The company I work for did not do the arc flash calculations for their power panels. Instead they said they used the 12 foot rule. Is this a vialble alternative to doing the calculations? I know that the labels are a lot simpler - basically saying to stay away.

Is this a legal labeling system? Should I submit a picture of what it looks like?

Thank you

There is no such thing as a 'legal' or 'non-legal' label. Each employer gets to decide what they want their label to look like and what information it will contain. Minimum label content requirements were added to NFPA70E in the 2012 edition, in particular they must list the appropriate PPE.

There really has never been something like a "12ft rule".
There used to be a 4ft rule, for arc flash, but it was removed in the 2012 edition.

Thank you. I will try to get the 2012 edition and make sure that everything is as correct as I can get it.

Are arc flash calculations required? I know that PPE requirements are supposed to be on the labels.

For new equipment, NEC art 110.16 (which is law, so must be followed, in most States) requires a label on quite some equipment warning about the flash hazard.

Yes labeling is required, but there is no actual 'legal' verbiage or layout.

NEC is a standard for minimum electrical recommended practices. The operative word is "recommended". Its not "law" or a legal standard in any state in the union. The final administration is with the local AHJ. Read NEC Article 80.13(1), (2). NEC and NFPA70E aren't legally mandated in any state... however OSHA and most local AHJ's use them as reference for enforcement.

2012 NFPA 70E is "the" recognized standard for arc flash labeling by OSHA. This does not mean OSHA enforces it by law, but OSHA does state that it uses the 2012 NFPA 70E as its guide (OSHA 3075).

If you would like to learn more about the latest arc flash labeling standards, vist: DuraLabel.com to review our past webinar on the subject.

If you aren't labeling to 2012 NFPA 70E standards, you aren't practicing generally accepted practices. The result leaves workers in the dark to safety and opens the door to liabilities.

Dave,

The only alternative to the detailed analysis, that I'm aware of, is to use NFPA 70E Table 130.7(C)(15)(a) which lists the parameters (VERY IMPORTANT TO KNOW) under which it applies.

As for labeling requirements, I recommend you go to OSHA 29CFR 1910.145(d)(1) which references ANSI Z53.1 - 1967. I recently requested an interpretation from OSHA about the signal words listed in 1910.145 as they are over 45 years old and not even close to the current standard which is ANSI Z535.4 - 2011. Almost every bid spec that I get for arc flash analysis/labeling mandates the labels be in accordance with ANSI Z535.4, and every proposal I submit states the current ANSI standard. I am currently working on a project that requires the removal of 400+ "generic" labels that a "safety professional" had affixed to the equipment without any rhyme or reason. It appears they were going to do something for arc flash safety whether it was right or wrong!

Whoops... forgot to add... yes the NFPA 70E 2012 has some new minimum labeling requirements.

Eric,

I think you need to re-read OSHA regs... OSHA does not say it uses NFPA70E for arc flash labeling.

From OSHA 3075, "OSHA’s electrical standards are based on the National Fire Protection Association Standards NFPA 70, National Electric Code, and NFPA 70E, Electrical Safety Requirements for Employee Workplaces."

The NFPA 70E-2012 covers labeling in section 130.5(C) Equipment Labeling.

Once again, this does not mean OSHA enforces NFPA 70E-2012 as law. However, I believe most interpret this to mean OSHA considers NFPA 70E-2012 as the generally accepted standards for electrical safety. This includes arc flash electrical equipment labeling.

Coming from a former OSHA inspector, I can tell you that OSHA does not and can not enforce NFPA 70E in a citation but can only reference it. 70E is a recommended standard industry practice that should be followed in good faith. The OSHA electrical standards are somewhat vague in some areas as in specific PPE, work practices, etc. which allows them to refer back to NFPA 70E as a guideline for a citation. All citations can be challenged and I have seen many citations where 70E was referenced but was thrown out because it is not part of the standard. It is a case-by-case basis and has a lot to do with OSHA history, if it is a fatality, etc. If you have a fatality at your site because of an Arc Flash then 70E is going to be referenced in your citation and there is a very small chance of getting the citation thrown out because OSHA knows they can win that in front of a jury.

At the end of the day, OSHA does expect employers to comply with 70E but citing the employer for not following 70E depends on the circumstance. Its no different then trying to get out of a speeding ticket. If you were going 120 MPH and you have three other tickets on your record, then you are getting a citation. If you were going 60 in a 45 and its your first ticket then you have a better chance of taking it to court and getting out of it.

On the panel board cover, the calorie of the energy calcuated to be availiable in the event of an arc. Will that provide enough labeling to satisfy the requirement for todays standard?

NFPA 70E 2012 130.5(C) tells you exactly what is required to meet 70E requirements. Also, remember to put the OSHA required items on it also (Voltage, Manufacturer, ETC.)

What OSHA standard requires items for labels (Voltage, Manufacturer, ETC.)?

General hazard sign & label design information
[SIZE=3]Although not currently required, use the latest design standards - ANSI Z535-2011 to ensure future compliance:[/size]
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9794

Labeling locations:
[i]OSHA Subpart S, General electrical (for electric utilization systems)[/i]
1910.303(e)(1) Identification of manufacturer and ratings. Electric equipment may not be used unless the following markings have been placed on the equipment: 1910.303(e)(1)(i) The manufacturer's name, trademark, or other descriptive marking by which the organization responsible for the product may be identified; and 1910.303(e)(1)(ii) Other markings giving voltage, current, wattage, or other ratings as necessary. 1910.303(e)(2) Durability. The marking shall be of sufficient durability to withstand the environment involved.

1910.303(h)(2)(iii)(B) Metal-enclosed switchgear, unit substations, transformers, pull boxes, connection boxes, and other similar associated equipment shall be marked with appropriate caution signs.

1910.303(h)(5)(iii) The following requirements apply to the entrances to all buildings, rooms, or enclosures containing exposed live parts or exposed conductors operating at over 600 volts, nominal: 1910.303(h)(5)(iii)(A) The entrances shall be kept locked unless they are under the observation of a qualified person at all times; and 1910.303(h)(5)(iii)(B) Permanent and conspicuous warning signs shall be provided, reading substantially as follows: "DANGER -- HIGH VOLTAGE -- KEEP OUT."

[i]OSHA Subpart S, General electrical (Wiring design)[/i]

1910.304(b)(1) Identification of multiwire branch circuits. Where more than one nominal voltage system exists in a building containing multiwire branch circuits, each ungrounded conductor of a multiwire branch circuit, where accessible, shall be identified by phase and system. The means of identification shall be permanently posted at each branch-circuit panelboard.

[i]OSHA Subpart S, General electrical (Wiring methods, components, and equipment for general use)[/i]

1910.305(j)(4)(ii) An individual disconnecting means shall be provided for each controller. A disconnecting means shall be located within sight of the controller location. However, a single disconnecting means may be located adjacent to a group of coordinated controllers mounted adjacent to each other on a multi-motor continuous process machine. The controller disconnecting means for motor branch circuits over 600 volts, nominal, may be out of sight of the controller, if the controller is marked with a warning label giving the location and identification of the disconnecting means that is to be locked in the open position.

1910.305(c)(3)(ii) Single-throw knife switches, molded-case switches, switches with butt contacts, and circuit breakers used as switches shall be connected so that the terminals supplying the load are deenergized when the switch is in the open position. However, blades and terminals supplying the load of a switch may be energized when the switch is in the open position where the switch is connected to circuits or equipment inherently capable of providing a backfeed source of power. For such installations, a permanent sign shall be installed on the switch enclosure or immediately adjacent to open switches that read, "WARNING -- LOAD SIDE TERMINALS MAY BE ENERGIZED BY BACKFEED."

[i]OSHA Subpart S, General electrical (Specific purpose equipment and installations)[/i]

1910.306(c)(6)(i) Elevators, dumbwaiters, escalators, moving walks, wheelchair lifts, and stairway chair lifts - Where there is more than one driving machine in a machine room, the disconnecting means shall be numbered to correspond to the identifying number of the driving machine that they control. 1910.306(c)(6)(ii) The disconnecting means shall be provided with a sign to identify the location of the supply-side overcurrent protective device. 1910.306(c)(7) Single-car and multicar installations. On single-car and multicar installations, equipment receiving electrical power from more than one source shall be provided with a disconnecting means for each source of electrical power. The disconnecting means shall be within sight of the equipment served. 1910.306(c)(8) Warning sign for multiple disconnecting means. A warning sign shall be mounted on or next to the disconnecting means where multiple disconnecting means are used and parts of the controllers remain energized from a source other than the one disconnected. The sign shall be clearly legible and shall read "WARNING -- PARTS OF THE CONTROLLER ARE NOT DEENERGIZED BY THIS SWITCH." 1910.306(c)(9) Interconnection between multicar controllers. A warning sign worded as required in paragraph (c)(8) of this section shall be mounted on or next to the disconnecting means where interconnections between controllers are necessary for the operation of the system on multicar installations that remain energized from a source other than the one disconnected.

1910.306(g)(1)(iv) Warning labels or signs that read "DANGER -- HIGH VOLTAGE -- KEEP OUT" shall be attached to the equipment and shall be plainly visible where persons might contact energized parts when doors are opened or closed or when panels are removed from compartments containing over 250 volts ac or dc.

1910.306(k)(4)(iv) Where single-pole connectors are used, they shall comply with the following: 1910.306(k)(4)(iv)(A) Where ac single-pole portable cable connectors are used, they shall be listed and of the locking type. Where paralleled sets of current-carrying single-pole separable connectors are provided as input devices, they shall be prominently labeled with a warning indicating the presence of internal parallel connections.

[i]OSHA Subpart S, General electrical [/i]([url='http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10708'][color=#000000]Hazardous (classified) locations.[/url][/color])

1910.307(c)(2)(ii) Equipment shall be marked to show the class, group, and operating temperature or temperature range, based on operation in a 40-degree C ambient, for which it is approved. The temperature marking may not exceed the ignition temperature of the specific gas or vapor to be encountered. However, the following provisions modify this marking requirement for specific equipment:
1910.307(c)(2)(ii)(A) Equipment of the nonheat-producing type, such as junction boxes, conduit, and fittings, and equipment of the heat-producing type having a maximum temperature not more than 100º C (212º F) need not have a marked operating temperature or temperature range; 1910.307(c)(2)(ii)(B) Fixed lighting fixtures marked for use in Class I, Division 2 or Class II, Division 2 locations only need not be marked to indicate the group; 1910.307(c)(2)(ii)(C) Fixed general-purpose equipment in Class I locations, other than lighting fixtures, that is acceptable for use in Class I, Division 2 locations need not be marked with the class, group, division, or operating temperature; 1910.307(c)(2)(ii)(D) Fixed dust-tight equipment, other than lighting fixtures, that is acceptable for use in Class II, Division 2 and Class III locations need not be marked with the class, group, division, or operating temperature; and
1910.307(c)(2)(ii)(E) Electric equipment suitable for ambient temperatures exceeding 40º C (104º F) shall be marked with both the maximum ambient temperature and the operating temperature or temperature range at that ambient temperature

[i]OSHA Subpart S, General electrical (Wiring methods, components, and equipment for general use)[/i]

§1910.335(b), OSHA 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.

Subpart F, General Working Conditions (Occup. Safety and Health Standards for Shipyard Employment)

1915.89(a)(3) When other standards in 29 CFR part 1915 and applicable standards in 29 CFR part 1910 require the use of a lock or tag, the employer shall use and supplement them with the procedural and training requirements specified in this section. 1915.89(a)(4) Exceptions. This section does not apply to: 1915.89(a)(4)(i) Work on cord-and-plug-connected machinery, equipment, or system, provided the employer ensures that the machinery, equipment, or system is unplugged and the plug is under the exclusive control of the employee performing the servicing; 1915.89(a)(4)(ii) Minor servicing activities performed during normal production operations, including minor tool changes and adjustments, that are routine, repetitive, and integral to the use of the machinery, equipment, or system, provided the employer ensures that the work is performed using measures that provide effective protection from energization, startup, or the release of hazardous energy. 1915.89(b)Lockout/tags-plus program. The employer shall establish and implement a written program and procedures for lockout and tags-plus systems to control hazardous energy during the servicing of any machinery, equipment, or system in shipyard employment. The program shall cover: 1915.89(b)(1) Procedures for lockout/tags-plus systems while servicing machinery, equipment, or systems in accordance with paragraph (c) of this section;

Subpart G, Cargo Handling Gear and Equipment Other Than Ship's Gear (Safety and Health Regulations for Longshoring)

1918.64(k) Lockout/tagout. 1918.64(k)(1) Conveyors shall be stopped and their power sources locked out and tagged out during maintenance, repair, and servicing. If power is necessary for testing or for making minor adjustments, power shall only be supplied to the servicing operation. 1918.64(k)(2) The starting device shall be locked out and tagged out in the stop position before an attempt is made to remove the cause of a jam or overload of the conveying medium.

Subpart G, Occup. Safety and Health Standards for Shipyard Employment (Ship's Machinery and Piping Systems)

1915.164(a)(2) If the jacking gear is steam driven, the employer shall ensure that the stop valves to the jacking gear are secured, and then locked or tagged, in accordance with § 1915.89.

OSHA Subpart J, General Environmental Controls

[url='http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1910_0145&src_anchor_name=1910.145%28c%29%283%29'][color=#000000]1910.145(c)(3)[/url] Safety instruction signs. Safety instruction signs shall be used where there is a need for general instructions and suggestions relative to safety measures.[/color]

§1910.145(f)(4)(i) Tags shall contain a signal word and a major message, such as "High Voltage," "Close Clearance," "Do Not Start," or "Do Not Use" or a corresponding pictograph used with a written text or alone.

[url='http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_0403&src_anchor_name=1926.403%28h%29'][color=#000000]OSHA [/url][/color][color=black][url='http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_0403&src_anchor_name=1926.403%28h%29'][color=#000000]Subpart K, [/url][/color][/color][url='http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_0403&src_anchor_name=1926.403%28h%29'][color=#000000]Safety and Health Regulations for Construction (General requirements)[/url][/color]

[color=black][url='http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_0403&src_anchor_name=1926.403%28h%29'][color=#000000]1926.403(h)[/url][/color][/color] Identification of disconnecting means and circuits. Each disconnecting means required by this subpart for motors and appliances shall be legibly marked to indicate its purpose, unless located and arranged so the purpose is evident. Each service, feeder, and branch circuit, at its disconnecting means or overcurrent device, shall be legibly marked to indicate its purpose, unless located and arranged so the purpose is evident. These markings shall be of sufficient durability to withstand the environment involved.

[url='http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_0403&src_anchor_name=1926.403%28h%29'][color=#000000]OSHA [/url][/color][color=black][url='http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_0403&src_anchor_name=1926.403%28h%29'][color=#000000]Subpart K, [/url][/color][/color][url='http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_0403&src_anchor_name=1926.403%28h%29'][color=#000000]Safety and Health Regulations for Construction (Wiring design and protection)[/url][/color]

1926.404(d)(1)(i) General. Means shall be provided to disconnect all conductors in a building or other structure from the service-entrance conductors. The disconnecting means shall plainly indicate whether it is in the open or closed position and shall be installed at a readily accessible location nearest the point of entrance of the service-entrance conductors.

1926.404(d)(2)(ii) Warning signs. Signs warning of high voltage shall be posted where unauthorized employees might come in contact with live parts.

OSHA Subpart K, Safety and Health Regulations for Construction (Wiring methods, components, and equipment for general use.)

1926.405(h) Portable cables over 600 volts, nominal. Multiconductor portable cable for use in supplying power to portable or mobile equipment at over 600 volts, nominal, shall consist of No. 8 or larger conductors employing flexible stranding. Cables operated at over 2000 volts shall be shielded for the purpose of confining the voltage stresses to the insulation. Grounding conductors shall be provided. Connectors for these cables shall be of a locking type with provisions to prevent their opening or closing while energized. Strain relief shall be provided at connections and terminations. Portable cables shall not be operated with splices unless the splices are of the permanent molded, vulcanized, or other equivalent type. Termination enclosures shall be marked with a high voltage hazard warning, and terminations shall be accessible only to authorized and qualified personnel.

OSHA Subpart K, Safety and Health Regulations for Construction ([url='http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10708'][color=#000000]Hazardous (classified) locations.[/url][/color])

1926.407(b) Electrical installations. Equipment, wiring methods, and installations of equipment in hazardous (classified) locations shall be approved as intrinsically safe or approved for the hazardous (classified) location or safe for the hazardous (classified) location. Requirements for each of these options are as follows: 1926.407(b)(1) Intrinsically safe. Equipment and associated wiring approved as intrinsically safe is permitted in any hazardous (classified) location included in its listing or labeling. 1926.408(b)(2) Marking. A Class 2 or Class 3 power supply unit shall not be used unless it is durably marked where plainly visible to indicate the class of supply and its electrical rating.

OSHA Subpart K, Safety and Health Regulations for Construction ([url='http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10708']General Requirements[/url])

1926.416(a)(3) Before work is begun the employer shall ascertain by inquiry or direct observation, or by instruments, whether any part of an energized electric power circuit, exposed or concealed, is so located that the performance of the work may bring any person, tool, or machine into physical or electrical contact with the electric power circuit. The employer shall post and maintain proper warning signs where such a circuit exists. The employer shall advise employees of the location of such lines, the hazards involved, and the protective measures to be taken.

OSHA Subpart K, Safety and Health Regulations for Construction ([url='http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10708'][color=#000000]Lockout tagging of circuits[/url][/color])

[color=black][url='http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_0417&src_anchor_name=1926.417%28a%29'][color=#000000]1926.417(a)[/url][/color][/color] Controls. Controls that are to be deactivated during the course of work on energized or deenergized equipment or circuits shall be tagged.[color=black][url='http://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1926_0417&src_anchor_name=1926.417%28b%29'][color=#000000] 1926.417(b)[/url][/color][/color] Equipment and circuits. Equipment or circuits that are deenergized shall be rendered inoperative and shall have tags attached at all points where such equipment or circuits can be energized.[color=black] 1926.417(c)[/color] Tags. Tags shall be placed to identify plainly the equipment or circuits being worked on.

OSHA [b]Subpart R, The types of installations covered by this paragraph include the generation, transmission, and distribution installations of electric utilities, as well as equivalent installations of industrial establishments. Supplementary electric generating equipment that is used to supply a workplace for emergency, standby, or similar purposes only is covered under Subpart S of this Part. [/b]

1910.269(l)(1) "General." Only qualified employees may work on or with exposed energized lines or parts of equipment. Only qualified employees may work in areas containing unguarded, uninsulated energized lines or parts of equipment operating at 50 volts or more. Electric lines and equipment shall be considered and treated as energized unless the provisions of paragraph (d) or paragraph (m) of this section have been followed.

1910.269(v)(4)(iii) Signs warning unqualified persons to keep out shall be displayed at entrances to the electrical equipment rooms and spaces.

1910.269(o)(6)(ii)(C) That test power disconnects are clearly marked and readily available in an emergency.

Whoa, totally invalid here for almost all operations. You CANNOT simply pick and choose sections of OSHA to quote as if they apply to all situations. Certain OSHA sections apply generally, while others are specific to particular industries or tasks. NONE of the sections quoted apply generally to ALL industries.

Everything in 1910.269 is from Subchapter R. This section ONLY applies to generation, transmission, and distribution. It does not apply to mining, construction, marine, or utilization. The line between distribution and utilization by the way is very fuzzy at times and clear cut in others.

OSHA 1910.3xx is from Subchapter S. It applies to electrical work on utilization equipment for operations/maintenance. In a generation/transmission/distribution facility depending on where you are at in the system, you may have to use these rules exclusively (if it is purely utilization), or mix Subchapter R and S rules if the equipment has characteristics of both. See Annex A of Subchapter R for how to parse this situation.

OSHA 1910.145 is from yet another Subchapter.

And NONE of these apply to construction, marine, or mining.

The subchapters are now included and additional info. Thanks Paul

Got it:

NFPA 70E 2012 requires arc flash labels to include:

1. At least one of the following:
   
   • Available incident energy and the corresponding working distance
   • Minimum arc rating of clothing
   • Required level of PPE
   • Highest Hazard/Risk category (HRC) for the equipment
2. Nominal system voltage
3. Arc flash boundary