Discussing the Safety and Efficiency of Today's Workplace and Workforce

Welcome to the sounding board for facility managers, maintenance directors, safety managers and operations executives with concerns and questions about workplace electrical safety and efficiency. This forum should open subjects and minds to understanding of OSHA, NFPA and common sence electrical management. And, in conjuntion, it will serve as a source of information on the latest facility management techniques for full operational efficiency.

Look for discussions about Arc Flash Analysis, developing Electrical Safety Programs, compliance issues, Infrared Inspections, Energy Audits, Employee Assessment, Lean Management in Maintenance and Facilities and where to find the help you need.

Welcome to the Journal! We welcome your contributions!

Wednesday, April 21, 2010

Compliance Issues Don't Go Out of Date!

This 1972 cartoon by J.N. Devin shows that not much has changed in the world of compliance. The issues around any facility are still there, and the safety of workers is paramount.

Let Martin Technical help you with your compliance issues and questions. Perhaps most importantly, we can provide Electrical Safety Program development assistance and Arc Flash Analysis for your plant. Check us out and keep the cartoonists away!

Friday, April 16, 2010

Maintenance Efficiency Addressed in an Audit

You can read more about the Martin Technical Maintenance Audit at this link. We'll address that more in the next few weeks. This is a key step in understanding your program and maximizing its efficiency!

This item appeared in Today's Facility Manager.

Wednesday, April 14, 2010

What to do Between Now and Your Arc Flash Analysis (Part III)

As mentioned, using the NFPA 70E 130.7 chart properly isn’t really a viable solution for either short term or long term. If a company wants to use the NFPA 70E 130.7 chart in a compliant way, they are running into the same problems as completing an arc flash analysis; time and money. So, in consideration of not being able to use the 130.7 chart to be compliant and having a gap in time before an arc flash analysis can be completed due to funding or other issues, many companies are left in limbo on what to do.


The following steps are suggestions to help protect your workers in the interim, get a program in place and start working towards completing an arc flash analysis:

1. Determine Hazardous Tasks Workers will do and Include in Documentation of Electrical Safety Plan

If you do not already have an electrical safety plan developed and documented, this should be done first. This plan will define how electrical systems are designed, maintained and managed including guiding both management and workers how to work on and around energized equipment in your plant or facility (see chart in Appendix for all information that should be included in your plan).

Part of this plan would include how workers should approach or work on energized equipment in absence of proper warning on the arc flash hazard category. A suggested plan would be as follows:

1. Using the NFPA 70E 130.7 charts, one can determine what combinations of voltage / equipment / tasks would require Cat 3 or 4 PPE based on the assumptions (see chart in Appendix). Based on this, the employer makes a determination if any of these tasks are something:

       A. Their workers are qualified to do, perform and want to continue doing

       B. Their workers are not qualified to do, perform or something that represents a risk that they do no want their workers exposed to and therefore, will outsource.

2. If the combination of voltage / equipment / task being performed is something that the customer will be doing internally, immediately invest in 1 - 2 sets of Cat 4 kit to handle those Cat 3 & 4 situations

3. If the combination of voltage / equipment / task being performed represents something that the employees do not do, are not qualified to do or represents a risk that the employer does not want employees taking, outsource those tasks to a qualified electrical contractor. From a liability standpoint, you should clearly advise the contractor that based off of the NFPA 70E 130.7 charts, this represents at least a category 3 or 4 hazard and they should take proper precautions.

2. Invest in Appropriate PPE

          1. Invest immediately in Cat 2 PPE*. After an arc flash analysis is done, the results typically show that the vast majority (and sometimes all) of the panels are rated Cat 0 – 2. Based on this outcome, employers typically end up putting all their workers in Cat 2 PPE as that covers all or nearly all the work they will be doing and is reasonable equipment to work in and purchase.

          2. Invest in Cat 4 PPE kits if the determination from step 1 is that the workers will be working on hazard categories 3 or 4 based on the NFPA 70E 130.7 Chart.

* The danger in this practice is that there are situations that under the assumptions made for the NFPA 70E 130.7 Chart will determine the risk hazard category as 0,1 or 2 when in reality, it could be a category 3, 4 or above category 4. A different than assumed short circuit current available or longer fault clearing can increase the hazard. This information can only be known, however, but doing an arc flash analysis.

          3. Set Approach Boundaries

NFPA 70E 130.3 (A) (1) defines the default arc flash boundary to be 4 feet for voltage levels between 50 volts and 600 volts the clearing time and the fault current do not exceed 100 KA cycles. Without doing an actual analysis, it’s virtually impossible for someone to determine if their equipment will not exceed 100 KA cycles and require a bigger approach boundary. In lieu of having the proper information to set the boundaries, a 4 foot boundary as a temporary means is suggested.

           4. Train Workers

1. Train those who would be working on or around energized equipment about Electrical Safety and Arc Flash (see Appendix for training outline). Part of this training includes specifics on PPE and tasks, including:

         Only perform the tasks allowed by NFPA 70E (i.e. troubleshooting) on energized circuits. Any other work on energized circuits requires a hot work permit which includes the results of an arc flash analysis and the defined arc flash protection boundary. It must be noted that even troubleshooting is not immune to arc flashes. Tasks as simple as voltage measurements and current probes can result in arc flashes.

A. How to properly identify equipment, voltages and tasks and understand their hazards

B. How to apply that knowledge to using the * NFPA 70E 130.7 charts, including the shortcomings of the chart

C. Crossover information from OSHA or local standards and the NFPA 70E 130.7 Chart for PPE

D. How to properly use the PPE equipment for tasks they are qualified to do and approved to do by their employer

E. How to properly recognize situations they need to avoid and outsource per directions of their employer

These suggestions are a short-term stop-gap approach to protecting your workers until an arc flash hazard analysis being completed, but it is in no way a permanent solution to protecting workers from electrical arc flash hazards nor is it considered compliant with OSHA or NFPA 70E.  Martin Technical maintains that nothing short of doing an arc flash analysis is properly warning workers of hazards or being in compliance with OSHA and NFPA 70E as it relates to arc flash hazards.

Wednesday, April 7, 2010

Considering an Arc Flash Analysis? Read on, and next week look for Part III in this series: "What to do Between Now and Completing an Arc Flash Analysis"

1. Perhaps the greatest gap in the NFPA 70E 130.7 Chart is what it doesn’t say. The chart does not discuss the greatest risk factor of all, an arc flash that is too severe for any PPE to protect people involved in the flash. Taking into consideration the information from arc flash studies, most companies will have 2% - 4% of their equipment that exceed the capability of PPE to protect their employees (i.e. greater than Category 4). The chart does not address this nor has any way to identify it. The only way to determine where these situations exist without performing the complete analysis.

2. The chart is conservative is many areas and will advise to use PPE that are 1 or even 2 categories above what may actually be required. In theory, it may seem like more is better, but in practical applications it is not.

      a. Investing in PPE for higher categories that you do not need can be more expensive than the cost savings of not doing an analysis for some companies.

      b. The higher up the chart one goes with the PPE, the more protective and also the more difficult and perhaps even dangerous to work in. A full Cat 4 PPE suit is not easy or comfortable to work in. Workers complain of the suits being hot, obstructing vision and losing dexterity. Loss of dexterity is a major concern for some workers because they are more likely to drop things such as tools or bolts, which could lead to an arc flash. Due to this, some workers have stated that they believe there is a higher chance of an arc flash happening when wearing Cat 4 PPE.

       c. If the PPE seems overly excessive, knowledgeable workers may question it and start making decisions based on their knowledge and experience and pay less attention to the chart.

3. To be compliant, warning labels must be applied to the equipment in order to warn workers of the hazard. Because the 130.7 chart is based in part off of tasks, the risk / hazard category can range from a “0” to a “4”, so it’s not possible to provide just one risk hazard category that identifies the proper PPE. There are the following options on the labels;

       a. Provide an arc flash warning label with information including the voltage and other information per NEC standards. This would require the workers to then reference and read the 130.7 chart, which leaves room for worker interpretation and errors.

       b. Provide a label that details the different tasks and hazard / risk categories for each piece of equipment along with the PPE required. The problem with this is that there is so much information that you might need 8” x 18” of uninterrupted label space to provide all the information, which isn’t very practical. Further, it still leaves the worker to read and interpret the information, leading to potential errors.

       c. Provide arc flash warning labels using only the highest category of risk hazard for any tasks for that piece of equipment. This would end up being a Cat 4 for most situations, meaning workers would be required to dress in a full Cat 4 PPE. As mentioned above, wearing a lot more PPE can cost a lot more, can be considered more likely to cause accidents and can lead workers to not believing the information on the labels and therefore, start making their own decisions.

4. Even with knowing the information on your electrical system to apply to the chart, the chart may still advise you to do an arc flash analysis for particular tasks or any for assumptions that do not fall within the parameters of the chart.

Costs & Time Involved in Gathering Information to Use the Chart.

If a company does not already have all the information to use the chart, they must go through an engineering analysis process that includes data collection, short circuit study and determination of fault clearing times. Then labels must be printed and applied to equipment to warn the workers. This process covers a big part of the cost of actually doing a proper arc flash, so it’s not a tremendous cost savings versus actually doing the analysis.

Further, for those situations that do not fit neatly into the 130.7 chart, an arc flash analysis is required anyways, making it the same cost as just staring out to do a full analysis.

Summary of Using the NFPA 70E Charts

Very few companies can actually use or do actually use the NFPA 70E 130.7 charts to be compliant for the following reasons:

• Without knowledge of short circuit current or fault clearing times, the charts can not be used.

• Gathering the information to use the charts can be nearly as expensive as just doing an arc flash analysis ( and can be even more if unnecessary PPE is purchased ).

• Even with the proper information, if the results don’t match the criteria or a task does not match the criteria, an arc flash analysis is required and the chart can not be used.

• The chart is conservative and may recommend PPE that really isn’t necessary leading to additional costs and potentially increasing the chance of an accident happening.

• The chart may still be inadequate by not identifying the most dangerous risk; greater than Cat 4.

• There are no good labeling options to warn workers.

When taking into consideration the time and cost to properly use the NFPA 70E 130.7 chart and knowing the shortcomings of the chart after implemented, it doesn’t make a whole lot of sense from either an investment standpoint or safety standpoint to choose to use the NFPA 70E 130.7 chart versus just doing an arc flash analysis.