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Arc Flash Risk reduction

Arc Flash Fun Facts

Arc flash = Electric short resulting from ionized air 36,000 F = Four times the surface of the sunArc Blast = Super heated air, vaporize metal, flying shrapnel 480 volt arc blast = 8 sticks of dynamite = 1000 pound waveSound > 160 db = 9 mm gunshot 2 -4 inches from ear.2 seconds from inception to blastSend metal parts flying at 700 MPH / Superman 1500 MPHCopper vaporizes 67,000 to 1Injuries include: Burns/Vision/Hearing/Physical /Concussion80% of all electrical injuries are due to arc flash80% of all electrical injuries are human error

Statistics

Arc Flash Burn Statistics: 5 – 10 workers go to burn centers every day 1 - 2 die every day Unreported

Construction, production, mining, and oil and gas extraction activities are inherently dangerous and the primary sources of electrical injuries and deaths

How does the pipeline industry compare? Risk Cannot be Eliminated

Satisfying All OSHA Regulations to the very Best of our Ability will Not Eliminate the Risk of Injury, Nor Will it Eliminate the Risk of OSHA Violations or Lawsuits

Risky Business

Human Injury / Loss of lifeOSHA CitationProduction LossEquipment Damage

At the Source Adjacent Equipment Nearby Equipment Equipment Damaged by Power Surge

Personal Injury ClaimRisk Cannot be Eliminated

Satisfying All OSHA Regulations to the very Best of our Ability will Not Eliminate the Risk of Injury, Nor Will it Eliminate the Risk of OSHA Violations or Lawsuits

Regulations and Standards

OSHA 1910

NFPA 70E

IEEE

OSHA Act of 1970 Sec 5 General Duty Clause

(a) Each employer --

(1) shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees;

(2) shall comply with occupational safety and health standards promulgated under this Act.

(b) Each employee shall comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to this Act which are applicable to his own actions and conduct.

OSHA 1910 Electrical Standard Final Rule 2007

Federal Register # 72:7135-7221 - regarding the nature of electrical accidents, “Electrical accidents, when initially studied, often appear to be caused by circumstances that are varied and peculiar to the particular incidents involved. However, further consideration usually reveals the underlying cause to be a combination of three possible factors: work involving unsafe equipment and installations; workplaces made unsafe by the environment; and unsafe work performance (unsafe acts). The first two factors are sometimes considered together and simply referred to as unsafe conditions. Thus, electrical accidents can be generally considered as being caused by unsafe conditions, unsafe acts, or, in what is usually the case, combinations of the two. It should also be noted that inadequate maintenance can cause equipment or installations that were originally considered safe to deteriorate, resulting in an unsafe condition.”

OSHA Regulations

OSHA 1910.333 Work Practices– regarding safe work practices, “Safety-related work practices shall be employed to prevent electric shock or other injuries resulting from either direct or indirect electrical contacts, when work is performed near or on equipment or circuits which are or may be energized. The specific safety-related work practices shall be consistent with the nature and extent of the associated electrical hazards

OSHA Regulations

OSHA 1910.332 – Electrical training 1910.332 (a) “Employees in occupations listed in Table S-4

face such a risk and are required to be trained.” 1910.332(b)(3)(iii) “Type of training. The training required

by this section shall be of the classroom or on-the-job type. The degree of training provided shall be determined by the risk to the employee.”

Table S-4 Electrical and Electronic Equipment Assemblers

Electrical and Electronic Engineers

Electrical and Electronic Technicians

Electricians Painters Welders

Mechanics and Repairers

Industrial Machine Operators

Material Handling Equipment Operators

Stationary Engineers

Riggers and Roustabouts

Blue Collar Supervisors

OSHA 1910 Interpretation

OSHA Interpretation 11/22/2005 – regarding insulation integrity of a temporary cable laying on the ground, “However, in the absence of a specific standard covering a hazard, OSHA may issue a citation under Section 5(a)(1), the "General Duty Clause," of the Occupational Safety and Health Act (OSH Act), if it determines that: 1) the employer failed to keep its workplace free of a hazard to which its employees were exposed; 2) the hazard was recognized either by the cited employer or the employer's industry; 3) the recognized hazard was causing or was likely to cause death or serious physical harm; and 4) there was a feasible and useful means available to correct the hazard.


OSHA Interpretation 11/14/2006 – regarding NFPA 70E, “OSHA has not conducted a rulemaking to adopt the requirements of the latest edition of NFPA 70E and, therefore, does not "enforce" those requirements. However, industry consensus standards, such as NFPA 70E, can be used by OSHA and employers as guides in making hazard analyses and selecting control measures.”


OSHA Interpretation 11/14/2006 – regarding managing hazards, “A violation of the General Duty Clause, Section 5(a)(1) of the Act, exists if an employer has failed to furnish a workplace that is free from recognized hazards causing or likely to cause death or serious physical injury. The General Duty Clause is not used to enforce the provisions of consensus standards, although such standards are sometimes used as evidence of hazard recognition and the availability of feasible means of abatement.”


OSHA Interpretation 11/14/2006 – regarding NFPA 70E, “OSHA recommends that employers consult consensus standards such as NFPA 70E-2004 to identify safety measures that can be used to comply with or supplement the requirements of OSHA's standards for preventing or protecting against arc-flash hazards.”


OSHA Interpretation 11/14/2006 - regarding non-compliance with a standard, “To establish all of the elements of the affirmative defense of impossibility, an employer who can show that compliance with the terms of a standard is impossible under the circumstances must also show that it used alternative measures to protect employees, or that there were no such control measures.


OSHA Interpretation 02/29/2008 – regarding PPE, “While the NFPA 70E consensus standard has not been adopted as an OSHA standard, it is relevant as evidence that arc flash is a recognized hazard and that PPE is necessary to protect against that hazard.”


OSHA Interpretation 02/29/2008 - regarding arc flash, “The risk of injury largely depends on the amount of energy available to the breaker, how old it is, how well it was maintained, and the task that is to be performed, among other factors.”

Basis for Compliance

The OSHA General Duty Clause requires an employer to furnish a workplace that is free from recognized hazards causing or likely to cause death or serious physical injury.

Consensus standards may be used as evidence of hazard recognition and the availability of means of abatement.

NFPA 70E is an OSHA acknowledged consensus standard

NFPA 70E provides evidence of arc flash hazard and the availability of means of abatement.

Clarification Notes

One Sentence Summary: A safe work place requires continuous hazard

recognition and abatement and a well trained (and verified) staff wearing appropriate PPE, using safe tools and following safe work practices

In addition to using consensus standards such as NFPA 70E, concerns must be addressed including how old equipment is, how well it is maintained, how well it is designed, and the task that is to be performed, among others.

OSHA citations usually include failure to train employees to perform work safely and/or to ensure that they implement what they learned.

Standard - NPFA 70E 2000

Part II Appendix B “Existing knowledge about arc flash exposure at voltage levels above 600 volts is limited.”

Article 2-1.3.3.3 “Where it has been determined that work will be performed within the flash protection boundary by 3-1.3.3.2 of Part II, the flash hazard analysis shall determine, and the employer shall document, the incident energy exposure of the worker. As an alternative, the PPE requirements of 3-3.9 of Part II shall be permitted to be used in lieu of the detailed arc flash hazard analysis approach described in 3-1.3.3.2 of Part II”

No labeling requirement.

Standard - NFPA 70E 2004

Article 400.11 “Switchboards, panelboards, industrial control panels, and motor control centers that are in other than dwelling occupancies and are likely to require examination, adjustment, servicing, or maintenance while energized shall be field marked to warn qualified persons of potential arc flash hazards. The marking shall be located so as to be clearly visible to qualified persons before examination, adjustment, servicing, or maintenance of the equipment.”


Article 130.3 states “An arc flash hazard analysis shall determine the Arc Flash Protection Boundary and the personal protective equipment that people within the Arc Flash Protection Boundary shall use.”

Article 130.3 Exception 2 states “The requirements of 130.7(C)(9), 130.7(C)(10), and 130.7(C)(11), shall be permitted to be used in lieu of a detailed incident energy analysis

Article 130.7(C)(9)(a) Added working distance basis for the short circuit and

clearing time method Less than 1000 volts - 18 inches Greater than 1000 volts - 36 inches

Reduced allowable short circuit for the short circuit and clearing time method


Low Voltage Systems Table D.9.1 – Maximum PPE for HRC 4 shown on

the table is 40 cal/cm2

Table D.9.1 Note 5 – Flash Protection Boundary (threshold distance for a second-degree skin burn) is 1.7m (6 ft) for HRC 2 and 4.9 m (16 ft) for HRC 4. PPE is required for all personnel working within the Flash Protection Boundary.

Table D.9.1 Note 5 – Working distance for the arc flash exposures is assumed to be 455mm (18 in.)


High Voltage Systems Table D.9.2 Note 2 – Working distance for the above

arc-flash exposures is assumed to be .92 m (3 ft) Table D.9.2 –The maximum calculated cal/cm2

allowed for HRC 4 using alternate method is 35 cal/cm2 and the minimum PPE allowed for HRC 4 is 40 cal/cm2 .

NFPA Incident Energy Clarification

“Section 130.7(A), Personal and Other Protective Equipment–General, has several important FPNs. FPN 1 reminds readers that personal protective equipment (PPE) prevents only injury from the burn part of an arc flash, not from the explosive effect or the pressure and shrapnel the arc flash generates. FPN 2 suggests finding alternative work methods when the incident energy level is above 40 cal/cm2. PPE rated as high as 100 cal/cm2 is available, but this FPN discourages users from working when the incident energy level is above 40 cal/cm2. Nothing in NFPA 70E prohibits wearing PPE rated higher than the incident energy level, and in some cases, that extra level of protection might be desired.” – Bill Buss, NFPA Senior Engineer

FPN = Fine print note

NFPA 70E 2012 Proposed Changes

FR Changed to ARRetraining Every Three YearsNew Arc Flash Labeling RequirementsInspection activities will be coveredHearing Protection RequiredWorking distance and flash boundary distance to be

included with each 130.7 (c)(9) task description (18” or 36”)

Category 2 and 2* join. Balaclava or arc flash suit hood required for both

NFPA Summary Recommendations

Perform hazard analysis of the electrical systemPerform incident energy or short circuit and clearing

time study using 18” and 36” recommended working distances

Reduce available incident energy to below 40 cal/cm2 (35 cal/cm2 )

Provide employees with PPE Label equipment with PPE required and protection

boundary, inter aliaEnsure recommended working distances are maintainedUpdate the study every 5 years and when changes occurProvide training every three years or more often as

required

Questions

What purpose do the existing ballistic blankets serve? Do they provide any protection at all? Up to what level do they provide protection?

If we install all the other equipment and keep the ballistic blankets does it negate having to move operators?

Do we have any idea of how to calculate the "probability" of a flash.

What are minimum regulatory requirements concerning Arc Flash? See Recommendation slide.

Questions

What are potential penalties for not following regulations?

Do we have any immediate dangers?Is it absolutely necessary to power down station at

transformer to complete information gathering to conduct Arc Flash study?

If it necessary to study every facility? Can we “infer” anything about similar facilities?

What is the benefit and to what purpose do we replace the unit electro mechanical breakers, add bus differential protection, change grounding?

Questions

Is there a way to change the boundary at stations so we do not have to move the control room area?

We need to identify station priorities… (Ultimately I would like to see a numbered list).

We really need to support the case that doing nothing is not an option and identifying what the minimum is while giving the recommendation and option for maximum protection. Kevin Finley

Recommendations

Use NFPA recommended working distances in our incident calculations.

It is desirable for many reasons to reduce incident energy well below 40 cm2

It is a better tactic to use NFPA recommended working distances in our incident energy calculations and then use control measures to lower them to levels that further improve safety, than to lower the working distance used in our incident energy calculations below NFPA recommendations. In the event of an unfortunate injury, it would be better to be able to describe our efforts to go beyond NFPA recommendations and then to be able to provide the resulting reduced incident energy for comparison purposes.

Risk Management Approach

Best Approach to Reduce Risk Identify Areas of Risk Perform Risk Assessment Identify Solutions Identify Solution Synergies Implement Solutions According to Assessment

Results

NFPA Arc Flash Control Methods

Arc Flash Study Steps Perform field verification and audit Update one-line drawing Create software model Perform short circuit analysis Calculate incident energy Perform protective device coordination

study

Protection Boundaries