DMB5mil wrote:
Thanks Guys,
I understand better the PPE levels and can see how rounding up will simplify labeling. I'm wondering if I must stick to the prescribed set of clothing & protection items for PPE#1, PPE#2, etc. if I am rounding up to keep to a few standardized AR thresholds.
For example - if I want to label all my panelboards at 120/208V which are fed by <125KVA transformers with '8 Cal AR PPE Required' can I also allow the electricians at those panels to wear only those specific clothing & equipment items required within the PPE#1 category (hence they don't have to wear a balaclava)? In this case, even though the label says 8 Cal (implying the full set of PPE#2 clothing and equipment should be used ) I wouldn't require a balaclava since it is not required of PPE#1 clothing per Table 130.7(C)(16).
Perhaps I'm talking myself in circles and confusing the issue more.
My recommendation isn't just to round up but suggesting that the levels in the table (1.2/4/8/25/40) are not ideal in the real world and that a different set of levels is perhaps more appropriate. Here is what I mean by an alternative that matches Annex H:
1. Up to 1.2 cal/cm2...nothing required. As in nothing. That includes the "exception" from IEEE 1584. This is as per the current (2015) version of 70E. The reason by the way that nonmelting clothing and any other "H/RC 0" requirements disappeared is that even untreated materials have a pretty good ATPV.
2. Up to 4 cal/cm2...arc rated shirts and pants or an arc rated coverall plus the other "stuff" on the list (ear plugs, hard hat, etc.). Frankly it doesn't matter what the arc rating is because you won't find any PPE with an ATPV that low. This means that the worker may be wearing an ATPV 10 shirt and ATPV 12 pants but since the face is underprotected we go by the lowest rating.
3. Up to somewhere around 8-12 cal/cm2...arc rated shirts and pants or alternatively a coverall plus the balaclava. Pick whichever level you feel most comfortable supporting from a vendor point of view, the higher the better. This would again go by the LOWEST ATPV of the PPE that are supplied. The table in 70E suggests ATPV 8 but frankly you won't find very much that is that low. A 12 oz./yd2 woven work shirt will usually be 10-12 cal/cm2 and denim jeans or duck pants will typically be at least 12+ ATPV while lighter duty twill pants are usually at least 8-10 cal/cm2.
4. Above 12 cal/cm2 a full hood is required and replaces the face shield and balaclava but nothing else. In addition the available PPE is going to be multilayer in nature. However if you make sure to specify and use a tested combination such as an arc rated shirt+pants and a set of coveralls or say the same shirt/pants plus arc rated rainwear or the same shirt/pants plus arc rated winter wear (overalls and jacket) even though individually these components may only have an ATPV of say 10-12, the combination quite often will be somewhere in the neighborhood of ATPV 20-35. I have not yet seen a combination that hits ATPV 40. So if you already issue and specify rainwear or winter outerwear or supply coveralls in addition to or in lieu of shirts and pants, you can use the rated combination to achieve an ATPV in the same range as PPE 3/4, especially if you eschew going any higher than this tested combination.
Finally when it comes to gloves, Arcwear has tested several brands and varieties of leather gloves as well as rubber gloves. What they found is that almost all the rubber gloves are at least ATPV 40 in combination with leather protectors. Similarly they found that leather gloves are at least ATPV 12. This is the reason that 70E lists these two types of gloves. Note that there is NO ATPV rating in this case...it's either a leather or rubber glove (with leather protectors) or it's not. There are cotton mittens on the market that are actually arc rated with an ATPV rating but there are three problems with them. First they offer no shock protection so they are not a replacement for rubber gloves (when required). Second they are soiled much more easily than leather gloves and at the price, they are definitely not disposable. Finally they really don't offer much abrasion resistance. So there's little reason to recommend them except for some switching situations.
And don't get too hung up on the glove issue. Try this...take an incident energy rating and change the working distance down to hand distance...say 2.5 cm (1 inch). What happens to the incident energy? Yep...sky high. This is where two things become obvious. The first one is that IEEE 1584 (and 70E) are not really intended to prevent injuries with PPE. In fact IEEE 1584 is designed around a 95% confidence interval of preventing a 2nd degree or more severe burn but ONLY in the most vulnerable part of the body...the face and chest area. There is no guarantee whatsoever that it will prevent a serious injury, only that a fatality is pretty unlikely.
And second and more importantly it highlights a more fundamental issue. The hierarchy of controls in 70E states that PPE is the last resort for protecting workers against hazards. Everything else (LOTO, EEWP's, maintaining equipment as per chapter 2) is designed around preventing workers from being exposed to hazards...lowering the risk. PPE NEVER prevents exposure to a hazard. It merely lowers the injury caused by the hazard. AND especially when it comes to voltage rated gloves and shock protection, PPE can and does fail so using it does not in any way prevent injuries at all. It MAY lessen the shock or arc flash to a tolerable level but it doesn't do anything to prevent the hazard in the first place. In fact given that all PPE is cumbersome and reduces visibility, decreases dexterity, increases risks to heat stroke, and has a tendency to cause workers to think they are superman and can take unnecessary risks, it becomes obvious why PPE is the worst solution available and not the best and should never be the first solution.