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 Post subject: What are necessary qualifications to perform an AFHS?
PostPosted: Mon Jan 25, 2016 9:17 am 

Joined: Fri Jan 22, 2016 7:40 am
Posts: 2
I am responsible for AFHS at our facility. I currently do not have my P.E.. I am curious wheather or not it is required of me to have my P.E. to perform a study like this.

Also, is it required to have a P.E. to perform studies for other facilities? I know if I were an electrical engineer for a facility and looking for an outside party to conduct a study for me, I would personally want it to be performed by a P.E.. However, I did not know for sure if it is required?

Also, in the case that the answere to these questions varys by state law, where can this information be found?

Thanks in advance


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 Post subject: Re: What are necessary qualifications to perform an AFHS?
PostPosted: Mon Jan 25, 2016 10:26 am 
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Location: Scottsdale, Arizona
mayfielj wrote:
I am responsible for AFHS at our facility. I currently do not have my P.E.. I am curious wheather or not it is required of me to have my P.E. to perform a study like this.

Also, is it required to have a P.E. to perform studies for other facilities? I know if I were an electrical engineer for a facility and looking for an outside party to conduct a study for me, I would personally want it to be performed by a P.E.. However, I did not know for sure if it is required?

Also, in the case that the answere to these questions varys by state law, where can this information be found?

Thanks in advance


This actually is a matter of an individual state's engineering licensing requirements. In IEEE 1584.1 ("Dot One") - IEEE Guide for the Specification of Scope and Deliverable Requirements for an Arc-Flash Hazard Calculation Study in Accordance with IEEE Std 1584™

We addressed this in 1584.1 with the following language:

The arc-flash study should be performed by, or under the direction of, a qualified person with the necessary
knowledge about power system analysis and arc-flash hazard analysis or experience in performing power
system analysis and arc-flash hazard analysis. It is recommended that engineers who are new to performing
the studies obtain peer or third party reviews from a more experienced engineer in this specific subject.
NOTE—Engineering licensing requirements of individual jurisdictions (states and/or provinces/nationalities) may
require the analysis to be performed by, or under the direction of, a registered professional engineer.


Many state engineering boards have exemptions for performing studies for your own facility.


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 Post subject: Re: What are necessary qualifications to perform an AFHS?
PostPosted: Tue Jan 26, 2016 7:14 am 
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Joined: Tue Oct 26, 2010 9:08 am
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Location: North Carolina
It's not just a matter of state law. Engineering license requirements are a matter of protection of the "public". That is if the results of what you are doing in terms of any engineering work affect the public such as working on "government" projects, or are offering engineering services for hire, a professional engineering license is required.

On the other hand if you are doing work internally for a company and it is essentially an "internal" matter, professional engineering licenses are not required at least by state law and few private companies actually require it for their own employees. It's kind of silly if it was and I'd never do it. Let's suppose for instance that you work for an engineering contracting firm and do an AFHS for a customer. In that case if something goes wrong then the engineering firm or the individual engineer is liable and typically their errors & omissions insurance covers the loss. And if I were working for an engineering firm I would never stamp any drawings with my personal stamp if at all possible because I'd want to shield myself behind the limited liability protection afforded to the firm (assuming that the business model is an LLC or corporation) so that I could not be sued personally.

As an employee though of a private company and something goes wrong, then the employer is obviously going to be liable for the incident. If again one stamped the drawings then you could be held personally liable and your employer could actually sue you, which would be an odd situation to be in because ultimately the same employer is approving work that you do, probably supplying information and resources, should be paying for errors & omissions insurance, and is otherwise deeply entangled in the work to the point where there is no practical way to maintain an air of independence and in which the ethics requirements of the engineering license itself are in jeopardy. So frankly just because of the nature of professional engineering licensure, any engineering studies that are stamped need to be truly independent and it sets up a more traditional contract arrangement rather than a master/servant (employee) relationship.


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 Post subject: Re: What are necessary qualifications to perform an AFHS?
PostPosted: Tue Jan 26, 2016 2:34 pm 

Joined: Fri Jan 22, 2016 7:40 am
Posts: 2
In reading your responses, I decided to ask the question elsewhere as well. I was told that in the state of KY, An Arc Flash Hazard study is considered the practice of engineering and a public safety issue, and therefore recquires licensure. It was also stated that there is no exemption for performing such studies for your own facility. I am somewhat confused as I have a few EE Contacts that I believe are performing studies at the facilities in which they are employed who do not have PE's.


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 Post subject: Re: What are necessary qualifications to perform an AFHS?
PostPosted: Thu Jan 28, 2016 5:46 pm 
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Joined: Tue Jan 13, 2009 5:00 pm
Posts: 542
http://www.lrc.ky.gov/statutes/statute.aspx?id=31420


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 Post subject: Re: What are necessary qualifications to perform an AFHS?
PostPosted: Fri Jan 29, 2016 11:47 am 
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You get into a strange quasi-jurisdictional situation too with any contract work. I've had two different experiences explained to me in two different situations. I'm putting these out here not to make any particular case but to point out issues I've had over the years with what the "proper" procedure is with regards to permits and licensing.

In case #1 in New Jersey, we started construction on a new truck scale out front of a very old plant (site was over 200 years old). The local Code officials got pretty worked up so I went down to their offices to see what the issue was and see what we could do to resolve it. The basic issue is that we didn't pull permits.

What is came down to is that their concern was that the county would question why they never inspected us. Granted I've NEVER pulled permits for any plant anywhere that wasn't a green field construction and I've gotten the same response from everyone I've ever discussed this with. What we agreed on is that they really didn't even WANT to inspect us and frankly I think they were afraid of the place. So I agreed to pull permits on any projects that were "road visible" as a courtesy and when we do an office building or some other similar commercial/residential system. We got along great after that and honestly the inspectors did find some things once in a while. In the end really I believe what we were doing was more of a public relations effort giving them a plant tour, showing them what we did and how we did it, and so forth.

The second case and granted this not a U.S. case, was with the official that was over licensing, permitting and Codes for the entire province of Saskatchewan. He was invited to a high level meeting with representatives from the U.S., and several provinces in Canada. We were interested in whether or not contractors needed licensing, whether or not our own people needed licensing, who is the "AHJ", and how and when to pull building permits. These are all roughly similar questions. His was of explaining it is that the entire purpose of the various permit rules is for protection of the public in some minimal way from incompetent contractors. They can't really enforce what you do with your "own property" once something is built and don't try. And as a practical matter it would be a struggle to define the difference between maintenance activities that clearly don't require pulling permits and construction activities that do. His opinion was that once the plant was built, it was the owner's problem in terms of dealing with it. Although he was very keen on ensuring that contractors were licensed again he stated pretty plainly that we could still contract with whoever we wanted. A lot of this came down to whether or not you put yourself out there as a company doing a certain kind of business or not.

As far as internal employees go again he felt that that becomes a contract dispute and not an issue of protecting the public. He stated that the employer already closely monitors their employees far closer than you can with a contractor so requiring licensing really doesn't make a lot of sense, especially when there is no "public policy" issue (it's all a private issue).

And as far as AHJ goes in this case he readily admitted that theoretically the Province is the AHJ in all matters. Internal operations are of course required to meet Provincial rules (Canadian CEC Part I, roughly equivalent to NEC). So even though the regulations still applied and needed to be followed, this would only ever become an issue if someone were hurt and the deficiencies showed up during an investigation by Canadian OH&S. So in truth the employer becomes a proxy AHJ...they have to inspect to ensure compliance or face fines during accident investigations or any other reason for an inspection/audit. But don't call the local Code inspector out to do it.

I'm not agreeing or disagreeing directly with what either code official had to say. I certainly paid attention and listened to their issues and only asked questions when I needed to clarify what our (working) relationship was going to be. What seems to be happening here but I can't put my finger on it is that at some point limitations on government encroachment are overriding the regulations but I can't tell you where that line exists.

Granted neither one has any bearing on the subject matter directly but it gives you at least some flavor of how the building trades and building permit departments see things.


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 Post subject: Re: What are necessary qualifications to perform an AFHS?
PostPosted: Mon Feb 01, 2016 7:29 am 

Joined: Fri Nov 06, 2015 1:05 am
Posts: 25
Location: Evansville IN
My personal belief is a PE shows a relationship with a professional organization with stringent qualifications. I have the highest respect for PE designation and the discipline it entails. From a qualification standpoint, I believe that many companies and individuals have the competency, qualifications and skills to perform these studies. I have read many articles and reports of equipment and building failures that have been reviewed by a PE or inspected by a PE. I have also read many reports where non-qualified and incompetent, non PE individuals have participated in the same type failures. I do understand the rigors of the PE testing and vetting process. I also understand the need to have a standard and how these fit into local regulation. My question I would pose back: Could a non PE individual perform a calculation correctly using the available methods and tools? I believe the answer will be “yes” Just a though.


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 Post subject: Re: What are necessary qualifications to perform an AFHS?
PostPosted: Mon Feb 01, 2016 8:09 am 
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Joined: Fri Apr 15, 2011 7:43 am
Posts: 177
Location: Colorado
Needing a PE or not is matter of law and circumstance. In general, if the "public" never enters your facility (occasional tours not included) you most likely do not need PE. If there is any question, you can hire a PE to do the work or possibly review your work.

The more important piece is being qualified. That includes knowledge (schooling/training) and experience. I am not judging you on either as I do not know you but I have been doing arc flash studies for 15 years and I run into situations that are difficult. I have several younger engineers that struggle at times. My suggestion, if possible, is for you to to do the majority of the work. Collect the data, build the model, run preliminary analysis but then hire a PE to "help" review.


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 Post subject: Re: What are necessary qualifications to perform an AFHS?
PostPosted: Tue Feb 02, 2016 4:27 pm 
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Joined: Tue Jan 13, 2009 5:00 pm
Posts: 542
engrick wrote:
Collect the data, build the model, run preliminary analysis but then hire a PE to "help" review.


Sounds like "plan stamping." Most regulations call for the engineer to have responsible charge for the project. Review afterward doesn't cut it.


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