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 Post subject: Who actually determines what is Industry Norms?
PostPosted: Fri Sep 19, 2008 6:32 pm 
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Is it possible that we can use this forum to make effective change in establishing industry norms?

Under the General Duty Clause all industries are required to adopted safety practices that are generally considered to be normal and typical within the industry. Since industries have not bothered to form cooperatives for the specific purpose of safety standards, industry has relied upon organizations like NFPA, IEEE, ANSI etc to create these standards which are then adopted by industry. The irony is that NFPA, IEEE, ANSI etc have no manufacturing expertise. They would say that their committees that establish the standards are expert from industries, which has merit. But they, as organizations, produce no commodity type products no do they oversee or perform real manufacturing.

Now, OSHA would say that failure to follow and implement proper safety programs that are considered norms within the industry could result in fines if there is an injury. OSHA would be quick to quote NFPA70E as an industry norm. I don't think we will ever be in a position to contradict that premise and prove that the industry norm does not follow NFPA. But I do think that a forum like this can fill in the voids.

Lets take the 2 second rule that we often discuss as being the longest clearing time to use in the IE formulas. The assumption is that an arc flash, especially from low voltage (600V and less) would not be sustained longer than 2 seconds, or if it were the Qualified person would be able to withdraw behind the arc flash boundary on or before the 2 seconds. No where does this 2 second assumption exist in NFPA70E or IEEE 1584. I do not know where it originated but generally agree with it (if someone knows its source please post details).

Now, if I post that I use this 2 seconds threshold in the analysis for my manufacturing plant, and I have to background to support that assumption, ie degreed EE, PE, 20 years petrochem, etc - then my assumption respresents a practive at my industrial site. Now, if 20 other engineers come to this forum, and formal state they also use the assumption, and that they have the educational background to evaluate it properly - we now have an 'Industry Norm'. I would state at that point, if the need arises, we have evidence to bring to OSHA that we are following the Industry Norm, even if NFPA and IEEE haven't acknowledged it yet. After all - WE ARE THE INDUSTRY - NFPA is a scientific/standards/safety/publishing company but they are NOT the Industry.

What say you?


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PostPosted: Sat Sep 20, 2008 7:10 am 
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2 Second "Rule"

Haze,

The 2 second "rule" is referenced in IEEE 1584 - Annex B, Page 76. Since it is not included in the main body of the "recommendations" of 1584 and not in NFPA 70E (that I have found), I have never considered it a rule, but only a suggestion. Seems it has suggested a lot of controversy. It even states that a person in a bucket may not be able to move away from the arc in 2 seconds. I have a problem with that statement because I have actually had to escape to the bottom of a bucket to avoid the flash with no injuries.

It seems that historically the standards have been adopted with no questions asked, but it appears that just maybe that time has passed. I do agree that we can go a long way toward that end with this forum.

We have all seen requirements in the preceeding codes that we have questioned, but never to this extent. The problem I have to date is that the 2 second cutoff is subjective and has yet to be tested in the courts, and we all can expect that it will be debated in that arena. After all, without protracted litigation the trial attorneys would not be able to eat.

If I have my numbers close I think previous NFPA 70 volumes sold about 100k copies. 70E sold over 400k copies. How about that for a cash cow!

There has been discussion in this forum about efforts to more closely align the NFPA and NESC. From what I am hearing though, the two bodies are still far apart, if not farther apart than they have ever been on these issues.

I am already seeing cases of utilities requiring 8 cal PPE just to enter a substation. These stations have the lowest live parts at 9 to 10 feet above ground level and anything below that is enclosed. They are merely concerned about liability since they already know it is not a safety issue.....all a result of confusion with the 2007 NESC. We already know that the tables have errors.

My and their (their being NESC) biggest problem with the NFPA approach to standards is that the data to support the recommendations does not exist. No doubt and sadly we all can refer to a worker who has been injured or killed from an arc flash or blast. After all, there is and always will be inherent risk associated with energized work. The question I think I must ask is whether or not the person just made a human error while following safety practices already in place, or violated existing safety rules in the process. In many cases proper procedures already in place were not followed.

It has been my experience over the last 30 years that electrocution injuries are more common with utility work than arc flash, and in most of those cases, safety practices already in place were not followed. Maybe that is why the NESC did not try to re-invent the wheel with arc flash rules.

As a private pilot I often also read articles or see incidents were proper judgement was not exercised. We in aviation refer to it as a chain of events. When reviewing an accident/incident and following the chain of events in reverse, we try to determine where the chain could and should have been broken. I think that is the case with any accident. Look at the chain of events, were proper safety procedures and judgement followed....the old cause and effect relationship.

I always try to teach safety as an attitude first! Without the proper attitude toward existing guidelines, how can we expect folks to accept more restrictive rules? Comments?

That's my nickels worth!
Alan


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PostPosted: Sat Sep 20, 2008 2:04 pm 
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Thanks Alan, I must have missed it but I'll check back in the Annex. The IEEE should not be excluded from the list of organizations out to make a buck. As a member I was able to buy the 30 page 1584 for $500. Then another $35 for the supplemental corrections. I don't get that, IEEE make mistakes in a document that you paid $500 for - and then has the gall to charge you for the corrections.

As for waiting for the lawyers to vet an outcome - thats the whole point. We, as the Industry determine the norms that the General Duty clause refers to. I am not sure what it would take, but I would say that if 10 manufacturing sites agree to a condition, we have established a norm. Its also not to say that you can't have a conflict between to norms. If one group says 2 secs and another says 4 - both can be correct. Just look at our beloved Art 130. We have one group of people that label to IEEE and have one PPE Level and another that follow the 70E PPE Matrix. So if the IEEE comes up with Level 2 but the 70E Task Matrix says Level 3 for that particular task - and there is an accident that results in injury - is the person conforming to IEEE wrong because they are using less PPE than 70E Matrix?

In essence we are forming our own collective, debating the subject, and arriving at an agreed conclusion. That sounds like a norm to me.


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PostPosted: Tue Sep 23, 2008 9:27 am 
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There seems to be some frustration and confusion about where things are going with arc flash standards. Let me give you a little history first so you can see how we got where we are. That helps explain where it is going.

Arc Flash has been around since the early days of electrical power systems. Some utilities used FR fabric, very few industrial and commercial companies did. Most wore safety glasses, gloves and non melting fabric. Arc flash was just accepted as an occupational risk. Many of us know people that lost out on that risk.

1982
In 1982 Ralph Lee presented a theoretical paper titled “The Other Electrical Hazard: Electrical Arc Blast Burns” This was about the Arc Flash Protection Boundary – how far back do you need to be so any burn injuries are either minor or not at all. No standards were in place yet – just theory.
- No method to calculate the incident energy either.

1995
NPFA 70E first began to recognize the Arc Flash Hazard. It was now part of a safety standard,

1998
In 1998, T.E. Doughty, T.E. Neal and H.L. Floyd wrote a paper “Predicting Incident Energy to Better Manage the Electric Arc Hazard on 600 V Power Distribution Systems” I know a few of these people – they are some of the top in the field! This paper gave us a method to predict Incident Energy. Incident energy is based on a lot of variables but short circuit current and protective device clearing times are the most important ones. This paper’s formulas were based on bolted short circuit current – no method existed for calculating the arcing short circuit current.

That was acceptable based on the structure of the formula BUT you can’t use bolted short circuit when evaluating a time current curve to see how quickly a device trips during an arc flash. Arcing current is less than bolted current and using the higher bolted current could indicate a clearing time that is too fast based on the time current curve. This is where the 38% rule came in. Research shows that at 480 Volts, arcing currents could be as low as 38% of bolted short circuit currents. In the absence of any method to calculate the arcing current, the clearing time was based on time current curves at 38% of the bolted short circuit current. Not perfect but 1998, it was as good as it gets.
- Still no calculation standard existed.

2000
NFPA had the Hazard Risk Tables based on the experience and opinion of some pretty knowledge people like Ray Jones.

2002
The IEEE 1584 Committee with a shoe string budget, blew a lot of stuff up to expand the calculations and published the IEEE Guide for Performing Arc Flash Calculations” It was an extension of the 1998 paper. This procedure now had a method to calculate the arcing current so you could more accurately predict the clearing time from a time current curve. This was a huge leap forward.

2004
NFPA 70E was revised in 2004. The conflict between IEEE and NFPA began. Initially NFPA and IEEE did not see eye to eye. IEEE had the research and NFPA had the safety standard. There were two methods to determine PPE, the 70E tables and the IEEE calculations. There was some conflict between the two BUT, the tables were as good as it got back then. The 1584 standard came out toward the very end of the 2004 NFPA 70E revision cycle to make much of an impact on it.

2004
The IEEE 1584 committee found that even though a lot was known about arc flash, the arcing current could still be less than the calculated value and more work was needed. The “2004 IEEE 1584a” version introduced the 85% of arcing current rule. This is where you take 100% of arcing current, look at the time current curve and calculate the incident energy based on the clearing time. Then you look at 85% of the arcing current (lower) to see if the clearing time increases which could create a higher incident energy. Which ever one is greater is the final answer.

Today
Since then, NFPA and IEEE have joined forces in an attempt to figure this all out. They are undertaking a massive research project to the tune of over $6 Million (not a shoe string budget!). They are using the top researchers on the planet to answer the questions that are still unresolved – i.e. blast, DC, toxic fumes and a whole lot more.

So now we have the question of timelines vs. completeness. It would be great if all this was done overnight. It will take quite a few years until we have all (?) the answers. It is difficult to publish one piece at a time because something we find out today might be disputed with the next thing that gets tested tomorrow - and to buy a revision costs $$$ something the committee has no input or control of.

For years I have used the simple analogy of seat belts. I’ve seen it quoted by someone in this forum. In the 1960’s cars did not have seat belts. Then we had front seat lap belts, then shoulder belts (that were awkward like in my first car) then air bags (that injured and killed in the early days) then three point restraint etc. etc. It took almost 40 years to get automobile “PPE” to where it is today. Lots of research, evolution, confusion, costs, mistakes. Hopefully it won’t take arc flash 40 years but it will take quite some time until it all shakes out.

Get Involved!
Are there companies on the committees looking our for their own interests? – yes. Are they intentionally trying to steer the standard to favor their product? I can’t speak for all standards but on the 1584 committee, believe it or not, it seems that the group as a whole is focused on getting it right and not steering it towards specific interests. It’s more about the represented companies trying to stay ahead of the evolving research by being part of it.

On the 70E side of the fence, those are propsols submitted by people in the industry – jump on board and help out!

Everyone reading this, especially if you are frustrated by it all, have something YOU can do. GET INVOLVED - we need everyone’s help. If you disagree with 70E articles and have a better idea, don’t grumble, instead submit a proposal for a change. If you need a sounding board, float the proposal in this forum first. Haze got that effort going quite well – thanks!.

This whole thing continues to evolve beginning with some great theoretical papers in the 1980’s, to testing and research in the 1990’s and up through now. It is far from perfect, it is far from finished but it is a work in progress and that makes it a little painful and confusing along the way. That’s why this forum was created – to get it out in the open.

_________________
Jim Phillips, P.E.
Brainfiller.com


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PostPosted: Tue Sep 23, 2008 4:53 pm 
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Excellent and educational summation of Arc Flash origins. Thanks Jim.
I know I sometimes come down hard on the NFPA, but thats probably because I have watched so many of my friends lose their job to foreign competition - and now I am losing mine. Manufacturing is the economic equalizer. It permits non-degreed people who want to work hard make a middle income living -something not easily done in the service industry. With my plant closing the Union is saying "hey, we'll do anything" Well its too late now. With OSHA we in industry had a recourse to regulation. But under the General Duty Clause we're at the whim of the Safety Organizations. I truely believe OSHA considered the effect on manufacturing and didn't desire to overburden the industry, and was good at finding the balance point. I blame NFPA in the sense that they don't recognize the potential damage they cause to industry with unwarranted safety guidelines, and not knowing where the goal has been met. Now, I am not saying that Arc Flash is unnecessary, there is tremendous value in Arc Flash. My displeasure is in the implementation and the complexity borne by industry. The research that IEEE did is fantastic and we need that. But what we don't need is to convey upon the average plant ESHA guy the same level of scientific research and ask him to duplicate it.

I am not one of those person that believes everything can be legislated. We can not stop every worksite accident. Well, we could if we pay welfare to every citizen and tell them not to come to work. Then we would just be left with the civil injuries in the home, boat, car, park, horseback, gym, etc. We need smart and simple guidelines that get the most bang for the buck and doesn't break the bank - the classic 80/20 rule. NFPA, in my opinon, is out of touch with the function they serve. Its not their money and they don't care about breaking the bank. Their result is improving to 83% and spending 99. I've seen a lot of electrical infrastructure in my 30 years. It doesn't vary very much. You know why we don't have fault currents greater than 65K? Because you can't find Switchgear and MCC's rated for more. Besides, who needs that low of an impedance in their supply transformers anyway - what purpose does it serve.

All the science is great. But rather than making every site perform a $50,000 fault current study and arc flash analysis - and then redo it in 5 years - which is where the 2009 code is taking us - why not just keep it simple. Use the $6MM IEEE research and formulas and just come up with a reasonable Task Matrix. But one that isn't limited with footnote and then forces engineering calculation to make sure the Table is suitable. And one that is about half the size of the present one. We don't have to be absolutely correct 100% of the time. There is tolerable error built in.

With a $6MM research budget we can only guess where the 2013 release is going. But I also have to ask - do we need it? Shouldn't we wait 10 years with existing Arc Flash regs and see what happens. What if in 2018 we look back as say, there were an average of 1.3 injuries per year over the last ten years, and that was from workers not properly wearing their arc flash. Do we then proceed to solve a problem that doesn't exist.

This is like the lobby groups in Washington. Somehow we need to break the financial motivation for the Safety Orgs to just keep pushing more and more regs on an industry that is in decline.


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PostPosted: Wed Sep 24, 2008 5:32 am 
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haze10 wrote:
Excellent and educational summation of Arc Flash origins. Thanks Jim.
I know I sometimes come down hard on the NFPA, but thats probably because I have watched so many of my friends lose their job to foreign competition - and now I am losing mine. Manufacturing is the economic equalizer. It permits non-degreed people who want to work hard make a middle income living -something not easily done in the service industry. With my plant closing the Union is saying "hey, we'll do anything" Well its too late now. With OSHA we in industry had a recourse to regulation. But under the General Duty Clause we're at the whim of the Safety Organizations. I truely believe OSHA considered the effect on manufacturing and didn't desire to overburden the industry, and was good at finding the balance point. I blame NFPA in the sense that they don't recognize the potential damage they cause to industry with unwarranted safety guidelines, and not knowing where the goal has been met. Now, I am not saying that Arc Flash is unnecessary, there is tremendous value in Arc Flash. My displeasure is in the implementation and the complexity borne by industry. The research that IEEE did is fantastic and we need that. But what we don't need is to convey upon the average plant ESHA guy the same level of scientific research and ask him to duplicate it.

I am not one of those person that believes everything can be legislated. We can not stop every worksite accident. Well, we could if we pay welfare to every citizen and tell them not to come to work. Then we would just be left with the civil injuries in the home, boat, car, park, horseback, gym, etc. We need smart and simple guidelines that get the most bang for the buck and doesn't break the bank - the classic 80/20 rule. NFPA, in my opinon, is out of touch with the function they serve. Its not their money and they don't care about breaking the bank. Their result is improving to 83% and spending 99. I've seen a lot of electrical infrastructure in my 30 years. It doesn't vary very much. You know why we don't have fault currents greater than 65K? Because you can't find Switchgear and MCC's rated for more. Besides, who needs that low of an impedance in their supply transformers anyway - what purpose does it serve.

All the science is great. But rather than making every site perform a $50,000 fault current study and arc flash analysis - and then redo it in 5 years - which is where the 2009 code is taking us - why not just keep it simple. Use the $6MM IEEE research and formulas and just come up with a reasonable Task Matrix. But one that isn't limited with footnote and then forces engineering calculation to make sure the Table is suitable. And one that is about half the size of the present one. We don't have to be absolutely correct 100% of the time. There is tolerable error built in.

With a $6MM research budget we can only guess where the 2013 release is going. But I also have to ask - do we need it? Shouldn't we wait 10 years with existing Arc Flash regs and see what happens. What if in 2018 we look back as say, there were an average of 1.3 injuries per year over the last ten years, and that was from workers not properly wearing their arc flash. Do we then proceed to solve a problem that doesn't exist.

This is like the lobby groups in Washington. Somehow we need to break the financial motivation for the Safety Orgs to just keep pushing more and more regs on an industry that is in decline.



Where are you located?


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PostPosted: Wed Sep 24, 2008 6:06 pm 
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I am in Rhode Island. A State that brings me even more frustration than NFPA. For the smallest State, we often can take pride in posting some of the nation's top statistics. For example:
RI is #2 in unemployment (now 8.5% and climbing)
RI is one of only two States that saw its population decline in 2007.
RI is the 7th highest tax State
RI is 2nd 'worst' in SAT scores (Mississippi had the worst but we are hoping to beat them this year.

I want to take a moment and reflect on some of my comments. I am NOT opposed to the NFPA. I am not opposed to OSHA. I never want to be the cause of an injury, and there is no job so important that proper safety precautions can not be met.

I believe that one of the great merits of this country is our reliance on 'checks and balances' in our government. The problem that I have is that NFPA is out to make a buck and maintains its cash flow, and we are talking big money. Once OSHA declared the General Duty Clause, and then backed away - they gave NFPA an open check. NFPA could now be the organization to decide what codes it felt most important, once it created the code it automatically became an Industry Norm (even if no industry was adopting it), it sold the books, it sold the training, and then not being satisfied with the monies made, it establishes its own release cycle. Gillette had this model when he began his razor blade company - give the razors away for free - but sell razor blades for years to come.

What we (or maybe just 'I' ) need to do is to start writing my Congressman. It is not NFPA that failed us, it is the Federal Government that granted them this unchecked authority. Only my Senators Reed and Whitehouse have never cared much about preserving industry. (they've been too busy trying to make RI #1).


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PostPosted: Thu Sep 25, 2008 1:21 pm 
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haze10 wrote:
I am in Rhode Island. A State that brings me even more frustration than NFPA. For the smallest State, we often can take pride in posting some of the nation's top statistics. For example:
RI is #2 in unemployment (now 8.5% and climbing)
RI is one of only two States that saw its population decline in 2007.
.



I feel your pain, I recently left Detroit,MI, which has the #1 unemployment rate and is the other state that had its population decline, automotive is killing that area, still have a house for sale up there.


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