NFPA 70E Arc Flash Labeling - Is it Required?

[vanetten]

Hello,
not sure if this the best location to post this question. Is arc flash labeling a requirement or recommendation? NFPA 70E is not mandated by law but OSHA enforces workplace safety. We have the means to perform arc flash studies to estimate the incident energy not sure if labeling is mandatory. Please advise

 

[jim dungar]

This is not an NEC other than a general hazard warning label.
Things like incident energy values and PPE requirements are not mandated by the NEC. This is an operational issue by the company, not an installation requirement.

 

[vanetten]

This is not an NEC other than a general hazard warning label.
Things like incident energy values and PPE requirements are not mandated by the NEC. This is an operational issue by the company, not an installation requirement.

Thank you for the response. Is that noted in the code books? We just had an audit and they said it is required to label all equipment on site.

 

[ron]

Thank you for the response. Is that noted in the code books? We just had an audit and they said it is required to label all equipment on site.

As mentioned by Jim, the actual code requirement is in the NEC Section 110.16. Anything more than the minimum is extra.

Auditors like insurance companies, can ask for anything they want. It is only required if it is a code or they hold something contractual over you, like insurance.

 

[vanetten]

As mentioned by Jim, the actual code requirement is in the NEC Section 110.16. Anything more than the minimum is extra.

Auditors like insurance companies, can ask for anything they want. It is only required if it is a code or they hold something contractual over you, like insurance.

I'm sorry but now I am confused. Art 110.16 says labeling is required. Did I read that wrong?

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.

 

[ron]

Field marked to warn qualified persons of potential electric arc flash hazards is not a detailed NFPA 70E sticker. It is a generic arc flash warning sticker, typically provided by the equipment manufacturers for field application, such as:

 

[vanetten]

Field marked to warn qualified persons of potential electric arc flash hazards is not a detailed NFPA 70E sticker. It is a generic arc flash warning sticker, typically provided by the equipment manufacturers for field application, such as:
View attachment 2573040

so where in the code can I use to tell the auditors labeling is not required? According to NEC 110.16, it says it is required

 

[don_resqcapt19]

so where in the code can I use to tell the auditors labeling is not required? According to NEC 110.16, it says it is required

What edition of the NEC applies in your area?

 

[jim dungar]

so where in the code can I use to tell the auditors labeling is not required? According to NEC 110.16, it says it is required

What labeling are your Auditors asking for?
The NFPA 70 only requires an advisory type of warning label.
Safety auditors usually quote NFPA 70E and ask for specific safety information on labels.

 

[tom baker]

I would tell your auditors we will comply with NEC 110.16, send them the section and purchase the warning labels.
If they push back ask for documentation on the requirement and show that 70E has been adopted in your jurisdiction

 

[qcroanoke]

Thank you for the response. Is that noted in the code books? We just had an audit and they said it is required to label all equipment on site.

Required by what code or department? 110.16 is all NFPA (NEC 70) requires. Ask them to show you.

 

[vanetten]

Field marked to warn qualified persons of potential electric arc flash hazards is not a detailed NFPA 70E sticker. It is a generic arc flash warning sticker, typically provided by the equipment manufacturers for field application, such as:
View attachment 2573040

yes these labels come with the equipment. Not all equipment have these labels

 

[vanetten]

I would tell your auditors we will comply with NEC 110.16, send them the section and purchase the warning labels.
If they push back ask for documentation on the requirement and show that 70E has been adopted in your jurisdiction

ok I agree. I will respond by we are conforming to the NEC 110.16 and then ask what documentation of the req. they are referring to

 

[vanetten]

110.16 Arc-Flash Hazard Warning.
(A) General. Electrical equipment, such as switchboards,
switchgear, panelboards, industrial control panels, meter socket
enclosures, and motor control centers, that is in other than
dwelling units, and is likely to require examination, adjustment,
servicing, or maintenance while energized, shall be field
or factory marked to warn qualified persons of potential electric
arc flash hazards. The marking shall meet the requirements
in 110.21(B) and shall be located so as to be clearly visible to
qualified persons before examination, adjustment, servicing, or
maintenance of the equipment.

What edition of the NEC applies in your area?

2017

 

[vanetten]

The auditor responded with this info from the NFPA 70E

130.5 (H) Equipment Labels:

• Unless in dwelling units, switchboards, panelboards, industrial control panels, meter socket enclosures, motor control centers, and similar that are likely to require examination, adjustment, servicing, or maintenance while energized must be field-marked with a label containing the following:
  • The nominal system voltage
  • Arc flash boundary
  • One or more of these:
    • Available incident energy and the corresponding working distance, or the arc flash PPE category in Table 130.7(C)(15)(a) or (b) for the equipment, but not both,
    • Minimum arc rating of clothing,
    • Site-specific level of PPE
• Exception: Unless changes in the system make the label inaccurate, labels applied before the effective date of this edition of NFPA 70E are acceptable if they complied with the requirements for labeling when they were applied.
• The calculations and data must be documented and reviewed for accuracy at 5-year maximum intervals. The label must be updated if changes have made it inaccurate.
• The label must be suitable for the environment for which it is installed.
• The owner of the electrical equipment is responsible for the documentation, installation, and maintenance of the field-marked label.

 

[jim dungar]

A customer has every right to require you to comply with NFPA 70E, but it should have been spelled out in contractual documents. These documents should also have provided an example of the label format and information.

 

[vanetten]

A customer has every right to require you to comply with NFPA 70E, but it should have been spelled out in contractual documents. These documents should also have provided an example of the label format and information.

yes I agree but is it required by law?

 

[tom baker]

yes I agree but is it required by law?

Like the NEC, 70E had to adopted by your jurisdiction, city or state. Ask whoever you pull an electrical permit from.

 

[don_resqcapt19]

The auditor responded with this info from the NFPA 70E

130.5 (H) Equipment Labels:

• Unless in dwelling units, switchboards, panelboards, industrial control panels, meter socket enclosures, motor control centers, and similar that are likely to require examination, adjustment, servicing, or maintenance while energized must be field-marked with a label containing the following:
  • The nominal system voltage
  • Arc flash boundary
  • One or more of these:
    • Available incident energy and the corresponding working distance, or the arc flash PPE category in Table 130.7(C)(15)(a) or (b) for the equipment, but not both,
    • Minimum arc rating of clothing,
    • Site-specific level of PPE
• Exception: Unless changes in the system make the label inaccurate, labels applied before the effective date of this edition of NFPA 70E are acceptable if they complied with the requirements for labeling when they were applied.
• The calculations and data must be documented and reviewed for accuracy at 5-year maximum intervals. The label must be updated if changes have made it inaccurate.
• The label must be suitable for the environment for which it is installed.
• The owner of the electrical equipment is responsible for the documentation, installation, and maintenance of the field-marked label.

What does the plant electrical safety plan say? Often 70E is referenced in that because it is an easy way to cover a lot of the things that need to be covered in an electrical safety plan.

Also OSHA has been known to cite 70E requirements under the general duty clause, when investigating an incident.

 

[jim dungar]

yes I agree but is it required by law?

To my knowledge NFPA 70E is not written to be implemented as an enforceable law.
NFPA70E says an employer must create an Electrical Safe Work Practices program. That program should include safety standards as well what you as a contractor need to follow.
Does your contract require you to follow industry standards practices, like hazardous material handling and disposal, as well as following the NEC.