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 Post subject: Are arc flash studies and rating postings required in public schools?
PostPosted: Mon May 20, 2013 1:36 am 
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Joined: Tue May 04, 2010 2:41 am
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Location: Central Ohio
I am a school board member and a maintenance technician. My district is in the process of building new school buildings and I don't know whether I should cause a fuss if electrical panels do not have arc flash ratings posted when the project is nearing completition or if public buildings have some sort of exemption. Thanks.


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PostPosted: Mon May 20, 2013 8:19 am 
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Joined: Thu Oct 18, 2007 7:10 pm
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Location: NW USA
The cover of January 2011 EC and M magazine cites US Postal Service as being in "Willful and Serious Violations" of electrical safety, much of which was ignoring arc flash safety. The fines associated with 900 OSHA inspections were $6 million and climbing at time of publication.


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PostPosted: Mon May 20, 2013 8:29 am 
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Location: Lima, OH
Slim,
I see that you're in Ohio. Public employees in Ohio are not covered by OSHA but rather by Public Employment Risk Reduction Program (PERRP) a division of the Bureau of Worker's Compensation. Even though public employees are not technically under OSHA, OSHA appears to be the standard to which PERRP adheres. When I investigated a list of recent citations filed by the PERRP inspectors, they consistently referenced the OSHA regulations as the basis of their investigations. Technically, no one actually has to have arc labels installed, but what they do have to provide is a necessary level of safety for their electrical workers. So basically the choice falls on either installing the labels or using the table method as found in the NFPA 70E as these are the accepted best practices. Either one of these methods needs to be supplemented with appropriate electrical safety training.
Hope this helps.
Roger


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PostPosted: Mon May 20, 2013 9:34 am 
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Most OSHA and State run OSHA inspectors will not make unannounced inspections to see if you have arc flash labels. Per NFPA 70E, the equipment should be labeled. If somebody at your site does have an accident and it is investigated by OSHA or your State OSHA, then most likely, you will be fined for not have labels on the equipment.

_________________
Robert Fuhr, P.E.; P.Eng.
PowerStudies


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PostPosted: Mon May 20, 2013 11:24 am 
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Roger wrote:
Slim,
Public employees in Ohio are not covered by OSHA but rather by Public Employment Risk Reduction Program (PERRP) a division of the Bureau of Worker's Compensation. Even though public employees are not technically under OSHA, OSHA appears to be the standard to which PERRP adheres.

Technically, no one actually has to have arc labels installed, but what they do have to provide is a necessary level of safety for their electrical workers. So basically the choice falls on either installing the labels or using the table method as found in the NFPA 70E as these are the accepted best practices. Either one of these methods needs to be supplemented with appropriate electrical safety training.
Hope this helps.
Roger


OSHA (and by extension PERRP) may have no specific requirement for arc flash marking since a requirement to mark equipment with flash hazard warnings was not included in the 1981 Subpart S revision.

But in Paragraph (e) of §1910.303, OSHA (and by extension PERRP) requires employers to mark electrical equipment with descriptive markings, including the equipment's voltage, current, wattage, or other ratings as necessary.

Additionally, in §1910.335(b), OSHA (and by extension PERRP) 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.

OSHA (and by extension PERRP) does not specifically mention NFPA 70E, nor do they specifically require arc flash labels, but note that they reference §1910.335(b) which is a general requirement for electrical safety labeling. The best solution is to use NFPA 70E compliant arc flash labels.

By complying with theNFPA 70E 2012 code for arc flash labeling, you'll also be in compliance with OSHA (and by extension PERRP) electrical labeling requirements.[color=black] In addition, you'll also be in compliance with the NEC requirements for arc flash labeling. [/color]

[color=black]So NFPA 70E labels are the key to overall arc flash labeling compliance, and the only exceptions provided in NFPA 70E are residences.[/color]

[color=black][font=Calibri][color=#000000][color=black][font=Calibri][color=#000000][color=black]Also I do not think using the tables negates the requirement to label the equipment.[/color][/color][/color][/font][/color][/color][/font]

[color=black][font=Calibri][color=#000000][color=black][font=Calibri][color=#000000][color=black][font=Calibri][color=#000000][color=black][font=Calibri][color=#000000][color=black]And ditto on Robertehfur's comment[/color][/color][/color][/font][/color][/color][/font][/color][/color][/font][/color][/color][/font]


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PostPosted: Mon May 20, 2013 3:21 pm 
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I am a vendor for some of the largest school districts in the country. These districts typically have 300+ schools. I work in over a hundred schools a year in Florida. I have yet to see any arc flash stickers in any of them. I have seen them in industry and in other private settings and seeing them there was the only way I knew they existed.

This doesn't mean that I don't follow the rules -- I use the tables. But I have observed that few county maintenance personnel are as careful as I am. They are doing things the way I did them twenty or thirty years ago when I was coming up and didn't know any better.

In Florida, the county school systems are State agencies, not local. One would think they would be more interested in safety.


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PostPosted: Tue May 21, 2013 6:52 pm 
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Location: North Carolina
NEC requires arc flash labels in many cases. It is required in all 50 states though at least New Jersey exempts schools from following NEC.


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PostPosted: Mon May 27, 2013 8:44 am 
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It is easiest to get the data when the equipment is new and the nameplates are readable. Also, the utility information is sometimes a major pain to get, but if someone takes note while it is being installed it solves the problem. The question is does the architectural /engineering or construction contract address performing the calculation and installing the labels. Acurate numbers need to reflect what is installed not what is estimated. The calculation to have the equipment meet the minimum AIC was probably done with estimated conservative numbers, which will probably result in a greater than real arc flash hazard.
When you ran for the school board people may have voted for you are because it sounds like you are not a lawyer and have common sense. As the member of a school board, you should be bringing your experience to the board as others on the board or administration may not have the knowledge about electrical safety and work place issues that you have learned. Also, if the maintenance staff is practicing safe work practices, it might get noticed by the children and children need to learn that their safety is their responsibility.


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PostPosted: Mon Jun 03, 2013 4:20 am 
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The NEC says in article 110.16 that there must be a warning label to notify workers of potential arc flash hazards; this warning must be located so as to be clearly visible to qualified persons before accessing or working on the equipment. However it does not require a rating to be included on that label.Fine print notes (FPN) are informational only and not enforceable as requirements of this code.

So unless the school paid for an arc flash study and labeling to be included with the installation, I believe a generic warning label is sufficient as far as the electrical contractor’s responsibility is concerned; however, it is now the employer’s responsibility to determine whether to have an arc flash hazard analysis performed to determine the incident energy, or to use the hazard/risk category table method.

OSHA 1910.132(d)(1) requires the employer to assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment. If such hazards are present the employer must select and have affected personnel use the type of PPE which will protect them from the hazards identified in the assessment. They must also train each affected employee to know what PPE is required, when it is necessary, how to properly wear and care for it and its limitations.

Despite the fact OSHA does not specifically address arc flash hazards, it is the enforcing agency and states in 29CFR 1910.335(a)(1)(i) that, “employees working in areas where there are potential electrical hazards shall be provided with and shall use electrical protective equipment that is appropriate for the specific parts of the body to be protected and for the work to be performed”. However, OSHA does not specify how to comply with this regulation and instead defers to the NFPA-70E, the national consensus standard for electrical safety in the workplace. Judicial courts have interpreted that because the NFPA-70E is a consensus standard and because OSHA references the NFPA-70E that it, or some other standard as effective, shall be used to prevent workplace injuries. So should there ever be an accident, this is the standard your electrical safety program will be compared to in determining if the employer has met obligations.

Quote:
NEC 110.16 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 servicing or maintenance shall be field marked to warn qualified persons of potential electrical arc flash hazards. The marking shall be located so as to be clearly visible to qualified persons before examination, adjustment, servicing or maintenance of equipment.

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



Some good stuff here:

NFPA 70E® 2012, 20 Most Frequently Asked Questions
By Michael Fontaine, May 2013
[url='http://f.e.nfpa.org/i/47/272412627/0510qw_NFPA70E20Questions.pdf']http://f.e.nfpa.org/i/47/272412627/0...0Questions.pdf[/url]


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