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| Re-label with ONLY incident energy OR PPE Category? https://brainfiller.com/arcflashforum/viewtopic.php?f=33&t=3382 |
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| Author: | Jim Phillips (brainfiller) [ Sun Jun 29, 2014 3:40 pm ] |
| Post subject: | Re-label with ONLY incident energy OR PPE Category? |
The 2015 edition of NFPA 70E now includes language that prohibits having both the calculated incident energy AND PPE category listed together. Listing both is very common and preferred by many. Even the exception that states labels applied before September 30, 2011 refers to using one method or the other but not both. Here is this week's question. Do you plan to relabel your / your client's system using only incident energy or category but not both? - Yes - No |
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| Author: | L. Hankle [ Sun Jun 29, 2014 4:47 pm ] |
| Post subject: | Re: Re-label with ONLY incident energy OR PPE Category? |
This has got to be one of the more ridiculous changes to NFPA 70E. It goes back to the thread some time ago that if Category 2 is a minimum 8 calorie PPE then if you need 8 calorie PPE you should be able to call it Category 2. There were a few that stated they are not the same when it referred to "Hazard / Risk" so people called it PPE Category instead. Now Hazard/Risk is gone from the table and it is called PPE Category and they still contend you can't list both. What nonsense. |
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| Author: | PaulEngr [ Sun Jun 29, 2014 4:51 pm ] |
| Post subject: | Re: Re-label with ONLY incident energy OR PPE Category? |
I'm in agreement in principle...the idea that you either adopt the arc flash analysis method in 70E or you do your kwn, but not to mix them. The PPE part though is the same for either system. So I could call in "local PPE" 1-4 and be done. This rule made more sense when the idea is that it was a combination of hazard and risk but no more. |
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| Author: | Voltrael [ Sun Jun 29, 2014 7:38 pm ] |
| Post subject: | Re: Re-label with ONLY incident energy OR PPE Category? |
PaulEngr wrote: I'm in agreement in principle...the idea that you either adopt the arc flash analysis method in 70E or you do your kwn, but not to mix them. The PPE part though is the same for either system. So I could call in "local PPE" 1-4 and be done. This rule made more sense when the idea is that it was a combination of hazard and risk but no more. I've already modified the label I create to only show incident energy, as all our labeling comes straight from the arc flash study. Once the standard comes out, we may look at having a site specific labeled designation, as is allowed by the new code. |
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| Author: | jtinge [ Mon Jun 30, 2014 5:52 am ] |
| Post subject: | Re: Re-label with ONLY incident energy OR PPE Category? |
At our center several years ago, as we completed our arc flash study and prepared to install labels, we checked the report on proposals to check the pulse of the code making committee. We saw a strong push to prohibit having both IE and HRC on the labels. Since we had just completed the calculations and we felt that there was a high probabitity that proposal to prohibit both IE and HRE on the labels we be codified, we decided to just use the IE value and not the HRC rating. We also included the listing of required PPE on the labels. Our training requires that when the worker determines he needs to use PPE, he must use the PPE listed on the label and the PPE must have an ATPV equal to or greater than the IE listed on the label. My personal experience when I discuss arc flash labels and PPE selection with my collegues is that they incorrectely associate HRC as a PPE value and use that to select their PPE rating. They never gave much thought to the risk element and that it was only applicable to the task tables until I pointed it out to them. So if we had included both the IE value and HRC level on our labels, I would check to see if the HRC rating on the labels corresponded to the correct PPE level based on the IE level and revise only the labels of the ones that were not correct. Reviewing our master data base of calculations should make this an realively easy thing to do. I then would add guidance to our training to treat the HRC level on our labels as PPE levels and not to associate them with risk, since we include IE levels on our labels. I would point out any new labels we install would only include the IE value and not HRC or PPE level. As we make changes and update our system as part of the normal couse of business, we would replace the non-compliant labels within a reasonable amount of time, but knowing that workers would be able to select the correct PPE level during the interim. Fortunately for us, we correctely predicted the direction of the code before we printed labels and made the call early on not to include HRC on our labels. |
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| Author: | Luc [ Mon Jun 30, 2014 6:28 am ] |
| Post subject: | Re: Re-label with ONLY incident energy OR PPE Category? |
I can understand this a bit but then I would be guessing the NFPA’s thought process. Only reason I can see were this would make sense is to simplify the labels and cause less confusion. Either you state the PPE level, the worker does not need to know specific incident energy he just needs to know the level of PPE’s to wear. Or you print the incident energy and you school your workers so they know how to select PPE with a given incident energy. I might not give the common worker enough credits here but you read a lot off ‘painful’ errors when you read about arc flash incidents but here are a few things that come to my mind that could happen when you print both incident energy and PPE category: The worker sees PPE level 4 and energy 35 cal/cm2 but on another label he sees PPE level 4 and incident energy 28. Result is confusion unless workers are schooled in PPE categories and incident energy. The worker sees incident energy 9 and PPE cat 3 on the label and decides to wear cat 2 PPE’s because it is not much higher (this can technically also happen when you just print incident energy). There are also cases when I calculate 40 cal/cm2 in 2 different situations, one results in cat 4 the other results in NO PPE EXISTS. This also leads to confusion but do note that the 40cal/cm2 does need to be rounded up or something when you just print incident energy. |
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| Author: | Voltrael [ Mon Jun 30, 2014 7:16 am ] |
| Post subject: | Re: Re-label with ONLY incident energy OR PPE Category? |
Luc wrote: I can understand this a bit but then I would be guessing the NFPA’s thought process. Only reason I can see were this would make sense is to simplify the labels and cause less confusion. Either you state the PPE level, the worker does not need to know specific incident energy he just needs to know the level of PPE’s to wear. Or you print the incident energy and you school your workers so they know how to select PPE with a given incident energy. I might not give the common worker enough credits here but you read a lot off ‘painful’ errors when you read about arc flash incidents but here are a few things that come to my mind that could happen when you print both incident energy and PPE category: The worker sees PPE level 4 and energy 35 cal/cm2 but on another label he sees PPE level 4 and incident energy 28. Result is confusion unless workers are schooled in PPE categories and incident energy. The worker sees incident energy 9 and PPE cat 3 on the label and decides to wear cat 2 PPE’s because it is not much higher (this can technically also happen when you just print incident energy). There are also cases when I calculate 40 cal/cm2 in 2 different situations, one results in cat 4 the other results in NO PPE EXISTS. This also leads to confusion but do note that the 40cal/cm2 does need to be rounded up or something when you just print incident energy. Regarding your example of incident energy 9 and PPE cat 3, if a worker's equipment is all rated at least 9 cal, than there is no reason he shouldn't be able to wear that equipment, and he shouldn't have to wear a 25 cal blast suit. An intelligent worker should be aware of the rating of all of his "base equipment" and know what he can and can't do with it. |
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| Author: | JKlessig [ Mon Jun 30, 2014 8:20 am ] |
| Post subject: | Re: Re-label with ONLY incident energy OR PPE Category? |
The thought process that says "printing either one is "good" and provides "enough" information, but having both is "bad", completley eludes me. If having both leads to "confusion", doesn't that really imply that one (or both) are wrong to some degree? So, if you are going to print only one, which do you choose? |
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| Author: | Larry Stutts [ Mon Jun 30, 2014 9:27 am ] |
| Post subject: | Re: Re-label with ONLY incident energy OR PPE Category? |
JKlessig wrote: The thought process that says "printing either one is "good" and provides "enough" information, but having both is "bad", completely eludes me. If having both leads to "confusion", doesn't that really imply that one (or both) are wrong to some degree? So, if you are going to print only one, which do you choose? If I had to choose one, I would choose the Incident Energy. IE should be listed on PPE. You should be able to look at the label and at the PPE to tell if the PPE provides adequate protection. |
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| Author: | bvadams [ Mon Jun 30, 2014 10:35 am ] |
| Post subject: | Re: Re-label with ONLY incident energy OR PPE Category? |
From a practical standpoint, we have been recommending using PPE level/category for a while. There are two issues that I think come up when labeling with IE. 1. I have different types of arc rated pants and shirts. They are all over 8 cal/cm2, so I know that they are good for category 2, but different styles of pants and shirts have different ATPV ratings. Some of these list the ATPV on an external tag, but some of them just list HRC on the external tag. It would be difficult for me to remember the exact ATPV of each piece of clothing that I have, so if I wanted to know if my clothing was good for 8.5 cal/cm2, I would need to go someplace that I could take my clothes off and read the internal labels. Also my shirt may be OK for 8.5 cal/cm2 one day, but if I wear a different shirt the next day it may not be properly rated. It is much easier for me to remember that my stuff is good for cat 2. 2. From a labeling standpoint, is there a threshold you use for how much a label needs to change before you replace it? If something changes in the system and some of the IE values change by 0.1 cal/cm2, do you change the labels? In a large facility with frequent changes, that could be a lot of effort spent changing labels with very minor changes, but if your policy is that the PPE has to be rated for the listed IE then 0.1 cal/cm2 could change what PPE is required. A change of 0.1 cal/cm2 can result in a level/category change, but only a small number of labels that are right at a level/category threshold are effected rather than every label in the plant. I would be very interested in hearing how people that use IE on their labels handle small changes and relabeling. |
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| Author: | Felix Nepveux [ Mon Jun 30, 2014 10:49 am ] |
| Post subject: | Re: Re-label with ONLY incident energy OR PPE Category? |
Every improvement of 70E is worse than the earlier version. The statements about using either the numeric values of cal/cm2 or PPE category do not plainly state what appears to be the intent of the panel. After listening to 3 panel members I believe they are saying that the arc level numbers come from a calculation, and if a category is used then it MUST HAVE come from the table method. Listing a category is a way to show the hazard level only when the tables have been used. Using numbers of cal/cm2 is a statement that a calculation was performed. You cannot use numbers and categories together because you cannot mix the methods used to determine PPE requirements, and the use of a category means you used the tables. They then say that if you have PPE rated by category you can convert category to the range of cal/cm2 and go ahead and use the PPE because everyone knows the ranges for each category. Also, if you find an arc level of 8.1 cal.cm2 you can wear PPE rated for 12 cal/cm2. If you use the table method you will probably be in a cat 3 or 4 suit. If you convert cal/cm2 to category numbers, a no-no, you also are forced to the cat 3 or 4 suit. Use the numbers. |
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| Author: | Roger [ Mon Jun 30, 2014 11:42 am ] |
| Post subject: | Re: Re-label with ONLY incident energy OR PPE Category? |
I think I finally understand what this tension about having labels that have both incident energy and category on it is all about. I ask you to bear with me as I have struggled with this a long time in need to see it simply expressed. I hope I haven't over simplified it. Correct me if I'm in error. In the past, we have been in the habit of assigning the category by virtue of its incident energy: if it is less than 1.2 cal/cm2 = cat 0; 1.2 to 4 cal/cm2 = cat 1; etc. the problem is that the category is meant to represent assessment of both hazard and risk, developed through strict parameter limitations. When we assign a category by solely using incident energy analysis, we are giving a wrong impression that the risk has been assessed. Presenting incident energy and category together gives a false impressionto the worker because the risk cannot be properly determined except that it is assessed task by task. On the other hand, a label with the incident energy on it with no category tells the worker the level of hazard that he/she is facing but leaves the assessment of the risk in the worker's responsibility based upon the task being performed. |
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| Author: | bvadams [ Mon Jun 30, 2014 1:18 pm ] |
| Post subject: | Re: Re-label with ONLY incident energy OR PPE Category? |
Roger wrote: the problem is that the category is meant to represent assessment of both hazard and risk, developed through strict parameter limitations. The category listed on the label does not represent the assessment of both hazard and risk. If you use the tables, your only real option for the labels is to show the, "highest Hazard/Risk Category (HRC) for the equipment". So, the category shown on the table is for the highest risk and any reduction in PPE based on a risk assessment must still be determined. The real benefit of the category system is that it provides a simple way to refer to the PPE requirements listed in table 130.7(C)(16). If the PPE listed under HRC 2 provides good protection for equipment with IE between 4 and 8 when using the tables, why isn't it good for equipment with IE between 4 and 8 that was calculated? |
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| Author: | Larry Stutts [ Mon Jun 30, 2014 1:46 pm ] |
| Post subject: | Re: Re-label with ONLY incident energy OR PPE Category? |
bvadams wrote: Roger wrote: the problem is that the category is meant to represent assessment of both hazard and risk, developed through strict parameter limitations. The category listed on the label does not represent the assessment of both hazard and risk. If you use the tables, your only real option for the labels is to show the, "highest Hazard/Risk Category (HRC) for the equipment". So, the category shown on the table is for the highest risk and any reduction in PPE based on a risk assessment must still be determined. The real benefit of the category system is that it provides a simple way to refer to the PPE requirements listed in table 130.7(C)(16). If the PPE listed under HRC 2 provides good protection for equipment with IE between 4 and 8 when using the tables, why isn't it good for equipment with IE between 4 and 8 that was calculated? Good point. As I see it, incident energy is incident energy. The real danger comes from the amount of time it takes to dissipate that energy. So if the label shows 15 cal/cm2 whether it is calculated or taken from the table, it does not matter. If you have a tA of .5 seconds you can mitigate the cal/cm2 by fusing to force a shorter tA and a lower cal/cm2. I've edited this thing 3 times - I have a point in there somewhere. |
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| Author: | william doss [ Tue Jul 01, 2014 12:45 am ] |
| Post subject: | Re: Re-label with ONLY incident energy OR PPE Category? |
Well, Our Company has well over 2500 pieces of equipment on one site. I am happy with just getting labels on new equipment. Our policy has recently been updated to reflect the current standard. I don’t think it was such a bad idea but for those that understand hazard versus protection, the standard clearly states you must show what the hazard is and incident energy is a quantitative expression of a hazard. Yes change isn’t always great but i don’t see this as a big issue. We will eventually have a contractor supply us the proper labels as we upgrade, move or install new equipment. I think we will struggle with getting all existing equipment labels changed. |
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| Author: | Jim Phillips (brainfiller) [ Tue Jul 01, 2014 2:45 am ] |
| Post subject: | Re: Re-label with ONLY incident energy OR PPE Category? |
Great conversation. Here are a few more points to consider. The "decoupling" of incident energy and PPE categories has two more pieces of information. There has been an attempt to decouple/unlink incident energy from Hazard/Risk tables for years and for good reason as many pointed out here. People that still wanted to use a category number simply began to call it PPE categories instead of H/R categories The 2015 Edition of NFPA 70E does away with H/R categories and does away with the risk in the tables and now calls them PPE categories too. The categories are based on equipment. No task or risk. And.... PPE categories are now the target that can not be linked to incident energy. The old argument saying you can't link the to H/R categories is no longer valid since the tables are no long er H/R based. Here is the BIG one. Several years ago, this was discussed in another thread prior to the 2012 Edition of NFPA 70E. Once again the language was going to be Incident Energy OR Category. Then I saw a draft of the 2012 edition and noted for the first time it focused on 12 cal/cm2 protection 12 cal/cm2 does not fit the traditional Category 1=4 cal/cm2, Category 2 = 8 cal/cm2 etc. etc. 12 cal/cm2 has a rating better than 8 cal/cm2 but still has to be listed as Category 2. i.e. no commercial advantage for 12 cal/cm2 if categories are used. I have discussed this with a few well placed people and it seems this could be the actual reason for the decoupling. When I raised this issue prior to the 2012 edition being adopted, the language was changed at the last minute to "select at least one...." I thought the additional information might be interesting for everyone. |
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| Author: | arcad [ Tue Jul 08, 2014 12:17 pm ] |
| Post subject: | Re: Re-label with ONLY incident energy OR PPE Category? |
Unfortunately, re-labeling with ONLY incident energy OR PPE Category to meet the new NFPA 70E year 2015 edition requirement does not resolve the inherent problem with NFPA 70E methodology. The methodology is based on the amount energy delivered without regard to how fast the energy was delivered. The problem was concisely summarized by Allice Stole, the pioneer in arc flash research and testings in [1]: Quote: "Serious misconceptions have crept into this field of research through adoption of rule-of-thumb terminology which has lost its identity as such and become accepted as fact. A glaring example of this process is the 'critical thermal load.' This quantity is defined as the total energy delivered in any given exposure required to produce some given endpoint such as a blister. Mathematically it is the product of the flux and exposure time for a shaped pulse. Implicit in this treatment is the assumption that thermal injury is a function of dosage as in ionizing radiation, so that the process obeys the 'law of reciprocity,' i.e., that equal injury is produced by equal doses. On the contrary, a very large amount of energy delivered over a greatly extended time produces no injury at all while the same 'dose' delivered instantaneously may totally destroy the skin. Conversely, measurements of doses which produce the same damage over even a narrow range of intensities of radiation show that the 'law of reciprocity' fails, for the doses are not equal." 1. A.Stoll, "Heat Transfer in Biotechnology", Advances in Heat Transfer, v.4. Academic Press. 1967 The above observation can also be applied to the existing PPE classification. For example, the 4 cal/cm2 PPE rating has no explicit indication about the time the PPE was exposed to the rated energy during tests before the PPE rating was awarded. That would not be a problem if the PPE was charged with and withstanded the energy it is rated to within 0.01 seconds (the minimum arc duration for IE calculations utilized in the industry). Classifying PPE in cal/cm2 however warrants only that the clothing system is capable to withstand energy it is rated to when the energy is delivered at slow enough rate (over the time equal to or exceeding the PPE test time). The very same PPE may not withstand a fraction of energy it is rated to when the energy is delivered fast enough. Likewise, a car rated speed is measured in miles per hour, and not in miles. That is to say, the car designed to drive at 100 miles per hour may not be capable to drive 100 miles per minute but would very well do 100 miles per day. |
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| Author: | Leonard [ Tue Jul 08, 2014 12:36 pm ] |
| Post subject: | Re: Re-label with ONLY incident energy OR PPE Category? |
I have always associated the HRC or PPE levels with the "Task Table Method" in oppose to an AFHA. With this being the case the HRC method is based on assumptions- short circuit current, clearing times. If the worker sees for example HRC or PPE level 2 on the label and then refers to the tables for selection of PPE, is this not cross engineering? As with the HRC or table method we are considering the assumptions, whereas with the AFHA the short circuit current and clearing times are supposedly known |
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| Author: | FFoote [ Thu Jul 10, 2014 7:35 am ] |
| Post subject: | Re: Re-label with ONLY incident energy OR PPE Category? |
So given the standard allows the IE to be printed on the label and a site specific level of PPE wouldn't it still be allowable to have the PPE level/category ("listed in the electrical safety program") for the facility and the IE on the label? |
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