OSHA Electrical Safety
When work must be performed on energized electric equipment that is capable of exposing employees to arc-flash hazards, does OSHA require the marking of the electric equipment to warn qualified persons of potential electric arc-flash hazards — i.e., as required by NFPA 70E?
OSHA has no specific requirement for such marking. A requirement to mark equipment with flash hazard warnings was not included in the 1981 Subpart S revision. However, paragraph (e) of §1910.303 requires employers to mark electrical equipment with descriptive markings, including the equipment's voltage, current, wattage, or other ratings as necessary. OSHA believes that this information, along with the training requirements for qualified persons, will provide employees the necessary information to protect themselves from arc-flash hazards.
Additionally, in §1910.335(b), OSHA requires employers to use alerting techniques (safety signs and tags, barricades, and attendants) . . . to warn and protect employees from hazards which could cause injury due to electric shock, burns or failure of electric equipment parts. Although these Subpart S electrical provisions do not specifically require that electric equipment be marked to warn qualified persons of arc-flash hazards, §1910.335(b)(1) requires the use of safety signs, safety symbols, or accident prevention tags to warn employees about electrical hazards (e.g., electric-arc-flash hazards) which may endanger them as required by §1910.145.
So the answer is no... but... yes arc flash labels are required.
OSHA does not specifically mention NFPA 70E, nor do they specifically require arc flash labels. Their answer states that other requirements in the OSHA standards will also cover the need for arc flash labels. But note that they reference §1910.335(b) which is a general requirement for electrical safety labeling. The best solution is to use NFPA 70E compliant arc flash labels. By complying with the NFPA 70E 2012 code for arc flash labeling, you'll also be in compliance with OSHA electrical labeling requirements. In addition, you'll also be in compliance with the NEC requirements for arc flash labeling. So NFPA 70E labels are the key to overall arc flash labeling compliance.
Richard S. Terrill, the Regional Administrator for OSHA in Seattle stated:
"Though OSHA does not, per se, enforce the NFPA standard, 2000 Edition OSHA considers NFPA standard a recognized industry practice. The employer is required to conduct an assessment in accordance with CFR 1910.132(d)(1). If an arc-flash is present, or likely to be present, then the employer must select and require employees to use the protective apparel. Employers who conduct the hazard/risk assessment, and select and require their employees to use protective clothing and other PPE appropriate for the task, as stated in the NFPA 70E® standard 2000 Edition, are deemed in compliance with the Hazard Assessment and Equipment Selection OSHA standard."
OSHA 29 CFR-1910 Subpart S
OSHA 29 CFR-1910 Subpart S regulates electrical safety, and states in part that "Safety related work practices shall be employed to prevent electric shock or other injuries resulting from either direct or indirect electrical contacts...." In general, employers have a number of responsibilities under this regulation:
- Creation and documentation of a facility electrical safety plan with defined responsibilities
- Documented training in electrical and arc-flash safety, for both electrical workers and any other workers who might be affected
- Identification and analysis of arc-flash hazards
- Provision of adequate personal protection equipment
- Placement of warning labels on equipment
- Provision of proper tools for safe electrical work.
- Verification, through annual inspections, that individual employees are complying with established safe work practices
OSHA emphasizes that no work should be performed on live electrical equipment above 50 V, except where (1) de-energizing equipment would cause a greater safety hazard; or (2) where de-energizing is not possible due to equipment design or the nature of the work being performed. Economic infeasibility of de-energizing is not an adequate excuse for performing work on energized equipment.
Once equipment has been de-energized, OSHA requires that appropriate lockout/tagout procedures are followed to ensure that the equipment is not accidentally re-energized. Violations of lockout/tagout procedures are consistently among the top ten sources of OSHA citations.
OSHA regulations do not, as a rule, establish specific safety practices (for instance, detailed rules for selecting PPE). Instead, relevant industry standards such as NFPA 70E are considered "how-to" guides for complying with the more general OSHA rules.
What Does NFPA 70E Require?
First, in order to know what the hazard level is, NFPA 70E requires that an arc flash analysis be conducted. This will determine the amount of energy that's available should an arc flash occur. This conducted. This will determine the amount of energy that's available should an arc flash occur. This information is then used to determine values that need to be on the arc flash label, such as the arc flash boundary distance as well as the type of PPE that is required to work within that boundary.
What Types of Equipment Need to Have NFPA 70E Compliant Labels?
NFPA 70E 2012 requires that the following types of electrical equipment, in locations other than dwellings, be marked with an arc flash warning label:
- Panel boards
- Industrial control panels
- Meter socket enclosures
- Motor control centers
What Information Needs to be on the Label?
NFPA 70E 2012 requires arc flash labels to include:
- At least one of the following:
- Available incident energy and the corresponding working distance
- Minimum arc rating of clothing
- Required level of PPE
- Highest Hazard/Risk category (HRC) for the equipment
- Nominal system voltage
- Arc flash boundary
Arc flash labeling is not an option. NFPA 70E compliant label must be used. NFPA 70E requires that labels be field applied. That means you must either pay the big fees of an arc flash consultant who will label your equipment, or you need a DuraLabel custom label printer. DuraLabel printers include database software (at no extra charge) for tracking and printing your arc flash labels. That makes keeping arc flash labeling records easy. With DuraLabel you get arc flash labels that are durable, easy to apply, and easy to make. Plus, your DuraLabel printer can be used for nearly every other labeling need in your facility. That delivers an incredible ROI.
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