Labeling Requirements

[J. Wells]

I hope someone knows the answer. I know NEC 110.16 requires what I consider "simple labels" on switchboards, panelboards, industrial control panels, meter socket enclosures and MCCs in other than dwelling units.

However, I continually run into consultants that insist when detailed labels are used (with incident energy, approach limits etc.) that just about everything gets labeled. Even terminal boxes, very small safety switches, etc. I even had one want to label twist lock receptacles. Where is this level of labeling required or are they just trying to cash in?

Also, on equipment such as MCC's, some people want to label every bucket. Isn't that overkill?

Help Please!:eek:

[LK4]

We put 1 label on the front of switchboards, MCCs etc. unless it is a long line up and the put 2. Also if the back can be accessed we will place 1 there as well. I have heard of people putting them on the side of large equipment. Labeling evey little switch, JBox, receptacle, MCC bucket etc, especially at the 120/208 level seems like a big overkill but perhaps someone wants that warm fuzzy feeling. Maybe someone else can shed some light on alternative methods.

[WDeanN]

We put one label for the switchboard, MCC's etc, but also try to put one on the main breaker. We assume that the breaker in the compartment being work on or where the incident occurs will not trip, but will be involved in the incident and burn up. Or that the fault will occur on the line side of the breaker, usually at the bus for switchgear, MCC's etc. We are also working down to load disconnects (for 480V equipment and above).

I like the idea of a sticker being placed on the back. Certainly a label on every bucket is overkill.

I don't think that this level of labeling is currently required, but we're getting there.

[PDS_Dave]

I'm one of those people who tends to analyze everything to the Nth degree, but I feel like NEC 110.16 is pretty clear in terms of what must be labeled. Most MCCs are single source, so I label on the panel that covers the incoming service. Machine controls, I label right next to the handle, so if one is opening the panel, they will be staring directly at it. I also label disconnects, however, and lighting contactors and such, mostly because of my experience as a thermographer. If its going to be opened during an IR survey, I label it. Of all of the energized work that is likely to be "justified" under 70E guidelines, I feel that IR is the one that is most comprehensive in terms of devices that will become "exposed' as defined by Article 100 of the 70E.

Twist lock connectors really? Someone has suffered from intra-anal insect penetration....you know....they've got a bug up their butt....

[C Chord]

PDS, I learned a new term today. Do we just refer to this as IAIP??

[Bombo]

I am glad I found this forum, this is a question I have come to...

I am an EE intern working at a large production company. I am tasked with figuring out where we should put IR viewing panes on the Switchgear and MCC's. An arc flash study was completed prior to my arrival, and labels have been affixed which list PPE category, voltage, boundary limits, name of bus and protective device for that bus.

As I began looking at the equipment I found that the labels are all placed differently. On one Switchgear (SG) the label for the line side of the main breaker might be right on the breaker panel and on an identical SG (with same ratings) the label might be on the transition panel (from transformer to breaker)??? This can be confusing. (some of the SG even have the label on the back with nothing on the front??) After talking with a senior electrician, now a trainer, he agrees with me that we should have a label on EVERY panel that could be removed for servicing or inspection. I don't think overkill here is bad. Does this really seem excessive, especially to the electricians out there:confused:

Again, I would think that if there is a panel that can/may be accessed it should have its own label, that way there is no question as to what PPE is needed. After researching Arc Flash, and with my safety culture background, I would feel terrible if someone got hurt or worse - and I knew there was something more I could have done...:(

Looking for both clarification of the code and/or opinions from those out there.

Thanks, Bombo

[Noah]

how do you guys deal with the single phase panel? Do you place the label on 120V/1p lighting panel? Or single phase disconnect switch?

[GPD_Steve]

Labelling every bucket in a MCC definitel seems like overkill. Often there are already other stickers on the gear (High Voltage, Multiple sources present, testing and maintenance labels, etc) and it looks like an advertisement billboard. Too many stickers is confusing and will most likely be ignored

What we do is label the incoming breaker which provides the arc flash info for the line side of the breaker and then put one label at the top of every column of breakers. Directly under that label is a seperate label stating that every bucket in this column refers to the above sticker. For switchgear we label every door, including the back of the switchgear. Disconnects get one label also.

I'm a consultant and have worked with several clients; some who are very interested in the project and have an in depth understanding of Arc flash and some who just want some stickers so they can tell their boss they meet code. How detailed we get with the labels and how far down in the system is often dictated to us by the owner. If they employ qualified persons then often they will do only what is required by code. If there are employees in the facility who are not trained and qualified and come in contact with energized equipment then maybe going the extra step is a good idea.

Single phase, 3 phase equipment <240V fed from a transformer <125kVA (IEEE minimum arc flash requirments), and DC equipment is something that still remains quite a mystery. I'm looking foward to the results from the IEEE/NFPA colaboration. Someday.................

[PDS_Dave]

I've already posted in this thread, but I certainly don't mind throwing in my 2 cents.

What might help everyone at your facility would be a training session to address how the maintenance personnel view the labeling process. If comprehensive training is performed that enlightens all affected personnel to the location of the labels for different types of devices, that should take a lot of the guesswork out of where to place them.

For example, if your IR crew knows that the warning label for an MCC is always found on the upper right hand panel cover, that's where they'll look before they open buckets. If they know that every unit substation has the label on the front, they'll look there before walking around to the rear to remove a cover. The cost of printing labels isn't terribly steep, but depending upon the size of your facility it could quickly add up. So putting labels on every possible point of access might not be feasible, whereas spending a few man-hours teaching people where to find the data they need might be.

I know you didn't ask about this, but as a thermographer I wanted to address it. Be very selective in your choice for IR windows. Some of the product lines on the market can have wide variances in transmissivity through windows within the same product line, an even within the same production lot. It's just a matter of the physical properties of the materals used. Some of the IR windows on the market can also have a transmissivity level of as low as 70%. That could serious impact the quality of the IR image, as well as the accuracy of the temperature reading.

There are IR viewports on the market that have no actual "window" material, but rather open up to a pre-drilled hole that mates to a lens adapter. This way, you're camera is looking directly at the equipment, not through a material that might attenuate the IR waves. Just something to think about.

[GPD_Steve]

I currently am working for a client who insists that we use a different colored label for every HRC (0, 1, 2, 3, 4, >4). Some of these labels are going outdoors so after one year the red labels will be orange, the orange labels will be pink, etc, etc... I hate the idea and I'm trying to get them to reconsider.

NEC 110.16, FPN No. 2 states: "ANSI Z535.4-1998, Product Safety Signs and Labels, provides guidelines for the design of safety signs and labels for application to products".

This standard uses the colors Red for Danger, Orange for Warning, and Yellow for Caution. I've never seen an AF label other than Orange or Red.

Besides the NEC referencing ANSI Z535.4, is there anything else I can do to try and convince them to use orange and red as label colors instead of white, pink, yellow, blue, etc.. Has anyone else had a similar experience?

Please advise. Thanks!

[Bombo]

What might help everyone at your facility would be a training session to address how the maintenance personnel view the labeling process. If comprehensive training is performed that enlightens all affected personnel to the location of the labels for different types of devices, that should take a lot of the guesswork out of where to place them.........

I know you didn't ask about this, but as a thermographer I wanted to address it. Be very selective in your choice for IR windows. Some of the product lines on the market can have wide variances in transmissivity through windows within the same product line, an even within the same production lot. It's just a matter of the physical properties of the materals used. Some of the IR windows on the market can also have a transmissivity level of as low as 70%. That could serious impact the quality of the IR image, as well as the accuracy of the temperature reading.

There are IR viewports on the market that have no actual "window" material, but rather open up to a pre-drilled hole that mates to a lens adapter. This way, you're camera is looking directly at the equipment, not through a material that might attenuate the IR waves. Just something to think about.

Thanks for the input it is appreciated, :)
we are discussing how to handle the training/labeling. I agree that there certainly needs to be training.
Have you worked with the Hawk windows, everyone makes it sound like those are the ones to go with?

Is it ok to install a viewing pane in a panel that has a category of "dangerous" ? (I am assuming that this is the intended purpose but not sure if they go all the way to dangerous or just to cat. 4)

[McQ]

We too install multiple labels on switchgear. Using the following as an example, if the line side of the 3000 amp breaker, in a 480 volt switchgear, is HRC Dangerous then that first section of the switchgear would receive the Dangerous label, both front and back, that the Arc Flash software dictates. If the load side of the breaker is then reduced to HRC 2 because of trip settings, the first section of gear is still labeled at HRC Dangerous because the breaker is in the first section and thus labeled at the higher HRC. Now the second, third and fourth section of the gear would be labeled at HRC 2 because of the trip settings of the 3000 amp main. Both front and back of these sections would receive a HRC 2 label. This is sometimes confusing to the untrained employee because they see 2 separate levels of HRC in sections of gear that are mounted next to each other. By labeling the gear in this manner it allows the feeder sections of the switchgear to be worked on while energized, I.E. breaker change outs or feeder cable pulling to branch circuits, as long as the HRC 2 PPE is worn.

This is more of how the real world operates. Manufactures do not want to shut down entire switchgears to install new feeder equipment to the existing gear. As long as the information given to the employee is correct (HRC 2 Gear) and he is wearing the proper PPE the installation can still be performed safely.

In this example if you had labeled the switchgear with just one label in the front, right hand corner you would have had to use the HRC Dangerous label which would not allow you to work anywhere in the gear while it was energized. I have seen switchgears that were labeled by other companies with just one label and even though I was intentionally looking for it, it took me 2 minutes to find because of were they choose to locate it.

I wish there were a standard created for labeling and performing the analysis. I work for a company that performs Arc Flash Analysis for customers. We put a lot of thought and effort into personalizing the analysis to there expectations. Jim if you read this thread this is an example of how we sometimes lose a project in a competitive bidding process. The labor and engineering in the example above are considerably different between the company that installs one label on the switchgear compared to the company that would use analysis and engineering to install 10 labels of different HRC on the same switchgear.

PLEASE SEE 2ND POST DATED 09-03-2009

[Bombo]

McQ, Thanks for the input!

Your method is definitely what I am leaning towards and so far the boss agrees. It can seem like overkill but having been an operator I know how easy things can get confusing and I think that labeling all the panels, front and back, is good, at least on the switchgear.

On the MCCs we're looking at just putting one label on the "in-coming line" panel. Unless there happens to be a change to a higher category, which we have just a few cases of. (the panels on the MCCs tend to be small, and 95% of them stay the same level, but we do have some cases where the MCC feeds an LP or DP that may have a higher category)

Then of course we don't want to forget the training. Critical!

Thanks again,

[brainfiller]

I wish there were a standard created for labeling and performing the analysis. I work for a company that performs Arc Flash Analysis for customers. We put a lot of thought and effort into personalizing the analysis to there expectations. Jim if you read this thread this is an example of how we sometimes lose a project in a competitive bidding process. The labor and engineering in the example above are considerably different between the company that installs one label on the switchgear compared to the company that would use analysis and engineering to install 10 labels of different HRC on the same switchgear.

I agree completely! There is not only inconsistancy among labeling and study practices that can lead to competitive bidding disadvantages, but there are many unscrupulous firms out there that try to sell inadequate/insufficient studies to undercut a competant firm's best efforts.

For now about the only solution is to educate the client about what they really need.... ... except as we all know, many clients don't care, they just say "I can't spend much money so just do the minimum so I can say I am in compliance" Then of course, if something goes wrong, they always push back and say "why didn't you tell me I should have done more?"

As you probably read elsewhere in the forum, we are working on an IEEE guide for performing arc flash studies (called IEEE 1584.1 - "dot one" distinguishes it from 1584) to help level the playing field (actually only two of us wrote it - right now the document sits on my laptop waiting for revisions and committe review and approval). It contains general guidelines on what should be included in the study, calculations, labels, etc.

It will take a while to get published (IEEE moves at the speed of a glacier) but ultimately competent companies that perform studies will like it and benefit from it and "fly by nighters" will hate it. (<<< that's actually our goal!:D )

[Zog]

I agree completely! There is not only inconsistancy among labeling and study practices that can lead to competitive bidding disadvantages, but there are many unscrupulous firms out there that try to sell inadequate/insufficient studies to undercut a competant firm's best efforts.

For now about the only solution is to educate the client about what they really need.... ... except as we all know, many clients don't care, they just say "I can't spend much money so just do the minimum so I can say I am in compliance" Then of course, if something goes wrong, they always push back and say "why didn't you tell me I should have done more?"

As you probably read elsewhere in the forum, we are working on an IEEE guide for performing arc flash studies (called IEEE 1584.1 - "dot one" distinguishes it from 1584) to help level the playing field (actually only two of us wrote it - right now the document sits on my laptop waiting for revisions and committe review and approval). It contains general guidelines on what should be included in the study, calculations, labels, etc.

It will take a while to get published (IEEE moves at the speed of a glacier) but ultimately competent companies that perform studies will like it and benefit from it and "fly by nighters" will hate it. (<<< that's actually our goal!:D )

I lost one with the other guys bid at 20% of mine, they were using the Bussmann arc flash calulator.

[K. Engholm]

I lost one with the other guys bid at 20% of mine, they were using the Bussmann arc flash calulator.

You can't be serious! Has anyone actually looked at this program? It is designed to sell fuses more than provide a good study. After entering the bolted fault current, the program makes the calculations based only on the device size that you enter (i.e. 225 A) and then it gives the category / i.e. calculation of their fuse compared to a "hypothetical" breaker of that size. There is no way to enter your actual breaker clearing time or even your device instantaneous trip setting - they do it for you (what numbers do they use for clearing times? - why their numbers that give you a higher incident energy of course) although it would be argued that this is "safer" They do not even have category 1 as an option. In most cases unless you use current limiting fuses, any incident energy often is above 1.2 (even when a calculation study shows it is below 1.2) and it throws you automatically into the more expensive category 2 when category 1 might suffice. It's a great program for marketing fuses but I surely would not want to use it for an actual study.

Sounds like the consultant pulled one over on someone!:eek:

[Zog]

That has happned on more than one occasion, fact is some plants just want it done and they dont care how, they just want to say they are compliant, cheapest bid wins, period. Thats fine, I dont want those customers anyways.

[PM Walsh]

cheapest bid wins, period.
You get what you pay for!
Would you like tires and an engine with that new car?

[McQ]

[QUOTE=McQ;844]We too install multiple labels on switchgear. Using the following as an example, if the line side of the 3000 amp breaker, in a 480 volt switchgear, is HRC Dangerous then that first section of the switchgear would receive the Dangerous label, both front and back, that the Arc Flash software dictates. If the load side of the breaker is then reduced to HRC 2 because of trip settings, the first section of gear is still labeled at HRC Dangerous because the breaker is in the first section and thus labeled at the higher HRC. Now the second, third and fourth section of the gear would be labeled at HRC 2 because of the trip settings of the 3000 amp main. Both front and back of these sections would receive a HRC 2 label. This is sometimes confusing to the untrained employee because they see 2 separate levels of HRC in sections of gear that are mounted next to each other. By labeling the gear in this manner it allows the feeder sections of the switchgear to be worked on while energized, I.E. breaker change outs or feeder cable pulling to branch circuits, as long as the HRC 2 PPE is worn.

This is more of how the real world operates. Manufactures do not want to shut down entire switchgears to install new feeder equipment to the existing gear. As long as the information given to the employee is correct (HRC 2 Gear) and he is wearing the proper PPE the installation can still be performed safely.

In this example if you had labeled the switchgear with just one label in the front, right hand corner you would have had to use the HRC Dangerous label which would not allow you to work anywhere in the gear while it was energized. I have seen switchgears that were labeled by other companies with just one label and even though I was intentionally looking for it, it took me 2 minutes to find because of were they choose to locate it.

QUOTE]

As time goes on and we seem to improve on our engineering skills your opinions will change as mine has on this topic of how to label a switchgear. I know feel that if the incoming feeder cables that are connected to the main circuit breaker in the switchgear are at a HRC of Dangerous, the entire adjoining section of gear (without barriers as normal gear is constructed) should also be labeled Dangerous.

Previously I wanted to use the settings of the main breaker to reduce the HRC in the adjoining sections. Now I feel as if you are working on the section next to the main while energized and you cause an arc flash to occur the molten metal and gases possibly can migrate to the line side of the breaker and causes a much more serious arc flash. For this reason I am now using the assumption that all the sections of the gear should be labeled as to what the main incoming feeders determine. If the results of the analysis are dangerous then all non-barrier adjoining sections should be labeled dangerous. This means that any time you would like to add additional equipment to the switchgear it would have to be de-energized to so. Something that takes a lot of discussion and training to convince plant managers to perform.

Previously simple task are now a quite expensive and time consuming task affecting production schedules. I now use this method of labeling because it is a safer method and the idea is to reduce the amount of work that use to be performed while energized.

Just my 2 cents!

[Lew Silecky]

You can refer to NFPA-70E 2009 130.3 ARC FLASH HAZARD ANALYSIS. Essentially no analysis is required ( therfore no labelling)for circuits rated 240Vac or less, the circuit is supplied by one transformer or the transformer is rated 125KVA or less.
Regards;
Lew Silecky

[THE CABLE GUY]

Arc Flash Hazard Labeling Do's and Don'ts
Ask for this PDF file. To big for me to attach but is a great source of information about labeling.

http://www.easypower.com/arc_flash/arc_flash_resource_center.php

[ChevsMark]

We use a tag like this for our 480 volt and lower panels. We put them on the door of the panel, be it 120/208 recepticle/lighting or 480 volt lighting. We also use them on panels for power distribution, all the way up to and including our sub stations (480 volt, spcl. tags for 13,200 v)
We use a program called MarkWare by Brady and I print all of the tags on "weatherproof" vinyl. This is what they look like. I change the information depending on the application/load/voltage etc.

http://i127.photobucket.com/albums/p158/chev454ss1967/eswptag2-1.png

[Terry Becker]

I didn't want to, but have to weigh in on this. In my audit work labeling is all over the map, inconsistent specification, colors, information presented, location, incorrect mitigation labels (e.g. arc flash relay, arc reduction maintenance switch, etc..). Here are a few comments, some you may not like as it will make work for you, but your Electrical Safety Program should cover this off:

1. You shouldn't include HRC for specifying your arc rated clothing on a detailed label when you have completed incident energy analysis. You can only call arc rated clothing by an HRC if you use the Table Method of arc flash hazard analysis.
2. I recommend you stick to ANSI Z535 Standard for the layout of the label and safety colors used, using and applying a consensus based Standard is your best due diliegence in court, using other colors, like blue, pink, green (there is another thread where someone was asked to do this). The colors have meaning and "we" recognize them, "what does pink mean?"
3. I recommend that you "plan" what you do by creating a Arc Flash & Shock Warning label and Signs (for the outside of the doors into your MCC/Electrical Rooms) Labelling Specification & Schedule (table used to document what labels were installed, where and by who). In this specificaiton you stipulate what your simple and detailed label formats are, when you will use Danger (e.g. 40, 50, 60 cal/cm2 if you didn't know the software just defaults to 40 cal/cm2, and you can configure this to tell it when you want Danger).
4. Again on the "plan" theme (e.g. based on ANSI Z10, Plan, Do, Check, Act philsophy) I have attached an MCC elevation drawing that ensures that the label will be installed in the same locations no matter what enterprise wide facility you have them installed in. You a specification and elevation, orthographic drawing to illustrate where you want the labels installed. [I tried to upload pdf, 48kb limit the file was 65kb, if you want the drawing email me at terry.becker@espsi.ca].
5. You will see some new direction on labels in next 70E, I am at the Technical Committee meetings in Memphis, TN right now. This also emphasizes that you utlimately need a label management system identified in your Electrical Safety Program.

Enough typing on this one.

Terry Becker, P.Eng.
ESPS Electrical Safety Program Solutions INC.
terry.becker@espsi.ca
403-465-3777

[Terry Becker]

Sorry I forgot to add that you also need to ensure you address what labels ar required when you engineer in ("Safety by Design") mitigation:

1. You need labels indicating "Normal" operating incident energy and AFPB data, and when the mitigation is "in service" e.g. arc reduction maintenance switch.
2. I recommend that a general Warning label be installed as well indicating what mitigation is installed and the need for it to be documented in a procedure.
3. When auditing I have found that the actual arc reduction maintenance switch is not labeled, and in somes cases the switch is remotely located to the actual breaker that it relates to, you need to ensure labelling is in place, unique ID for the switch and what switch relates to what breaker.
4. You need one label for the "Line" side and the "Load" side of Main Breaker.

You must manage your labels initially and thereafter as your electrical system changes.

I can't upload the jpegs I have as examples of labels, they are too big for the forum software.

Terry Becker, P.Eng.
ESPS Electrical Safety Program Solutions INC.
terry.becker@espsi.ca
403-465-3777