NFPA 70E 2009....again

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eric7379

Member
Location
IL
My question pertains to whether or not arc flash labeling that includes the incident energy level available or required level of PPE needs to be applied to electrical equipment when an arc flash analysis has not been performed. More specifically, if someone uses table 130.7(C)(9) of the NFPA 70E-2009 in lieu of an arc flash analysis, then does the label that is applied to electrical equipment need to have the incident energy level available or required level of PPE?

My employer says that only a generic label is needed; a label that only warns of the dangers of an arc flash or shock hazard. I say that the incident energy level available or the required level of PPE needs to be on the label.

When I read NFPA 70E-2009, 130.3(C) a little closer, I can kind of see why they interpret it that way.

This is directly from the NFPA 70E-2009, 130.3(C) :

(C) Equipment Labeling. Equipment shall be field marked with a label containing theavailable incident energy or required level of PPE.

After the arc flash hazard analysis has been completed, equipment must be labeled to provide sufficient information for a worker to select the necessary arc-rated protective equipment.

So, if an arc flash hazard analysis has not been done, and table 130.7 (C)(9) is used, then just a generic label can be used? The only reason why I say this is because in the note directly after 130.3(C), it says after the arc flash hazard analysis has been completed. So, if the analysis has not been done, does the label need to have the energy level or the PPE level on it, or not?

Don't get me wrong, I think it does need to be on the label (the energy level or the PPE level) but the higher ups at the company that I work for don't seem to think so.
 

ron

Senior Member
Using the tables is part of a arc flash hazard analysis. PPE calcs are not required as part of a arc flash hazard analysis if the calcs to comply with the Table notes are acceptable.
 

zog

Senior Member
Location
Charlotte, NC
Using the tables is part of a arc flash hazard analysis. PPE calcs are not required as part of a arc flash hazard analysis if the calcs to comply with the Table notes are acceptable.

Exactly. So if you do the calculations you can either put the Ei or the PPE required. If you used the table method, you would just out the HRC on the label. Either way, the PPE info or Ei needs to be on the label.
 

richxtlc

Senior Member
Location
Tampa Florida
If you use the tables, you must comply with all the applicable notes at the end of the tables. Also, this is a task matrix and therefore you cannot assign an HRC category to a particular piece of equipment as the HRC depends on the task being performed.
 

eric7379

Member
Location
IL
Exactly. So if you do the calculations you can either put the Ei or the PPE required. If you used the table method, you would just out the HRC on the label. Either way, the PPE info or Ei needs to be on the label.

That is exactly how I read it. I am pushing to have at least the HRC on the label, but management is saying that it is not neccessary because an arc flash analysis has not been done (for figuring out the incident energy available). Trust me, I do not think it is right that we are going to be using the tables. But, since I am not the one paying the bills here, it is not my call.
 

eric7379

Member
Location
IL
If you use the tables, you must comply with all the applicable notes at the end of the tables. Also, this is a task matrix and therefore you cannot assign an HRC category to a particular piece of equipment as the HRC depends on the task being performed.

Where in the NFPA 70E-2009 does it specifically say that the label does not have to have the HRC on it if the task table is used? Every place that I have looked, it says that a label with either the incident energy available or the HRC must be used. What would be wrong with using a label that has the different tasks and HRC listed on it? I saw this on another forum (thanks to chris kennedy for the link in another thread!) and the example that I saw would suit this very well.
 

zog

Senior Member
Location
Charlotte, NC
That is exactly how I read it. I am pushing to have at least the HRC on the label, but management is saying that it is not neccessary because an arc flash analysis has not been done (for figuring out the incident energy available). Trust me, I do not think it is right that we are going to be using the tables. But, since I am not the one paying the bills here, it is not my call.

Keep in mind that using the tables still requires some part of the analysis. You need to determine the available fault current and clearing time of the protective devices to know if you are within the limitation of the tables (Notes) before they can be used.
 

jim dungar

Moderator
Staff member
Location
Wisconsin
Occupation
PE (Retired) - Power Systems
What " table 130.7 (C)(9) task" HRC are you going to put on the label? For example, operating CB with door closed or voltage checking of energized bus with enclosure covers removed?

I believe a case can be made, that you need to analyze the table for the task you will perform. You must then put an appropriate label on the equipment. After you perform the task, you need to remove the label as it may no longer be applicable for the next task.
 

eric7379

Member
Location
IL
What " table 130.7 (C)(9) task" HRC are you going to put on the label? For example, operating CB with door closed or voltage checking of energized bus with enclosure covers removed?

I believe a case can be made, that you need to analyze the table for the task you will perform. You must then put an appropriate label on the equipment. After you perform the task, you need to remove the label as it may no longer be applicable for the next task.

I know that we have the check to make sure that we are within the parameters of the footnotes of table 130.7(C)(9) in order to be able to use the tables.

IF it is determined that we are able to use the tables, then an analysis will be done on the electrical panels in order to determine what tasks would apply to a particular panel.

The type of label that I was thinking of using is the example PDF that is attached. This was an example given by user John Perotti on the Arc Flash Forum website.

But the question still remains: I am under the impression that even if we do use the task tables of 130.7(C)(9), that we are still required to at least list the HRC on the label. Is this correct?
 

jim dungar

Moderator
Staff member
Location
Wisconsin
Occupation
PE (Retired) - Power Systems
But the question still remains: I am under the impression that even if we do use the task tables of 130.7(C)(9), that we are still required to at least list the HRC on the label. Is this correct?
I agree, a PPE selection aid (not necessarily an HRC) is required. Technically an HRC only comes from the task table.
 

richxtlc

Senior Member
Location
Tampa Florida
The only way that I can see you satisfy the need to use a label with the HRC and use the task matrix is to insert the matrix as part of the label so that the person performing the task will know what PPE is required for each task. Most label makers have the ability to configure the label so as to show each task and its appropriate HRC. Again, if you use the matrix, you must comply with all the notes at the end of the table.
 

advidana

New member
I think there is a bigger problem to this Arc Flash labeling system. NFPA 70E calls out for a "required level of PPE".

I think it should read "required Harzard/Risk Categeories (HRC) Level of PPE" because level of PPE is also used in calculations to describe the minimum ATPV Rating PPE cal/cm2. There is a numbering system for that too. It corrolates to the HRC numbers. A PPE of 4 is equal to Hazardous risk category of 1, A PPE of 8 is equal to Hazardous risk Category of 2 and etc.

Some computer generated calculations have results shown with both PP2 cal/cm2 levels and PPE HCR levels. It could mis-lead the client, installer or staff of what PPE levels numbers to use. Leading to errors when markings the Arc Fault labels. I don't think the foot note in Hand Book addresses this problem.

I know the labeling system is not perfect but it is a big step in the right direction. I know of people that have died because they were not properly protected from arc flash.
 

puckman

Senior Member
Location
ridgewood, n.j.
The company I work for has started a safety program and listed all work to be done not to be above 2* , if so we have to get outside help.
So in our mcc we can't remove any of the buckets for repairs of any kind because it comes up above 2* , we have to get ec to do that work. I asked about labeling and was put off.
The people who setup this program is a safety guy and a non electrical person , so when you have questions you really don't get a fair or professonal answer. They set this program up as a 70e but I doubt it. It is kind of hard to go against them because the first thing they bring up is money.
 

zog

Senior Member
Location
Charlotte, NC
The company I work for has started a safety program and listed all work to be done not to be above 2* , if so we have to get outside help.
So in our mcc we can't remove any of the buckets for repairs of any kind because it comes up above 2* , we have to get ec to do that work. .

Seems like a big waste of money, why not use a remote MCC bucket extractor?
 

puckman

Senior Member
Location
ridgewood, n.j.
You 're right it is a big waste of money, except to the company. To the electricians they want to do the the work and not have to wait for outside help. It is something they have always done in the past. I googgled and found Seimens extractors, but did not see anything for square d mcc buckets. I will bring this up too the department heads , thanks for the ideas.
 

zog

Senior Member
Location
Charlotte, NC
You 're right it is a big waste of money, except to the company. To the electricians they want to do the the work and not have to wait for outside help. It is something they have always done in the past. I googgled and found Seimens extractors, but did not see anything for square d mcc buckets. I will bring this up too the department heads , thanks for the ideas.

A division of my company makes universial bucket extractors, they can be operated wirelessly from 250FT. They don't advertise the bucket extractors because we can hardly build them as fast as they sell without advertising. PM your info and I can send you some stuff on them.


http://www.cbsarcsafe.com/index.htm
 
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