Kenneth Sellars wrote:
So a contractor who performs electrical repairs on homes/apartment complexes and works in these panels...knowing that the short circuit currents can sometimes be found to be higher than previously assumed, how does the contracting company ensure OSHA compliance? No scc levels posted, no arc flash labels required, thus no idea of the actual danger levels, etc., yet OSHA required the employer to ensure a safe working environment from known hazards...hmmmm....Feedback?
Have to be careful here. OSHA holds employers responsible for RECOGNIZED hazards and taking industry recognized steps for responding to them. Although there is some experimental data out there that suggests that there are arc flash hazards <240 VAC, it is not a hazard which is generally recognized by industry...ie, no standard documenting the size and scope of the hazard so it is not practical to do anything yet other than perhaps take some reasonable precautions such as standing away from the breaker while energizing/de-energizing it. If we turn the clock back 20 years ago although you could hardly say that arc flash was not a recognized hazard, the industry consensus standard for safety was just that...stand to one side when operating the breaker.
Stepping away from your situation, I have a 22.9 kV distribution system. There are only three available methods for addressing the hazard/risk. First is the tables in 70E. The second is to use ArcPro software. The third is to use the calculation in Annex D.1 or D.2 which results in grossly overly conservative values...3 times the values actually measured at 15 kV and it gets increasingly distorted as the voltage and/or current increase and is only valid for equipment configurations which don't address my major concern (indoor switchgear lineups). Given that only one of the three methods (70E tables) has anything close to an industry consensus behind it, that's what I use.
In the case of residential work, the industry consensus that is currently published in IEEE 1584 is that there is no appreciable arc flash hazard with transformers smaller than 125 kVA and <240 VAC. Even using the tables in 70E, you'd be looking at H/RC 0 for almost all cases. There is a caveat here...the size of the transformer for IEEE 1584, and the available fault current and interrupting time for 70E. You don't have enough information to even begin to verify either one. You may consider at best, looking at the BLS data to see if a similar injury has ever occurred to what you are considering.
So similar to the world above 15 kV, you have to make an evaluation of the available standards themselves and go with that. Hence the reason for adopting the tables in 70E as the best you can do given limited information. It's better than "stand to one side". If you try to do something like recommending something beyond a recognized industry consensus safety standard "just in case", you also put yourself out there defining the standard with no defensible standard to work from...a legally precarious position to be in because if something ever did happen, your judgement gets called directly into question as to whether or not you went far enough as opposed to leaving the lawyers to argue with the NPFA and a panel of industry experts which carry far more weight than a single engineer or safety manager or maintenance department manager.