Especially for Electrical Contractors a Question?
Especially for Electrical Contractors - A Question?
How do you manage a new prospective customer that does not have the NFPA 70e Labeling on their electrical control boxes and equipment? Do you take them on as customers? Do you charge them more, as your employees must take more time to determine the hazards and to protect themselves?
Sometimes smaller manufacturing operations I tour do not have this labeling. In my hazard assessments I tell them that they are highly recommended. Next, I am typically asked if OSHA requires them. I tell them all the standard stuff about NFPA and ANSI, but they persist. I tell them OSHA says they must protect their employees and that although OSHA does not precisely require NFPA 70e labeling, OSHA would issue a citation if an employee was seriously injured, possibly using 5A. I am usually told that their employees are not supposed to go into the panels as they hire electrical contractors. But they and I know their maintenance employees do go into the panels.
Once an owner told me he was not paying $50,000 for an electrical survey as his people did not go into the panels. He hired electrical contractors to do so, and they knew the hazards. If an electrician from a contractor was injured on his equipment, it would not have any effect on his WC mod rate. I agreed that in that case I would not sweat his mod rate. However, I asked him if he had ever heard of insurance subrogation. He looked puzzled and I said the mod rate would be “peanuts” if a horribly burned contractor took him to civil court for liability and the contractor’s insurance company joined the suit to regain their costs (subrogation). He still refused and I did not get the business, which I think was for the best.
I am just looking for more ammunition I can put in my formal written memo to them in my recommendations.
Comments (10)
Technically, per NFPA 70E, the labeling is only required if you plan to examine, adjust, service, or maintain the equipment while it's energized. If a company can ensure they will NEVER do that type of work on electrical equipment while it's live/energized (which there are only 4 justifications to do so), then they could technically be compliant with NFPA 70E with no labeling on their panels, switchboards, etc. However, although NFPA 70E is the gold standard for electrical safety, OSHA requires equipment labeling in 1910.303(e), so even though NFPA 70E is more descriptive, it's still a legal requirement per OSHA - just not as specific as the NFPA 70E requirements for equipment labeling (e.g., OSHA doesn't require arc flash labeling - mainly just electric shock hazard info/data).
There are still other ways to determine what the necessary PPE and protection boundaries are without labeling. All you need to know is the nominal voltage, maximum available fault current, maximum OCPD clearing time, and minimum working distance - then you can just use the PPE category method (aka "Table Method") to determine your PPE requirements and protective boundary distances. They can get this required technical data from one-line/single-line drawings, apps (e.g., Eaton has a good one), or various other schematics.
Overall, it's the host facility's responsibility to label the equipment (if required), regardless of whether it's their own employees working on the circuits or contractors.
As usual, Drew has nailed it. As a hospital, we're (mostly) pretty well labeled because we do sometimes have occasion where we have to do live work, because we can't shut down the ICU for example.
If you're a simple retail storefront, it should be pretty easy to de-energize. In many cases the maximum available fault current is listed right on the electric meter, but sometimes it can be pretty complicated to calculate if you have a complex industrial facility with it's own substation/switchgear/etc...