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 Post subject: OSHA preferred method for arc-flash hazard calculation
PostPosted: Tue Apr 24, 2012 2:24 pm 

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What are the main differences between the arc-flash hazard calculation methodologies of IEEE 1584-2002 and Annex D of NFPA 70E - 2012.
Which is the OSHA preferred standard ?


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PostPosted: Tue Apr 24, 2012 3:34 pm 
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mnewman wrote:
What are the main differences between the arc-flash hazard calculation methodologies of IEEE 1584-2002 and Annex D of NFPA 70E - 2012.
Which is the OSHA preferred standard ?

There are a couple of things to consider. OSHA does not specify how one goes about performing the arc flash study. They are concerned about adequate protection and safety at a more general level. The details are left to standards such as NFPA 70E.

Annex D of NFPA 70E contains several calculation methods. Method D.7 in the annex contains the IEEE 1584 equations. D2 - D6 are based on earlier methods which are not used as much (if at all). The industry tends to lean heavily towards using IEEE 1584-2002 since it is still the "latest and greatest" as far as standards go.

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PostPosted: Fri Apr 27, 2012 6:51 am 
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Is there a projected date for the revision of IEEE 1584-2002?


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PostPosted: Fri Apr 27, 2012 8:15 am 
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MattB wrote:
Is there a projected date for the revision of IEEE 1584-2002?

I don't see a new release anytime soon. There was talk by some of a new release later this year however my view from behind the scenes is there are many issues that need to be sorted out yet. This will take some time and after it is all sorted out, the process is still quite slow.

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PostPosted: Mon May 07, 2012 9:53 am 
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OSHA is on NFPA 70E and NESC and David Wallis hasn't shown any preference in the meetings. NESC used ArcPro for calculations in the tables for HV and used PG&E data for LV. I think something is better than nothing at this point.

The new OSHA Subpart V is moving from the economists desk to OMB this month likely and then should be out in around 90 days. It may have some guidance. Leaving this open is likely OSHA's continued tac.


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PostPosted: Sat Jun 16, 2012 6:42 am 
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Gentleman / Ladies:
New to this forum but not safety and health so I apologize if I am placing this post in the wrong forum topic. Allow me to briefley introduce myself. My name is John P. Leseganich, CPEA. After working with OSHA, both in the enforcement, consultation and Public Relations sector for over 32 years I retired back in 2005 and began my own Private EH&S consulting firm, Independent Consultation Services, LLC or ICS:. With that said; I am sure that many of you are aware of the impact or concern this somewhat new (as to the enforcement aspect) requirement being placed on the employer...that being the "Arc Flash" requirements. To cut to the point, the concern is the assessment portion of the requirement. Many smaller employer (fabrication type shops) simply don't have the ability, knowledge, time and or money to spend (assessments can be costly) on performing the task. As an EH&S Consultant, my very first step in bringing these smaller employers into compliance and reducing the risk of injury is to study their assigned employee task, and usually develop an Electrical Safety Policy which simply states; "No employee is required to or will work on ANY energized electrical equipment and or component". Now it goes a little deeper but that is the gest of the policy, thus reducing risk of injury or exposure to "Arc Flash". As you can see, that does not eliminate the need for the required "labeling". So...without hiring an Arc Flash Assessement firm, without purchasing a costly program (computer), any suggestions as to how one would go about in meeting the labeleing requirements. I should point out, the majority of these shops are simply dealing with electrical panel boxes (110-240) and possibly shutting-switching breakers. I understand the risk/hazards are present in all electrical components.....but.....I beleive that certain voltage units are excempt withing NFPA 70 E. Summary: Is or Are there any exemption when considering: employee task, size-type of electrical sources, units equipment etc. Look forward to some good conversations. Take care.


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PostPosted: Sun Jun 17, 2012 4:42 am 
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I beleive that certain voltage units are excempt withing NFPA 70 E. Summary: Is or Are there any exemption when considering: employee task, size-type of electrical sources, units equipment etc. Look forward to some good conversations.


There was an exception in 70E-2009. It was removed in 70E-2012. Two reasons for this. One is that 70E itself does not inherently give any preference to any particular arc flash risk assessment methodology over any other. It offers no less than 8 different calculation methods in the annex as information sources but does not prefer or specify any particular one.

The exception to which you are referring is a particular clause in one of the methods specified in IEEE 1584. If you read the actual text, it is very vague by itself and suggests that there is a lower limit but does not offer any shred of proof or conclusive evidence for it. So to begin with, the "exception" was on shaky ground.

As I understand it from at least one 1584 committee member recent experimentation data has definitely concluded that the "<208/240 VAC, <125 kVA" rule is not true and there is definite evidence that an arc CAN be sustained long enough to exceed 1.2 cal/cm^2 at those voltage levels.

This does not say that you CANNOT still get to a desired "cutoff". Simply take the arc flash protection boundary calculation and fix some of the variables (voltage, working distance, time=2 seconds), and you will arrive at the desired threshold without relying on a clause in IEEE 1584 that is most likely going to be stricken in an upcoming version, IF IEEE 1584 is your calculation method. If not, there are a variety of other calculation methods.

Finally, consider the task and the likelihood that an arc flash hazard even exists. This is specifically called out in the definition in 70E as well as in the section in 130 describing the need to perform an arc flash hazard risk assessment. Note: it does not say arc flash hazard CALCULATION. The calculation as per ArcPro, Duke, IEEE 1584, Lee, Neal/Doughty, or any other method, only establishes the potential hazard. It does not address whether or not the hazard is likely to occur. That requires a risk assessment methodology. There are several other standards for this such as ANSI B11.TR03, the RIA standard, IEC 61508, IEC 61511, the PMMA method, etc., etc. All require you to calculate the likelihood that a hazard may occur, typically using data from existing reliability data sets, if there is no testing methodology and result such as those provided by TuV available.


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PostPosted: Sun Jun 17, 2012 5:48 am 
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Very good reply and I thank you. Just as a side bar discussion; with the need for assessment/calculation do you see the confusion and cost placed on the smaller shops I referenced in my earlier post? As I stated in my previous post I have spent the majority of my career with the Agency (OSHA) and confusion as to needed action when it comes to regulatory requirements is probably the most applicable reason for "non-compliance", following closely is cost. Now please don't misunderstand me, I truly believe in doing what is needed both for compliance and employee safety and health but too often "what needs to be done" is simply not properly explained as to the "How" or "Why". The focus on "Arc Flash" is bringing out the "Really" comments from so many of my current, past and hopefully future clients. They are asking why "all of a sudden" is this a concern. Those of you in the field along with myself have seen and understand the concerns and potential injury / property damage that can occur due to an accidental "Arc Flash", but would you not agree for smaller shop operations, based on electrical services and employee task, the potential for "exposure" is Low? I am simply attempting to bring this requirement to my clients in a more (to use a term I am truly getting tired of) "user-friendly". My attempt is to show my clients (smaller - on budget employers) how to comply, provide the needed protection, with the NFPA 70 E when considering what they and their employees do. To close; I am glad I found this forum which provides me the ability to discuss and receive great comments not only on the NFPA requirements but my position. Hey, to those of us who it applies to: "Happy Fathers Day".


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PostPosted: Sun Jun 17, 2012 5:56 pm 
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John P. Leseganich CPEA wrote:
Very good reply and I thank you. Just as a side bar discussion; with the need for assessment/calculation do you see the confusion and cost placed on the smaller shops I referenced in my earlier post?
[/quote|

This is not limited to smaller shops. They simply have less money to throw at the problem. I work in a site with well over 1000 people, 10% of which are electrical. We have multiple engineers on staff, both safety and electrical. And we still have regular arguments about what the right thing to do is.

Quote:
Those of you in the field along with myself have seen and understand the concerns and potential injury / property damage that can occur due to an accidental "Arc Flash", but would you not agree for smaller shop operations, based on electrical services and employee task, the potential for "exposure" is Low?


No. From experience, it is definitely NOT intuitive when the risk gets very large. From experience typically the lower the voltage, the greater the hazard tends to be. There is a point on the very low end (commercial/residential) where it finally does become less of an issue, but even a small machine shop can have a significant risk.

The issue though is that OSHA and others started to jump in and start recognizing the existing body of arc flash knowledge WAY too early. That is one of the reasons that we are struggling with using detailed engineering calculations...typically first we work with long, complicated, detailed calculations. Eventually the "simplified" approaches come when folks recognize what's really important and what's not and simplify it down. We're not there yet but it's getting closer. That would be the point where perhaps OSHA, NEC, etc., should have weighed in. However as with anything regarding safety there is a strong need to balance the need to protect workers from injury against the need to study a phenomena to the point where the issue is well settled.


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PostPosted: Mon Jun 18, 2012 4:12 am 
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I understand your position, but for the sake of argument allow me to ask. Has there been substantial increase in "Arc Flash" injuries or incidents? I know (according to my research) that "Arc Flash" suddenly appeared on the OSHA radar based on the somewhat recent change in NFPA 70E and I believe the change (revision) was based on a number of reasons, e.g. 1. Overall increase in electricity use, both commercial and residential. 2. Increase in voltage usage, and 3. The way / means electricity is brought into a facility (high voltage then dropped down). This "high voltage" distribution I believe is done so as to take advantage of electricity cost. I do apologize for the above reasoning’s being simply described, but that is how I see it again based on my research. But even with those reasons given for the "Arc Flash" action., yes the possibility for injury may be heightened, but has there been an increase? Now in asking that, I have seen two recent incidents which have been associated with "Arc Flash" in our area, this according to the preliminary "news" investigations. Neither resulting in personal injury but in property damage. So, my question; Has there been or will we see an increase in "personal injury" unless true, honest assessments and precautions are taken? Your opinions are appreciated.


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PostPosted: Mon Jun 18, 2012 6:52 am 
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John P. Leseganich CPEA wrote:
So, my question; Has there been or will we see an increase in "personal injury" unless true, honest assessments and precautions are taken? Your opinions are appreciated.


I don't think it has anything to do with preventing an increase, I think we are looking at a decrease in the number and severity of injuries caused present 'marginally' safe work practices and lax wearing of PPE.


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PostPosted: Sat Jun 23, 2012 4:05 am 
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Has there been or will we see an increase in "personal injury" unless true, honest assessments and precautions are taken?


No. ESFI.org undertook a recent effort to comb through all the burn and electrical injury cases in the BLS database and showed that there has been a roughly 60% overall decrease over the past 15 years. Arc flash injuries according to their data set are half of shock (0.2/10,000 workers vs. 0.1/10,000 workers) currently. There is concern on both sides however. There are cases that the current analysis method does not model well (over or under protects). There is the usual problem of getting workers to do what is required properly. There are still big question marks...there is no published data for arcing faults over 15 kV for instance (my shop has 22.9 kV as an internediate distribution voltage as well as 230 kV incoming).

From an anecdotal point of view when you look at the data it appears that there was a big drop somewhere around 2002 to 2006. The specific changes that you are referring to are two fold. First, 70E was first changed to something similar to the current form around 2000 including extensive references to dealing with arc flash hazards. Second, more importantly, NEC was changed to including a requirement to apply arc flash labeling and gave a reference to 70E. Since virtually everyone in every industry at least uses NEC as a minimum safety standard and it is required in most "OSHA districts", this got a lot of attention by the more proactive groups. When OSHA issued fines to an automotive company starting towards the latter part of that time period, it got even more attention.

However, as you said, many smaller shops even if they try to be proactive about it are finding the cost daunting. The cost is generally around $20K to $30K for a small shop just to get the study, training, etc., in place. It is effectively as costly as doing a proper risk assessment with the rigors of HAZOP or similar techniques.

On a positive note however, I am seeing signs of improved equipment on the market beyond "arc resistant gear". Circuit breakers are starting to come equipped with maintenance free magnetic actuators, the first actually completely new design in 20-30 years. There is a general recognition that arc flash can only be truly addressed either by eliminating arcing faults via solidly insulated switchgear or by tripping fast enough so that it cannot develop into a major hazard. Both may eventually result in brand new categories of "arc resistant". There is also a growing awareness that we can no longer make gross assumptions about equipment failure rates nor about how equipment is maintained (which is also true in other safety fronts) but that this must be incorporated into the engineering. I've actually seen several papers and articles recognizing for instance that the claimed higher reliability of draw out gear is not as good as it sounds after all. The equipment fails more often, and when it does the extra failure modes are virtually all arcing faults across the board. And the number of failure types where you can repair it while energized are not really enough to justify the decreased reliability and downtime associated with using it. Other designs eliminate all these issues and some (using IEEE 386 connectors first instance) are just as repairable "online".


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PostPosted: Sat Jun 23, 2012 6:28 am 
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Very interest comments and take. I truly appreciate all the input. My readings, study and look into the “Arc Flash” concerns at this point (based on client request) are focused on “regulatory compliance”. In other words “what do I need to do so as not to receive a citation for non-compliance issues”? As I stated in an earlier post, most of my clients are small to medium (25-150 employees) manufacturing or fabricating shops. Required employee task which are somewhat associated with electrical components would be limited to throwing a power box switch or re-setting a breaker. I would like to believe that although the “risk” of “Arc Flash” exposure may exist during these activities, the exposure is low based on the task, components and voltage…..understanding that the possibility remains. That is why my initial focus – recommendations to my clients is the development, implement a “job description” with the emphasis placed on what “not to do” when the need for electrical component work (repair, extensive maintenance) is required. I believe the risk of injury is the first priority. But now the labeling aspect of 70E is the hurdle. This, based on my past experience and knowledge as to how and what an OSHA Compliance Officer will initially look for (labeling). In order for an employer to fully comply with the labeling aspect, the need for that costly assessment comes into account. I fear that we may be seeing labels applied and questionable information being noted on the labels which may not be adequate or correct. It reminds me of the “floor loading” requirement within the OSHA “General Industry” standards: 29 CFR 1910.22(d); “Floor loading protection” (posting a rated load capacity plate). At one time this was an easy item to spot and if not posted issue a citation (recent rulings have reduced the posting requirements). But, very few compliance officers truly understood or looked into whether those posting were correct, as long as there was a posting. I fear that is what we may begin to see when compliance on the labeling portion becomes the “citable” portion of 70E. Blank labels can and are being purchased, stuck on panels and information provided via a clear, readable “Sharpie” with the possibility of being incorrect, simply to have a label (compliance). We (consultants, engineers, providers) need to be able to provide proper guidance, bring employers into compliance, and address the “Arc Flash” concerns without dropping the $15-$20,000.00 cost on the employer. Not sure if as noted, the assessment is properly performed can be done. Don’t get me wrong, I understand the risk, the potential for injury, but getting what needs to be done (smaller shops) is what I see as a difficult task. Just my “two cents” worth.


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PostPosted: Sun Jun 24, 2012 9:55 am 
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To be in compliance with NEC (which is required nearly everywhere in the U.S.) the label merely has to indicate that an arc flash hazard may be present. It does not need to specify any way to deal with it. I have not seen OSHA yet cite anyone for inadequate labels for this. The reason is that although 70E requires more extensive labeling, it is entirely voluntary and merely REFERENCED by NEC which is not voluntary in most cases. 70E in turn REFERENCES 70B as well as the competing standard, NETA MTS. But it does not mandate use of either one as an example of electrical maintenance requirements for safety.

NEC also requires a short circuit study and 70E requires this as well as a coordination study. A quick simplification of the short circuit study is to assume that all cables and buses have zero impedance and only consider the transformer impedances. This gets you to a conservative result for short circuit and coordination studies. Many folks erroneously take these values and plug them into an arc flash equation.

This very simple approach quickly yields either the "opening time" required for short circuit studies. HOWEVER, especially early on, many folks were plugging these values directly into an arc flash equation, or using the opening time to decide whether or not to use the tables in 70E. They did this because these simplifications in a short circuit study result in conservative values. However, this is invalid in an arc flash model because cable impedance matters quite a bit and because arcing fault currents are usually significantly less than the short circuit current. Both can and quite often do result in much longer opening times than expected.

On the very low end of things even without the "125 kVA, <240 V" exception, you can still calculate a "cutoff". Take the short circuit current value and plug it into the arcing fault equation but force the trip time to 2 seconds instead of using the short circuit opening time. By defaulting to the IEEE 1584 "cutoff" value, you can establish a maximum bolted fault current below which there is no reason to calculate incident energy. Note that this does not take into account generators or large motors so it can't be necessarily be used if there are motors over 50 HP.


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PostPosted: Sun Jun 24, 2012 12:42 pm 
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Interesting. As to potential OSHA citation reference to "Arc Flash" labels, here is my take and experience (Past CSHO). When an inspector questions the employers "action taken" reference to "Arc Flash" concerns, the need for a full explanation as to how they (employer) has addressed the known risk along with procedures implemented so as to eliminate and or reduce those risk needs to be given. That takes us to the “required” Arc Flash assessment or analysis we began this conversation with. That "assessment" would result in identifying the specifications (Extent of Arc Flash - Required PPE, Distance, Arc Flash Present when, etc.) which are noted on the newly revised "Arc Flash" labels. Once obtained, informing employees of those risks must be provided and the explanation as to how that information was shared must be given. Now, if one would go through the assessment process, obtain the needed information, why would one not simply place the Arc Flash labels with that information on the electrical components in question? Why not use those labels for information sharing – warning along with some training? This reminds me of the OSHA PPE standard which states that an assessment must be conducted so as to determine what if any PPE may be required in the workplace. The standard (OSHA) does not specify that this assessment be in writing, BUT, if and when an inspector (OSHA) ask if that assessment has been conducted, they need proof……the only or best way to provide verification of the assessment (PPE) is to record it on a form or within a policy. I know it sounds as if I am “splitting hairs”, but bottom line, if you conduct a proper “Arc Flash” assessment (analysis), I would suggest you back that up and take those findings (information) apply it to the newly revised “Arc Flash” labels and label your equipment. Use those labels as part of your "Arc Flash" policy and procedure....training, awareness aspect.


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PostPosted: Tue Jun 26, 2012 5:08 pm 
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NEC only requires that you have an arc flash label and only on certain equipment. It does not tell you what the content must be. Since 70E is a voluntary guidance document, it does not have the regulatory weight of NEC. 70E references 10 different models including the table method in 70E (and the table method in NESC). The various arc flash models that it contains are not derived from provable first principles...none are "exact" in nature, not even Lee. There are also numerous published papers showing various failures to address various arc flash scenarios such as protection against plasma in addition to radiative heat, questions about arc blast, problems with modeling metal clad vs. metal enclosed gear, problems with the size of the enclosure or the orientation of the bus bars, etc.

That being said then, I can show a way that I could use the "silly" labels and have a methodology and avoids paying for an arc flash engineering study. First, assume that all equipment is capable of generating a significant arc flash hazard. We can remove some equipment from consideration if we exercise for instance the IEEE 1584 "<125 kVA, <240 V" rule. For everything else, take the extremely conservative approach and assume that there is no effective PPE available. Now looking at the likelihood of an arcing fault, we can identify a set of tasks where the likelihood is acceptably low such as switching tasks, opening and closing panels, and taking measurements with insulated tools. This can be done without benefit of an arc flash study. Remaining tasks would have to be done in a de-energized state, except if we can exercise the greater hazard rule by executing an EEWP subject to management review. This is already the case currently using 70E for cases where the incident energy is over 40 cal/cm^2 unless a company adopts a policy of not allowing those tasks to be performed at all which is above and beyond 70E.

That completes the exercise...no arc flash hazard required. Surprisingly this is not very far off from what a lot of companies actually do in practice. If anything we could go one step further and just require 40 cal suits for those cases where an arc flash hazard is considered likely and assume that if it is even practically possible to provide protection, this is the best that we can do. The major advantage of doing the arc flash modeling is that PPE can be identified that will provide effective protection 95% of the time at least as per the IEEE 1584 method, and we can dispense with the extremist approach of going for the 40 cal suit for everything.

So...the inherent value in the engineering study becomes the fact that you can reduce/eliminate/control the arc flash hazard and frequently allow workers to operate with far less PPE or perform tasks that would potentially be possible to perform while energized and to do so safely. I realize that this may be a controversial stance but with the way that the verbiage surrounding the EEWP process is currently written, this is the inevitable result...that even if we have reduced the hazard to an acceptable level, the EEWP still prevents the activity from being performed unless the greater hazard or infeasibility rule can be exercised.

This also points out the inherent silliness in the EEWP procedure, and a corollary to ALARP. Since PPE is considered the least desirable method of protecting workers, a very strict interpretation of the greater hazard rule is that de-energized is required in virtually every circumstance except for some troubleshooting tasks (that are already exempt). The problem with the EEWP rule is that even if the hazard has been eliminated or reduced to a very low likelihood, it is still unacceptable because the EEWP rule does not allow for work where the likelihood of the hazard is remote and thus EEWP would not need to be invoked in the first place. Unlike ALARP, the EEWP procedure as written does not recognize when the risk (not hazard) may be very low. It may lead to cases where EEWP justifications become things like "because the face shield decreases visibility and is a greater hazard" or "heat exhaustion is a greater hazard", or "de-energizing carries a greater risk of an arc flash hazard". I know this is the case because I've personally written these! ALARP recognizes that if engineering controls and other methods have already reduced the hazard to an acceptable level, then administrative controls (EEWP) and/or PPE are unnecessary.


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PostPosted: Tue Jun 26, 2012 7:35 pm 
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Very interesting and enlightening. I believe you shared my position on the need for or at least the emphasis being placed on the revised 70E requiring an “Arc Flash” assessment. I am speaking of the emphasis being placed by OSHA. I say this from experiences. For example; One of my clients who has received the SHARP recognition from the OSHA On Site Consultation program ([color=black]On-site Consultation Program’s Safety and Health Achievement Recognition Program - [/color][url='http://www.osha.gov/dcsp/smallbusiness/sharp.html']http://www.osha.gov/dcsp/smallbusiness/sharp.html[/url]), was recently re-visited which is required so as to continue or extend the recognition. I was present during that visit and the revised 70E came up. The consultant requested to see the “Arc Flash” assessment or how the employer was addressing the concern. I informed the On Site consultant that I (private consultant) was working with the employer, we were well aware of the revisions and we had developed (revised) the current Electrical Safety Policy and Procedures which addressed required employee task which reduced or eliminated the potential exposure to possible arc flash. We based this on similar task you mentioned within your last reply along with taking into consideration the type of service (voltage, amperage, enclosures) which may be worked on. The consultant in my opinion was not too familiar with the revisions or “Arc Flash” itself and wanted to see the written assessment and the Arc Flash labels I discussed earlier. I believe after some discussion we convinced the consultant that our action addressed the concern (Arc Flash) and reduced and in some cases eliminated employee exposure but we did not have the assessment or the labels per request. It wasn’t but a week or so later when another client of mine was at a luncheon (not sure who the speaker was) and came back with information he obtained informing him of the need (OSHA) for the assessment and labeling (Arc Flash).

I realize that these are isolated cases, but I see OSHA focusing in on the 70E revisions. I understand that NFPA/NEC has no enforcement powers but being adopted consensus procedures, OSHA can and has done in the past issue General Duty Citations (5(a)(1)) and reference these standards.

My position, and you gave some great information is to address the concern (Arc Flash) and eliminate or reduce the possibility of injury / exposure but in a “performance based” method. OSHAs’ position (it appears) is to enforce the procedures based on what 70E recommends.

That is the dilemma which I believe we may be facing until OSHA comes out with a directive or ruling (FOM) as to how CSHOs will address the concern (Arc Flash).


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