I've asked this before, but has anyone else tried the site specific PPE program? We've done site specific programs at about 20 different sites and have learned a bit I'd like to pass on.
First, I found it takes more time and effort to implement the program. For example, printing labels can become a challenge because you first must define the limits for each of the site specific levels, then determine if and when to prevent energized work. For example, do you want Level A or Level 1 to be between 0 and 8 calories or between 1.2 and 6 or 8 or 10 or 12 calories? Do you want there to be a Level B and C and D? Where do you set the calorie limits for each? Reaching those decisions can be difficult.
Then, you must explain decide how to implement or use the program. What the user must do at minimum to insure his people are properly using the site specific PPE. There are assumptions and expectations that the user must know about. For example, where and how does the end user plan to keep the PPE? Is he going to use separate lockers for Level A and B and C? How about bagging each? What about listing of the pieces in the containers? Who is responsible to insure the condition of each set of PPE? Are the employees assuming someone else will keep a status on the PPE? Are they still expected to inspect the PPE before each use? What about getting PPE mixed up? Who is responsible for what? All things I'd urge you to consider before going down this road.
Personally, I think Table H3b could be made a bit more user friendly and less confusing. For example, the question of when to wear a balaclava has been asked on the forum. I get that as well and it's always linked to high heat conditions as well as reasonableness. I think Table H3b could use an overhaul. May be add another Incident Energy Exposure column to the list. How about 1.2 to 5 or 6 calories? Or include language that tells the user to wear a balaclava if the arc flash boundary is more than X inches. I'm interested in hearing your comments and if you think Table H3b is useful?
Thanks

All of these things are required as soon as you use IEEE 1584. So why does it seem "hard"?

I was referring to my experience with getting decisions from clients about how many PPE levels they want and where to divide them up. I was also referring to insuring the client or user understood they have some specific responsibilities if they go with a site program.

I believe one of the goals with a site specific program is to reduce or eliminate decisions by the user. Decisions about if they are to use PPE or what PPE they use are eliminated. I believe the data show that some arc flash injuries can be traced to failure to provide the correct PPE - or the employee's failure to properly wear it. It seems reducing or better yet, eliminating decisions as to if, or what PPE to use gets us closer to working safely.

The old "2" (or 3) level system is about as simple as you get. You can make the "levels" decisions very easily without getting caught up in nuances.

Decision #1: Do you mandate FR PPE already or are you planning on doing so? This moves the bar for the "minimum" PPE from 1.2 to something higher. It's an easy decision for industries that already require FR PPE for other reasons. Speaking from the point of view of a service technician, we switched uniforms last summer and haven't looked back. The current FR PPE is pretty darned comfortable as daily wear and no reason to hold back unlike years past. It's just a cost question.

Decision #2: What's the highest single layer PPE you are going to stock? This is almost always above 8 ATPV and is usually in the range of 10-12 ATPV. It is pretty much technologically limited to <=12 ATPV. Whatever you pick this becomes one of the levels.

Decision #3: Do you want/need to have a level where a face should and/or a balaclava is not required? 70E in the tables allows this up to 4 cal/cm2 with face shield only. OSHA 1910.269 levels are somewhat different. Annex H is more restrictive than the tables. My advice: pick one. Obviously there is a divergence of opinions here. Just pick one that you can accept and move on. This decision "splits" the 1.2 to single layer PPE range if you use it.

Decision #4: What's the highest level of PPE you are going to stock/carry? Look at the arc flash study results sorting the incident energies from highest to lowest. There are going to be a very small (usually less than 1%) of areas where PPE is just not a practical solution. Walk these down and stop when working around the lack of PPE is not practical. That defines the upper level. Choose the upper level of PPE accordingly such as 40 or 100 ATPV.

Decision #5: Are you going to allow combinations such as wearing winter jackets and overalls over the top of the "regular" PPE? If so and it's a tested combination, this may give you an intermediate level between 10-12 and 40 cal/cm2.

After walking through these, calculate the number of busses or percentage that are covered in the various ranges and decide if it's even worth it to use one or more levels. A little adjustment/discussion takes care of this. It really helps if you can dump the entire study into a spreadsheet where playing "whatif" is easy to do.

It is possible/practical by the way to drive arc flash ratings down to 8 cal/cm2 or less almost across the board. There are a couple ESW papers discussing doing this with major operations such as paper mills, as long as thee is an interest in making the investment to make the required changes.

Paul, so you've done a few site specific PPE plans where you print labels and specify the exact PPE to wear?

I have been to plants that do this but I don't recommend it for two reasons. NFPA 70E has altered the list a couple times already for instance with getting rid of 2* and changing the face shield and balaclava requirements. Plus as the PPE supplier and/or PPE changes in house, you don't want to spend all your time running around reprinting labels. In addition when contractors come onto the site, their PPE requirements may not exactly match the site PPE.

So there are really only two options in my mind. The first is to simply put the incident energy on the label and be done with it. The second is to put that number on there but to "round up" to the plan specific PPE values as a way of "simplifying" things. That works as well as using your own levels but serves the dual purpose of supporting outside contractors or PPE changes/upgrades.

And as per my previous post, you CAN have a 4 or 5 level system but most plants only use 2 or 3 of them. It's really not that hard to figure out or memorize for anyone.

I wanted to clarify something I posted. With site specific plans, you could change the range values and leave the labeling the same. However, if you added another level or two, you'd probably need to change or add labels. I may have said this before, but I think one idea that makes the site plan better is it eliminates user choice. That's particularly important when it's hot. Give a person the option to use H3b, and you may fine he interpreted the table to mean he did not need to wear a balaclava. I can certainly appreciate doing that when it's hot, but the one time he does not wear it is when he's in arc flash and his face is burned.