ARC FLASH MITIGATION, PART 4: PPE AND PERSONNEL SAFETY

In this final installment of our four-part series on arc flash mitigation, we will look at the last line of defense against injury caused by arc flash explosions – personal protective equipment (PPE). In our previous articles, we investigated the importance of arc flash studies and circuit coordination as ways to reduce the severity of an event when it did occur, and discussed a variety of safety devices that could be installed in switchgear to protect workers and equipment. But these devices only reduce the intensity of an arc flash; they do not eliminate it. With that in mind, employees exposed to a potential arc flash still need to be protected from the thermal, electrical, radiant, percussive, and physical hazards associated with such an occurrence. Selecting and using the proper PPE is essential for employee safety.

The need for proper PPE is not only good business practice, but is also mandated by OSHA in 29 CFR 1910.335, Safeguards for Personal Protection, which states generally that employees must be provided with, and wear, electrically protective equipment to prevent exposure to hazards, and that employers must have a written policy on PPE use as well as documented training. Although not specifically stated, OSHA refers to the requirements found in NFPA 70E as the basis for compliance. Companies are not required to specifically follow the NFPA protocol, but if they don’t, they must be able to prove that their electrical safety program is equivalent in scope and substance to NFPA 70E in order to comply with OSHA standards.

The PPE requirements spelled out in NFPA 70E are very specific and are based on a Hazard/Risk Category (HRC) of 0 through 4, which is defined for a wide variety of tasks within the standard. For each category, both the clothing and equipment requirements are explained, with the clothing being specified to meet the minimum arc rating stipulated for the hazard. The PPE requirements are delineated in the table below:

Hazard/Risk Category (HRC)	Protective Clothing Required	Protective Equipment Required
0	Untreated natural fiber or non-melting clothing (wool, cotton, silk, rayon, and blends of these fibers) with a minimum weight of 4.5 oz/yd2 Long Sleeve Shirt Long Pants	Safety Glasses or Goggles Heavy-Duty Leather Gloves Ear Plugs
1	Clothing must have a minimum arc rating of 4 cal/cm2 Arc-Rated Long Sleeve Shirt and Pants, or Arc-Rated Coverall Arc Flash Suit Hood or Arc-Rated Face Shield Arc-Rated Rainsuit, Jacket, Parka, or Hard Hat Liner	Safety Glasses or Goggles Heavy-Duty Leather Gloves Ear Plugs Hard Hat Leather Work Shoes
2	Clothing must have a minimum arc rating of 8 cal/cm2 Arc-Rated Long Sleeve Shirt and Pants, or Arc-Rated Coverall Arc Flash Suit Hood or Arc-Rated Face Shield and Arc-Rated Balaclava Arc-Rated Rainsuit, Jacket, Parka, or Hard Hat Liner
3	Clothing must have a minimum arc rating of 25 cal/cm2 Arc-Rated Long Sleeve Shirt Arc-Rated Pants Arc-Rated Coverall Arc-Rated Flash Suit Jacket Arc-Rated Flash Suit Pants Arc-Rated Flash Suit Hood Arc-Rated Gloves	Safety Glasses or Goggles Ear Plugs Hard Hat Leather Work Shoes
4	Clothing must have a minimum arc rating of 40 cal/cm2 Arc-Rated Long Sleeve Shirt Arc-Rated Pants Arc-Rated Coverall Arc-Rated Flash Suit Jacket Arc-Rated Flash Suit Pants Arc-Rated Flash Suit Hood Arc-Rated Gloves Arc-Rated Rainsuit, Jacket, Parka, or Hard Hat Liner

Training & Documentation a Must

The other important component of OSHA compliance regarding electrical safety and the use of PPE is training and documentation. Employees assigned to wear electrically-protective PPE must receive periodic training on its safe use and care. In addition, companies must document this training, and have it available for review during an OSHA visit. Employees must be able to demonstrate to an OSHA auditor, through face-to-face discussions or written in their own words, that they understand the use and function of any PPE they are required to wear.

While OSHA does not directly require that employers follow the requirements of NFPA 70E, the committee that wrote the NFPA 70E standard was chartered specifically to develop standards which OSHA could use to determine whether businesses were in compliance with electrical safety requirements. Companies can, and have been, cited for non-compliance based on the contents of the NFPA standard, and a willful violation can result in fines up to $70,000 per citation.

OSHA considers each employee who is not provided with PPE or hazards training as a separate violation of the PPE standard; for example, if two employees are not provided with PPE or training, OSHA will cite two separate violations.

Case in point: In 2009, OSHA proposed $88,200 in fines against New York Electrical Contractor for 14 alleged serious violations of safety standards after a company employee was burned in an electrical arc flash on the North Campus of the State University of New York (SUNY) Buffalo. OSHA’s inspection found that one of the switches had not been de-energized as required before employees began their work, nor had the switches been properly barricaded and tagged to prevent exposure to live electrical parts.

OSHA also determined that the injured worker and other employees had not been adequately informed about and supplied with appropriate personal protective clothing. In addition, they had not been adequately trained in electrical safe work practices and in proper hazardous energy control procedures.

NAT’L Can Help

If your company is involved in operating, maintaining, or inspecting electrical equipment in excess of 50V and does not have a written electrical safety policy, it would be a wise investment to hire a company like National Field Services to come in and help develop a policy based on the NFPA 70E standards to suit your business, as well as train employees on the safe and proper use of the PPE they are required to wear.

For more information, contact an NAT’L service representative.