OSHA and Arc Flash Label Requirements

[Flapjack]

Are there any arc flash label requirements other than the generic labels required by NEC 110.16? I always follow NFPA 70E, but that is not mandatory. I am in need of help on what is required for arc flash labels.

As far as I can tell, OSHA's general clause and 1910.335 require the employer to protect and alert workers to arc flash and shock hazards in the workplace, but do not require arc flash labels as discussed in NFPA 70E. They did pass a final rule for 1910.269 for arc flash and appendix E provides guidance, but it seems that it only applies to utility workers for power generation, transmission, and distribution installations.

So for the owner of a commercial building or industrial facility, if they did not want to implement arc flash labels per NFPA 70E, they wouldn't have to. They would not be required to do any more than NEC 110.16 and that is only if maintenance/servicing/examination is done on equipment while energized, right? They could, however, be fined by OSHA for non-compliance if a worker was injured because the owner did not properly assess the hazard and require the right PPE.

 

[wbdvt]

I suppose one could label just per the NEC article and not label to the NFPA article but then how does a worker know what the incident energy level is at the piece of equipment he needs to work on?

One way would be to keep a chart or the results of the study in an area that is readily accessible to the workers that need to be protected. This would require a worker to go back to the central location to determine what PPE he needs. This can be cumbersome for very large facilities or facilities that have multiple locations but only one maintenance shop. Do you keep multiple copies of the study/hazards in each truck or multiple facilities? How do you control those copies so that only the latest version is in use?

What do you do for contract employees that may be in working? They may not have the same access to information that regular employees do. The Host Employer is responsible to inform the contract workers of the hazards they may be exposed to. This can be tricky if there is not a robust contract employee program in place.

What happens in a situation where a process control tech has to work on a PLC that is inside a control panel that has exposed 480V inside? Is a generic type sticker that one sees all over the place including places like Home Depot on their electrical equipment going to cause someone to pause and think about opening the cabinet?

For the minimal cost of having labels made up as part of a study, it doesn't seem that there is any benefit to not having them.

 

[Flapjack]

I completely agree with you that it is worth it and don't see a reason why an owner would not pay for a study and labels in comparison to litigation, OSHA fines, injury/death if an accident does occur.

An owner is asking what is required vs what is recommended. I can take care of the recommended part but am seeking additional help on the required part if I am missing any codes.

 

[Flapjack]

I suppose one could label just per the NEC article and not label to the NFPA article but then how does a worker know what the incident energy level is at the piece of equipment he needs to work on?

That's exactly what I thought. Below is an excerpt from OSHA in 2006 on their website.

Question 1: When work must be performed on energized electric equipment that is capable of exposing employees to arc-flash hazards, does OSHA require the marking of the electric equipment to warn qualified persons of potential electric arc-flash hazards — i.e., as required by NFPA 70E-2004?

Reply: OSHA has no specific requirement for such marking. A requirement to mark equipment with flash hazard warnings was not included in the 1981 Subpart S revision. However, paragraph (e) of §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 §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.

 

[wbdvt]

Thank you for the excellent OSHA reference. That should push the labeling issue to the conclusion it should be labeled.

 

[Flapjack]

Thank you for the excellent OSHA reference. That should push the labeling issue to the conclusion it should be labeled.

I read the OSHA reference as NFPA 70E arc flash labels are not required, and compliance with OSHA could be met simply by placing the generic arc flash labels of NEC 110.16 on equipment. Nowhere does OSHA require the incident energy level or PPE requirements to be shown on a label.

 

[wbdvt]

ok, I read that different in that it is a way to meet the OSHA requirements of providing the proper PPE for known hazards and a host employer being able to communicate the known hazards. I know there are other ways to warn employees of hazards but a label that states specifically what the hazard is versus a generic statement seems to be the surest way to communicate the hazard and PPE needed.