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 Post subject: Suggestions to the NFPA70E Committee
PostPosted: Fri Jul 25, 2008 6:39 am 
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Since there are people on this forum who have direct or indirect input to the writers of Art 130, I was thinking lets start a thread to offer suggestions for future revisions. I'll start.

1) Drop the requirement for the individual permit. Its childish and too invasive into the individual policies of a corporation. Training and PPE should be enough. These guidelines should be minimum guidelines, not so specific that they try to run the company. Let individual companies decide for themselves whether or not they want a permit policy.

2) With regard to the Task/PPE Tables:
a) Change all the 2 cycle clearing times to something that would include all the larger molded case and switchgear breakers. In many cases these are just slightly over 2 cycles. I would suggest 6 cycles. There would not be a great deal of change to IE from 2 to 6 cycles and then the Table covers a far greater percentage of industry.

b) Eliminate any reference to PPE for switching operations that take place behind metal deadfronts. Art 130 starts by saying "Deciding to work on or near live parts...." By definition there are no live parts if you have a deadfront. Even requiring Level -1 is a hardship to many facilities. Uniforms and clothing today incorporates meltable synthetic fibers like polyester - janitors and operators whose job duties require them to switch on/off circuit breakers or disconnects (all with covers on) should not even be mentioned in Art 130 as these are not live parts. Again, this should be a minimalist approach. I seriously doubt we have sufficient arc flash injuries per year associated with switching with deadfronts to warrant a national intervention.

3) Create a single number for the Arc Flash Boundary or create a very simple table - but don't ask small business owners to calculate total fault current cycles to see if its under 300KA Cycles. This requires a fault current calculation and the ability to read a TC curve. Make the boundary 10 feet, but make it simple to define. Its easier for business to deal with maintaining simple distances than for electricians to know how to calculate fault current cycles.

I got several more, but will wait to see how this thread is accepted by the rest of you. Is this a good idea or bad idea?


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PostPosted: Fri Jul 25, 2008 11:07 am 
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haze10 wrote:
Since there are people on this forum who have direct or indirect input to the writers of Art 130, I was thinking lets start a thread to offer suggestions for future revisions. I'll start.


It dosent matter if I was the chairman of the commitee you still have to go through the process to recommend changes. The changes are all in for the 2009 edition, if you havent read it yet you should many of your questions are address already http://www.nfpa.org/assets/files/PDF/ROP/70E-A2008-ROP-Preprint.pdf

haze10 wrote:
1) Drop the requirement for the individual permit. Its childish and too invasive into the individual policies of a corporation. Training and PPE should be enough. These guidelines should be minimum guidelines, not so specific that they try to run the company. Let individual companies decide for themselves whether or not they want a permit policy.


The whole point of the EEWP is that it is never used, except in special circumstances where justification is necessary. 2000 arc flash victims a year going to burn centers in the US worlplaces proves that companies cannot make the right decisions themselves, they need to be told what to do.

haze10 wrote:
2) With regard to the Task/PPE Tables:
a) Change all the 2 cycle clearing times to something that would include all the larger molded case and switchgear breakers. In many cases these are just slightly over 2 cycles. I would suggest 6 cycles. There would not be a great deal of change to IE from 2 to 6 cycles and then the Table covers a far greater percentage of industry.


I think this may actually be something valid to put in for 2014 edition

haze10 wrote:
b) Eliminate any reference to PPE for switching operations that take place behind metal deadfronts. Art 130 starts by saying "Deciding to work on or near live parts...." By definition there are no live parts if you have a deadfront. Even requiring Level -1 is a hardship to many facilities. Uniforms and clothing today incorporates meltable synthetic fibers like polyester - janitors and operators whose job duties require them to switch on/off circuit breakers or disconnects (all with covers on) should not even be mentioned in Art 130 as these are not live parts. Again, this should be a minimalist approach. I seriously doubt we have sufficient arc flash injuries per year associated with switching with deadfronts to warrant a national intervention.


Arc rated switchgear is included in the 2009 tables and other parts of the standard, just because there are not exposed live parts does not mean there is not an arc flash hazard. My job requires me to respond to switchgear failures and I see metal clad gear blown apart on a regular basis.

haze10 wrote:
3) Create a single number for the Arc Flash Boundary or create a very simple table - but don't ask small business owners to calculate total fault current cycles to see if its under 300KA Cycles. This requires a fault current calculation and the ability to read a TC curve. Make the boundary 10 feet, but make it simple to define. Its easier for business to deal with maintaining simple distances than for electricians to know how to calculate fault current cycles.


There have been several submissions like this but none have passed because 10 feet is rarely sufficient on 480V switchgear.


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PostPosted: Fri Jul 25, 2008 11:50 am 
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Arc rated switchgear is included in the 2009 tables and other parts of the standard, just because there are not exposed live parts does not mean there is not an arc flash hazard. My job requires me to respond to switchgear failures and I see metal clad gear blown apart on a regular basis.

The arc flash protection boundary is defined as
Quote:
An approach limit at a distance from energized electrical equipment within which a person interacting with the equipment could receive a second degree burn if an electrical arc flash were to occur.

In doing an arc flash analysis, how does one determine if you can receive a second degree burn while reading a meter or operating a breaker on metalclad switchgear? Or opening a breaker on a panelboard with the cover intact? The theoretical and empirical equations were based on exposure to an arc without a metal barrier. They are not based on arc pressure blowing apart metalclad switchgear.


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PostPosted: Fri Jul 25, 2008 7:26 pm 
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I realize that the proper way to address the board is through written correspondence, but you miss the purpose of the thread. Its really too late to get any input to the 09 edition. But with contribution from others in industry, and especially from those on this forum, we can formulate and dissect future recommendations. Are we afraid of a friendly discussion and debate? Will the NFPA gods rein terror and doom if we dare?

I don't know all the in's and out's of why OSHA chooses to enforce specific guidelines. I remember an internet discussion years ago about a lawyer group opposed to Art 130 that claimed OSHA manipulated regarding the number of injuries. Apparently there was some court case years ago that determined that OSHA had to respresent some specific number of accidents per year. These are national laws that affect all US industry, and while all accidents are terrible, there needs to be some recognized statistical deficiency for the government to intervene. I don't remember the exact number but something like 4000/yr comes to mind. The claim was that there were NOT 4000 accidents as a direct result of arc flash and OSHA had to include categories like electricians falling from ladders, etc to get the volume they needed. If anyone has any info on these claims it would be interesting. Of course, the lawyer group was soliciting clients for their own financial gain, so I have no idea if the claims they were making was legit.

Again, to express solely my opinion, I think the permit process is naive and shows a lack of understanding for big industry. I've worked several chemical manufacturing sites, all 24/7/365. Sometimes planned shutdowns are three years apart, often one week per year. You never shutdown MCC banks or breaker distribution panels except in the administration buildings. Especially not for items like MCC that are designed to have buckets inserted into them without having to touch live parts, or I-line or QO panels where the breakers just snap in. The premise that these industries will now shutdown to accommodate an operation that most electrician consider perfectly acceptable, and idle the 30 man workforce in that area, and spend a day to recover from the interruption - is in my opinion - naive. In a complex with some 800 motors and 300 circuit break panels, someone is checking voltage, changing fuses, changing buckets, adding breakers, etc, - several times a day. Industry can and has administered respect to safety for decades. To say the government needs to do it, again in my opinion, is naive. Industry can and is quite responsible. Try to go on any site today, even small ones, where employees don't wear safety glasses or use hardhats. Look at MSDS data sheets, everyone I talk to knows what they are and that they have a right to see them.

I find, again in my opinion, that the NFPA contradicts itself by in one breath choiring the dangers of live and energized parts, and in the other claims PPE needs for deadfront operations. Please reference in Art 130 wear NFPA talks about the danger of deadfront exploding from normal operation. How do we explain to degreed engineers and licensed electricians, the need to don PPE to read a voltmeter on a panel board, but observe 10 year old children sitting on the lawn of the public library within 4 feet of the pad mount transformer. I'm try to be a reasonable person, but obviously the risk of deadfront explosions is not so statistically evident that it is recognized as a national danger. At least it hasn't made Ophra yet.

If this thead goes anywhere I would be happy to collect all the recommendations, and say in 9 months, send them in for the next review. IF no one else wants to contribute this thread will die, and I will keep my opinions to myself and file my own recommendations later. Had I started earlier in my Arc Flash study I would have sent in reviews for this edition. But as many in industry will attest, Arc Flash is still relatively new in industry and is only now catching on as a requirement. I think a lot of industry was just waiting hoping it would go away.


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PostPosted: Sat Jul 26, 2008 6:57 am 
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I hope you didnt take my post wrong at all, it is just that some of your ideas have already been oresented to the commitee several different in several different ways, and believe me the commitee knows more about how large manufacturing facillities operate than either one of us.

Heavy industrial is about all I do, steel mills, automotive plants, aircraft manufactures, etc..you have some very good points but you should also know that it is common place to do some tasks live that there is no reason that they need to be done that way, even in a 24/7 operation (Which is pretty rare these days, not many places still have production all 7 days on all 7 shifts).

As far as the permit goes, no reason why you need one for racking in a ircuit breaker or a MCC bucket, and if you still think you do you can always make a "Standing" EEWP for those routine tasks. You think I write an EEWP everyday for IR and Corona scanning?

You are right about many people wishing this all would go away, but i think we all know it is not.

Haze, you obviously have read and reread the 70E many times and know it inside and out, but the whole story isnt there, your points are valid but you are not the first one to bring them up. I highly recommend you get more involved in the process, attend some conferences where the 70E commitee is available and doing open discussions, IEEE, NETA, ect are all good avenues. Download and ead the ROP's for this cycle, it is a long read but you will learn more about the 70E and the thinking that goes behind it than you can from any online discussion.

I think your idea to openly discuss some ideas to submit for the next revision is a great idea, but please read the ROP's first, I dont have the time or energy to post the responses and reasons a previous proposal was shot down for every idea.

P.S. Dont believe everything you read on the internet.


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PostPosted: Sun Jul 27, 2008 11:46 am 
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Great Discussion!!
Your discussion in this particular thread was one of the goals of this forum - excellent. Hopefully even more people will get involved and discuss their views, concerns, interpretations etc. and this might help the standards evolve. A 70E "wish list" makes sense and this would be a great place to debate an idea before an attempt is made to submit a formal proposal. i.e. get people's reactions here first.

There are already a handful of members in this forum from the various committees such as IEEE 1584, NFPA 70E, NESC, Z462 and some global organizations so they can see how the standards are being received and where confusion, problems and concerns still exist. - YES some of this does get back to the committee!

Just like it was mentioned in this thread, a good place to begin is to review past ROP and ROCs of 70E to see what has been attempted before (get a feel for what does an does not get accepted) and submit proposals for changes if there is stong sentiment about an issue. I know a few of the members of 70E and one thing became very clear, if no one submits a change, 70E will not change so feel free to jump in and help with the process.

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PostPosted: Mon Aug 04, 2008 7:34 am 
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haze10 wrote:
Since there are people on this forum who have direct or indirect input to the writers of Art 130, I was thinking lets start a thread to offer suggestions for future revisions. I'll start.


Great Idea Haze! This would be a great place to test the waters before making a formal submittal to the 70E committee. Here is one that might stir things up.

As I understand, the 2009 edition of 70E requires the incident energy or PPE to be included on the label. I assume the PPE is from calculations like IEEE / computer programs otherwise if the 70E tables were used you would have several levels of PPE listed on the label. I heard nothing about approach limits or flash protection boundary being posted in the 2009 revision.

Here is an idea:

Since this requirement pretty much means someone has to perform a study, should the shock / approach limits and flash protection boundary be added to the label requirements in the next 70E revision? I'm not trying to make this more difficult but if the information is already known from the calculations and many computer programs make this available, why not add it to the label and be done with it.


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PostPosted: Mon Aug 04, 2008 11:28 am 
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LLB wrote:
Since this requirement pretty much means someone has to perform a study, should the shock / approach limits and flash protection boundary be added to the label requirements in the next 70E revision? I'm not trying to make this more difficult but if the information is already known from the calculations and many computer programs make this available, why not add it to the label and be done with it.


Well you dont need to do a study, you can use the tables to select the PPE. But, the LAB, RAB, and PAB should be mandatory, I think the arc flash boundary is a good idea but I think I saw a proposal similar to that for 2009 that was shot down because that would require a study.


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PostPosted: Tue Aug 19, 2008 6:48 pm 
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Unauthorized power of for profit professional groups.

Maintaining what I hope is a thought provoking thread, I would like to discuss what I believe is a growing trend in US industry.

There is something positive about the government getting involved in industry. At least in the US, the general government philosophy is that less regulation is best for a strong economy, so the government only imposes itself where there is a defined need, and then with a 'less is better' attitude.

The other positive about the government getting involved is that the legislation is vetted. There is typically years of discussion and intervention, so that what regulations finally pass, the whole package is one of compromise that all can live with. Plus, if the need is great, there is an avenue of regress through the courts.

This historically, has been the path of OSHA.

But what do we have now?

OSHA has taken the easy way out and has stopped passing laws. What they do now is enforce the non descriptive General Duty Clause. But here is the rub, the General Duty Clause is suppose to be a method to force companies to maintain a status quo with other companies of a similar nature to assure safety. A good example of this would be having an MOC (management of change) policy in a chemical plant. I think all major chemical plants will agree that MOCs are well entrenched in the industry and are considered norms.

But what do we have today? We have 'for profit' professional organizations determining the norm for industry, before industry itself even realizes the risk. These are the NFPA and IEEE as well as ASME and ISA organizations of the world. Even if we assume that some of the underlying programs, such as Arc Flash, are good - we also have to ask - where does it end? These are for profit organizations, they maintain their existence through sales. Whether or not industry reaches a point of saturation, where added safety measures results in a minimal decrease in injury - the organizations need to make a profit to pay salaries and maintain their financial strength. So what happens at this point - do the code organizations just say, " NO, WE DON'T NEED A NEW REVISION BECAUSE WE HAVE ACHIEVED OUR ORIGINAL GOAL". I don't think so. I think they just keep cranking out more and more refinements and restrictions. This keeps their sales constant as we all play catch up - but ultimately it hurts all US manufacturing. Now, do you think these organizations care about what effects they have on the US manufacturers. Of course they do, but its on par with trial lawyers. They care only in as much as they can extract revenue. This may be a bit harsh as I am sure intent of these organizations is good (just like trial lawyers), but they create cash machines that are self feeding. Like US civil laws, there is only addition to existing and rarely removal. So the requirements just grow and grow, until business owners look to the overseas locations to get them away from all the trials and tribulations of doing business in the US.

I realize I am coming down hard on these professional organizations. I don't mean to. I am a member of several of them. In general I have always felt that they do an excellent job of bringing standards and norms to our US industries. I still do, as I don't blame them for being driven to maintain their jobs and cash flow. But I do blame OSHA and the US government for allowing it to happen and taking the easy way out.

I always viewed manufacturing as the US economic equalizer. It gives opportunity for non-degreed workers, whose only qualifier is a willingness to work hard, to succeed in the American dream and afford a middle income life style. Yes, the service industry needs hotel clerks, waitresses, and delivery men - but the income just isn't there. We have already lost so much manufacturing in this country that I want to cry. But I must do it in silence for I can't find anyone else who cares. So let me ask a simple question - do you think US manufacturing would grind to a halt, or accident deaths sky rocket - if all present codes were frozen for 10 years?


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PostPosted: Wed Aug 20, 2008 6:57 am 
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Now THAT my friend, is a thought provoking post!

I think it is a delicate balance, having taught thousands of electrical safety courses to the largest companies in the US and Canada I would have to agree with your views. I am going to use the Automotive industry and the UAW as an example here but in no way do I mean to single them out, it is basically the same in all large manufacturing.

Look at our auto industry, these new standards are putting a huge financial burden on the big 3, training, PPE, arc flash studies at a time when they are losing billions. They have skilled trades making 6 figure incomes (With lots of OT) on many times a HS or GED education. When they went through training 20 yesrs ago, none of these standards existed, so what to do? The companies have great corperate ESWP's, in fact one of them has had about the same rules as the 70E BEFORE the 2000 70E was in effect, and the guy that developed them is (was) a commiee member, so the INTENT of the company is right, even without the 70E. The problem is, getting from a corperate level to the guy on the production floor that needs to get the line back up and running while there are 1000 assembly worker standing around (On the clock) doing nothing, he has pressures from the production supervisor and if he dosent do it, "someone else will" (I have heard this many times). This guy grew up riding bikes without helmets, in cars without seatbelts, and coming home "when the streetlights come on". This guy, regardless of what the 70E says, is going to replace that fuse in that live panel or reset that breaker, or T/S that circuit.

The change needs to come from the new generation of worker, it needs to be a culture change, problem there is the kids becoming adults now dont want manufacturing jobs, they want jobs where thye can express thier creative side and work on a computer and bluetooth headset.

Safety makes good business, the average cost of a survivable serious arc flash accident is $17,400,000 (Ontario hydro study from a few years ago), you can do alot of training and buy alot of PPE for that. If thee companies would police themselves, we wouldnt need the NFPA 70E, but they dont do it (Not very well at least). But you are right, there needs to be a line drawn in the sand, when is "risk" acceptable? Is it better to have a good paying job, with some risks involved, than flipping burgers? You gotta pay the rent, replacing that fuse, takingthe chance that an arc flash may occur, is much safer than even walking into the factory that guys dad worked in 50 years ago.

I just left Detroit because the big 3 is falling fast, if you dont work for one of them you work for a supplier or a vendor for them, when you hear 28,000 layoffs from GM, you can multiply that by 3 for the other jobs lost due to the trickle down effect, detriot skilled trades worker are willing to take that risk, better than losing your house when your plant closes.

Now, that said, the 70E does take this into account, they do address risk, and will so even more in the 2009, seems to me the 2009 is much more user friendly. OSHA will be adopting the 70E ESWP's and I bet they are scaled back, just like they were in 1981 (Based on the 1979 70E), to be more enforceable, OSHA needs to step up to the plate and find that fine line of how much to protect our workers, from acidents, and from losing thier job.


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PostPosted: Wed Aug 20, 2008 7:01 am 
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Let me add that right now , IEEE is spending $7M on arc flash research and one of the stated objectives is to "Provide practical safegaurds for employees"

I will have some invovement in this project and will keep the forum updated,


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PostPosted: Thu Aug 21, 2008 12:10 pm 
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You lost me!

haze10 wrote:
There is something positive about the government getting involved in industry. At least in the US, the general government philosophy is that less regulation is best for a strong economy, so the government only imposes itself where there is a defined need, and then with a 'less is better' attitude.


I couldn't read past that point, my eyes were tearing over and I was shaking from laughing so hard!! :eek:


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PostPosted: Wed Aug 27, 2008 6:05 pm 
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2009 Now exposed is not enough

Let me first state that I stole this thread from Zog. It was one of the points I wanted to raise on the 2009 edition and seeing his thread told me it was time.

In the 2009 edition of NFPA 70E, a new fine-print note will be added, which will state in part, The collective experience of the task group is that in most cases closed doors do not provide enough protection to eliminate the need for PPE for instances where the state of the equipment is known to readily change, i.e. doors open or closed, rack in or rack out.

One of the problems is that this is not adequately defined. If they are referring to racking in switch gear breakers then I might not have as much a problem with it. If however, they mean to include throwing a disconnect switch on a MCC bucket or Local disconnect, with doors closed - then I have a real problem.

First, as I stated before, we can see the NFPA moving to remedy problems where there is no statistical evidence of injury. And they get forced down upon industry under the all powerfull General Duty Clause. I would like the see the 'collective evidence' and doubt it would ever approach the criteria OSHA would need to pass it into 1910.

Here is what I see as the major problem to business. Lock out/ Tag Out is well entrenched in industry and has been for years. But lock out/tag out doesn't necessitate a Qualified person to throw a disconnect, especially with doors closed. In a chemical or petrochemical facility, every manufacturing person is trained in lockout, and every operator may perform lockouts.

Now the problem is that many manufacturers provide uniforms for their employees. None of the major uniform companies like Aramak want to provide FR clothing. For one thing, there is a reason polyester is used in fabric, and its not because its cheaper. Its because it helps the fabric maintain a degree of body, helps retards wrinkles and stains, and promotes long wear.

So now since we have almost a whole manufacturing plant who may be eligible to do lockout/tagout, we have to triple our uniform budget to supply FR clothing. Plus, FR clothing is hot. So now morale is down as we have a lot of uncomfortable employees.

We also are seeing that deadfront is not enough. When is it going to end. The committee is fabricating needs based upon their collective experience that don't respresent reality. I have 30 years in the petrochemical industry, my experience does not say this is warranted.

This is bad code, lets hope it gets eliminated or severely restricted to its context to a very limited number of tasks.


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PostPosted: Mon Sep 01, 2008 2:13 pm 
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Analysis versus Task Matrix Table.

130.3 Arc Flash Hazard Analysis of the proposed 2009 revision. Here we see the NFPA volunteering to spend money on behalf of the owner. It appears that the NFPA is now directing that an 'arc flash analysis be completed. Plus, a review of the analysis has to be completed every 5 years to look for changes in the electric distribution. A full analysis to determine fault current and incident energy values is going to run at least $10,000 for a single building manufacturing facility. For a multiple building campus it is probably around $40,000. Next, you can already see that they are going to be dictating the frequency of breaker maintenance, I'll lay money that is in the next revision.

But this is where I get confused. NFPA states that for those cases where detailed analysis calcs are not performed, the new Flash Protection boundary is 4.0 feet. but with the reduced value of 1667 amp seconds max.

If we now are forcing an engineering analysis, why is NFPA still providing the PPE/Task Matrix? The analysis will determine and Incident Energy value that is for all tasks, the NFPA Matrix has variable PPE levels depending on their interpretation of how risky the task is.

Is the 2009 Revision demanding an analysis, and if so, why even include a PPE/Task Matrix with assumptions of fault current and clearing times?

Is it either - or?


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PostPosted: Mon Sep 01, 2008 7:48 pm 
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My understanding is that using the tables and making labels based on the tables meets this requirement, but you need to do somewhat of an analysis in order to use the tables (To find out if you are within the limits)


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PostPosted: Tue Sep 02, 2008 10:24 am 
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The label is supposed to list the PPE required. You can't post the entire PPE/Task Matrix Table. So you have to then put something like,
" PPE Level: As per NFPA Table 130.7(C)(9)(A). If there are two optional paths, one being IEEE analysis and one being NFPA Task Matrix - they should state this.


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PostPosted: Mon Sep 08, 2008 7:33 am 
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What happened to routine?

In the 2004 guideline there is an exemption to the permit process for work that it considered routine, ie, a trained and qualified electrician who changes a fuse in a MCC. The proposed 2009 guideline does not mention it. Is that because its in the Handbook interpretations and will it be in the 2009 interpretation also?


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