California Code of Regulations
Title 8 - Industrial Relations
Division 1 - Department of Industrial Relations
Chapter 4 - Division of Industrial Safety
Subchapter 5 - Electrical Safety Orders
Group 2 - High-Voltage Electrical Safety Orders
Article 36 - Work Procedures and Operating Procedures
Appendix D - Protection from Flames and Electric Arcs

Current through Register 2024 Notice Reg. No. 38, September 20, 2024

I. Introduction

Section 2940.11 addresses protecting employees from flames and electric arcs. This ssection requires employers to: (1) Assess the workplace for flame and electric-arc hazards; (2) estimate the available heat energy from electric arcs to which employees would be exposed; (3) ensure that employees wear clothing that will not melt, or ignite and continue to burn, when exposed to flames or the estimated heat energy; and (4) ensure that employees wear flame-resistant clothing [FN1] and protective clothing and other protective equipment that has an arc rating greater than or equal to the available heat energy under certain conditions. This appendix contains information to help employers estimate available heat energy, select protective clothing and other protective equipment with an arc rating suitable for the available heat energy, and ensure that employees do not wear flammable clothing that could lead to burn injury.

II. Assessing the Workplace for Flame and Electric-Arc Hazards

Section 2940.11(a)(1) requires the employer to assess the workplace to identify employees exposed to hazards from flames or from electric arcs. This provision ensures that the employer evaluates employee exposure to flames and electric arcs so that employees who face such exposures receive the required protection. The employer shall conduct an assessment for each employee who performs work on or near exposed, energized parts of electric circuits.

A. Assessment Guidelines

Sources electric arcs. Consider possible sources of electric arcs, including:

* Energized circuit parts not guarded or insulated,

* Switching devices that produce electric arcs in normal operation,

* Sliding parts that could fault during operation (for example, rack-mounted circuit breakers), and

* Energized electric equipment that could fail (for example, electric equipment with damaged insulation or with evidence of arcing or overheating)

Exposure to flames. Identify employees exposed to hazards from flames. Factors to consider include:

* The proximity of employees to open flames, and

* For flammable material in the work area, whether there is a reasonable likelihood that an electric arc or an open flame can ignite the material.

Probability that an electric arc will occur. Identify employees exposed to electric-arc hazards. The Division of Occupational Safety and Health will consider an employee exposed to electric-arc hazards if there is a reasonable likelihood that an electric arc will occur in the employee's work area, in other words, if the probability of such an event is higher than it is for the normal operation of enclosed equipment. Factors to consider include:

* For energized circuit parts not guarded or insulated, whether conductive objects can come too close to or fall onto the energized parts,

* For exposed, energized circuit parts, whether the employee is closer to the part than the minimum approach distance established by the employer (as permitted by Section 2940.2)

* Whether the operation of electric equipment with sliding parts that could fault during operation is part of the normal operation of the equipment or occurs during servicing or maintenance, and

* For energized electric equipment, whether there is evidence of impending failure, such as evidence of arcing or overheating.

B. Examples

Table 1 provides task-based examples of exposure assessments.

III. Protection Against Burn Injury

A. Estimating Available Heat Energy

Calculation methods. Subsection (a)(2) of Section 2940.11 provides that, for each employee exposed to an electric-arc hazard, the employer shall make a reasonable estimate of the heat energy to which the employee would be exposed if an arc occurs. Table 2 lists various methods of calculating values of available heat energy from an electric circuit. The Division of Occupational Safety and Health does not endorse any of these specific methods. Each method requires the input of various parameters, such as fault current, the expected length of the electric arc, the distance from the arc to the employee, and the clearing time for the fault (that is, the time the circuit protective devices take to open the circuit and clear the fault). The employer can precisely determine some of these parameters, such as the fault current and the clearing time, for a given system. The employer will need to estimate other parameters, such as the length of the arc and the distance between the arc and the employee, because such parameters vary widely.

TABLE 2 -- METHODS OF CALCULATING INCIDENT HEAT ENERGY FROM AN ELECTRIC ARC

1. Standard for Electrical Safety Requirements for Employee Workplaces, NFPA 70E-2012, Annex D, "Sample Calculation of Flash Protection Boundary."

2. Doughty, T.E., Neal, T.E., and Floyd II, H.L., "Predicting Incident Energy to Better Manage the Electric Arc Hazard on 600 V Power Distribution Systems," Record of Conference Papers IEEE IAS 45th Annual Petroleum and Chemical Industry Conference, September 28-30, 1998.

3. Guide for Performing Arc-Flash Hazard Calculations, IEEE Std 1584-2002, 1584a-2004 (Amendment 1 to IEEE Std 1584-2002), and 1584b-2011 (Amendment 2: Changes to Clause 4 of IEEE Std 1584-2002).*

4. ARCPRO, a commercially available software program developed by Kinectrics, Toronto, ON, CA.

* This appendix refers to IEEE Std 1584-2002 with both amendments as IEEE Std 1584b-2011.

The amount of heat energy calculated by any of the methods is approximately inversely proportional to the square of the distance between the employee and the arc. In other words, if the employee is very close to the arc, the heat energy is very high; but if the employee is just a few more centimeters away, the heat energy drops substantially. Thus, estimating the distance from the arc to the employee is key to protecting employees.

The employer shall select a method of estimating incident heat energy that provides a reasonable estimate of incident heat energy for the exposure involved. Table 3 shows which methods provide reasonable estimates for various exposures.

NOTES:

1 Although the Division of Occupational Safety and Health will consider these methods reasonable for enforcement purposes when employers use the methods in accordance with this table, employers should be aware that the listed methods do not necessarily result in estimates that will provide full protection from internal faults in transformers and similar equipment or from arcs in underground manholes or vaults.

2 At these voltages, the presumption is that the arc is three-phase unless the employer can demonstrate that only one phase is present or that the spacing of the phases is sufficient to prevent a multiphase arc from occurring.

3 Although the Division of Occupational Safety and Health will consider this method acceptable for purposes of assessing whether incident energy exceeds 2.0 cal/cm2, the results at voltages of more than 15 kilovolts are extremely conservative and unrealistic.

4 The Division of Occupational Safety and Health will deem the results of this method reasonable when the employer adjusts them using the conversion factors for three-phase arcs in open air or in an enclosure, as indicated in the program's instructions.

Selecting a reasonable distance from the employee to the arc. In estimating available heat energy, the employer shall make some reasonable assumptions about how far the employee will be from the electric arc. Table 4 lists reasonable distances from the employee to the electric arc. The distances in Table 4 are consistent with national consensus standards, such as the Institute of Electrical and Electronic Engineers' National Electrical Safety Code, ANSI/IEEE C2-2012, and IEEE Guide for Performing Arc-Flash Hazard Calculations, IEEE Std 1584b-2011. The employer is free to use other reasonable distances, but shall consider equipment enclosure size and the working distance to the employee in selecting a distance from the employee to the arc. The Division of Occupational Safety and Health will consider a distance reasonable when the employer bases it on equipment size and working distance.

* NA = not applicable.

[DAGGER] The terms in this equation are:

MAD = The applicable minimum approach distance, and

kV = The system voltage in kilovolts.

Selecting a reasonable arc gap. For a single-phase arc in air, the electric arc will almost always occur when an energized conductor approaches too close to ground. Thus, an employer can determine the arc gap, or arc length, for these exposures by the dielectric strength of air and the voltage on the line. The dielectric strength of air is approximately 10 kilovolts for every 25.4 millimeters (1 inch). For example, at 50 kilovolts, the arc gap would be 50 / 10 x 25.4 (or 50 x 2.54), which equals 127 millimeters (5 inches).

For three-phase arcs in open air and in enclosures, the arc gap will generally be dependent on the spacing between parts energized at different electrical potentials. Documents such as IEEE Std 1584b-2011 provide information on these distances. Employers may select a reasonable arc gap from Table 5, or they may select any other reasonable arc gap based on sparkover distance or on the spacing between (1) live parts at different potentials or (2) live parts and grounded parts (for example, bus or conductor spacings in equipment). In any event, the employer shall use an estimate that reasonably resembles the actual exposures faced by the employee.

1 Source: IEEE Std 1584b-2011.

2 NA = not applicable.

Making estimates over multiple system areas. The employer need not estimate the heat-energy exposure for every job task performed by each employee. Subsection (a)(2) of Section 2940.11 permits the employer to make broad estimates that cover multiple system areas provided that: (1) The employer uses reasonable assumptions about the energy-exposure distribution throughout the system, and (2) the estimates represent the maximum exposure for those areas. For example, the employer can use the maximum fault current and clearing time to cover several system areas at once.

Incident heat energy for single-phase-to-ground exposures. Table 6 and Table 7 provide incident heat energy levels for open air, phase-to-ground electric-arc exposures typical for overhead systems. [FN2] Table 6 presents estimates of available energy for employees using rubber insulating gloves to perform work on overhead systems operating at 4 to 46 kilovolts. The table assumes that the employee will be 380 millimeters (15 inches) from the electric arc, which is a reasonable estimate for rubber insulating glove work. Table 6 also assumes that the arc length equals the sparkover distance for the maximum transient overvoltage of each voltage range. [FN3] To use the table, an employer would use the voltage, maximum fault current, and maximum clearing time for a system area and, using the appropriate voltage range and fault-current and clearing time values corresponding to the next higher values listed in the table, select the appropriate heat energy (4, 5, 8, or 12 cal/cm2) from the table. For example, an employer might have a 12,470-volt power line supplying a system area. The power line can supply a maximum fault current of 8 kiloamperes with a maximum clearing time of 10 cycles. For rubber glove work, this system falls in the 4.0-to-15.0-kilovolt range; the next-higher fault current is 10 kA (the second row in that voltage range); and the clearing time is under 18 cycles (the first column to the right of the fault current column). Thus, the available heat energy for this part of the system will be 4 cal/cm2 or less (from the column heading), and the employer could select protection with a 5-cal/cm2 rating to meet Section 2940.11(b)(2). Alternatively, an employer could select a base incidentenergy value and ensure that the clearing times for each voltage range and fault current listed in the table do not exceed the corresponding clearing time specified in the table. For example, an employer that provides employees with arc-flash protective equipment rated at 8 cal/cm2 can use the table to determine if any system area exceeds 8 cal/cm2 by checking the clearing time for the highest fault current for each voltage range and ensuring that the clearing times do not exceed the values specified in the 8-cal/cm2 column in the table.

Table 7 presents similar estimates for employees using live-line tools to perform work on overhead systems operating at voltages of 4 to 800 kilovolts. The table assumes that the arc length will be equal to the sparkover distance [FN4] and that the employee will be a distance from the arc equal to the minimum approach distance minus twice the sparkover distance.

The employer will need to use other methods for estimating available heat energy in situations not addressed by Table 6 or Table 7. The calculation methods listed in Table 2 and the guidance provided in Table 3 will help employers do this. For example, employers can use IEEE Std 1584b-2011 to estimate the available heat energy (and to select appropriate protective equipment) for many specific conditions, including lower voltage, phase-to-phase arc, and enclosed arc exposures.

NOTES:

* This table is for open-air, phase-to-ground electric-arc exposures. It is not for phase-to-phase arcs or enclosed arcs (arc in a box).

[DAGGER] The table assumes the arc length to be the sparkover distance for the maximum phase-to-ground voltage of each voltage range (see Appendix A). The table also assumes that the employee will be the minimum approach distance minus twice the arc length from the electric arc.

[DOUBLE DAGGER] The Department of Labor, Occupational Safety and Health Administration calculated the values in this table using the ARCPRO method listed in Table 2.

# For voltages of more than 72.6 kV, employers may use this table only when the minimum approach distance established under Section 2940.2 (a) is greater than or equal to the following values:

** The voltage range is the phase-to-phase system voltage.

B. Selecting Protective Clothing and Other Protective Equipment

Subsection (b) of Section 2940.11 requires employers, in certain situations, to select protective clothing and other protective equipment with an arc rating that is greater than or equal to the incident heat energy estimated under Section 2940.11(a)(2). Based on laboratory testing required by ASTM F1506-10a, the expectation is that protective clothing with an arc rating equal to the estimated incident heat energy will be capable of preventing second-degree burn injury to an employee exposed to that incident heat energy from an electric arc. Note that actual electric-arc exposures may be more or less severe than the estimated value because of factors such as arc movement, arc length, arcing from reclosing of the system, secondary fires or explosions, and weather conditions. Additionally, for arc rating based on the fabric's arc thermal performance value [FN5] (ATPV), a worker exposed to incident energy at the arc rating has a 50-percent chance of just barely receiving a second-degree burn. Therefore, it is possible (although not likely) that an employee will sustain a second-degree (or worse) burn wearing clothing conforming to Section 2940.11(b)(2) under certain circumstances. However, reasonable employer estimates and maintaining appropriate minimum approach distances for employees should limit burns to relatively small burns that just barely extend beyond the epidermis (that is, just barely a second degree burn). Consequently, protective clothing and other protective equipment meeting Section 2940.11(b)(2) will provide an appropriate degree of protection for an employee exposed to electric-arc hazards.

Subsection (b)(2) of Section 2940.11 does not require arc-rated protection for exposures of 2 cal/cm2 or less. Untreated cotton clothing will reduce a 2-cal/cm2 exposure below the 1.2- to 1.5-cal/cm2 level necessary to cause burn injury, and this material should not ignite at such low heat energy levels. Although Section 2940.11(b)(2) does not require clothing to have an arc rating when exposures are 2 cal/cm2 or less, Section 2940.11(b)(1) requires the outer layer of clothing to be flame resistant under certain conditions, even when the estimated incident heat energy is less than 2 cal/cm2, as discussed later in this appendix.

Additionally, it is especially important to ensure that employees do not wear undergarments made from fabrics listed in Section 2940.6(j) even when the outer layer is flame resistant or arc rated. These fabrics can melt or ignite easily when an electric arc occurs. Logos and name tags made from non-flame-resistant material can adversely affect the arc rating or the flame resistant characteristics of arc-rated or flame resistant clothing. Such logos and name tags may violate Section 2940.11(b), (b)(1), or (b)(2).

Subsection (b)(2) of Section 2940.11 requires that arc-rated protection cover the employee's entire body, with limited exceptions for the employee's hands, feet, face, and head. Subsection (b)(2)(A) of Section 2940.11 provides that arc-rated protection is not necessary for the employee's hands under the following conditions:

Subsection (b)(2)(B) of Section 2940.11 provides that arc-rated protection is not necessary for the employee's feet when the employee is wearing heavy-duty work shoes or boots. Finally, Section 2940.11(b)(2)(C), (b)(2)(D), and (b)(2)(E) require arc-rated head and face protection as follows:

* These ranges assume that employees are wearing hardhats meeting the specifications in Section 3381, as applicable.

[DAGGER] The arc rating shall be a minimum of 4 cal/cm2 less than the estimated incident energy. Note that Section 2940.11(b)(2)(E) permits this type of head and face protection, with a minimum arc rating of 4 cal/cm2 less than the estimated incident energy, at any incident energy level.

[DOUBLE DAGGER] Note that Section 2940.11(a)(5) permits this type of head and face protection at any incident energy level.

IV. Protection Against Ignition

Subsection (b) of Section 2940.11 prohibits clothing that could melt onto an employee's skin or that could ignite and continue to burn when exposed to flames or to the available heat energy estimated by the employer under Section 2940.11(a)(2). Meltable fabrics, such as acetate, nylon, polyester, and polypropylene, even in blends, shall be avoided. When these fibers melt, they can adhere to the skin, thereby transferring heat rapidly, exacerbating burns, and complicating treatment. These outcomes can result even if the meltable fabric is not directly next to the skin. The remainder of this section focuses on the prevention of ignition.

Section 2940.11(b)(2) generally requires protective clothing and other protective equipment with an arc rating greater than or equal to the employer's estimate of available heat energy. As explained earlier in this appendix, untreated cotton is usually acceptable for exposures of 2 cal/cm2 or less. [FN6] If the exposure is greater than that, the employee generally shall wear flame-resistant clothing with a suitable arc rating in accordance with Section 2940.11(b)(1) and (b)(2). However, even if an employee is wearing a layer of flame-resistant clothing, there are circumstances under which flammable layers of clothing would be uncovered, and an electric arc could ignite them. For example, clothing ignition is possible if the employee is wearing flammable clothing under the flame-resistant clothing and the underlayer is uncovered because of an opening in the flame-resistant clothing. Thus, for purposes of Section 2940.11(b), it is important for the employer to consider the possibility of clothing ignition even when an employee is wearing flame-resistant clothing with a suitable arc rating.

Under Section 2940.6(j), employees may not wear flammable clothing in conjunction with flame-resistant clothing if the flammable clothing poses an ignition hazard. [FN7] Although outer flame-resistant layers may not have openings that expose flammable inner layers, when an outer flame-resistant layer would be unable to resist breakopen, [FN8] the next (inner) layer shall be flame-resistant if it could ignite.

Non-flame-resistant clothing can ignite even when the heat energy from an electric arc is insufficient to ignite the clothing. For example, nearby flames can ignite an employee's clothing; and, even in the absence of flames, electric arcs pose ignition hazards beyond the hazard of ignition from incident energy under certain conditions. In addition to requiring flame-resistant clothing when the estimated incident energy exceeds 2.0 cal/cm2, Section 2940.11(b)(1) requires flame-resistant clothing when: The employee is exposed to contact with energized circuit parts operating at more than 600 volts [Section 2940.11(b)(1)(A)], an electric arc could ignite flammable material in the work area that, in turn, could ignite the employee's clothing [Section 2940.11(b)(1)(B)], and molten metal or electric arcs from faulted conductors in the work area could ignite the employee's clothing [Section 2940.11(b)(1)(C)]. For example, grounding conductors can become a source of heat energy if they cannot carry fault current without failure. The employer shall consider these possible sources of electric arcs [FN9] in determining whether the employee's clothing could ignite under Section 2940.11(b)(1)(C).[FN1]

Flame-resistant clothing includes clothing that is inherently flame resistant and clothing chemically treated with a flame retardant. (See ASTM F1506-10a, Standard Performance Specification for Flame Resistant Textile Materials for Wearing Apparel for Use by Electrical Workers Exposed to Momentary Electric Arc and Related Thermal Hazards, and ASTM F1891-12 Standard Specification for Arc and Flame Resistant Rainwear.)[FN2]

The Department of Labor, Occupational Safety and Health Administration used metric values to calculate the clearing times in Table 6 and Table 7. An employer may use English units to calculate clearing times instead even though the results will differ slightly.[FN3]

The Department of Labor, Occupational Safety and Health Administration based this assumption, which is more conservative than the arc length specified in Table 5, on Table 410-2 of the 2012 NESC.[FN4]

The dielectric strength of air is about 10 kilovolts for every 25.4 millimeters (1 inch). Thus, the employer can estimate the arc length in millimeters to be the phase-to-ground voltage in kilovolts multiplied by 2.54 (or voltage (in kilovolts) x 2.54).[FN5]

ASTM F1506-10a defines "arc thermal performance value" as "the incident energy on a material or a multilayer system of materials that results in a 50% probability that sufficient heat transfer through the tested specimen is predicted to cause the onset of a second-degree skin burn injury based on the Stoll [footnote] curve, cal/cm2." The footnote to this definition reads: "Derived from: Stoll, A. M., and Chianta, M. A., 'Method and Rating System for Evaluations of Thermal Protection,' Aerospace Medicine, Vol 40, 1969, pp. 1232-1238 and Stoll, A. M., and Chianta, M. A., 'Heat Transfer through Fabrics as Related to Thermal Injury,' Transactions-New York Academy of Sciences, Vol 33(7), Nov. 1971, pp. 649-670."[FN6]

See Section 2940.11(a)(4)(A), (a)(4)(B), and (a)(4)(C) for conditions under which employees shall wear flame-resistant clothing as the outer layer of clothing even when the incident heat energy does not exceed 2 cal/cm2.[FN7]

Subsection (a)(3) of Section 2940.11 prohibits clothing that could ignite and continue to burn when exposed to the heat energy estimated under subsection (a)(2) of that section.[FN8]

Breakopen occurs when a hole, tear, or crack develops in the exposed fabric such that the fabric no longer effectively blocks incident heat energy.[FN9]

Static wires and pole grounds are examples of grounding conductors that might not be capable of carrying fault current without failure. Grounds that can carry the maximum available fault current are not a concern, and employers need not consider such grounds a possible electric arc source.

1. New Appendix D filed 2-27-2018; operative 4-1-2018 (Register 2018, No. 9).

Note: Authority cited: Section 142.3, Labor Code. Reference: Section 142.3, Labor Code.