Do you still find electrical equipment without an arc flash label (that should have one)

Yes
No

I would imagine the results will be all "Yes" votes. I see unlabeled equipment everywhere every day locations such as stores, gas stations etc.

I have never seen an arc flash label at my facility. Management feels that all of our equipment, control panels , and such fall into a category that does not require a label(globally).

Seems like a two part question. Have I seen panels without a label? Yes. Should they have one? Well, that's very debatable. So in the tradition of all good engineers, I'm going to speak out both sides of my mouth and answer both yes and no. I answered the poll question "no" just to ensure that the counter-argument gets some credit.

NEC 70-2014 110.16 requires equipment such as "switchboards, switchgear, panelboards, industrial control panels, meter socket enclosures, and" MCC's that are "likely to require examination, adjustment, servicing, or maintenance while energized" to have an arc flash label. Switchgear was added in 2014 and curiously, disconnects and starters still remain off the list. A grey area for instance is a motor peckerhead or a junction box with terminal strips, both of which may require routine examination. And as for the latter two, I don't think I have ever seen labels on them anywhere even if they meet the strict definition of 110.16. The Code uses the word "such as" so the list is a recommendation rather than absolute although many contractors and engineering firms treat it as an absolute requirement and will argue for hours that disconnects don't need labels even if it is fused or a circuit breaker, but the same groups fall all over themselves trying to label a small lighting panel with a 10 kVA transformer feeding it and waste a lot of my time figuring out what they are asking for. So on this basis alone I would have to answer "yes" every time.

Second, and this is where lots of plants are technically Code violations, there is a huge amount of equipment that in many plants they simply don't label it. As an example of where this is commonly practiced, lighting panels. We can probably make up dozens of stickers that read "<=1.2 cal/cm^2" and stick them on all the lighting panels but it truly serves no purpose to anyone to warn them of any hazard at all. In plants where FR clothing is already required such as refineries, steel mills, or foundries, generally the lower boundary on worker clothing (PPE in this case) moves up to 4 cal/cm^2 as "standard work wear". So many of these operations rather than going through the expense and time of maintaining a whole lot of labels that are basically providing no practical purpose whatsoever just go ahead and include the ratings in their plant policies that those panels are assumed to be 1.2 or 4 cal/cm^2, or less. On this basis I would argue that a huge amount of equipment that is not labelled even if it meets both the strict and functional definition in 110.16 should not be labelled as long as it is identified in some way, even in a procedure. This is far better than the generic label, "Warning! Arc flash hazard present" that I commonly see especially from a manufacturer to meet strict Code rules but skirt around having to do the study. Furthermore, having labels only on the equipment where arc flash exceeds standard work wear requirements for the site calls attention to the areas where safety is a concern compared to the "noise" that is present in electrical equipment today where panels may have up to 5 or 6 labels on them just to meet all the requirements in NEC. If most of the time there are no labels for arc flash then electricians will pay more attention to the few that do have them because it is something different in the work environment that is not encountered every day.

Nice response Paul.

Where we have completed studies we do install generic warning labels, even if the risk is minor and covered with plant base level PPE. The reason for this is driven by expectation that if a serious accident occurs, the safety inspectors will write up any bureaucratic infraction they can find, including those that seem to have no real world effect.


(Of course I do encounter the many sites without any labels, that should have them for higher exposure also, the cost of doing a study it is a tough sell )

OSHA states that a LOTO procedure has to be AVAILABLE. They even go so far as to state that quoting the regulation is sufficient. Some companies (e.g. GM) go so far as to develop a detailed LOTO plan for each piece of equipment and physically post it next to the equipment. Utilities in particular even go so far as to develop clearance procedures (essentially LOTO) sometimes per job.

I see no reason that 70E can't state the requirements and then state that it has to be available using the same wording that OSHA uses for LOTO. Then a label would be one specific method of achieving it but not necessary the only way to achieve it.

NEC requires a label, but then NEC requires a label for almost everything although in recent years they have come around to the idea that having documentation available is sufficient for some things that require engineering. If 70E changed to only requiring documentation then eventually NEC could come around to the same approach.

I've already stated arguments for why labelling "everything" might be a bad idea ("generic" labels cease to call attention). The counterargument is this. Prior to 2002 NEC when arc flash labels were required, engineering studies for arc flash weren't being done. After 2002 and especially when fines were issued in 2006, it was on the radar.