Does 110.16 belong in the NEC?

Status
Not open for further replies.
M

muhandas

Senior Member
I hope this is the right Forum for my question.
NEC 110.16 is concerned about the safety of qualified individuals working on hazardous live systems and equipment. This is the only location in the NEC that I can think of where workplace safety rather than building safety is addressed. Workplace safety is more completely covered in other codes (for electrical in NEC 70E) and is enforced by jurisdictions other than the usual AHJs; workplace safety is enforced by OSHA who has adopted NEC 70E into the Code of Federal Regulations. 70E is not part of any Building Codes with which I am familiar.
It could also be argued that if the individuals are qualified they would be aware of the hazards and such a marking would be unnecessary and if they aren?t qualified they shouldn?t be working live and, in fact, shouldn?t be working on such equipment at all.
Furthermore, NEC 110.16 is considerably ?weaker? than the corresponding marking requirements of NEC 70E that include description of available energies, approach distances and specific descriptions of the required PPE, and therefore a marking complying with 110.16 would not be in compliance with OSHA and NEC 70E.
For the above reasons, it seems to me that 110.16 does not belong in the NEC and I am thinking of submitting a code revision request to the NFPA to have it deleted but before doing so I would like to hear whether the wise and experienced professionals in this forum agree or disagree with my proposal and why.
 
Stay

Stay

IMHO, (I don't consider myself nearly as wise as some of the folks on the forum, but not a slouch either)

1st the FPN refers you to NFPA 70E provides assistance in determing levels of hazards there may come a time when its not sufficent and possibly some other area of the NEC may give a bit more clarification.

2cd its not overly cumbersome and does not pose a contradiction (to my knowledge and may be opening a can of worms) to any other code.

3rd I was taught above all else don't kill the electrician so the more times something that takes our safety into consideration is printed the more likely it will be read and may even hit home (the whole redundnacy thing)


So, I think it should stay as its not hurting anything or making me confused...
 
I think this clause gives inspectors the duty to fail an inspection if the appropriate arc flash analysis has not been done.

That has both good and bad implications.

How many places have such a study conducted at inspection time? I am guessing close to none.

And why are dwelling units exempted? I bet a lot of apartment complexes have some pretty serious arc flash potential, and they often have some of the dumber maintenance guys working on electrical stuff.
 
Last edited:
Bob,
There is nothing in the current rule that requires an arc flash study. The current rule in the NEC only requires the application of a generic lable saying that there is an arc flash hazard.

I understand that for the 2011 code, there will be a label required that states the available fault current, but still no requirement in the NEC for an arc flash study and posting of the required PPE.
 
I was told that the intent of Article 110.16 was that 70E is not law and that the NEC is. This way, the NEC gives some "power" to the NFPA 70E although they have as of yet to determine the extent of the Arc Flash requirements.

Also, I do not agree with:

muhandas said:
This is the only location in the NEC that I can think of where workplace safety rather than building safety is addressed.
Click to expand...

As the NFPA does go into preventing electrocutions. Specifically, the articles dealing with GFCIs. I would refer you to Article 590.6. This article is not concerned with building safety but workplace safety.
 
muhandas said:
I hope this is the right Forum for my question.
NEC 110.16 is concerned about the safety of qualified individuals working on hazardous live systems and equipment. This is the only location in the NEC that I can think of where workplace safety rather than building safety is addressed. Workplace safety is more completely covered in other codes (for electrical in NEC 70E) and is enforced by jurisdictions other than the usual AHJs; workplace safety is enforced by OSHA who has adopted NEC 70E into the Code of Federal Regulations. 70E is not part of any Building Codes with which I am familiar.
It could also be argued that if the individuals are qualified they would be aware of the hazards and such a marking would be unnecessary and if they aren?t qualified they shouldn?t be working live and, in fact, shouldn?t be working on such equipment at all.
Furthermore, NEC 110.16 is considerably ?weaker? than the corresponding marking requirements of NEC 70E that include description of available energies, approach distances and specific descriptions of the required PPE, and therefore a marking complying with 110.16 would not be in compliance with OSHA and NEC 70E.
For the above reasons, it seems to me that 110.16 does not belong in the NEC and I am thinking of submitting a code revision request to the NFPA to have it deleted but before doing so I would like to hear whether the wise and experienced professionals in this forum agree or disagree with my proposal and why.
Click to expand...

The first "red" highlight is a fact, unfortunately there are too many "un-qualified persons" that consider themselves as "qualified", and are just hell bent on proving Darwin correct.
As far as the second red highlight, Good luck with that. :)
 
muhandas said:
I hope this is the right Forum for my question.
NEC 110.16 is concerned about the safety of qualified individuals working on hazardous live systems and equipment. This is the only location in the NEC that I can think of where workplace safety rather than building safety is addressed. .
Click to expand...

What about all the lockout requirements throughout the NEC?
 
Tom Baker:
You are absolutely right. I had not thought of the lock-out, tag-out requirements. I stand (actually, sit) corrected.

nollij:
You are also correct. 590.6 addresses temporary power receptacles, almost always used during construction. I did think of GFCIs but only in the context of 210.8 where the concern is for the people who live in the buildings.

I get the sense that the forum members who've responded to my original post like 110.16 in the NEC because even in its relatively weak form it at least is a "heads up" to professionals working on live systems. I understand and respect your opinion and will not submit a Code revision request.

Thanks to all of you.
Heinz R.
 
don_resqcapt19 said:
Bob,
There is nothing in the current rule that requires an arc flash study. The current rule in the NEC only requires the application of a generic lable saying that there is an arc flash hazard.

I understand that for the 2011 code, there will be a label required that states the available fault current, but still no requirement in the NEC for an arc flash study and posting of the required PPE.
Click to expand...

If they didn't do the study, how would they know if there was an arc flash hazard? or not?
 
petersonra said:
If they didn't do the study, how would they know if there was an arc flash hazard? or not?
Click to expand...
The NEC assumes that all of the equipment covered by the rule in 110.16 has an arc flash hazard. There is no current requirement in the NEC that requires an arc flash study.
 
tom baker said:
What about all the lockout requirements throughout the NEC?
Click to expand...

There are no lock out requirements in the NEC. There are requirements to provide a way to lock out if desired or required by some other standard.

There is nothing in NEC requiring any workplace safety methods. There are requirments that make following workplace safety procedures easier, disconnects within sight of equipment, locking provisions, working space clearances, labeling/identification requirements.

We have working clearances for equipment likely to be examined while energized, and we have rules that say you can not work on anything while it is energized. People that are not part of this trade, if they hear this will think that is very stupid. The older I get the more in favor I am of having working clearance for all equipment energized or not, and it should all be between 42-78 inches above floor:)
 
don_resqcapt19 said:
The NEC assumes that all of the equipment covered by the rule in 110.16 has an arc flash hazard. There is no current requirement in the NEC that requires an arc flash study.
Click to expand...

So the code is going to require you to put a sticker on something stating it has an arc flash hazard when it might or might not?

What happens down the road when someone does a study and decides there is no hazard. Perhaps not likely for these kind of things, but suppose it happens. Can they take the sticker off and replace it with one that says there is no hazard?

And then the next time that piece of work gets inspected it gets failed because the sticker is gone?
 
petersonra said:
So the code is going to require you to put a sticker on something stating it has an arc flash hazard when it might or might not?

What happens down the road when someone does a study and decides there is no hazard. Perhaps not likely for these kind of things, but suppose it happens. Can they take the sticker off and replace it with one that says there is no hazard?

And then the next time that piece of work gets inspected it gets failed because the sticker is gone?
Click to expand...
All equipment covered by the rule has to have the warning label. There is no exceptions. However the required warning does not say that there is an arc flash hazard. Is says there is a "potential" arc flash hazard.
110.16 Flash Protection
Switchboards, panelboards, industrial control panels, meter socket enclosures, and motor control centers that are in other than dwelling occupancies and are likely to require examination, adjustment, servicing, or 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.
Click to expand...
 
I tried to get rid of the field marking part of the requirement, but the CMP rejected my proposal. With a generic label warning of a "potential" hazard, there is no reason that the label has to be field installed. It could be installed by the manufacturer and often is, but that manufacturer installed label is in violation of the rule.
 
petersonra said:
What happens down the road when someone does a study and decides there is no hazard.
Click to expand...
That cannot happen! The very lowest of all possible results of the study is that the risk is "Category 0." But that category does not mean that there is zero arc flash risk. It means that the available arc flash energy is below 1 cal/cm2, an amount of energy is still enough to inflict second degree burns.
 
Quote:
110.16 Flash Protection
Switchboards, panelboards, industrial control panels, meter socket enclosures, and motor control centers that are in other than dwelling occupancies and are likely to require examination, adjustment, servicing, or 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.
__________________
shall be field marked to warn qualified persons of potential electric arc flash hazards.

shall be field marked to warn qualified persons of potential electric arc flash hazards.

Wouldn't you think qualified persons should know there is risk of potential arc flash hazards?

About as dumb as surgeon generals warning on a pack of cigarettes.

People who smoke know it but smoke anyway.

Qualified electrical persons know there is hazards and they either protect themselves or they don't.

If they get to the equipment and don't already have protective gear you really think they will see the label and go get the proper gear?

Is there not potential arc flash hazard when plugging a cord into a receptacle?
 
Status
Not open for further replies.
Top