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Should Arc Flash Studies (for clients) be performed by or under a licensed P.E.
Yes 63%  63%  [ 86 ]
No 20%  20%  [ 28 ]
It depends 17%  17%  [ 23 ]
Total votes : 137
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 Post subject: Re: Arc Flash Study Qualifications
PostPosted: Thu Sep 06, 2018 9:40 am 
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stevenal wrote:
We can test that duty to report easily enough. Anyone here wish to fess up to unlicensed practice or practicing outside their area of competence? Please provide name and jurisdiction.

I also need to dispute that Canada has no enforcement. I distinctly recall the Ontario board going after Microsoft over their network engineer certification. I believe the fine was $1000 Canadian.


I'll admit I can play a pretty good architect. Here's an example of my design architect's shpeel:

Clearly, from the 10,000' level, we can drill down, into the weeds, leverage our synergies, think outside the box and celebrate a win-win paradigm shift"

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 Post subject: Re: Arc Flash Study Qualifications
PostPosted: Sat Sep 08, 2018 8:52 am 
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stevenal wrote:
We can test that duty to report easily enough. Anyone here wish to fess up to unlicensed practice or practicing outside their area of competence? Please provide name and jurisdiction.

I also need to dispute that Canada has no enforcement. I distinctly recall the Ontario board going after Microsoft over their network engineer certification. I believe the fine was $1000 Canadian.


Obviously this is intended to point out how ridiculous the whole idea of "self policing" is?

I believe they tried that in the U.S. and lost on "software engineer" so they had to actually create a test and provide a path, etc. One of the prominent issues is the use of the "MCSE" title in software which requires no educational or apprenticeship period and simply passing a test. Trouble is that if you read the descriptions of the states that have supported this, the description refers to things like safety systems in controls...it really just ends up a controls engineer but with a different title. That being said the ISA and AiChE crowd routinely do classes and certify people in every aspect of safety systems but the majority of controls guys learned the craft from OJT rather than college route and even then most never did ABET certification.

And then we have this one...

https://www.washingtonpost.com/opinions ... 9aacd860d8

There are several more related articles but the fundamental issue is that an engineer that was not licensed in Oregon published a critique of red light cameras because the timing flagrantly violated basic physics. So the state sued the guy for essentially doing basic math and publishing the results for personal reasons without selling his services and by using the word engineer in the publication. Frankly this makes nearly all engineering publications (IEEE, etc.) violations. At least in Oregon, clearly engineers are prohibited from doing basic math in public.

Or this one...

https://www.machinedesign.com/engineeri ... profession

And the follow up...

http://www.chicagonow.com/chicago-liber ... -illinois/

The essential issue here is that the State of Illinois objected to the company name "Budd Engineering" which restricted itself to industrial clients and operated within the industrial exemption for Illinois. The courts agreed that Budd Engineering clearly was not working without a license because a license was not necessary.

The original two engineering professional societies were the ASCE and the AIME (now SME). ASCE has always pushed for engineers to be effectively independent consultants whereas if I recall correctly most of AIME's members weren't even degreed engineers originally. The first president of ASME wasn't either. ASME, AIEE (now IEEE), and many others believe that the idea of engineering societies is to promote education and provide technical standards to better society at least at their founding. If they don't do that then in reality "professional" licensing is little more than trade organization protectionism. For instance many states require licensing for florists and hair dressers, despite the fact that there is obviously little or no public interest or public safety involved. Engineeering has a different problem. OVer 80% (some claim over 90%) of engineers aren't licensed. They are so deeply rooted in the business environment that business interests and engineering interests are basically one and the same. Licensing amounts to little more than more silly regulation that does not benefit anyone. On the other hand although it can be argued that the licensing process basically doesn't work as intended, there are plenty of examples of where bad designs and inspections have resulted in fatalities and injuries, and although it clearly doesn't work, that is what licensing is intended to prevent.

I'm all for the idea of peer reviewed standards, educational programs, shared traaining and knowledge in scientific methods and pricniples, which is what IEEE among others is heavily into promoting. As to fixing the woes of our profession, let's put it this way....you can bring a horse to water, but you can't make it drink. Promoting technical standards is the best defense we have as a profession in terms of providing tools to the courts and businesses to help recognize and prevent poor engineering practices. Licensing as it exists is little more than trade group protectionism. Hence the reason that the state agencies spend 95%+ of their time on going after "practicing without a license" even if it's accusing someone of pointing out something embarassing by using basic math.


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 Post subject: Re: Arc Flash Study Qualifications
PostPosted: Sun Sep 09, 2018 1:45 pm 
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Jim Phillips (brainfiller) wrote:
This week’s question may set off a bit of discussion.

A bit of an understatement on my part! Great discussion.


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 Post subject: Re: Arc Flash Study Qualifications
PostPosted: Sun Sep 09, 2018 4:16 pm 
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Jim Phillips (brainfiller) wrote:
Jim Phillips (brainfiller) wrote:
This week’s question may set off a bit of discussion.

A bit of an understatement on my part! Great discussion.


I think I mentioned it at the end but in my mind promoting the scientific method and peer reviewed standards should be the major purpose of engineering professional societies. This is where I'm a huge fanboy and offering nothing but kudos to what's going on with the IEEE 1584 WC. This has been going on within the IEEE and indeed was one of the major reasons that AIEE was established for over a century and it's their strongest contribution to the field of engineering. Setting up standards does two important things. First it establishes a methodology for approaching a given engineering problem such as establishing work methods for dealing with shock and arc flash hazards. Second it levels the playing field from a legal point of view. An engineer ought to be held accountable for providing poor opinions and advise (engineering malpractice/malfeasance) as well as providing an affirmative defense for engineering opinions and judgements based on peer reviewed standards. Without those standards, it is impossible to hold engineers to any kind of standard. So I have strong convictions in support of engineering societies like IEEE and their role in society.

A PE Stamp is sort of like signing sworn testimony, like a notary. Notaries by the way need no formal education other than most states have a few hours of training, keeping a log book, and some other very basic requirements. The stamp itself signifies that the state has certified a certain amount of education, passing a test, and having some witnesses sign off on experience claims. That's really all that it represents. It doesn't speak much to the character of quality of the work done. The state licensing board can sue someone for practicing without a license but that's pretty much the beginning and end of enforceable actions against poor workmanship unless there is an established written standard. Without it even if the state board was more aggressive, they don't have a leg to stand on.

Engineering standards create the standard for judging workmanship as well as establishing the procedures and methodology for performing work.

Consider my wife's credentials. She has worked for years as a chemist. She has been qualified in multiple courts as an expert witness. She underwent an interview discussing her work experience, credentials, qualification at other courts, etc., At the end the court decided whether or not her credentials were acceptable or not. Invariably they were accepted. PE licenses are little more than the same level of scrutiny. There is no reason short of economic ones (trade guild protectionism) that the PE license needs to exist. I'm not arguing for getting rid of the system because I feel that I'm fighting a losing battle on that front, only advocating against making the system out to be more than it is.

Even within the U.S. wide swaths of the engineering population don't have PE's and never will. It is not required for engineers employed by most utilities, most industrial plants, most state agencies, and all federal agencies. That's just in the U.S., never mind other countries. It's doubtful that we will ever get away from the PE system as it exists today but making it a requirement in a peer reviewed standard does not do justice to 90% of the engineers who might otherwise adopt the standard.

I'll come clean on why I really despise the whole idea of the PE system. This isn't just all the practical and theoretical reasons I mentioned. It's personal.

If it's not obvious off and on I've been a member of SME and IEEE among others, and worked inside of the industrial exemption side of things for almost 3 decades. More if you count before I had a degree but back then I was mostly doing software engineering (contract programming). Over time my employers gave me less and less time to pursue professional interests so I kind of dropped off the radar. I've pushed the envelope of science in many areas, particularly in the "soft" sciences such as mineral processing, which ended up in published technical papers and more than one that was patentable (we chose to go trade secret route)

I've supervised projects up to $15 MM in size and scope as a pure electrical project. Let me be clear on what I mean by "supervised". That means that I wrote the capital project requests, handled all the bidding, handled all the project management, from start to finish. To use an old term, the buck stops with me. When I was heavy into project engineering, my work load was about that number on an annual basis with usually 2-3 large multimillion dollar projects and a dozen smaller ones. That's "progression" as required by NCEES model standards if there ever was one. The only way to go "bigger" in electrical work is to either be doing power generation and transmission, or supervise a team of engineers with a larger work scope including mechanical. As the sole EE for a period of time for the entire division of the largest integrated phosphate mining operation in the world, I have been to the top of the mountain so to speak.

Most contract engineering firm EE's will never even approach a resume that looks like mine. For 80-90% of engineers who don't work for contract engineering houses (that's NSPE's number, not mine) the chance of working under the supervision of a PE is slim to none, including myself. I did a short stint at a contract engineering house, with roughly a 25% haircut to the pay check. Even if I had the PE, the hair cut would still be around 15-20%. Going forward the pay rate at that engineering house or others would not have been much improved by my analysis so I left the business pretty quickly and didn't look back. With a 6 digit salary, we're not arguing about pocket change here. This is in direct contrast with NSPE's claim that PE's make about 5% more. I don't know where they get their statistics but anecdotally speaking the PE would come in real handy in my current work but the experience requirement is all but impossible to meet, even with over 20 years of experience under my belt. By NCEES standards (written mostly by civil engineers) 3 of the 5 references you give have to be PE's and they have to vouch for the work you did under them. For me personally the year I worked with the big pay cut at the contract engineering firm is the first, last, and only time I was working directly under the supervision of a PE, although I've worked for a lot of engineers and some non-engineers over the years. I'm not alone in this regard, far from it. Most EE's that obtain a "PE" that work in the "industrial exemption sector" do it by finding 3 friends with PE's to vouch for them, not out of actual experience working directly under the supervision of a PE as they are supposed to do. Outside of certain fields of engineering (most notably civil), many engineering degrees rarely if ever have PE's so even finding 3 friends with PE's is no simply task, one I have yet to be successful at. I can get to 2 but not 3.

NSPE's push to make this a fundamental requirement to be an engineer is of course crazy because it shuts 90% of us out of making a living, including me. It would be one thing too if we had an established "profession" like doctors and lawyers back in the 1800's but the horse has left the barn on that. Trying to undo the last 200 years of history in turning engineering into a profession like doctors and lawyers runs afoul of the 80-90% of engineers that would be put out of work. Pushing for it in standards is fraught with similar problems. My experience really doesn't even suit contract engineering houses and my pay rate is so far above theirs that it's all but impossible for us to ever meet in the middle. So thus the "hair cut" problem. And as I said, I'm far from alone in this regard. Would you rather have someone doing arc flash calculations that has 20+ years of up close personal experience with equipment design, construction, installation, maintenance, repair, and an intimate knowledge of what can go wrong, or someone armed with a software program and a cell phone keying in information without any clue what they are looking at, relying on lay people to give them the answers, and spitting out a report at the end without even the capability of verifying the correctness of the results? This speaks directly to the competence issue but that's really what happens most of the time.

The idea of having someone competent to perform engineering studies is of course very valid but hard to achieve in practice. Enough postings have already been made on this thread pointing out the problem and no need to rehash others. So how do we prove competence? I can tell you how I've done it in the past. It's not cheap but it works. The way to do it is to have person or firm A do the work and to have person or firm B check their work. This is no different than the draftsman and checker system that we used on drawings years ago although most firms have done away with this, or the Listing system that we use with third party verification on product standards for electrical products. It can be relatively inexpensive to do so if the system is already established but it's pretty hard to do starting from scratch. The "PE system" if used as intended of course is a mentoring system which again establishes two people with different backgrounds performing and checking the work.

And even if this all seems crazy ridiculous, in the "big project" I mentioned earlier ($15 MM electrical project), I set up an outside engineering/equipment builder, installer, and construction supervisor. The installer was competent with the design and served to check the engineering firm and vice versa. The construction supervisor was there daily watching both of them paying attention to day-to-day tasks the installer and subs were doing as well as coordinating with other work crews outside the electrical work, and I stayed outside the system and acted as QA verifying that all three were checking behind each other as well as serving as mediator when required. The project was completed on time, on budget, with very minor safety incidents outside of one that became a learning experience for the safety department, and met all the stated objectives. And yes, we did an arc flash study too along the way, along with mitigation. The whole system even at 12-15 MW peak demand was under 1.2 cal/cm2 everywhere, no small feat and not one that a glorified key punch operator with an engineering software program could hope to achieve.

This is a far cry from throwing the paper over the wall and asking an outside engineering firm to do an "arc flash study" and taking everything they say at face value only without doing any sort of checking or verification, in house or otherwise. Even without performing the math involved a technician of average skill armed with a basic understanding of how arc flash works should be able to look at an arc flash study and verify the correctness of the results, especially because all the heavy lifting (calculations) is typically done by a computer program. A PE license is not and should not be a substitute for quality control on the work that is being performed.

A PE license is little more than a certificate from say an arc flash study training class put on by Jim Phillips. It's an indicator of competence but nothing else. There is a claim that somehow stamping attaches a higher level of liability to the work product but we can all agree that this is a very, very weak argument. Anything written, even informal E-mails and most recently texting by government agents to their girl friends on company cell phones, can and have become evidence in legal proceedings.

If anything my argument for controlling work quality (IEEE 1584.1 requirements) would be some kind of verification or quality control procedure on the work product. All safety standards specifically specify that reviews of hazards and risk should be undertaken by a multidisciplinary team for two reasons. The first one is simply to get a diversity of opinion so that we leave no stone unturned. As an electrical engineer I see the world differently from a safety professional who sees the world differently from a production supervisor, operator, mechanic, or electrician. The second reason is that hopefully the team structure is set up in such a way that when one particular team member makes a judgement error, hopefully one or more members of the same team catch the error and correct it. There are of course standards speaking to different roles such as "coach", "team champion", "clerk", and so forth which are intended to improve team dynamics but we're getting so far afield that such requirements can't really be folded into IEEE 1584.1. At best they might be incorporated by reference.

For me personally I've been called to participate in countless teams where an outside engineering firm was commissioned to do some kind of risk/hazard survey and they stuck something in there that was an obvious, blatant screw up. Just in terms of arc flash for instance one of those was to ignore cable impedance and use the infinite bus assumption for calculating available fault current. Another one was to determine "maintenance switch" requirements by picking the lowest setting on circuit breakers without regard for whether or not this was even feasible. Still another was to perform the entire arc flash study with all mains and all ties on double ended substations closed. Still another was to assume throughout the entire study that both incoming lines were done and only generator power was in operation as a "normal" operating state despite 50 years of never having operated under those conditions because it produced "conservative" (wrong) results. Still another was to use the Lee equation results for 23 kV and 230 kV systems, and then multiply by 2 somewhat arbitrarily. Still another was to apply 24" working distance rules to cutout switches mounted over 20 feet off the ground that were operated either from a bucket truck 8 feet away or from the ground with telescoping hot sticks. Still another was to assume 10 seconds instead of 2 seconds without really any justification at all. Still another was when doing risk assessments to basically run the calculations then direct the plant to simply use 40 cal suits for all work irrespective of incident energy rating because the condition of maintenance was not part of the scope of work. Worse still all of these decisions were made by licensed PE's and initially accepted because the results were "thrown over the wall" without any kind of review system in place, with the obvious glaring technical and operational issues that resulted. Most but not all of them were done by one particular large nationally recognized engineering firm that at least gave the impression that they had an internal review system in place.

My argument thus calls not for certifications and similar paperwork but rather establishing an effective review process for the work product. It's only be establishing such a process that companies can hope to avoid many of the obvious glaring technical issues that have been pointed out in this thread. So please, please don't contaminate engineering standards with crazy stupid competence requirements that do anything but establish competence. Among others I hate to mention them again but AiChE really is on the forefront of this kind of thing. And there are two major differences. First, chemical engineering is even more varied in terms of the types and scope of hazards that they encounter. Second chemical engineering is far more of a "soft science" compared to electrical engineering. They've been at it addressing major risks in chemical systems that don't just severely injure one or two electricians but have the potential to wipe entire cities off the map. When it comes to addressing risks and hazards, they are truly on the forefront of standards development and there is no harm in stealing truly good ideas. They've done a pretty good job of establishing what an effective risk assessment process is and there is no reason for IEEE or NFPA to try to blaze new territory in this regard with the track record of that group.


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 Post subject: Re: Arc Flash Study Qualifications
PostPosted: Mon Sep 10, 2018 8:26 am 
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PaulEngr wrote:

Obviously this is intended to point out how ridiculous the whole idea of "self policing" is?


Not at all. I don't find it ridiculous, and take it seriously. I would be risking my own license, something I worked hard to achieve, if I were to fail to report unlicensed practice I became aware of.


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 Post subject: Re: Arc Flash Study Qualifications
PostPosted: Thu Sep 13, 2018 10:40 am 
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stevenal wrote:
PaulEngr wrote:

Obviously this is intended to point out how ridiculous the whole idea of "self policing" is?


Not at all. I don't find it ridiculous, and take it seriously. I would be risking my own license, something I worked hard to achieve, if I were to fail to report unlicensed practice I became aware of.


It's ridiculous to expect unlicensed engineers to self-police. As you stated the only way to do this is to ask the question and see if you get anyone to own up, which is obviously crazy, unless you encounter it somewhere along the way in practice.

It is even more ridiculous to expect licensed engineers to actually enforce workmanship. It is simple to prove unlicensed engineers performing work which requires a license, usually when they advertise and someone starts checking their credentials. It is much harder to prove engineers performed poor workmanship, licensed or not.


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 Post subject: Re: Arc Flash Study Qualifications
PostPosted: Wed Sep 19, 2018 11:42 am 

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Hello Jim and AF Forum,
use of IEEE 1584 for North American onshore installations seems clear and the need to use or be guided by an experienced PE.

However, what about on ships, and particularly cruise ships that are built and operated all over the world...
For example, Lloyds Register ship Rules, now require IEEE 1584 guidance to be considered when designing and building new ships with HV switchgear and distribution systems.
These ship designs and the arc flash calculations required thereof might not be carried out by people that are professionally registered in North America.
Though the ship might sail and operate in the North American sector.

What i am really asking here: will the IEEE 1584 guide, acknowledge global PE equivanace when looking at the responsible person who carried out the arc flash calculations?
thank you


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 Post subject: Re: Arc Flash Study Qualifications
PostPosted: Thu Sep 20, 2018 3:22 am 

Joined: Wed Sep 19, 2018 11:28 am
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Mackem wrote:
Hello Jim and AF Forum,
use of IEEE 1584 for North American onshore installations seems clear and the need to use or be guided by an experienced PE.

However, what about on ships, and particularly cruise ships that are built and operated all over the world...
For example, Lloyds Register ship Rules, now require IEEE 1584 guidance to be considered when designing and building new ships with HV switchgear and distribution systems.
These ship designs and the arc flash calculations required thereof might not be carried out by people that are professionally registered in North America.
Though the ship might sail and operate in the North American sector.

What i am really asking here: will the IEEE 1584 guide, acknowledge global PE equivalence when looking at the responsible person who carried out the arc flash calculations?
thank you


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 Post subject: Re: Arc Flash Study Qualifications
PostPosted: Thu Sep 20, 2018 3:09 pm 
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Mackem wrote:
Hello Jim and AF Forum,
use of IEEE 1584 for North American onshore installations seems clear and the need to use or be guided by an experienced PE.

However, what about on ships, and particularly cruise ships that are built and operated all over the world...
For example, Lloyds Register ship Rules, now require IEEE 1584 guidance to be considered when designing and building new ships with HV switchgear and distribution systems.
These ship designs and the arc flash calculations required thereof might not be carried out by people that are professionally registered in North America.
Though the ship might sail and operate in the North American sector.

What i am really asking here: will the IEEE 1584 guide, acknowledge global PE equivalence when looking at the responsible person who carried out the arc flash calculations?
thank you


The scope of IEEE 1584 is for the calculation of incident energy, arcing short circuit current and arc flash boundary. There are not any qualification requirements regarding who can perform the study in the standard. That is often up to the state, provincial boards or something similar. Although there are exemptions as discussed here.

IEEE 1584.1 (which is next in the cue for updating) does reference minimal qualifications and has a note about state boards but it is a guide. From clause 3.4 of IEEE 1584.1:

The arc-flash study should be performed by, or under the direction of, a qualified person with the necessary
knowledge about power system analysis and arc-flash hazard analysis or experience in performing power
system analysis and arc-flash hazard analysis. It is recommended that engineers who are new to performing
the studies obtain peer or third party reviews from a more experienced engineer in this specific subject.
NOTE—Engineering licensing requirements of individual jurisdictions (states and/or provinces/nationalities) may
require the analysis to be performed by, or under the direction of, a registered professional engineer.


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