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 Post subject: What are the Labeling Requirements for Facility Upgrade Projects?
PostPosted: Fri Oct 28, 2011 6:54 am 

Joined: Thu Oct 27, 2011 5:00 pm
Posts: 5
Location: Vermilion Ohio
Hey everyone. I am new to this board and have been involved with ARC Flash, but my last experience was a little over 3 years ago. I have been trying to get caught up on the latest concerning ARC Flash analysis and labeling. The work that I do is with existing DATA Centers (Telecom facilities), which includes the utility and power distrbution (120-480VAC). Most if the projects that I am involved in are transformer, UPS, ATS, Generators and power distribution upgrades include replacements. The facilities that I work in have no ARC Flash Labels and with my projects only effecting part of the existing power distribution system. My questions are:

What ARC Flash Labeling is required?
Do I only label the equipment I touch or install? or is there more too it?

I am being told by installation that labeling is not required.

Thanks in advance for any help.

Jack, P.E.


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PostPosted: Fri Oct 28, 2011 11:20 am 
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Location: Scottsdale, Arizona
Question 1
What arc flash labeling is required?

According to the 2012 Edition of 70E the equipment that needs labeled is:

130.5(C) Equipment Labeling. Electrical equipment such as switchboards, panelboards, industrial control panels, meter socket enclosures, and motor control centers that are in other than dwelling units, and are likely to require examination, adjustment, servicing, or maintenance while energized, shall be field marked

Most interpret “field marked” as retroactive meaning labels should be placed on existing equipment that falls under the description above.

Question 2
Do you only label the equipment that you touch or install? This question has two meanings.

If you mean are you responsible to label equipment that you work on or install, I believe most would say - no. It is up to the owner. ...and then the question is how do you know what to wear. - That is when most people will revert back to the 70E tables for PPE selection or try to convince the owner to have an arc flash study performed.

If you mean are labels only required on equipment that might be worked on, the answer is - yes. NFPA 70E uses the language “and are likely to require examination, adjusting, servicing or maintenance while energized”

Hope it helps! Some of the other forum members may have different thoughts - it's a good group of people that have many ideas, opinions etc. and usually quite willing to help out.

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Jim Phillips, P.E.
Brainfiller.com


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PostPosted: Fri Oct 28, 2011 1:11 pm 

Joined: Thu Oct 27, 2011 5:00 pm
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Location: Vermilion Ohio
Jim, I appreciate your response. For some reason in the telecom industry they are under the impression that the NEC does not apply to them, they have their own standards. I have never seen an ARC Flash Label in this technology, but the AC power distribution equipment is no different than any other “industrial” facility. In your response I am confused by the comment “what the customer wants”, our customers want no labeling and claim that the generic equipment manuf warning label that comes on the equipment from the factory complies with NEC 110.16, which I do not agree due to FPN No.1 and 2. This generic factory label only warns of a possible ARC Flash w/o PPE or IE levels indicated. If the customer does not want the labeling do I just go alone with them and just ignore the code (FPN No. 1 and 2)? If there are no labels on the equipment and there is an injury or accident, am I responsible?


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PostPosted: Sun Oct 30, 2011 1:07 pm 
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The "generic label" is really all that NEC 110.16 references

There was a proposal to add language to the 2008 NEC which would have required listing much more info. It was rejected due to the “burden” it would place on the designer who would not have all the info.

One of the NFPA rejection comments was that belongs in the safety standard not the NEC, so that means the problem falls back to NFPA 70E and OSHA.

NFPA 70E defines the "proper" labeling requirements. Labels should also be in accordance with ANSI Z535 colors and signal words.

My opinion of the situation is the burden rests with the owner but based on some of my expert witness activity, anything can happen in the U.S. legal system.

Perhaps put in writing to the owner that they are advised to comply with NFPA 70E and adhear to 70E's labeling requirements. I'm sure they will not be pleased to have that document but if something occurs in the future, you are on record.

OSHA should be a concern to them as well. If there is an inspection, no labels, not PPE etc. could be quite a problem for them. (as many companies have found out).

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PostPosted: Sun Oct 30, 2011 6:59 pm 
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Joined: Wed Jun 04, 2008 9:17 am
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Location: Spartanburg, South Carolina
JBK89UT wrote:
For some reason in the telecom industry they are under the impression that the NEC does not apply to them, they have their own standards.

The telecom exemption to NEC applies to installations of communications equipment, not to power equipment.


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