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 Post subject: Arc Flash Labels
PostPosted: Mon Feb 22, 2016 4:50 pm 

Joined: Tue Dec 02, 2014 7:46 am
Posts: 14
Labels affixed on equipment created in 2007-8 does not list 'Hearing Protection' PPE.

70E issued in 2012 and 2015 requires 'Hearing Protection' as a part of PPE.

70E does not ask to replace a label.

Let me have your thoughts that what you will do in this scenario ? Do I need to make and affix new labels and scrap out existing labels - , hundreds of them Thank you


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 Post subject: Re: Arc Flash Labels
PostPosted: Tue Feb 23, 2016 5:47 am 
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Joined: Wed May 07, 2008 5:00 pm
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Location: Rutland, VT
In the NFPA 70E-2004 hearing protection is required for HRC 2, 3, & 4. In NFPA 70E-2009, hearing protection is listed for all categories. If my memory is correct, I remember seeing an IEEE paper that had 145 db recorded for an arc flash event with around 3 cal/cm2 IE. So can be a lot of noise.

Another item to consider since your labels are more than 5 years old is were they the result of a study? If so, the study is required to be reviewed and updated as needed, every 5 years so you could be past due.

NFPA 70E-2015 Article 130.5(D) on equipment labeling has some specific items that need to be on a label and your labels may not meet these. There is also this sentence to be considered "Where the review of the arc flash hazard risk assessment identifies a change that renders the label inaccurate, the label shall be updated.

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 Post subject: Re: Arc Flash Labels
PostPosted: Tue Feb 23, 2016 4:58 pm 
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My preference is NOT to list the PPE on the label - It is not required. Instead, have a note on the label referencing either the latest edition of NFPA 70E or referencing a separate document that specifies the required PPE. That way when changes like this occur or if company PPE practices change, you don't need to relabel, just change the document that is referenced.


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 Post subject: Re: Arc Flash Labels
PostPosted: Thu Feb 25, 2016 11:11 am 
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Joined: Wed Jun 10, 2009 5:00 pm
Posts: 267
Location: Toronto
SheelPandey wrote:
Labels affixed on equipment created in 2007-8 does not list 'Hearing Protection' PPE.

70E issued in 2012 and 2015 requires 'Hearing Protection' as a part of PPE.

70E does not ask to replace a label.

Let me have your thoughts that what you will do in this scenario ? Do I need to make and affix new labels and scrap out existing labels - , hundreds of them Thank you


I would place new labels on top of the existing labels instead of removing old labels. You can send us your arc flash data and we will generate and print the labels for you. Check please for more information. Below is a label layout you may consider for replacement.

Image

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Last edited by wbd on Thu Feb 25, 2016 12:31 pm, edited 1 time in total.
deleted link to commercial website


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 Post subject: Re: Arc Flash Labels
PostPosted: Tue Mar 01, 2016 1:58 pm 
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Joined: Tue Jan 19, 2010 2:35 pm
Posts: 152
I'd say it's time to revisit your study. It's nearly 10 years old, a lot could have changed in 10 years. If you had a study done, you should have gotten a report and possibly the work product (on disc) they used to produce the study. The vendor probably used a software program like SKM. I'd reach out to them (if they're still around) and ask them to quote updating your study. I'd also ask for a copy of the work product from the software. You won't be able to open the data, but someone with the same software should be able to. It's also possible one of the newer arc flash software programs could import the data. If so, they could use it as the basis to update your work. It's worth checking.

Something to seriously consider is a site specific PPE program. These are relatively simple set up, use and they generally eliminate lots of confusion for the people who have to wear PPE. If you want to find out more, there's information on this website as well as information in the 70E Standard. This might be a good chance to update your study and put a simple to use site specific PPE program into place.

Good luck,


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 Post subject: Re: Arc Flash Labels
PostPosted: Mon Mar 07, 2016 6:39 am 
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Joined: Tue Jul 01, 2014 8:40 am
Posts: 106
I have to agree with Jim's note above, there is no requirement to list PPE on the detailed warning labels. In fact you do not want to list the PPE. Firstly as an engineer you want to limit your liability. Also in listing the PPE, it points the worker to just put on PPE without thinking in many cases. We want the worker to do some form of risk assessment/ JHA based on the whatever task is being performed, in oppose to donning PPE and not really knowing why just because it is listed on a label


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 Post subject: Re: Arc Flash Labels
PostPosted: Mon Mar 07, 2016 7:47 am 
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Joined: Mon Jan 18, 2010 11:35 am
Posts: 544
Location: Wisconsin
I too vote for limiting information on labels.

There is almost no other industrial task that includes complete PPE specifics on their warning labels.
Why do we hold arc flash as being so different than hazardous materials?

Basic worker safety training - If you do not understand what is on the label, you are not qualified.


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 Post subject: Re: Arc Flash Labels
PostPosted: Tue Mar 08, 2016 7:59 am 
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I beg to differ on "changing all the labels". The 5 year cycle is a REVIEW. If it can be verified that nothing has changed, then nothing more needs to be done. I doubt very many clients will keep coming back if engineering companies insist on smacking them with charges for redoing the entire study from scratch every 5 years. That's ridiculous and definitely not what the standard requires.

An ideal review would look like this:
1. Review the code changes relative to the previous survey. Flag anything in the old survey that differs from current code and rework as needed. At this point there may even be some discussion as to what "correct" interpretation really means.
2. Review the high level parts of the study such as assumptions made and perhaps including a risk assessment vs. a hazard assessment. Include any accidents, near misses, or safety violations that have been documented over the past five years and review if the survey and/or other documents address any issues uncovered.
3. Review any known changes to the electrical system and the model to ensure that it is still accurate and up to date.
4. Review site maintenance procedures since these affect the results as well.
5. Request and review utility information as quite often their values change over time.
6. Do a sampling of the site survey. Choose about 1% of all components at every level and perform a site survey on those components. This needs to be truly random. Typically sites don't mess with the distribution level components. Most discrepancies are going to be found with items like adding or changing panelboards or MCC's. Adding any kind of structure to the survey is likely to miss something so a true random sampling prevents biases in the survey.

If the results are materially the same as the study from 5 years ago, the review is complete.

At this point the result of the review should be a list of recommendations and/or changes. The recommendations may include redoing the site survey, especially if step 6 uncovers a significant discrepancy. If not, then close out the review and wait another 5 years.

In terms of the sampling, the action taken at this point depends on what the discrepancies are, if any. It may mean recommendations to redo the survey in a specific area or it may mean surveying a specific component. For instance it would not be surprising in some plants to find that all the circuit breaker settings have been jacked up but it is far less likely to find all the cables replaced with different sizes. It is also not unusual to find bus plugs moved around and breaker sizes changed, or extra circuits added to panelboards or MCC's. This may warrant for example a visual inspection of modified or additional branch circuits which basically consists of checking every single distribution point looking for new or changed labels and overcurrent protection devices without concern for settings or cable sizes. This abbreviated survey can be done very quickly to locate modifications that have been done but not documented. Then the modified areas can be surveyed more thoroughly to update the model.


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