Companies looking to save some money can avoid arc flash surveys. Seriously. Well, kinda anyway. In a tongue-firmly-in-cheek article, Dave Carpenter writes about the two ways arc flash surveys are not required:
“Exceptions” in NFPA 130.3, for those of you who may not have found this “Magic” way of avoiding having and arc flash analysis, here are the basic details.
- Exception #1- If your electrical system is so small it doesn’t have enough wallop to hurt someone, and then you don’t have to do an arc flash analysis.
- Exception #2- If you put on a whole bunch of PPE every time you work on something, then you don’t have to do an arc flash analysis.
How about that! Finally a way around the Arc Flash Survey debacle!
In the past few years, Carpenter has encountered people charged (pun intended) with safety programs or those who are acting as safety managers. He doesn’t take issue with their ability to read the NFPA, but he is concerned with their inability to grasp their job: providing safe work environments for workers in their facility. Carpenter believes most of these “managers” are simply looking for ways to save the company money. However, by following the lead of these individuals, the companies find themselves in trouble almost every time. Two horrible examples are the BP oil rig explosion in the Gulf of Mexico and the people who lost their lives deep in Virginia mines.
Let’s take the Electrical Safety issues for instance. Recently, a large organization was in the process of complying with OSHA’s requirements for electrical safety based on OSHA 1910.333. Those being to provide the “Proper” PPE for workers charged with repairing and maintaining electrical systems and equipment in their facilities. In the midst of the implementation of proper Arc Flash Surveys, or Arc Flash Analysis as some call it, a young lady was hired as the new safety person from a another company (after you read this you may figure out why the other company let her go). This new person was “Dead” set on stopping the entire process… I suppose to save money… and asserted that the Arc Flash Analysis was not needed. She was proud to announce that she had found a “Magic Loophole” in the NFPA requirements called on by OSHA as the “Industry Consensus” to provide a safe electrical work environment. She had found the two big “Exceptions.”
The exceptions? The two I listed above. Carpenter’s solution?
While the exception number one seems easy enough to understand, it’s the second exception that seems to get us into trouble… or at least it’s what got her into trouble. That exception actually states that if the requirements of NFPA table 130.7(C)(9) AND 130.7(C)(10) AND 130.7(C)(11) are met and followed… you don’t have to do and arc flash study, arc flash analysis, or arc flash survey ( all the same thing ). Sounds great doesn’t it… finally a way around doing the expensive arc flash surveys! Well… there is only one little thing I have to show you… The charts that this NFPA exception are talking about have some very specific things that need to be done in order to allow a company to get by without an arc flash survey. Let’s look at the first table… assuming that your electrical equipment is 600 volt class equipment as is most of the electrical equipment found in industry, You will read that you can read panel meters , do thermography, operate switches, switch breakers on and off, and other things wearing very minimal PPE. However, in every case, when you open doors or covers to expose energized electrical conductors, you must wear Category 4 PPE. The second chart tells us that we must wear the following; Arc-rated long sleeved shirt, Arc-rated long pants, Arc-rated coveralls, 40 calorie arc flash suit jacket, 40 calorie arc flash suit hood, 40 calorie arc flash suit pants, Arc-rated rain wear as needed, a hard hat, FR hard hat liner, Safety glasses or goggles, hearing protection, Arc rated gloves, and leather work shoes. The NFPA Handbook states that you still have to know the “available fault current”, “duration of the arcing fault”, and “distance between the worker and the arcing fault”. To get this data, you need and arc flash analysis.
So there you have it… you don’t need to do an arc flash analysis! Simply supply every worker with those 13 items listed there, and make sure they wear it any time they open any one of those electrical cabinets and you’re in the clear! Seriously, I believe what the NFPA has intended by giving us this exception, is to be able to repair or work on an electrical cabinet that has not yet been surveyed or does not have the Arc Flash data label on it. You just have to put on all the PPE you can!