Who has the legal responsibility for ensuring a cabinet is labeled or has a study conducted for Arc Flash boundaries and PPE? The manufacture, installer, or owner of the equipment?
Ultimately the owner is responsible for their equipment. The owner's insurance may require labeling/listing.
The installer may have to pass an inspection where the local inspector will require labeled/listed equipment.
The manufacturer only needs to provide labeled/listed/tested if required.
If there is no inspection by a local or insurance authority then there may be insurance issues if there is an actual claim.
If the installation is done right and following the code then everybody will be on board. If there is no specification for the equipment to labeled/listed the installer should still put the correct. Per the NEC 110.2 requires equipment to be approved but not labeled/listed but labeling/listing will generally get it approved.
Hope that helps
Thank you this helps. To get a little more specific, I'm wondering at what point/by whom is it required to find out what PPE is required.
If I am the manufacturer and installer - and plan to have my employees do software commissioning inside that cabinet (live) - is it then my responsibility to have the equipment receive an adequate analysis, or is it the customer who will ultimately own the equipment once it's up and running?
If my customer wants to wait until they have full turn over of the equipment to do the analysis, do we have a legal argument to ensure it's done prior to our work being conducted?
There are a number of factors. I will assume this equipment will have three phase power and 480V. There needs to be design work done to verify that it will meet the short-circuit rating, voltage...... If one has that information then the arc flash is easy. It sort of sounds like the owner is asking for equipment to be installed (they are doing the "design") and you are providing the equipment and commissioning your equipment. The equipment must be adequate for installation but the manufacturer needs to have the parameters to design to and only the designer/owner can do that.
If you are trying to determine what PPE your people need to do the work it might be your responsibility to do the calculation but you would need information on the electric system from the owner. If they pay you for doing that calculation then you can share that information, if not - that is your choice.
I would say in this case, with the limited info, there seems to be a design portion missing on the owners part and they expect you to provide that. If that was not specified and you are not doing the install (hooking to the power source) then you are limited to the inside of the equipment
The original installer is responsible for labeling the equipment, however the labeling of the equipment may not have been required when installed. If any equipment was repaired, replaced, or added to the system, the installer at that time is responsible for re-labeling the equipment. That's why the date the calculation was performed is always required to be part pf the label.
The owner of the equipment is also responsible for properly maintaining the equipment and for providing the proper PPE to anyone working on the equipment.
Good morning Brian,
In order to better clarify would you include references to substantiate. I have found that people that initiate an inquiry are often doing so to gather the tools needed to better communicate or to reach a mutual understanding.
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