Arc Flash Labeling – What You Need to Know

There is often a lot of confusion about what is required for arc flash labeling compliance. Are labels even required? Who requires them? What equipment do they pertain to? What information should they contain? The questions can go on and on. My goal today is to clear up the confusion. I believe by the end of this article you will have a clear picture of where your facility stands currently and what it needs to do moving forward.

Note: We are simply talking about labeling compliance not to be confused with overall electrical safety compliance. For more on that click here.

Is Arc Flash Labeling Required?

The answer is yes. Arc Flash labeling requirements can be found in the National Electrical Code, Article 110.16 for new equipment, NFPA 70E-2009 Article 130.3(C) for existing equipment, and OSHA 1910.335(b)(1) for general safety hazards.

In addition ANSI Z535.4 provides standards for the look and type of warning labels in general.

What Equipment Should be Labeled?

According to NFPA 70 (National Electric Code), Electrical equipment that is likely to require examination or maintenance while energized should be marked with a clearly visible sign or label warning qualified persons of a potential arc flash hazard. Switchboards, panel boards, industrial control centers, meter socket enclosures, and motor control centers all present potential hazards and should be marked.

NFPA 70E specifies that equipment over 50 volts should be labeled.

In a nutshell, any electrical device with a nominal voltage > 50 volts that can be worked on in an energized state should contain an arc flash label. This also includes transfer switches, disconnects, enclosed circuit breakers, starters, contactors and transformers.

Is a Generic Warning Label Compliant?

The answer to this is no. A generic warning label is not compliant. Before 2009 a generic warning label would suffice, but NFPA 70E 2009 changed all that. There is now certain information that is required to be on arc flash labels. The 2012 NFPA 70E identifies three pieces of information that are required.

  1. At least one of the following:
    a. Available incident energy in cal/cm2 and the corresponding working distance.
    b. Minimum arc rating of clothing as tested for arc flash exposure.
    c. Required level of personal protective equipment (PPE) to work in an energized state.
  2. Nominal System Voltage
  3. Arc Flash boundaries, including
    a. Limited approach boundary
    b. Prohibited approach boundary (REMOVED from 2015 Standard)
    c. Restricted approach boundary
Label 1

As of 2009 this label is no longer compliant with 70E.

Label 2

NFPA-70E now requires field labels to show incident energy level or PPE.

Bottom Line

Additional information provided by Easy Power about arc flash labels in Arc Flash Hazard Labeling Do’s and Don’ts.

To summarize, arc flash labeling is not as simple as just placing a warning label on a piece of equipment and walking away. There are certain requirements for type of equipment along with detailed information about the severity of the hazard and approach boundaries. To get this type of information, an arc flash engineering study is necessary. Only then are we able to calculate the incident energy that exists at each device.

It also needs to be understood that simply meeting labeling standards does not mean that you are suddenly NFPA 70E compliant. Click here to see what NFPA 70E compliance means.

Thoughts on OSHA’s Top Ten Citations for 2014

The Occupational Safety and Health Administration (OSHA) recently issued its annual report highlighting the ten most frequently cited safety violations for the past year. Three of the top ten citations during Fiscal 2014 were related to electrical safety violations.

Citations relative to the lockout/tagout of energized equipment ranked sixth on the list. Failure to implement proper electrical wiring methods ranked eighth, while failure to comply with general electrical requirements ranked 10th.

The fact that electrical safety issues held three of the top ten spots is rather remarkable, given the common knowledge – even among non-electricians – of the potential dangers of working with electricity. It’s pretty clear that virtually every “average” homeowner knows that danger lurks within their main electrical panel or their home appliances. So it really should be no surprise to plant managers and those who work daily with electrical and electrically charged components that steps must be taken to protect workers. Unfortunately, far too many employers (and workers for that matter) simply don’t realize the risk, or they take an “It can’t happen to me” attitude and then pay a heavy price for their laxity.

Given the preponderance of violations in this area, it’s also no surprise that regardless of the violation, OSHA is not shy about holding employers responsible when an employee is injured – or in the worst case killed – while on the job.

In fact, OSHA routinely cites companies not only for failure to train employees in the proper safety procedures, but also – even in cases where training was provided – for their failure to ensure that employees are actually following those procedures. This clearly shows that training is not enough: Employers are obligated to hold their employees and temporary workers accountable to practice what they learn in training.

So, what must employers and their workers know before working in electrified environments? Here is our own Top Ten list:

  • Understand electrical accidents and arc flash incidents do, indeed, happen, they CAN happen to you, and the results can be catastrophic, tragic with strong financial consequences!
  • Employers must insist on safe work practices and support electrical safety programs rather than relying on a policy that is simply in place and ignored unless “the safety person” is watching.
  • Employees MUST be adequately trained so they understand AND USE proper safety procedures.
  • Contrary to popular belief, ignoring the issue or bending the rules to save money does not save money. It simply increases your risk of liability.
  • Employees must know that their employer will hold them accountable for ignoring or violating prescribed safety procedures.
  • Relying only on Personal Protective Equipment (PPE) – while a necessary and relatively easy first step – is not sufficient protection.
  • Failure to use a permit system signed off with the understanding energized work by true definition is not normally necessary or required.
  • Procedures must be in place to lockout and/or tagout machines or equipment to “prevent unexpected energization, startup or release of stored energy.” The “stored energy” component of this requirement is something many managers overlook or don’t understand: Oftentimes, even “de-energized” machines and equipment will hold a potent charge that must be released before maintenance is performed.
  • Periodic inspections of equipment are a vital element of the safety plan.
  • Failing to properly test equipment to ensure it operates as designed.

Mitchell & Lindsey has worked with companies in 33 states to develop and implement safety improvement plans. We can also help your organization. Our services include arc-flash analysis, safety training, compliance audits and more. Give us a call at 502-682-8491 or visit us at www.MitchellandLindsey.com.

See OSHA’s list of Top 10 Citations for 2014.

See our post about OSHA’s Top 10 for 2015: “David Letterman’s got nothing on OSHA’s Top 10

OSHA Fines Lax Employers More Than $800,000

Over the past few months, OSHA has taken strong action against employers who have ignored, dismissed or cut corners with regard to the safety of workers in their facilities. In the examples summarized below, the proposed fines totaled more than $800,000, or an average of $200,000 per company. In each case, some of the cited conditions, and a least a portion of the fines, were directly related to electrical safety violations.

Some of the hazards for which citations were issued may seem rather innocuous to many facility managers, but situations like those mentioned below – a leaky roof, failure to conduct regular and periodic inspections, and failure to lockout equipment for even routine maintenance – can lead to serious safety hazards and costly fines for any kind of business.

There is a clear lesson here for facility managers: Pay attention, even to issues that appear to be minor, because they can have catastrophic results. In addition, employers must realize and remember that they are responsible not only for having safety protocols but also for training and requiring that their employees follow those protocols. Cutting corners to save money is both dangerous and can be costly over the long term.

Mitchell & Lindsey helps employers throughout the United States avoid scenarios like these by providing workplace safety inspections – with a specialization in arc flash analysis. We also provide workplace safety training.

Here are summaries of four recent OSHA citations:

Central Transport, LLC

OSHA fined Central Transport, LLC in Billerica Massachusetts $330,000 for “knowing and repeated disregard for basic worker safeguards,” according to an OSHA news release. Employees at the company’s freight shipping terminal in Billerica were exposed to electrocution and other hazards, including falls, crushing and other injuries. The cited conditions put employees at risk of deadly or disabling injuries, according to OSHA officials, and the company failed to take corrective action in spite of previous citations for similar violations.

Among the electrical citations: The building’s roof leaked water on to the work floor where electrical cabinets and forklift battery chargers were located. As a result, employees stood in water while plugging in battery chargers, exposing them to possible electrocution.

Read the OSHA News Release

 

Colonna Shipyard, Inc.

OSHA inspectors found various safety hazards at Colonna’s Shipyard Inc., a ship repair facility in Norfolk, Virginia. In addition to falling hazards, inspectors found that, because of defective equipment, employees were exposed to a number of electrical hazards while welding. Having been previously cited for similar hazards in 2010, the company received four repeat citations, carrying an $85,000 penalty. A portion of the fine – $16,000 – was assessed for expecting workers to use damaged electrical equipment and unguarded machinery.

Read the OSHA News Release

 

Wagner’s LLC

Wagner, LLC, a bird food producer in Jericho, New York, was cited by OSHA after an employee suffered serious injuries while cleaning birdseed from an industrial mixing tank. The machine apparently turned on while the man was working on it, severely injuring his hand and arm.

The resulting OSHA investigation found that, “Wagner’s failed to lockout energy sources to protect the worker from contact with rotating machine parts and the machine turning on while he cleaned it. The company also failed to conduct periodic inspections of written protocols related to locking out machines and did not train workers on these procedures.”

OSHA stated that violations like these at manufacturing plants are among the most frequently cited by OSHA. Wagner’s was cited for three willful violations related to these hazards. “A willful violation is one committed with intentional, knowing or voluntary disregard for the law’s requirement, or with plain indifference to employee safety and health,” according to OSHA.

Read the OSHA News Release

 

D&D Manufacturing, Inc.

D&D Manufacturing Inc. of Plano, Texas was cited for 41 safety and health violations – including 36 deemed “serious violations,” according to an OSHA news release. “Workers were at risk of serious injuries because D&D Manufacturing failed to guard mechanical and hydraulic presses and to ensure machines were de-energized during maintenance,” according to OSHA’s area director in El Paso.

OSHA’s news release adds, “With a penalty of $177,300, the 36 serious violations were cited for failure to provide adequate machine guarding; properly inspect power presses; and utilize proper procedures to de-energize equipment during maintenance, including punch presses. The employer also failed to… provide proper maintenance on conductors with damaged insulation; and exposed workers to live electrical parts.

Read the OSHA News Release