Arc Flash Safety Hazard Warning Labels. NFPA 70E Compliance & Electrical Safe Work Practices Tips

www.e-Hazard.com

The Problem: Little Official Guidance

Arc Flash Labels are a sticky issue. Even before the NEC (National Electric Code NFPA 70) requirement for arc flash and shock warning labels in 2002, some companies have included warning labels for shock or electrical hazards. The NEC 110.16 requirement pointed to NFPA 70E-2004 for guidance but it had no requirements. The NEC Fine Print Note (FPN) to see NFPA 70E was non-mandatory which didn´t help the confusion. So what should you do on arc flash labels?

Why label equipment at all?

Most states legislate the so this is a legal requirement. The 2008 NEC 110.16 states the following:

"Flash Protection. Electrical equipment, such as 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.

FPN No. 1: NFPA 70E-2004, Standard for Electrical Safety in the Workplace, provides assistance in determining severity of potential exposure, planning safe work practices, and selecting personal protective equipment.

FPN No. 2: ANSI Z535.4-1998, Product Safety Signs and Labels, provides guidelines for the design of safety signs and labels for application to products."

OSHA citations are picking up and the VPP (Voluntary Protection Program) group is auditing arc flash labels. The consensus is in on labeling and the "such as" above is not all inclusive. The labeling requirement is the responsibility of the owner of the building, not the manufacturer or installer of the equipment so this is not just a worker issue but a liability issue. If you hire contractors for all electrical work you still stand liable since the NFPA 70E standard requires the equipment owner to provide contractors with "information about the employer´s installation that the contract employer needs to make the assessments required." NFPA 70E 110.5(A)(1)b. The labeling requirement took effect in 2002, so technically equipment installed before then does not have to be labeled. But modification or upgrading of the equipment would require it be brought up to the NEC code and labeling requirements would apply.

Minimum Label Requirements

Generic Labels Risk

Some companies attempting to help companies meet the requirements have offered generic labels but these labels don´t really meet the intent of the standard.

Common labels recognize both shock and arc hazard, which is admirable but miss the point in two ways. Danger and red indicates life threatening injury but is reserved for only the worst instances. Normally Orange Warning is used if the work can be performed within this enclosure. Since the NEC intends for work to be performed and for this to be a warning label for the qualified electrician, most companies do not use Danger. Some software labels print DANGER on any incident energy exposure >40 cal/cm². Companies selling engineering mitigation devices often give the impression that NFPA 70E prohibits work on >40 cal/cm². This is NOT the intent of the standard. Even if a company decided to de-energize >40 cal/cm² exposures one would have to perform voltage testing, and grounding on the devices so "working on" the live parts still must occur.

The label above offers another point. We must communicate with all the workers exposed to the hazard. If multiple languages are spoken and especially if other languages are not well understood in a workplace, one must consider multilingual signage.

What is the minimum?

The 2009 version of NFPA 70E adds one requirement to the NEC. What we find in working with our clients is that designs for labels range from the bare minimum to the overly detailed. Is there a happy (and more appropriate) medium? Absolutely.

The 70E standard requirements are quite clear – "Equipment shall be field marked with a label containing the available incident energy or required level of PPE" (NFPA 70E 2009 130.2(C)). Additionally 130.7(E) (1) requires that "Safety signs, safety symbols, or accident prevention tags shall be used where necessary to warn employees about electrical hazards that might endanger them. Such signs and tags shall meet the requirements of ANSI Z535."

The ANSI Z535.4-2007 standard design elements required for this label are:

1. Capitalized word WARNING in black on an orange background. WARNING represents "a hazardous situation which, if not avoided, will result in death or serious injury"

2. A listing of the hazard or hazards – Arc Flash and Shock Hazard.

3. The safety symbol associated with the hazard. Numerous symbols represent arc flash and shock hazards with the lightning bolt, perhaps, the most commonly recognized.

At the other end of the design spectrum is the label crammed full of data. The label below displays information on everything from BUS ID to who performed the calculation. In this design, the purpose of flash hazard label is lost.

When deciding what information to include on arc flash labels, always remember for whom the labels are posted – the electrician or maintenance person in the field. Labels must communicate crucial information at a glance in low light to someone in a hurry.

A best practice label contains the following (this is based on both NFPA 70E and Canada´s CSA Z462 Annex Q):

• Arc Flash & Shock Hazard,

• Voltage

• PPE level/Incident Energy (IE)

• Working distance (necessary to define the IE)

• Flash hazard boundary,

• Name of the equipment on drawings,

• Device fed from,

• Date Printed.

Critical information on this label can be seen and understood instantly. White space surrounding each component creates an easy-to-read layout.

When determining what arc flash hazard labels to use and what to include on them, always focus on the end users – the persons in the field exposed to the hazards. These labels exist to protect them, to give them the information they need to do their work and stay safe. Keep the information brief and easy to read. And always train, audit, re-train. People don´t do what you expect, they do what you inspect. Personnel must understand the purpose of these labels, the safety net they provide, and, as with any other tool or safe work practice, how to use them.

The NEC requirement states that the marking must be located so that it´s clearly visible to qualified persons before they begin work. Typically, the label is placed outside the panel or enclosure door. If labels are placed inside the door for outdoor equipment or harsh environments this must be considered in training. Other means to communicate the hazard might need to be employed.

Hugh Hoagland and Vickie Frost develop electrical safety and arc flash training. They may be reached at hugh@e-hazard.com or Vickie.Frost@e-Hazard.com or 502-716-7073.

For a FREE full version of this paper with examples of labels and other helpful features sign up for label paper at www.e-Hazard.com