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 Post subject: Label Requirements 2015
PostPosted: Thu Feb 12, 2015 12:29 pm 
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The statement below is from the 2015 NFPA70E addition. My question is: when performing a detailed analysis of a facility (We use SKM PowerTools) is it still acceptable to put both PPE and incident energy on the label? According to item (a) below it states "but not both"

Opinions?

Recommendation?

Any help would be appreciated!

(D) 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 that are likely to require examination, adjustment, servicing, or maintenance while energized shall be field-marked with a label containing all the following information:
(1) Nominal system voltage
(2) Arc flash boundary
(3) At least one of the following:
a. Available incident energy and the corresponding
working distance, or the arc flash PPE category in
Table 130.7(C)(15)(A)(b) or Table 130.7(C)(15)(B)
for the equipment, "but not both"
b. Minimum arc rating of clothing
c. Site-specific level of PPE


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 Post subject: Re: Label Requirements 2015
PostPosted: Thu Feb 12, 2015 1:36 pm 
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Location: Port Huron, Michigan
You have to either choose to give the PPE value from the tables OR the actual incident energy. If you do an actual study (such as with SKM) they are pushing for you to put the calculated incident energy values on the label. And when you do a study you don't use the tables, those are for use for people before they do a study.

"c. Site-specific level of PPE" allows you to put something very similar to the old HRC number on your label, you just have to use a different term for it. But you can still come up with something that reflects the ranges you want.




McQ wrote:
The statement below is from the 2015 NFPA70E addition. My question is: when performing a detailed analysis of a facility (We use SKM PowerTools) is it still acceptable to put both PPE and incident energy on the label? According to item (a) below it states "but not both"

Opinions?

Recommendation?

Any help would be appreciated!

(D) 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 that are likely to require examination, adjustment, servicing, or maintenance while energized shall be field-marked with a label containing all the following information:
(1) Nominal system voltage
(2) Arc flash boundary
(3) At least one of the following:
a. Available incident energy and the corresponding
working distance, or the arc flash PPE category in
Table 130.7(C)(15)(A)(b) or Table 130.7(C)(15)(B)
for the equipment, "but not both"
b. Minimum arc rating of clothing
c. Site-specific level of PPE


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 Post subject: Re: Label Requirements 2015
PostPosted: Mon Feb 16, 2015 8:50 am 

Joined: Fri Oct 19, 2012 7:10 am
Posts: 4
I'm still confused about this. Can anyone offer any clarification of "site-specific level of PPE"? That would seem to me to be the category associated with the calculated incident energy level, much like has always been done when using software such as SKM or DesignBase (EDSA). However, the other text in the section would seem to preclude this. I've been trying to find some clarification on-line but, so far, haven't had any success.


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 Post subject: Re: Label Requirements 2015
PostPosted: Mon Feb 16, 2015 10:39 pm 
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Location: North Carolina
You can edit the settings in the custom label section of 70E to make label 'categories' anything you want.

Site specific labels can be anything. Say for instance we have a PPE chart as follows:
A - nonmelting clothing only, standard PPE including ear plugs (<=1.2 cal)
B - arc rated long sleeve shirt and pants, leather or voltage rated gloves (<=4 cal)
C - B+balaclava & arc rated face shield (<=10 cal)
D - 40 cal suit (<= 40 cal)

Using letters A, B, C, D would be a site specific system. I raised 'PPE 2' because the available PPE is rated 10.5 cal, and dropped PPE 3 because it is kind of pointless. If it were a utility following .269 PPE rules, I would increase the cal cutoff for B to 10-12 cal and drop C. Either way, Annex H lays out the generic table and more or less requires site specific rules.

By the way, the “but not both“ is a holdover from 70E-2012. In that edition PPE levels also sort of included risk so the table was not supposed to be used 'backwards' if a hazard stjdy (IEEE 1584) was used and Annex H would be used instead. With the recently issued TIA Annex H and the PPE table are now harmonized so the rule against having both PPE level and incident energy level is now no longer technically justified.


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 Post subject: Re: Label Requirements 2015
PostPosted: Mon Mar 09, 2015 3:07 pm 

Joined: Mon Mar 09, 2015 2:36 pm
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I have discussed this with engineers who believe, and I concur, that it is acceptable and appropriate to include both the incident energy and the PPE Category as long as the PPE category is determined from Table 130.7(C)(16). Note that Table 130.7(C)(15)(A)(b) and Table 130.7(C)(15)(B) are for determining PPE categories based on: type of equipment, available short-circuit current, etc. . . . everything EXCEPT actual incident energy. These tables CANNOT be compared to actual incident energy by definition. However, Table 130.7(C)(16) defines PPE per category as defined by actual incident energy. If one has calculated the incident energy, the (15)(A)(b) and (15)(B) tables are irrelevant and one can go directly to Table 130.7(C)(16). By using the Table 15 methods, the arc flash categories are being approximated with the hope that the results will be in line with the incident energy levels identified in Table 130.7(C)(16), but it won't be as accurate as actual incident energy calculations. Table 130.7(C)(16) clearly states what PPE is required for a specific INCIDENT ENERGY range. How can this not be applicable to, and usable with, the calculated incident energy method?
And remember, the code verbiage below does NOT exclude the use of PPE categories from Table 130.7(C)(16) from being included on the label along with the incident energy.

Any thoughts?

Code Text:
(D) 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 that are likely to require examination,
adjustment, servicing, or maintenance while energized
shall be field-marked with a label containing all the
following information:
(1) Nominal system voltage
(2) Arc flash boundary
(3) At least one of the following:
a. Available incident energy and the corresponding
working distance, or the arc flash PPE category in
Table 130.7(C)(15)(A)(b) or Table 130.7(C)(15)(B)
for the equipment, but not both
b. Minimum arc rating of clothing
c. Site-specific level of PPE


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 Post subject: Re: Label Requirements 2015
PostPosted: Tue Mar 10, 2015 4:51 am 

Joined: Fri Oct 19, 2012 7:10 am
Posts: 4
Thanks. But 130.5(C) seems to prohibit what you're saying:

(C) Arc Flash PPE. One of the following methods shall
be used for the selection of PPE. Either, but not both, methods
shall be permitted to be used on the same piece of
equipment. The results of an incident energy analysis to
specify an arc flash PPE Category in Table 130.7(C)(16)
shall not be permitted.


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 Post subject: Re: Label Requirements 2015
PostPosted: Tue Mar 10, 2015 9:34 am 

Joined: Mon Mar 09, 2015 2:36 pm
Posts: 2
Thank you for this.

Now I am really confused.
The text you quote just doesn't seem to make any sense to me at all.
With Table 130.C(16) specifying PPE categories that are expressly defined by the incident energy released, the text of 130.5(C) appears contradictory with the table.

I think the previous suggestions to simply define a category system for the particular site and give it a different designation (like A,B,C etc.) sound like the answer. However, customers won't be happy at all about this when they already have AF labels with the PPE categories 0,1,2,3,4. I hope the standards committee addressed this issue soon and issues a clarification, rather then waiting for the next scheduled code.

Thanks again.
This site is very useful and appreciated.


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 Post subject: Re: Label Requirements 2015
PostPosted: Tue Mar 10, 2015 9:49 am 

Joined: Fri Oct 19, 2012 7:10 am
Posts: 4
I agree that it doesn't make any sense. How is one to base the PPE in Table 130.C(16) on incident energy if you're not allowed to calculate the incident energy to use the table? Sounds like a case of the committee needed to "pass the revisions to find out what was in the revisions". :D

That said, there has never been a hazard category higher than 4 at 40 cal. However, these days manufacturers are making suits that are rated for higher incident energy - 75 cal and even 100 cal. So the old 40 cal limit might be becoming outdated, anyway.

For now, I am just not printing the category on the labels anymore. The clients don't like it but I very politely take a "don't shoot me, I'm just the messenger" approach with them and tell them that this is the way we're required to do it now-a-days. I print the incident energy and tell them that it's their responsibility to be sure they wear PPE with at least that rating. I have been looking for a clarification or even a loophole to let us get around this but I haven't found one. So far, I haven't been asked to cook up any sort of arbitrary "site-specific" rating, at least.


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 Post subject: Re: Label Requirements 2015
PostPosted: Mon Apr 27, 2015 5:56 am 
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Quote:
I agree that it doesn't make any sense. How is one to base the PPE in Table 130.C(16) on incident energy if you're not allowed to calculate the incident energy to use the table? Sounds like a case of the committee needed to "pass the revisions to find out what was in the revisions"


You are not doing it right. If you calculate incident energy, you use the tables in Annex H, NOT in Article 130. That is the reason for the prohibition against using PPE levels and incident energy on the same label.

There are TWO methods. First method is to basically do something external to the Code. Do the risk assessment and hazard assessments EXTERNAL to the Code. For the former I recommend following CCPS LOPA. Don't bother with the "risk assessment" in the Annex. It's incomplete and relies on what appears to be a version of ANSI B13 which is an inappropriate methodology for arc flash. For the latter, I recommend IEEE 1584 for 250-15 kV, ArcPro for >=10 kV, and test data for 50-250 V. PPE is listed in Annex H, NOT the tables in the text.

For the second method, follow the 3 tables (task table, equipment table, PPE table) in that order. The result is a PPE value (1-4). The major complication is the equipment table which theoretically includes doing a coordination study as inputs to the process. This is where things get silly because that is also the raw data required for IEEE 1584 empirical method so the same amount of data is required for either method and the tables end up not really being useful at that point since they give overly conservative ratings.

AOENGR wrote:
I have discussed this with engineers who believe, and I concur, that it is acceptable and appropriate to include both the incident energy and the PPE Category as long as the PPE category is determined from Table 130.7(C)(16). Note that Table 130.7(C)(15)(A)(b) and Table 130.7(C)(15)(B) are for determining PPE categories based on: type of equipment, available short-circuit current, etc. . . . everything EXCEPT actual incident energy. These tables CANNOT be compared to actual incident energy by definition. However, Table 130.7(C)(16) defines PPE per category as defined by actual incident energy.[/qupte]

No. This is backwards. The tables give a value for selecting PPE by ATPV. If all the PPE table said was "multilayer flash suit" then one rated with an ATPV of 25 could be used for PPE level 4 when the minimum requirement for PPE level 4 is an ATPV of 40. The only thing you should be giving is a PPE level from the tables. You can of course include the actual PPE required including ATPV.

Quote:
If one has calculated the incident energy, the (15)(A)(b) and (15)(B) tables are irrelevant and one can go directly to Table 130.7(C)(16).


No. That's the wrong table. Use Annex H, which is what it's for. Annex H is given in incident energy whereas Table 130.7(C)(16) is given in PPE levels. You'd want to use Annex H anyways. It gives a lot more flexibility in the 8-12 cal/cm^2 area.

[qupte]By using the Table 15 methods, the arc flash categories are being approximated with the hope that the results will be in line with the incident energy levels identified in Table 130.7(C)(16), but it won't be as accurate as actual incident energy calculations.


The calculated method is an approximation. The calculation method is applied (behind the scenes) to the equipment table and the PPE levels are upper bounds on the values in that table. For example the equipment table value might be 6 cal/cm^2 but it is given as Level 2 (ATPV=8). That's how it works in the real world anyways. For instance a shirt might be rated 10.8 cal/cm^2 and be used for everything from 1.2 all the way to 10.8 cal/cm^2. No company is going to stock shirts for 1.3, 1.4, 1.5...

And BOTH methods are approximations anyways because neither one is relying on actual test data but rather they are just approximations based on engineering studies. So the idea that the table method is an approximation is simply not true. When it becomes a best guess is if you use the tables without doing a coordination study to validate the short circuit and opening time values given in the equipment table.

Quote:
Table 130.7(C)(16) clearly states what PPE is required for a specific INCIDENT ENERGY range. How can this not be applicable to, and usable with, the calculated incident energy method?


No, it gives an incident energy value specifically for PPE requirements (ATPV). As with all Codes everything is written from general to specific, top to bottom, left to right. The starting value is a PPE Level, not incident energy.

Quote:
And remember, the code verbiage below does NOT exclude the use of PPE categories from Table 130.7(C)(16) from being included on the label along with the incident energy.


It does exactly that. You could technically give an incident energy on the label derived from the tables rather than giving a PPE level. The result is the same either way...PPE is selected based on the incident energy value. As of 2015, the Annex H table and Table 130.7(C)(16) are harmonized at least to the point that say 8 cal/cm^2 results in the same PPE requirements. But 10 cal/cm^2 would be very different in Annex H compared to Table 130.7(C)(16), since Annex H allows PPE rated for 10 cal/cm^2 and Table 130.7(C)(10) would (again by reading it backwards) result in PPE rated for ATPV 25. This might now matter if you find shirts that are actually rated ATPV 8, but mostly it seems that the traditional 12 oz. "work shirt" is around 10 cal and the long sleeve "jerseys" are around ATPV 6 in many cases.


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 Post subject: Re: Label Requirements 2015
PostPosted: Mon Apr 27, 2015 7:11 am 
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We still use 8 cal = Level 2 and 40 cal = Level 4 and refer to it as "site specific" PPE requirements. Saying you can not do this makes no sense at all. If Cat 2 is 8 cal, why can't the need for 8 cal be Cat 2? We look at the "site specific" statement as permitting this as do quite a few others that I have talked with.


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 Post subject: Re: Label Requirements 2015
PostPosted: Fri May 01, 2015 3:14 pm 
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K. Engholm wrote:
We still use 8 cal = Level 2 and 40 cal = Level 4 and refer to it as "site specific" PPE requirements. Saying you can not do this makes no sense at all. If Cat 2 is 8 cal, why can't the need for 8 cal be Cat 2? We look at the "site specific" statement as permitting this as do quite a few others that I have talked with.


As long as it is "site specific" or somehow anything other than "from the table in Article 130", you're good to go. 70E prohibition is only against using the table in Article 130 "backwards". So long as you do your own thing, and in this regard Annex H is guidance and not Code, there is nothing in 70E saying that you can't add additional information to an arc flash label beyond what is required by Code, even if it's a "site specific" PPE rating. It only prohibits using 70E-specific PPE categories and incident energy on the same label.


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