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 Post subject: When is an Arc Flash Study Required
PostPosted: Fri Sep 24, 2021 10:39 am 

Joined: Fri Sep 24, 2021 10:28 am
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I am new to the forum and I have spent all day researching. I am getting nowhere.
Can you please help me with the following very basic questions - for the USA.

1) Is every commercial building in the USA is required to have an Arc-Flash Study done?
2) What about grandfathered buildings?
3) Is this enforced by any known local jurisdictions? If so, where?
4) Is this enforced by all known local jurisdictions?
5) Is this required in all jurisdictions now in order to get a Certificate of Occupancy?
6) Let's say we are in West Virginia at a strip shopping center where half is empty and the other half have 8 tenants from nail salons to used clothes stores. Do we expect each of these shops to have a $5k+ study completed?

I am really just trying to fully understand the issue. Thank you for your insight?


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 Post subject: Re: When is an Arc Flash Study Required
PostPosted: Fri Sep 24, 2021 1:19 pm 
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First all, outside of a specific OSHA requirement for utilities to perform an arc flash study, there is no legal requirement. That being said, studies are performed for the following reasons:

1. Arc flash is a known hazard and OSHA requires employers to protect from known hazards (General Duty Clause)
2. Employers are required by OSHA to provide the proper PPE to protect them from hazards in the workplace (1910.132)
3. Some insurance companies will require an arc flash study as a condition of insurance
4. Companies care about their employees and want to provide a safe workplace

Since arc flash is a known hazard and there are means to protect employees from the hazard, if not done and there is an accident, the employer leaves themselves exposed to lawsuits.

Outside of determining the incident energy, a good electrical study will examine short circuit, equipment duty ratings and coordination to enable the employer to have a safe electrical system.

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Barry Donovan, P.E.
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 Post subject: Re: When is an Arc Flash Study Required
PostPosted: Fri Sep 24, 2021 1:34 pm 

Joined: Fri Sep 24, 2021 10:28 am
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Barry!
Thank you! Thank you! Thank you! Thank you!
You stated in your answer, "OSHA requirement for utilities".

Are you saying that this OSHA requirement only applies to utility companies such as GA Power? If not, what do you mean?

I am also confused because you state that it is only required for utilities, but then state:
Arc flash is a known hazard and OSHA requires employers to protect from known hazards (General Duty Clause)

So, is it required or not required?


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 Post subject: Re: When is an Arc Flash Study Required
PostPosted: Sat Sep 25, 2021 4:49 am 
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Let me clarify my statement. What I was saying that in the OSHA requirements, the only place you will find the terms arc flash are in the section related to utilities, OSHA 1910.269. This section was revised starting in ~2004 with it finally being published in ~2015. It required utilities to perform an arc flash assessment of their systems.

For non-utility electric systems, there is no term "arc flash" listed as a hazard. Therefore, OSHA looks at it as a known industry hazard and therefore, employers have to protect their employees from that hazard.

Note that OSHA considers employers who have utility like systems, to fall under the utility OSHA regulations. For example, a company owns the substation which takes service from the utility, at say 34.5kV. They own all the 34.5kV equipment, the substation, etc. so they would fall under OSHA 1910.269 regulations and would have had to have the assessment done.

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 Post subject: Re: When is an Arc Flash Study Required
PostPosted: Sat Sep 25, 2021 5:40 am 

Joined: Fri Sep 24, 2021 10:28 am
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You stated it is legally required for:
OSHA specifically mentions Arc-Flash being required for Utilities, but does not specifically mention it for people working in open panels.

You then stated, "That being said, studies are performed for the following reasons:"

1. Arc flash is a known hazard and OSHA requires employers to protect from known hazards (General Duty Clause)
2. Employers are required by OSHA to provide the proper PPE to protect them from hazards in the workplace (1910.132)
3. Some insurance companies will require an arc flash study as a condition of insurance
4. Companies care about their employees and want to provide a safe workplace"

It seems to me, that you believe it is not really required legally, but that some people inferring that it was. If not, you would have said that it was all legally required.

I just really trying to figure out what is really going on here. It would seem that if OSHA required it for other things they would have spelled it out as they did elsewhere for this purpose as well - because it costs tens of thousands of dollars for millions of properties. It is not just the cost of purchase and use of proper equipment.


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 Post subject: Re: When is an Arc Flash Study Required
PostPosted: Sun Sep 26, 2021 10:26 am 
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Great discussion. Adding to the wealth of info that Barry provided:

The requirements of an arc flash study are from a series of standards taken together. The US OSHA that is pointed out requires:

Section 5(a)(1) (General Duty Clause)
Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.

1910.335(a)(1)(i)
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.

This is in addition to what is stated in OSHA 1910.269 for utility systems.

With that said, for non utility systems OSHA looks towards the US NFPA 70E standard for the details. In 1975 OSHA contacted NFPA to develop a stand alone electrical safety standard. In 1979, the first NFPA 70E standard was published.

NFPA 70E requires that both a shock risk assessment and arc flash risk assessment be performed. The arc flash risk assessment requires determining the likelihood and severity of an arc flash for a given location. The likelihood question can be answered by Table 130.5(C) Estimate of the Likelihood of Occurrence of an Arc Flash Incident for ac and dc Systems This is based on equipment condition and task to be performed.

The severity question for selecting arc rated clothing and PPE can addressed by either an incident energy analysis (arc flash study) or by using the NPFA 70E PPE tables.

So the bottom line is workers need to be adequately trained and protected. NFPA 70E provides two options for determining protection but stops just short of mandating incident energy calculations. That is very common with standards - state the objective but leave the method somewhat open ended.

My usual disclaimer: This is my opinion - It is not an official opinion/interpretation of any of the standards that I am involved with - NFPA 70E, IEEE 1584, IEC TC78 Live Working.


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 Post subject: Re: When is an Arc Flash Study Required
PostPosted: Sun Sep 26, 2021 12:21 pm 

Joined: Fri Sep 24, 2021 10:28 am
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So - I would like to restate just to make sure that I am clear.
In a nutshell, OSHA requires that you need proper PPE and you need to look at NFPE 70E to determine how to do that.

NFPE 70E requires an arc flash risk assessment which includes assessment of likelihood and severity

NFPE 70E says that:
For likelihood, we just look up on Table 130.5(C) Estimate of the Likelihood of Occurrence of an Arc Flash Incident for ac and dc Systems
For severity, we complete an arc-flash assessment OR we look it up on the NFPA 70E PPE Table.

I believe this is the NFPA 70E PPE Table, is this it? If not, please advise.
https://tinyurl.com/k6rkvxv6

Is the above correct?
I used to hear people all of the time say, the NEC is so convoluted and says different things in different sections. Then I read the NEC. It is actually very clear if you know how to read it (yes - this was 15+ years ago).

As I read what you are referencing now, it seems clear and makes sense - and does not put undue pressure on buildings to complete arc-flash analysis.
Is this correct?
I thank you so much for giving me a full accounting of the requirements.


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 Post subject: Re: When is an Arc Flash Study Required
PostPosted: Mon Sep 27, 2021 5:39 am 
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That is part of the table and if you look at it, you will see that there are parameters that need to be known to use the tables. For example: the first line in the table you show states that the fault current must be a max of 25kA and 2 cycle clearing time. How do you know that without a study done? Study done it is not that much more work to determine the incident energy with today's software programs.

Another aspect to remember is that the employer is also responsible for informing contractors on site of the known hazards. So an HVAC contractor arrives to work on a roof top unit, the employer has to tell them about the hazard and they need to protect themselves. HVAC asks what PPE do I need? Employer look it up in the tables. HVAC contractor - can you tell me what the fault current and clearing time is? Employer ???

I know it never goes like that but it should or better yet the employer had a study done, equipment is labeled and as part of the PO requirements for the contractors, they are told they need to be trained in NFPA 70E and wear the PPE for the incident energy level on the label.

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 Post subject: Re: When is an Arc Flash Study Required
PostPosted: Tue Sep 28, 2021 2:48 pm 
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Hopefully, this will help. I think of OSHA as the police and NFPA as the law makers. It makes understanding how we got here a bit easier for me.
Understanding that OSHA does not set standards, they look to expert organizations like the NFPA to establish those standards. Instead of establishing safety standards, they just adopt the stuff experts say are important. All OSHA is doing is enforcement, like the police.

As you know, all businesses are required to provide their employees with a safe work place. To do this means the business must determine, among other things, just how big each hazard is. For example, suppose a company makes steel beams. There lots of hazards related to that process and the company must identify those hazards and take steps to protect their workers. Just as with making beams, electrical work has hazards. So how do you determine how big the electrical hazards are? With an arc flash study. And all a study is, is just a way to determine how big the arc flash hazards are so workers know how much PPE to wear and where to establish boundaries.


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 Post subject: Re: When is an Arc Flash Study Required
PostPosted: Mon Oct 04, 2021 8:14 am 
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I would also like to point out that Section NFPA 70E 130.5(H) states "The owner of the electrical equipment shall be responsible for the documentation, installation, and maintenance of the marked label." In your example of a strip mall, the owner/management company of that strip mall is responsible for labeling the electrical equipment.

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 Post subject: Re: When is an Arc Flash Study Required
PostPosted: Thu Oct 14, 2021 3:46 pm 

Joined: Tue Apr 20, 2021 4:07 pm
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The other element too, is you can mandate as an employer that any work to electrical equipment must be done completely de-energized. This is actually the best way to comply without necessarily requiring an arc-flash study. But where it is likely (or even a chance) that energized work is to take place (even for something as simple as inspections of equipment or metering while energized), it should be considered for all of the reasons those have described above. Insurance is a big one, and triggers the study for many of the clients we work with.


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 Post subject: Re: When is an Arc Flash Study Required
PostPosted: Mon Oct 18, 2021 11:51 am 
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kartracer087 wrote:
The other element too, is you can mandate as an employer that any work to electrical equipment must be done completely de-energized. This is actually the best way to comply without necessarily requiring an arc-flash study. But where it is likely (or even a chance) that energized work is to take place (even for something as simple as inspections of equipment or metering while energized), it should be considered for all of the reasons those have described above. Insurance is a big one, and triggers the study for many of the clients we work with.


The fallacy of this statement is that the equipment must be verified de-energized prior to considering it de-energized to work on. This means you need to consider the equipment energized until proven so by doing a test known live with meter, test specimen, test known live again. Since it is not considered de-energized until proven, you need to wear the proper PPE to perform the test. What do you wear if no arc flash study done or a short circuit study done so that you know the short circuit and clearing time to meet the NFPA 70E tables to use the table method to determine PPE?

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www.workplacesafetysolutions.com


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 Post subject: Re: When is an Arc Flash Study Required
PostPosted: Mon Oct 18, 2021 11:57 am 

Joined: Fri Sep 24, 2021 10:28 am
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You have once again gone into the "you are overdoing it to the point of being ridiculous" territory.

How about checking to see if the lights that were on - are now off? Wiggy?

By this point of view, I cannot work on any switch or receptacle in the building because I am not sure if it is really turned off at the breaker. I also need to do an arc-flash study on every device in the building and put a sticker there to see what PPE I need to wear while I am checking to see if the plug is "off" or "on" now because it may still be hot. Better get grandma into some PPE before she plugs in lamp.

You need to just breath and relax.


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 Post subject: Re: When is an Arc Flash Study Required
PostPosted: Tue Oct 19, 2021 6:46 am 
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I think you should read OSHA 1910.333 in particular 1910.333(b)(2)(ii)(B) and 1910.333(b)(2)(iv)(B) to educate yourself on OSHA requirements in this matter.

I do not find the subject of electrical safety "ridiculous" but rather people who try to skirt around the safety procedures as dangerous to work with and create an unsafe work environment.

By your comment about Grandma plugging in a lamp and needing PPE, I can see you will gain a lot knowledge by reading many of the posts on this forum and will eventually see the fallacy of your statement. I do hope for your sake and the sake of your coworkers, you educate yourself more on this topic so you can work safely.

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