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 Post subject: Deadline for instituting Arc Flash Protection Practices in our Organization
PostPosted: Wed May 23, 2012 11:23 am 
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Does anyone know of a deadline for instituting Arc Flash protection in our organizations? I have an idea it has to be implemented by the end of this year, but I'm not sure. Thank you anyone!

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PostPosted: Wed May 23, 2012 9:03 pm 
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phanderson wrote:
Does anyone know of a deadline for instituting Arc Flash protection in our organizations? I have an idea it has to be implemented by the end of this year, but I'm not sure. Thank you anyone!


NEC (regulatory requirement in all 50 states) required arc flash labels starting with the 2002 code edition. Sometimes these things disappear in a code cycle but it was reiterated in 2005. OSHA first issued fines for failing to protect against arc flash in 2006. The 2000 edition of 70E wasn't much of a help but the 2004 edition was pretty usable. So my best guess on what you may consider a deadline to be in compliance with the general duty clause was probably around 2005.


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PostPosted: Thu May 24, 2012 6:18 am 
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For US utilities, an arc hazard assessment was required by January 1, 2009 by NESC-2007.


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PostPosted: Thu May 24, 2012 7:31 am 
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The NEC requirement for Arc Flash labels have nothing to do with the NFPA70E labeling requirements.

OSHA fine for failing to protect workers is a given. OSHA points to NFPA70E as an industry accepted standard not as a specific document which must be followed. However imagine explaining before a judge and jury why your method, of determining appropriate PPE, is better than the consensus standard.


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PostPosted: Thu May 24, 2012 2:59 pm 
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JBD wrote:
The NEC requirement for Arc Flash labels have nothing to do with the NFPA70E labeling requirements.


OP asked about the "deadline" for implementing some kind of arc flash mitigation program. I responded that in areas that are covered by NEC Code (which is most of the U.S.), it was required starting whenever each state adopted NEC-2002 edition. OSHA has never clearly drawn a line in the sand but when they issued fines starting in 2006, it seems to me that it is pretty clear that the deadline was some time before 2006.

As to saying that NEC has nothing to do with 70E, I don't agree. NEC specifies that SOME label on certain types of equipment must be present indicating the presence of an arc flash hazard. NEC does not specify the content, only that a label must be present. An informational note attached to the Code points to 70E for guidance on this. You can of course substitute your own rules or substitute another Code such as IEC or IEEE (NESC for instance). Back in 2002, lots of folks were applying labels that said something like "Warning! Arc flash hazard present" but didn't give any guidance. This meets NEC. 70E is of course entirely voluntary and optional and a general sticker meets NEC even if it doesn't meet 70E, but then we run into the slippery slope argument of the "general duty" clause.


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PostPosted: Thu May 24, 2012 6:12 pm 
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PaulEngr wrote:
OP asked about the "deadline" for implementing some kind of arc flash mitigation program. I responded that in areas that are covered by NEC Code (which is most of the U.S.), it was required starting whenever each state adopted NEC-2002 edition. OSHA has never clearly drawn a line in the sand but when they issued fines starting in 2006, it seems to me that it is pretty clear that the deadline was some time before 2006.


The NEC is not a retro-active document.There is no NEC requirement to put arc flash warning labels on existing equipment. Installations which were installed prior to the adoption of the 2002 version are grandfathered in. There are still some areas of the country (i.e. Chicago) which are still on the 1999 edition of the NEC.

The deadline to protect your employees under the "General Duty" clause was the first day they worked for you.
For the most part, as soon as you are aware of a hazard, OSHA requires you to protect against it. The day you start asking questions about arc flash is the day you need to start addressing the issue of Electrical Safe Work Practices"


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PostPosted: Tue May 29, 2012 4:25 am 
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In my opinion, it was required when OSHA wrote 1910.132(d)... "the employer SHALL assess the workplace to determine if hazards are present, or LIKELY to be present... to determine appropriate PPE." (paraphrased) So, becoming aware of, or asking about arc flash, is irrelevant. General industry has had a mandate to ASSESS for decades.

OSHA issued citations associated with electrical injuries well before 2006 for:

1 - Failing to deenergize
2 - Failing to provide appropriate PPE
3 - Failing to train employees.

Today, they are issuing citations without an any incident; recordable or lost time.


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PostPosted: Fri Jun 01, 2012 9:22 am 
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jghrist wrote:
For US utilities, an arc hazard assessment was required by January 1, 2009 by NESC-2007.

Thank you!

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PostPosted: Fri Jun 01, 2012 9:23 am 
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viper57 wrote:
In my opinion, it was required when OSHA wrote 1910.132(d)... "the employer SHALL assess the workplace to determine if hazards are present, or LIKELY to be present... to determine appropriate PPE." (paraphrased) So, becoming aware of, or asking about arc flash, is irrelevant. General industry has had a mandate to ASSESS for decades.

OSHA issued citations associated with electrical injuries well before 2006 for:

1 - Failing to deenergize
2 - Failing to provide appropriate PPE
3 - Failing to train employees.

Today, they are issuing citations without an any incident; recordable or lost time.

Thank you for your reply

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PostPosted: Fri Jun 01, 2012 9:23 am 
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JBD wrote:
The NEC is not a retro-active document.There is no NEC requirement to put arc flash warning labels on existing equipment. Installations which were installed prior to the adoption of the 2002 version are grandfathered in. There are still some areas of the country (i.e. Chicago) which are still on the 1999 edition of the NEC.

The deadline to protect your employees under the "General Duty" clause was the first day they worked for you.
For the most part, as soon as you are aware of a hazard, OSHA requires you to protect against it. The day you start asking questions about arc flash is the day you need to start addressing the issue of Electrical Safe Work Practices"

Thank you for your reply.

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Priscilla Anderson :D


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PostPosted: Fri Jun 01, 2012 9:24 am 
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PaulEngr wrote:
OP asked about the "deadline" for implementing some kind of arc flash mitigation program. I responded that in areas that are covered by NEC Code (which is most of the U.S.), it was required starting whenever each state adopted NEC-2002 edition. OSHA has never clearly drawn a line in the sand but when they issued fines starting in 2006, it seems to me that it is pretty clear that the deadline was some time before 2006.

As to saying that NEC has nothing to do with 70E, I don't agree. NEC specifies that SOME label on certain types of equipment must be present indicating the presence of an arc flash hazard. NEC does not specify the content, only that a label must be present. An informational note attached to the Code points to 70E for guidance on this. You can of course substitute your own rules or substitute another Code such as IEC or IEEE (NESC for instance). Back in 2002, lots of folks were applying labels that said something like "Warning! Arc flash hazard present" but didn't give any guidance. This meets NEC. 70E is of course entirely voluntary and optional and a general sticker meets NEC even if it doesn't meet 70E, but then we run into the slippery slope argument of the "general duty" clause.

Thank you.

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Priscilla Anderson :D


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PostPosted: Fri Jun 01, 2012 9:25 am 
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JBD wrote:
The NEC requirement for Arc Flash labels have nothing to do with the NFPA70E labeling requirements.

OSHA fine for failing to protect workers is a given. OSHA points to NFPA70E as an industry accepted standard not as a specific document which must be followed. However imagine explaining before a judge and jury why your method, of determining appropriate PPE, is better than the consensus standard.

Thank you.

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PostPosted: Fri Jun 01, 2012 9:26 am 
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PaulEngr wrote:
NEC (regulatory requirement in all 50 states) required arc flash labels starting with the 2002 code edition. Sometimes these things disappear in a code cycle but it was reiterated in 2005. OSHA first issued fines for failing to protect against arc flash in 2006. The 2000 edition of 70E wasn't much of a help but the 2004 edition was pretty usable. So my best guess on what you may consider a deadline to be in compliance with the general duty clause was probably around 2005.

Thank you.

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PostPosted: Fri Jun 01, 2012 9:31 am 
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I appreciate everyone's response to my question - this is very good information. We are adding Arc Flash to our Electrical Safety Program, and have already begun having our staff wear FR shirts and pants, complying with HRC 2 ratings. The complaints are pouring in! So, I wanted to see if others had received a deadline for compliance, because we haven't, officially, but we are just working to get it all in place ASAP. These responses will help us in helping our staff understand that we are not just trying to make their life miserable! Thank you again.

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PostPosted: Sat Jun 02, 2012 3:12 am 
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phanderson wrote:
I appreciate everyone's response to my question - this is very good information. We are adding Arc Flash to our Electrical Safety Program, and have already begun having our staff wear FR shirts and pants, complying with HRC 2 ratings. The complaints are pouring in! So, I wanted to see if others had received a deadline for compliance, because we haven't, officially, but we are just working to get it all in place ASAP. These responses will help us in helping our staff understand that we are not just trying to make their life miserable! Thank you again.


Just shirts and pants doesn't do it. To meet H/RC 2 ratings, you must also wear all the other PPE required in the table. In an operation where there is already a significant fire/burn hazard (such as a steel mill, foundry, or oil refinery) it is a relatively simple transition because everyone is already wearing FR clothing. It is also relatively easy in an operation where uniforms are already required. However in all others, especially if you make the transition in summer, you'll hear a lot of complaints. In the operation where I work at now, we carry H/RC 2 coveralls (actually, 12 cal/cm^2). We only put them on when we are going to do work where we are going to be exposed to an arc flash hazard along with ALL of the other required PPE where the risk is 8 cal/cm^2 or less. If it is 8-40, then we upgrade to a 40 cal/cm^2 multilayer flash suit. Then we strip once we complete the task.


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