16.2 Other EU Directives

The following is a list of EU directives that have most impact, in addition to the Framework Directive, on the management of the arc flash hazard.

16.2.1 PPE Directive

European Council Directive 89/656/EEC covers the minimum health and safety requirements for the use by workers of personal protective equipment at the workplace.

The PPE Directive sets the minimum requirements for the assessment, selection and correct use of personal protective equipment. Priority must be given to collective safety measures. PPE can only be used where the existing risks cannot be sufficiently limited by technical means or collective protection or work organization procedures. The employer must also provide the appropriate equipment free of charge and ensure that it is in good working order and hygienic condition.

PPE can only be prescribed after the employer has analysed the risks which cannot be avoided by other means. For arc flash this means an employer must consider other means of achieving safety prior to considering the use of PPE such as the elimination of hazard, engineering controls and safe systems of work. Issues of use, which must be part of the risk assessment process, must include ergonomics, sensory deprivation of user, continuing integrity of PPE and other injury mechanisms, including loss of hearing and sight. In summary, PPE must be used as a last resort.

16.2.2 Use of Work Equipment Directive 2009/104/EC

The Use of Work Equipment Directive 2009/104/EC defines the minimum health & safety requirements for the operation of work equipment by employees at work.

The employer is obliged to take every measure to ensure the safety of the work equipment made available to workers. During the selection of the work equipment the employer shall pay attention to the specific working conditions which exist at the workplace, especially in relation to the health and safety of workers. If risks cannot be fully eliminated during the operation of the work equipment, the employer shall take appropriate measures to minimize them. Employers have to provide workers with adequate, comprehensible information, usually in the form of written instructions, not only for the use of the equipment but also foreseeable abnormal situations. Workers shall be made aware of dangers relevant to them. The employer shall ensure that workers receive adequate training, including risks and specific training on specific risk equipment.

Arc flash risk enhancing situations such as the lack of proper equipment maintenance, inadequate equipment design and installation, deficient commissioning and initial inspection and poor worker competence should not happen if working within the “Use of Work Equipment Directive”.

16.2.3 Provision of Health and Safety Signs at Work.

Council Directive 92/58/EEC defines the minimum requirements for the provision of health and/or safety signs at work and complements the Framework Directive 89/391/EEC on health and safety at work.

This directive states that safety and/or health signs must be provided where hazards cannot be adequately reduced by techniques for collective protection or by measures, methods or procedures used in the organization of work. In other words, as required by a risk assessment in circumstances where risks to health and safety have not been avoided by other means, for example engineering controls or safe systems of work. Signs must be standardized across Europe in a way in which will reduce the hazards which may arise from linguistic and cultural differences between workers.

Safety signs are to warn of any remaining significant risk or to instruct employees of the measures they must take in relation to these risks. It is very important that employees fully understand the meaning of such safety signs and are aware of the consequences of not following the warning or instruction given by the sign.

It should be noted that arc flash labelling and field marking must conform to Directive 92/58/EEC and in fact labels based on the U.S. ANSI Z535 Standard would not be acceptable in most instances.

16.3 UK and Ireland

Most legislation in member states is driven by acts and regulations backed up by codes of practice and voluntary guidance based on national and international standards. It is through this local legislation that the EU Framework Directive is translated.

The cornerstone of this legislation is risk assessment and there is a move away from prescriptive measures which may involve a direct link from the arc flash hazard into PPE. In other words, the goal is to eliminate, minimise or mitigate the hazard before considering PPE. A result of this is a much lower tolerance of live working for workers in the industrial sectors and even utility workers will have to justify working on or near energized conductors. For instance, in Ireland and the United Kingdom the regulations covering live working are stated as follows.

Regulation 14 of the UK Electricity at Work Regulations 1989 (EAWR) and 86d of the Irish Safety Health and Welfare at Work (General Application) Regulations requires that three conditions are met for live working to be permitted where danger may arise. It is stressed that if just one of these conditions cannot be met, live working cannot be permitted, and dead working is necessary. The conditions are:

1. It is unreasonable in all the circumstances for the conductor to be dead; and
2. It is reasonable in all the circumstances for the person to be at work on or near that conductor while it is live; and
3. Suitable precautions (including, where necessary, the provision of personal protective equipment) have been taken to prevent injury.