule out all circumstances where covers are closed. A non-exposed conductor is not a shock hazard, but is still an arc flash hazard.) The exceptions listed are: ?testing, troubleshooting, voltage measuring, etc? as well as ?visual inspection? (a great relief for those of us performing field surveys for arc flash studies). No where is operating breakers listed as an exception. We both agree that troubleshooting and breaker operation require appropriate PPE. Troubleshooting is clearly stated as NOT requiring a EEWP. So what is the basis in the standard for your view that breaker operation is also exempted?

I?m not trying to be contentious, but I need to have a credible explanation to provide my customers. I know NFPA has a good means for dealing with issues in the next version of the standard, so maybe this will be further clarified in the next revision (I would suggest a statement that breaker operation requires appropriate PPE, but is exempted from an EEWP). In the meantime, can you demonstrate to me your point of view with article citations? It will be a relief to several of my customers.

I have one additional circumstance that I am curious about: working in a safely de-energized and locked-out piece of equipment that is within the arc flash boundary of another piece of equipment that is NOT de-energized. Do I still need arc flash PPE? My view at this time is: a gray area according to the standard?probably ?no?; but from a practical perspective, if I startle a mouse who then runs across the phases in the equipment I?m NOT working on, I?m still going to get burnt, even though I?m in the de-energized equipment. I don?t have to wear PPE, but I?m going to prefer to wear PPE.

Thanks again for your valuable input. I am interested in the courses you recommend, and in the remote switching devices you mentioned. You can send me a PM if that would be better than elaborating here.

 

[jim dungar]

LAB applies to electric shock, not arc flash...

My oops.

I meant to discuss the required PPE when the calculated arc flash boundary is only 2". The operator of the switch would be outside of the arc flash zone, except their hand.

 

[big john]

Diakonos1984,

I'm not a safety guru but I'm going through the same stuff at my plants that you are at yours and here's my take:

Remember that 70E addresses two totally distinct electrical hazards: Shock and arc-flash. Operating a properly functional circuit breaker from outside a closed cabinet presents no shock hazard. Take a look at the definition of "working on" in 70E. I'm paraphrasing, but it basically says "capable of coming in contact with energized parts." There are no exposed energized parts on a normal circuit breaker. You are not "working on" that breaker by the defintion laid out in 70E.

It is still energized work, however, because you are switching an energized breaker. There may be a significant flash-hazard associated with that and it should be addressed totally independently of the shock hazard analysis.

Just my $0.02

-John

 

[zog]

Well, I made it back to the office this afternoon after all, so I am reviewing my copy of the standard and the NFPA videos again.

In the 2004 ?Video Seminar on NFPA 70E? Joe Sheehan spends several minutes at the beginning of the second segment emphasizing that establishing an electrically safe work condition is hazardous work. So what you are saying is that while it is ?hazardous work? it is not ?energized work?. I think we would all agree from a practical perspective that it is only ?hazardous? because it is ?energized? (hence my conclusions regarding the EEWP), but you are saying that that is not what the standard intends. I am about 95% convinced you are right, but here are the reasons for my hesitation (convince me!):

130.1(A) has the requirements for an EEWP and says "before an employee works within the LAB. The LAB only applies to exposed energized conductors (See exception of insulated or gaurded equipment in 130.2 (C)

Maybe it?s just me, but I think it is painfully unclear in the standard. I don?t find your phrase ?interacting with equipment? in the standard (doesn?t mean it?s not there, you?ll just have to show me where),

Definition section. Arc Flash hazard.

so I?m left with ?safe work condition?, ?unsafe work condition?, and ?energized electrical work?. In 2009 Article 130 ?Work Involving Electrical Hazards? the requirements regarding Energized Electrical Work are laid out, including our favorite EEWP. 2009 130.1(A)(3) FPN No. 3 recommends remote racking and remote opening and closing of switching devices. Since the context is energized electrical work, I have heretofore assumed that to rack, open, or close a switching device WITHOUT a remote control would indeed be electrically energized work! In addition, 2009 Article 130.1(B)(3) lists types of work ?performed within the Limited Approach Boundary of energized electrical conductors or circuit parts? that may be exempted from the Work Permit requirement. (Since they did not say ?exposed?, I don?t think they are intending to rule out all circumstances where covers are closed. A non-exposed conductor is not a shock hazard, but is still an arc flash hazard.)

You have it figured out, the definition of an "Electrical hazard" may help, it covers arc flash hazards and shock hazards.

I have one additional circumstance that I am curious about: working in a safely de-energized and locked-out piece of equipment that is within the arc flash boundary of another piece of equipment that is NOT de-energized. Do I still need arc flash PPE? My view at this time is: a gray area according to the standard?probably ?no?; but from a practical perspective, if I startle a mouse who then runs across the phases in the equipment I?m NOT working on, I?m still going to get burnt, even though I?m in the de-energized equipment. I don?t have to wear PPE, but I?m going to prefer to wear PPE.

AS long as no one is interacting with the adjacent equipment I would say no PPE required. Yes the mouse could happen (See attached pic) but the line of risk has to be drawn somewhere or we would be wearing FR all the time. That was the intent of the "interacting" FPN, and the 2012 revision will be expanding on that, many proposals submitted to clear that up.

Thanks again for your valuable input. I am interested in the courses you recommend, and in the remote switching devices you mentioned. You can send me a PM if that would be better than elaborating here.

This is a great train the trainer program, Hugh is one of the best in the business. http://e-hazard.com/train_trainer.php

 

[diakonos1984]

Well John and Zog,

Those definitions now have me about 99% convinced. Thank you! I am waiting for my requested official interpretation from the NFPA to make up the remaining 1%.

So a few things for further clarification:
1) Based on those definitions, are we correct in saying that the EEWP's primary intent is to protect from Electrical Shock hazards? After all, we're wearing Arc Flash PPE w/o the EEWP.

2) If "working on" means hands, feet, tools, etc coming in contact with the energized conductor, what about installing buckets in live MCCs? Is that "working on"? It requires insulated gloves. Does it require an EEWP? Just thinking out loud, if the bucket is out, the conductors are exposed, though if the bucket is deeper than 12 inches, then neither my body nor my tools are within the LAB. However, the bucket is somewhat of a probe, and you are installing parts onto a live service. I thought that was one of the pet bad practices the NFPA was trying to minimize. How about racking breakers? Unlike an MCC, if the breaker is racked out, the shutters should be down, so no conductors are exposed... Or do both of these fit the "removing or replacing components" part of the "working on" definition?

3) How about opening 480V panels? This is interesting--Let's say an electrician is opening the panel for me for my arc flash study. We're within the LAB of conductors we might be exposed to, but since we're only doing visual inspection, we don't need an EEWP. Now if the panel is loose on the wall, and the electrician is going to tighten the mounting screws/bolts, then because he is working within 1 foot of exposed energized conductors, he needs an EEWP, or better yet, to put the panel into an electrically safe work condition. Here, he is not "working on" by the strict definition, but he "might be exposed" by 130.1(A).

4) Back on one of my original questions regarding operators doing LOTO for mechanics. I suppose that if no conductors are exposed, and they use the additional Try-Out test (as in Lock-Out Tag-Out Try-Out), then they don't need to visually verify and use a voltage detector (per 120.1) to make sure they got the right motor. The mechanic doesn't care if the switch broke and one phase is still hot, as long as the motor doesn't turn while he's changing the pump! Hence, while we're not sure that the source of energy has been removed, "it sure ain't working!" I can see that that is probably ok under this standard, but man, I'm not quite comfortable with that... a lot could go wrong (like what if it wasn't working in the first place--Try-Out doesn't prove anything!).

Ok, well I do appreciate your input everyone. And thanks for those pics and that training recommendation, Zog. I'll check it out.

PS. What are the rules about using pictures that people post here? Can I show the poor mouse in a powerpoint?