There have been millions of dollars spent over the past decade on Arc Flash Analysis. And although I am one who spent some of that money because I believe in their value, I am asked often if this costly analysis is actually required. Most facilities have hired an electrical expert to perform a very detailed analysis of each electrical cabinet in the facility and this costs a lot of $. So a lot of companies still have not analyzed their arc flash potentials, leaving their qualified electrical workers at risk. But does my arc flash analysis have to be done via a third party expert and cost me a lot of $. The simple fact is NO – there is an alternative to comply with OSHA (and NFPA 70E) arc flash requirements…
NFPA 70E recognizes two methods of Arc Flash Analysis:
- the “arc flash hazard assessment” (technically called the “incident energy (calculation) method”) and
- the “hazard/risk category (table)” method
The “arc flash hazard assessment” is the one that can costs ten’s of thousands of dollars and in my opinion is the most efficient and effective safety measure for the facility. But OSHA (and NFPA) recognize the use of the ”hazard/risk category (table)” as a means to comply.
NFPA 70E permits Table 130.7(C)(15)(a), Table 130.7(C)(15)(b), and Table 130.7(C)(16) to be used in lieu of an incident energy analysis (e.g. traditional arc flash analysis usually conducted by a third party expert) in accordance with 130.5, Exception; which states…
The requirements of 130.7(C)(15) and 130.7(C)(16) shall be permitted to be used in lieu of determining the incident energy at the working distance.
NOTE: 130.7(c)(15) is Selection of Personal Protective Equipment When Required for Various Tasks and 130.7(C)(16) is Protective Clothing and Personal Protective Equipment.
OSHA will cite 1910.335(a)(1)(i)-(v) if the electrical workers are not adequately protected based on either type of arc flash analysis. There is NO DOUBT that OSHA will, and has multiples times, cite a company for not properly protecting their workers from arc flash hazards. We MUST use one of the prescribed methods to determine the level of PPE necessary should an arc flash occur. But we have options and a facility with highly TRAINED and EXPERIENCED electrical workers, the “hazard/risk category (table)” method may be suitable. But for those facilities who have limited number of electrical personnel and struggle to implement electrical safety related work practices, the formal, and yes costly, analysis is the SAFEST method. It may be costly in the sense of $, but when done right, it makes the PPE hazard assessment for arc flash hazards as simple as reading a label and thus IMPROVES ELECTRICAL SAFETY.
Don’t be fooled into thinking that the the “hazard/risk category (table)” method (i.e. NFPA 70E, 130.5 exception) does not have its flaws! In fact, in almost every audit I have been involved in over the past 10 years, the facilities that laid claim to using the “hazard/risk category (table)” method vs. not having a formal analysis on hand did not even have access to the NFPA tables and had not trained their qualified electrical workers in their proper use.
Trust me when I say, OSHA will ask for your analysis. Not having a fancy binder and labels as part of your analysis will not result in a citation. But when we fall back on the “hazard/risk category (table)” method as the acceptable “exception” we MUST have the documentation to show we are in fact protecting our workers using this exception.
In 2012 NFPA published a really nice document titled NFPA 70E® 2012 20 Most Frequently Asked Questions By Michael Fontaine. This document used to be available in the public domain and a quick Google search will lead you to it – if it is still avialble in the public domain. SAFTENG Members can see this document Here.
Disclaimer:
SAFTENG does NOT provide electrical safety consulting. This article is NOT meant to be consulting advice, but to offer an alternative to comply with OSHA and NFPA. When done PROPERLY, the exception provides an acceptable level of safety for electrical workers; however, it is my opinion that the formal arc flash analysis is far superior for the safety of workers.