THE FINAL FRONTIER SAFETY BY DESIGN: EMERGING STANDARDS AND

DESIGNS IN LOW-VOLTAGE MOTOR CONTROL ASSEMBLIES

Copyright Material IEEE
2008 IAS/PCA CIC

David B. Durocher
Senior Member, IEEE
Industry Director
Eaton Corporation
26850 SW Kinsman Road
Wilsonville, OR 97070
USA


Daleep Mohla
Fellow, IEEE
Industry Consultant
DCM Consulting Services, Inc.
4702 Summer Lakes
Missouri City, TX 77459
USA


Abstract - Over the past several years a growing focus
on improved electrical safety has arisen. A better
understanding of both electrical shock and arc flash
hazards faced by personnel working on or near energized
equipment has led to consensus standards such as the
NFPA-70E. These standards deal primarily with safe work
practices designed to identify and quantify the hazard,
then assure that personnel are clothed with appropriate
personal protecti ve equipment (PPE) to reduce the risk.
Consensus opinion among safety experts is that the best
method to reduce the risk of injury is by designing the
hazards out. The next frontier in reducing electrical
injuries will arise from improved designs of electrical
products which mitigate hazards by design. One primary
product area of interest is the low-voltage motor control
center used for control of motors rated 1000 volts and
below. In process applications such as cement, pulp &
paper and petroleum & chemical plants, maintenance
personnel often find it necessary to work on, or near,
energized motor control centers while performing
maintenance and operational acti vities.

This paper will review work in progress by the Institute
of Electrical and Electronics Engineers (IEEE) Working
Group 1683 Standard for Motor Control Centers Rated
up to 1000 volts with Requirements Intended to Reduce
Injuries Working Group. This group was initially formed
by the IEEE Industry Applications Society Petroleum &
Chemical Industry Committee and is working on ideas to
improve the functional design and test requirements for
motor control centers rated up to 1000 volts ac 50/60 Hz
with specified safety and reliability features. The paper
will briefly review the emerging standard and advise
engineers that are interested in how to get invol ved to
offer inputs for improving the standard. Information on
new safety based low-voltage motor control center
designs that have been recently introduced by several
manufacturers will be reviewed. The review will show how
the industry is responding to the product need articulated
by the user community and the IEEE 1683 Working Group
for product safety by design.


Index Terms Safety by Design, Low-Voltage Motor
Control Centers, Consensus Standards.
I. INTRODUCTION
What North American Standards define the design and
construction requirements for low-voltage motor control
centers (MCCs)? Do these standards address safety for
personnel performing tasks such as racking in starters, for this
class of equipment while energized? Are standards for this
class of equipment different outside of North American
markets? Can current standards be improved upon, and what
is the process to change the status quo? Questions like these
inspired the authors to write this paper, seeking answers and
new direction toward a safer work environment.
Process industries of today including metals, mining,
cement, pulp & paper and petroleum & chemical are
predominantly dependent upon motor and other loads fed
from low-voltage MCCs. Often times, a shut down of an MCC
can result in loss of the entire process. Loss of the process
may increase the probability of environmental and safety
concerns. Also, certain diagnostic activities can only be
performed while equipment is energized. Because of this,
maintenance personnel are frequently faced with the need to
perform troubleshooting or testing of low-voltage MCCs while
energized.
The safest method is to deenergize and place all electrical
equipment in an electrically safe work condition prior to
performing any operational, maintenance and diagnostic
activities. It is recommended that safety procedures defined
by codes and standards as well as company safety processes
and manufacturers operating manuals be followed. Invariably,
the recommendations of these documents require that
equipment is deenergized before any service or maintenance
is performed. Since de-energizing the MCC may be infeasible
due to an adverse impact on safety and environmental
concerns, process industries need to find new ways to both
maintain their process and associated electrical systems,
while at the same time minimizing risk of electrical hazards.
II. IMPACT OF CODES AND STANDARDS
Its instructive to review the various existing consensus
codes and standards surrounding construction, installation
and operation of low-voltage motor control centers. This will
assist in gaining a better understanding of the purpose and
impact of these standards on safety based designs. As the
PRESENTED AT THE 2008 IEEE IAS PULP AND PAPER INDUSTRY CONFERENCE IN SEATTLE, WA: IEEE 2008 - PERSONAL USE OF THIS MATERIAL IS PERMITTED.
very use of electricity is inherently dangerous, these
standards are both useful and necessary to assist in offering
ground rules regarding their use.
A. National Electrical Code
In the United States, the National Electrical Code (NEC) [1]
was first adopted in 1896 by a group of private organizations
trying to create a unified set of rules for dealing with electrical
devices. Early on, the dangers of fires and facility damage as
a result of inadequately installed equipment became the
primary force in driving toward ongoing revisions of the NEC.
Over the course of many years, this standard has primarily
focused on safe equipment installation. Being an installation
standard, issues such as product design and performance
have traditionally been left to equipment manufacturers and
listing agencies. In some cases, evolving product technologies
that enhance electrical safety have found their way into the
NEC, making this consensus standard one possible vehicle
for enhanced safety based designs. One example is NEC
210.8 mandating the application of Ground Fault Circuit
Interrupter (GFCI) protection for personnel. Another is NEC
210.12 requiring Arc Fault Circuit Interrupters (AFCI), and
406.11 requiring tamper resistant receptacles in dwelling
units.
However, the NEC does not address safe work practices
related to power distribution assemblies such as low-voltage
MCCs. An example is the NEC 2002 update to section 110.16
entitled Flash Protection. This revision just over 5 years ago
added Switchboards, panelboards, industrial control panels,
meter socket enclosures and motor control centers that are in
other than dwelling occupancies and are likely to require
examination, adjustment, servicing, or maintenance while
energized shall be field marked to warn qualified persons of
potential electric arc flash hazards. The marking shall be
located so as to be clearly visible to qualified persons before
examination, adjustment, servicing, or maintenance of the
equipment. Manufacturers of low-voltage MCCs and other
electrical equipment responded to this requirement by
including labels similar to that shown in Fig.1. Since the NEC
Standard included the term field marked, most often this
label is now included with the operating manual when the
MCC is shipped from the factory, but the owner is required to
actually affix it to the assembly. This label obviously identifies
that a hazard exists, but does not quantify the magnitude of
the hazard, nor what steps should be taken to assure that
personnel working on this class of equipment while energized
are safe from electrical arc hazards. It is clear that although
there are signs of encouraging steps forward, the NEC is not
designed or intended to address safe work practices.
B. Occupational Safety and Health Administration
The Occupational Safety and Health Administration (OSHA)
regulations [2] came along many years after the NEC. This
body of work became law when the Occupational Safety and
Health Act (OSHACT) was first adopted by the US
Government in 1970. Section 5(a)(1) of this act is known as
the General Duty Clause. This clause simply states that
employers must provide each employee employment and a
place of employment that are free from recognized hazards
that are causing or likely to cause death or serious physical
harm. In many areas, OSHA regulations mirror the language
and intent of other standard such as the NEC and the National
Fire Protection Agency (NFPA) 70E, a standard that will be
discussed later in this text. One important distinction between
the NEC and OSHA is that OSHA is a regulation, not a
standard. Thus, a Federal, or State Regulating body
investigates incidents and may issue citations and levy fines
for violation of OSHA regulations. OSHA has the burden of
proof, so violation of an OSHA regulation would be
determined by an investigation conducted by either the federal
or state OSHA office, or by an Authority Having J urisdiction
(AHJ ). The latter is typically an appointed representative from
an independent third party such as Underwriters Laboratories
(UL) who is knowledgeable and trained regarding OSHA
regulations. In many instances, OSHA will invoke the General
Duty Clause when there is no specific standard to cover an
alleged hazard. One common area where the General Duty
Clause is enforced is exposure to electrical hazards.
Reviewing specific language in this regulation surrounding
electrical safety, OSHA 29 Code of Federal Regulations
(CFR) Part 1910 [3] defines electrical installation requirements
and standards. OSHA electrical standards require avoidance
of energized work wherever possible and practical. Section
1910.333 (a)(1) states Live parts to which an employee may
be exposed shall be deenergized before the employee works
on or near them, unless the employer can demonstrate that
deenergizing introduces additional or increased hazards or is
infeasible due to equipment design or operational limitations.
Section 1910.399 introduces the definition of a Qualified
Person being One who has received training in and has
demonstrated skills and knowledge in the construction and
operation of electric equipment and installations and the
hazards involved. NECs definition of Qualified Person adds
training requirements to recognize and avoid the hazards
involved. Clearly this regulation includes requirements around
safe work practices.
Although the OSHA regulations tend to take a step beyond
the NEC, there is still a gap in the area of defining product
designs based on enhanced safety performance. Some have
suggested since OSHA is the regulating authority, that
standards based on safe product designs should be
Fig.1: One sample of a label supplied for field marking by
equipment user.
mandated by this body [4]. Others assert that OSHA should
not dictate product design standards to manufacturers, but
only require that product designs are safe.
Regardless of ones position in this debate, the fact remains
that the process to change OSHA standards is very lengthy.
OSHA recently published the final rule of its Subpart S
revisions on February 14, 2007. The effective date of this new
revision is August 13, 2007. This is the first revision in 25
years! The updated version refers to the 2002 National
Electrical Code, because the rulemaking that just ended
began in April 2004.
C. Mining Safety and Health Administration
Although OSHA maintains regulatory control over many
process industries, some industries such as mining and
cement are governed by regulations set forth by the Mining
Safety and Health Administration (MSHA). MSHA has
responsibility for administration and enforcement of the Mine
Safety and Health Act of 1977, which protects the safety and
health of workers employed in mines across the US. Similar to
OSHA, MSHA regulations cover a broad spectrum of
requirements surrounding safety and health and since this is
also a federal agency, adherence to regulations are
mandated. Unlike OSHA, MSHA regulations related to safe
work practices do not mirror the NEC or NFPA 70E. MSHA
currently regards NFPA 70E as a performance standard.
However, there are a number of specific MSHA regulations
that address electrical safety. Two such examples are 30CFR
46.7 that covers personnel training and procedures, and
30CFR 56.15006 that includes details of required protective
equipment and clothing for workplace hazards.
D. National Fire Protection Association Standard 70E
The National Fire Protection Agency Standard 70E
Standard for Electrical Safety in the Workplace [5] was first
published in 1979. The first NFPA 70E committee was
established at the bequest of OSHA. As the title of this
Standard suggests, this document focuses on electrical safety
related work practices. This is an important standard because
it offers employers and their employees a roadmap toward
workplace safety. This is a welcome addition to the traditional
motivation of fear from OSHA enforcing regulations.
Today, when OSHA investigators are evaluating the
adequacy of an employers electrical safety program, they
recognize NFPA 70E as an example of what an adequate
electrical safety program must contain. Furthermore,
employers are encouraged to conduct periodic reviews of their
safe work practices, because the 70E committee remains very
active and is clearly focused on continually improving
workplace safety. Since its inception, this Standard has
encouraged efforts to conduct tests quantifying arc-flash
incident energy, defined standards for personal protective
equipment (PPE) and established safe work practices such as
energized work permits. At present, the 2004 Edition of the
NFPA 70E Standard is in a revision cycle and a new 2009
version is expected to be available sometime during the third
quarter of 2008.
Using the methods defined in the NFPA 70E and IEEE
Standard 1584 [6], actual incident arc flash energy can be
calculated. The sample stick figure (Mr. Ouch) label in Fig 1.
may be replaced with a label that looks more like the one
shown in Fig. 2. .It should be noted that the current OSHA 29
CFR 1910 (Sub part S), NEC 2008, and NFPA 70E-2004 only
require a warning sign of Flash hazard and not quantification
of the hazard as shown in the label below. This label was
generated by one company to show an example of the results
following calculated arc flash energy. This is a significant
improvement in quantifying both the shock hazard and the arc
flash hazard. In recent updates, OSHA has made good on
their commitment to follow the NFPA 70E-2000 in the most
recent revision.
It is the opinion of the authors that the NFPA 70E Standard
likely has the best chance to impact a new Safety by Design
platform for electrical equipment, including low-voltage MCCs.
Although the present scope of the 70E standard does not
extend to installation design, it seems natural that inherently
safer product designs should find their origins in safe work
practices. However, it appears this Committee to date is
consumed with keeping up to date with emerging knowledge
in the area of arc flash hazards. Indeed, there is much work to
be done as the industry presses to learn more about not only
incident energy and potential burn from an arc flash event, but
also dig deeper into areas such as sound and arc blast force,
as well as the impact of shrapnel and other phenomena
associated with this hazard.
The 70E Standard offers industry an excellent tool to
recognize hazardous conditions under which much work is
done in the field, and adopt solutions that reduce the
exposure to those hazards. Many of the requirements set forth
by this Standard are extensive, but they are necessary to
ensure safe workplaces.
E. National Institute for Occupational Safety and Health
The National Institute for Occupational Safety and Health
(NIOSH) has been active by increasing awareness of
electrical safety and safe work practices. This organization
has led the way in publishing statistics on electrical injuries
and incidents in the workplace, improving awareness in this
important area. Most recently, NIOSH has begun an initiative
titled Prevention through Design (PtD). The concept of PtD as
defined at the NIOSH website [7] is defined as Addressing
occupational safety and health needs in the design process to
prevent or minimize the work-related hazards and risks
Fig. 2: A label resulting from an arc flash study. This includes
arc flash and shock hazard as well as the required Personal
Protective Equipment required.
associated with the construction, manufacture, use,
maintenance, and disposal of facilities, materials, and
equipment. NIOSH sponsored a PtD workshop in J uly 2007
as a first effort to kickoff this initiative. The workshop attracted
225 participants from various industries. A promising start, but
how the NIOSH PtD initiative might impact product design
standards remains an open question.
Interestingly, in reviewing NEC, OSHA, NFPA 70E, NIOSH
documents and other electrical standards, it becomes quickly
obvious that most recommendations surrounding safe work
practices are of a retrofit nature. In other words, identify and
quantify the hazard of working on energized equipment, then
use technologies to either move personnel outside of the flash
protection boundary, or wear the appropriate PPE to assure
the worker is protected in the event of an arc flash incident.
Clearly, adopting safety by design principles in product
standards offers a path forward in reducing injuries while
allowing improved productivity via removal the added burden
of a prescribed retrofit approach. At present, it appears that
our existing consensus codes and standards do not serve the
industry well in the area of designing products that are
inherently safe to work on while energized.
III. THE UNIQUE NATURE OF THE HAZARDS
There have been a number of excellent papers including [8]
and [9] that have done a thorough job of identifying the unique
nature of the hazards in working on energized low-voltage
MCCs. Unlike other classes of low-voltage power distribution
equipment, MCCs tend to require frequent access in industrial
facilities. The flexibility of the assembly design makes
changing horsepower ratings or adding new motor loads as
well as troubleshooting existing loads a frequent occurrence.
Every MCC door is interlocked to prevent access to
energized parts with the disconnect device in the ON position.
An interlock bypass mechanism is provided for qualified
persons to access the energized parts for diagnostic work.
After defeating the appropriate interlocks, most of todays
MCCs allow energized work while the unit or bucket door is
open. MCC bucket assemblies with plug-on stab connections
can be removed while energized. Removal of a typical MCC
bucket is shown (with an operator wearing proper hand
protection) in Fig. 3. As stated previously, OSHA1910 Subpart
S is clear regarding working on equipment while exposed to
live conductors. The language clearly states that the employer
must demonstrate that deenergizing introduces increased
hazards or is infeasible due to equipment design or
operational limitations. Interestingly, reading the fine print in
any low-voltage MCC manufacturers maintenance
procedures also requires that the assembly be de-energized
prior to maintenance or removal of a plug-on bucket from the
bus. Although it is recommended that these safety procedures
be followed, often times process industries are faced with the
need to work on energized equipment, versus deenergizing
and facing increased risks in process safety or environmental
concerns.
Removal of MCC buckets from live bus is often followed by
a bench test or maintenance while the unit is outside of the
MCC. Typically, maintenance persons will set the unit on a
work bench, with the electrical components within the bucket
sub assembly such as the circuit breaker and motor starter
facing upward. Unfortunately, this requires that the bucket
stab assembly be resting on a work bench. Direct or angular
force on the stab assembly can distort the stab fingers,
presenting a serious hazard when the bucket is returned to
the MCC cell.
Misalignment can cause a phase to phase or phase to
ground short circuit. As a result, it is not unusual that removal
and test or repair of the sub assembly, intended to improve
the reliability of the MCC, results in diminished reliability, or
even worse a potential safety hazard.
Many of todays motor control centers include factory
mounted adjustable frequency drives that typically offer
troubleshooting diagnostics. In some cases, troubleshooting
of this equipment requires that the MCC door be open. Once
again, this frequently subjects the operator to exposed live
conductors. Clearly, MCCs represent a product area that
needs to be reviewed for safety enhancements.
Refer to Appendix A Low-Voltage MCC Electrical Safety
Standards The Big Picture to review operations and
maintenance tasks and relationships for energized MCCs.























IV. DEFINING THE NEED - THE BASIS FOR DESIGN
IMPROVEMENT
In the USA, present design standards for low-voltage motor
control centers are defined by UL845 Standard for Motor
Control Centers [10]. This standard has recently become
harmonized across North America and applies to motor
control centers to be used in accordance with the U.S.
National Electrical Code, ANSI/NFPA 70, the Canadian
Electrical Code, Part 1, CSA C22.1, and the Mexican
Electrical Installations (Utility), NOM-001-SEDE. Today, this
standard serves as the basis for design and performance for
LV MCCs applied to dc and single and three-phase 50 and 60
Hz ac motor control centers rated not more than 600 Vac or
1000 Vdc, applied on systems with available short circuit
currents not more than 200,000 amperes.
This document by no means excludes the requirement for
safety features as a part of the MCC design. For instance,
Section 8.1.8 defines requirements for doors and covers.
Fig 3: A LV MCC bucket being removed from a vertical structure
after defeating the mechanical interlock. Note that the circuit
protective device is deenergized, but the stab assembly is still
connected to live bus.
Section 8.1.8.2 states If bare live parts are exposed by the
opening of doors or covers, means requiring the use of a tool
to open them or means that can be locked shall be provided
to secure the doors or covers in the closed position. And,
Section 8.1.9 Doors required to be opened during normal
operation may have hand-operated latches or screws, and
a) doors shall be hinged such that the door will not come
off inadvertently;
b) barriers or finger-safe devices shall be used to prevent
contact with bare live parts during normal operation, unless
the door is provided with an interlock to a disconnecting
means that de-energizes all hazardous voltages. However,
this standard is primarily focused on construction
requirements such as ventilation, spacing, disconnecting
means and connectors. Required tests are also specified such
as withstand, overload, temperature and short circuit.

A. Case Study

Fig. 4 shows the results from a study of electrical incidents
that occurred in multiple facilities of a major US based
chemical company [11]. In this study, an electrical incident
was defined as an event resulting from either personnel
action or equipment failure involving electrical installations
that have the potential to result in injury due to:

1) Electrical flash and/or burn,
2) Electrical shock from a source greater than 50V, or
3) Reflex action to an electrical shock.

Of a total of 597 reported incidents, 80 (13.4%) occurred in
low-voltage MCC equipment. This was second only to control
equipment where 104 (17.4%) of the incidents occurred.
Since control equipment includes primarily control panels, it is
assumed that many of the incidents involving this equipment
were due to a shock event when personnel were exposed to a
120Vac circuit.

B. Market Research

There have been other efforts to define and prioritize MCC
design features that would enhance safety. One motor control
center manufacturer conducted an extensive survey for 8
months of over 100 users across multiple industries. Focus
Groups of electrical engineers and maintenance personnel
frequently engaged in operation and maintenance of low-
voltage MCCs were used, testing various value propositions
and feature sets of the product that would be important to
enhance electrical safety. The results of these sessions were
then analyzed using a Quality Function Deployment (QFD)
matrix, see Fig. 5. This process is used to mathematically
weight the results of the sessions and determine the most
important product features identified by the focus groups.
Although the QFD matrix is too complex to be legible in this
text, the tool establishes a weighted ranking of desired
product features in absolute and relative importance and also
provides a technical feasibility assessment to implement
enhanced feature sets. Although this information has been
presented previously [8], the top 10 list is repeated here.

Top Ten LV MCC Design Features

1. Component Rejection features - Ensure compatible
components are used and improper components are
rejected.
2. Voltage Test Points - Provide means of testing for
LV MCCs LV MCCs
Fig. 4: Among all electrical safety hazards, Low-Voltage MCCs rank second only to control equipment.
presence of all voltage sources in the unit from the
dead-front cover.
3. Correctly applied torque to electrical joint connections -
Provide capability of ensuring all electrical joints have
been correctly torqued at the factory.
4. Finger safe terminals throughout - Prevent exposure to
live parts.
5. External Voltage Indication - Provide voltage indication
on outside of individual unit.
6. Proper Component Selection - Ensure properly rated
components are used in the system.
7. Insulated/Isolated Bus & shutters - Provide insulation
and isolation of bus with shutters wherever possible.
8. Remote Racking Mechanism - Provide capability of
racking the unit in/out outside of the arc-flash
boundary.
9. Correct Instruction Materials - Provide correct and
adequate instruction material including installation and
maintenance procedures.
10. Use Current limiting Interrupters - Fuses and high
interrupting current limiting breakers shall be used.
The results of this market survey are significant, providing a
framework that defines actionable product design changes
that could improve electrical safety. Some of the top 10
feature sets identified such as finger safe terminals are
incremental changes. It is believed that most any
manufacturer of low-voltage MCCs could implement a change
such as this with relative ease. Other safety driven features
identified by the survey such as remote racking or voltage test
points would require new invention.
V. IEEE 1683 WORKING GROUP A PATH FORWARD
One significant effort in the area of improving Safety by
Design of low-voltage MCCs is the work of the Institute of
Electrical and Electronic Engineers (IEEE) 1683 Working
Group. This group is developing a Standard for Motor Control
Centers Rated up to 1000 volts with Requirements Intended
to Reduce Injuries. This Working Group was first formed by
interested members of the IEEE Petroleum and Chemical
Industry Committee. As the process for formation and
standards development by a working group is not well
Fig. 5: A The Quality Functional Deployment was used to mathematically weigh the most important MCC safety features as identified by
over 100 user clients across multiple industries.
publicized, the authors will cover the steps involved.
A. Formation of Working Groups
IEEE working groups are formed by any interested parties
in the IEEE that share a common interest or goal. Within the
IEEE, Industry Applications Society there are five operating
committees including Petroleum & Chemical, Pulp & Paper,
Cement, Metals and Mining. As mentioned previously,
industries that deal in continuous processes are unique in that
there are frequent occasions when it may not be practical to
deenergize MCC equipment before service, troubleshooting or
minor upgrades are performed. In the case of 1683, a group
of interested engineers representing end-users, consultants
and supplier companies from the IEEE Petroleum and
Chemical Industry Committee shared a common goal to
pursue a new standard in low-voltage MCCs. The collective
group believed that developing a functional specification for a
MCC with enhanced safety features could be used in
applications where the facility owner was interested in a
greater degree of safety.
Because by definition a working group requires
collaboration by engineers from various companies including
some that routinely compete in the open marketplace, there
may be risk of antitrust and patent issues. The IEEE maintains
a robust policy regarding antitrust and patent concerns, and
as a result, the organization provides a valuable platform for
engineers and designers across the industry to work together
in developing a common goal such as this. Standard
messages shared with all members of the working group
before each meeting are:
Dont discuss the validity/essentiality of patents/patent
claims
Dont discuss the cost of specific patent use
Dont discuss licensing terms or conditions
Do bring any possible patent issues to the attention of
the IEEE SA patent office
Dont discuss product pricing, territorial restrictions, or
market share
Dont discuss ongoing litigation or threatened litigation
Do speak up if inappropriate topics are
discussedand do formally object.

The 1683 working group was first formed during the annual
conference of the Petroleum and Chemical Industry
Committee in September of 2005. Today, the working group
meets twice per year, in September at the aforementioned
conference and again in February during the IEEE Electrical
Safety Workshop [12]. Note that the number 1683 is not
significant: it is only the next number taken from a sequence
of numbers issued by the IEEE Standards Association.
B. Structure of 1683 Working Group
The structure of the 1683 Working Group (WG) includes a
governing Task Group (TG), identified as TG0, and six
operating Task Groups identified as TG1 through TG6. The
governing task group does not maintain veto power as the
definition suggests, rather it simply serves as a collection
point where the work by all operating task groups is
assembled. So, the TG0 functions more like a steering
committee. TG0 is comprised of a Chairman, Vice Chairman,
Secretary and the six operating TG leaders.
The work of developing drafts of the text for the standard is
divided among the operating Task Groups as follows:

TG 1 Protection and rejection features
TG 2 Increase Ingress Protection
TG 3 Increased Diagnostics & Indicators
TG 4 Mfg/Specifier/Installer/User interface
TG 5 MCC Mechanical design
TG 6 Stab and bus design

Operating task groups meet routinely (about every 30 to 60
days) typically via teleconference to discuss and finalize
proposed content of the standard. Care is taken to define
what as opposed to how. In other words, definition of a
standard of performance rather than explanation of specific
product features. Task group meetings are open to anyone
that is interested. Being an active member of the IEEE is not a
requirement to participate in the task groups. After the task
groups have completed their work in developing a
specification section, they each submit their draft.
Drafts are then distributed to all Working Group members
for review and comment. The comments are then compiled
and sent back to the Task Group. The Task Group decides on
a response to each comment such as accept, reject, accept in
principle, or accept in part. For any response other than
accept, an explanation is required. The comments with
responses are then sent to the full Working Group. If a
commenter is not satisfied, they can appeal to the Chair to
find a resolution that satisfies the commenter. Meanwhile, the
Task Group is moving on and further developing their draft.
All task groups and anyone else interested assembles
during a working group meeting. During WG meetings, each
task groups reports activities since the last meeting, and
common issues are discussed and resolved. On occasion, a
vote is needed. Only eligible members are allowed to vote on
issues including the decision to accept or reject proposed
drafts of the work. In order to become eligible as a voting
member, one must participate in two successive working
group meetings. Conversely, missing two consecutive working
group meetings will result in the voting member losing his or
her voting rights. The structure is obviously designed to
inspire participation. Attendance is recorded at each working
group meeting to determine the eligible voting members. The
author of this text is an active member of the 1683 Working
Group and also routinely participates as member of Task
Group 6.
This key initiative driving the project forward is the need by
many users (facility owner representatives) for a safety by
design product. With this as a starting point, strong user
participation is required. While many low-voltage MCC
manufacturer representatives are active participants in the
process, not enough users typically participate. To enable
more user participation, the WG introduced the concept of
Corresponding Members. Many users may not be able to
travel, but can participate from their offices by e-mail and
teleconference. This new membership category recognizes
that most of the real work of developing the text is done by
individuals drafting proposed text and developing comments
on text written by others. This work, along with occasional
teleconferences, where comments are resolved generally
require no travel. At the time of this writing, twenty users had
signed up as Corresponding Members, significantly increasing
the number of users. Still developing a standard is a long
process and it is hard work. Perhaps the most difficult barrier
to success in todays economy is devoting time now to
something for which the payoff will be a few years down the
road. Every employee of every company wrestles with this
issue.
C. The Ultimate Deliverable and Discussion of the Process
At present, the six operating task groups of 1683 are
moving toward finalizing a draft of the low-voltage MCC
specification. Following completion of this work, the working
group will approve the complete draft and submit it to the
IEEE Standards Association (SA). The IEEE SA ballot
process involves a separate Ballot Group. Anyone who joins
the IEEE and the Standards Association may ask to be
included in the ballot group for a particular standard. The SA
ballots the standard electronically member participants vote
and submit comments. The working group or more commonly
its ballot task group must then respond to all comments and
update the draft. The SA will then send the updated draft out
for another ballot. Again, participants can comment if they
disagree with the proposed changes. This process continues
until the WG has responded to all comments and has the
required percentage of voters agreeable to approving the
standard.
The draft is then submitted for IEEE SA Board approval.
Following draft approval, the work will be published as a new
IEEE standard. This process actually mirrors the same
approach used by several of the standards groups mentioned
previously including the NEC, NFPA 70E and IEEE1584. It is
anticipated that within the next 12 to 24 months, the proposed
standard 1683 will become an active IEEE Standard.
The 1683 working group offers industry the best chance of
delivering a low voltage motor control center based on a
Safety by Design approach. Since developing the new
standard represents a collective effort by users, consultants
and suppliers alike. Every possible stakeholder from
designing and assembly of the product, to specification and
application in a facility, to installation, operation and
maintenance after the product is energized is engaged in the
process from the beginning. In addition, the speed to market
of the process has distinct advantages over other groups that
are required to operate at a higher level of governance.
Indeed, there are several excellent examples where use of the
IEEE standards development process has delivered new and
improved specifications for products requiring enhanced
performance or safety features. One notable example is
IEEE/UL Standard 841 for Severe Duty Motor Applications
[13]. Today, this is applied as a supplement to NEMA
Standards Publication MG-1, Motors and Generators.
Although the standards development process described
above is well designed and is structured to deliver results,
there are some notable drawbacks observed from actual
participation in this group.
First, the group struggles to attract and maintain
involvement from the user community. Although there are
some dedicated users that remain involved, it has been very
difficult to keep everyone in the fold. An informal survey
during a recent working group meeting identified 1) Not
enough hours in the day, and 2) Not a high enough priority
relative to other work, as the two top reasons why users
struggle to remain involved. Of course, no manufacturers/
suppliers or consultants are apt to pay much attention to this
effort without users. The introduction of the Corresponding
Member category may resolve this.
Second, several of the people involved in the task groups
are manufacturers that are very familiar with the current
UL845 specification for low voltage MCCs. Many of these
people actually sit on the UL845 standards making panel. As
a result, there is some part of the group that maintains a Why
do we need a new standard for low voltage MCCs, when we
already have one? attitude. This is counterproductive, but
progress is being made.
Third, one of the IEEE rules of engagement for this and any
new standard is the IEEEs patent policy. In short, this policy
requires that no new invention can be included in the new
standard without full disclosure of existing and planned patent
applications. This policy is designed so that the ultimate
approved standard does not specify a technology that is the
intellectual property of only one manufacturer. In this
environment, it is incumbent upon the manufacturers of low-
voltage MCCs to act in the best interest of the industry as a
whole. This might include agreeing to license innovation that
represents advancements in safety by design offerings. In an
environment where most major low-voltage motor control
center manufacturers are represented by major corporations
that are beholden to their shareholders for profitability, taking
a big picture view can at times be very difficult.
VI. SOME RESPONSES BY MCC MANUFACTURERS TO THIS
INITIATIVE
Interestingly, a few manufacturers have pushed forward
with new designs and additional innovation that perhaps is in
response to the efforts of the 1683 working group. Its
instructive to review a few of these product innovations to use
as a benchmark of the progress in this industry. Examples
below are currently available from multiple manufacturers.
A. Enhanced Door Latches
Dangerous levels of arc flash energy are more apt to do
harm to personnel when the MCC unit door is open than when
its closed. This is proven in [8] and other technical papers,
where arc flash testing of low-voltage MCC units for arcing
faults as measured by array calorimeters, shows arc flash
energy is greatly reduced when the unit door is closed. Fig. 6
below shows one example of a spring latch design that
secures the door in the closed position should an internal
arcing fault occur. Although ANSI C37.20.7 standard exists for
Fig. 6: Shows spring latch, designed to keeps door from de-
latching while allowing pressure relief during an arc flash event.
Fig. 7: Voltage Test Block allowing potential test of line and load
MCC unit terminals without opening the unit door. Reverse Side
view shows spring loaded shutters requiring that the ground
probe is inserted before the second probe.

Reverse Side of VTB
Voltage Test Block VTB
Reverse Side of VTB
Voltage Test Block VTB arc resistant medium-voltage metal-enclosed switchgear [12]
no standard presently exists for arc resistant low-voltage
MCCs. All the same, maintaining a secure door during an
arcing fault is certainly a best design practice.
B. Installation of a Main Current Limiting Circuit Protective
Device
Although low-voltage MCCs in most process industry
applications generally are not applied with a main circuit
protective device (circuit breaker or current limiting fuse),
installing a main device will greatly enhance personnel safety
while working in an MCC unit that is engaged with energized
vertical bus bars. The calculation for incident arc flash energy
while working in a live MCC unit is not determined based upon
the current limiting characteristics and clearing time of the
protective device in the unit. Instead, since the line side of the
unit circuit protective device typically involves exposed
energized conductors, the next upstream device is called
upon to interrupt the arcing fault. In many cases, this can be a
larger frame low-voltage power circuit breaker in an upstream
unit substation. Addition of a main current limiting protective
device such as a current limiting molded case circuit breaker
or fuse in the MCC assures more current limiting and faster
clearing times. Some manufacturers now offer an enhanced
design that includes a main protective device. Calculations
have apparently yielded some limitations with this approach,
as the main bus rating is limited to 1200 amperes.
C. Door-Mounted Voltage Test Block
Recall in Section IV of this text that one need identified in
market research was through the door voltage test points. All
lock out/ tag out procedures require a confirmation of a zero
energy state before work can be performed. In a low-voltage
MCC, one catch 22 issue is that the MCC unit door must be
open before a test instrument can be used to determine if
voltage is present. Using the guidelines outlined in NFPA 70E,
personnel must be properly dressed in the appropriate PPE
when exposed to energized conductors. Even if the MCC
source has been deenergized, the voltage test requires
appropriate PPE simply to verify this is the case. As shown in
Fig. 7, one possible solution is an externally mounted voltage
test block, accessible with the door closed. The test block
allows measurement of line and load phase-to-phase and
phase-to-ground testing while the door is closed. The test
block design would be part of the unit device panel, so no
power wiring hinged about the door. Because this new device
allows cover mounted access to the 480 Vac three-phase
power, the design would include an internal shutter feature.
The shutter requires the operator to insert the first probe at
the ground potential test point before the second probe can be
inserted to test for potential at the line or load terminals in the
MCC bucket.
D. MCC Unit Remote Racking Capability
One area of interest for the IEEE 1683 Working Group is in
finding some way an MCC bucket can be removed from or
inserted onto an energized bus while the operator is outside of
an area designated as the restricted approach boundary as
defined in NFPA 70E. One way to accomplish this would be to
include a retractable MCC unit assembly or unit stab
assembly that would allow remote racking. Similar to a low-
voltage power circuit breaker in low-voltage switchgear, this
design would include the capability to rack the unit off the
live bus with the door closed.
One potential design concept using this approach is offered
in the unit design shown in Fig 8. This new unit assembly
would include some designated space at the top of each
removable bucket that is dedicated to a mechanical racking
mechanism. Standing in front of the MCC with the unit door
closed, an operator could use a tool to directly remove the unit
from the energized bus, or perhaps a remote motor operated
racking mechanism could be used. If an arc flash event
occurred while the unit was inserted or withdrawn, the
operator would be outside of the restricted approach boundary
and clear of the arc flash energy. Ideally, this new design
would not require additional depth and a NEMA size 1 and
size 2 unit would still occupy 12 inches, similar to conventional
designs. Similar to power circuit breakers, there would be a
Connected, Test and Disconnected position with front
Fig. 8: Low-voltage MCC unit design concept with retractable stab
assembly. Allows removal of a stab-in type MCC unit without
opening the door.
mounted position indication via a mechanical indicator. This
would offer the operator a visual indication of the MCC unit
position. For added electrical isolation, the MCC unit for this
design might also include a shutter to isolate the phase stab
assembly from the vertical bus when the unit stab is fully
disengaged.
VII. A NOTE REGARDING COST
One item that has yet to be addressed is the incremental
cost of Safety by Design for low-voltage MCCs. Suffice it to
say, enhancing the current designs available with feature sets
discussed in this paper will not come without some additional
cost. In a free marketplace, ultimately the demand for these
added features that enhance product safety will drive the
market value for new designs. Clearly, there are many
industry applications where discrete processes allow low-
voltage MCCs to be deenergized, effectively removing the
hazards of electrical shock and arc flash hazards. Even in
process applications where this is more difficult, the premium
on personnel safety coupled with emerging consensus
standards driving for improved electrical safety will likely
continue to drive the need for change. The authors assert that
the continuing escalation of cost of non-compliance and cost
of injury will drive MCC users toward safer designs. In fact,
today this is already happening.
VIII. CONCLUSIONS
Because frequent modifications and troubleshooting are
required in low-voltage MCCs, NIOSH statistics of electrical
incidents support the assertion that this product continues to
be one of the most significant safety hazards for personnel
working on energized electrical equipment. In the world of
evolving and ever changing safety standards, most solutions
available today in North America are essentially retrofit in
nature. A Safety by Design approach is clearly needed in
order to take electrical safety to the next level. Today, the
existing consensus standards are improving, but there are
really no standards that are pushing toward Safety by Design
with any great speed. Some MCC manufacturers are working
to improve product designs, but others seem to be waiting for
a clear need to become available. The IEEE 1683 Working
Group appears to be the best catalyst that will serve as a
sounding board based on the needs of the user community for
low voltage MCC designs that include enhanced safety
features. The authors encourage the user community that
really cares about improvements in electrical safety to get
involved in the work of the 1683 Working Group and actively
become a part of the next generation of low-voltage MCCs
that are built based on Safety by Design.
IX. ACKNOWLEDGEMENTS
The authors wish to acknowledge the contributions of Craig
Wellman, IEEE Fellow and principle of Wellman Electrical
Engineering for his inputs and support in developing the text
and concepts outlined in this paper.



X. REFERENCES

[1] NFPA 70, National Electrical Code (NEC), Fire
Protection Association, 2005
[2] Occupational Safety and Health Act of 1970. National
Archives and Records Administration, Washington DC
[3] 29CFR1919.301 to .399, OSHA Sub Part S, Electrical
Installations, National Archives and Records
Administration, Washington DC, 2007
[4] D. Liggett, Refocusing Electrical Safety, IEEE
Transactions on Industry Applications, Vol. 42, NO. 5,
September/October 2006
[5] NFPA 70E, National Fire Protection Association
Standard for Electrical Safety in the Workplace, 2004
Edition
[6] Standard 1584, IEEE Guide for Performing Arc-Flash
Hazard Calculations. September 2002
[7] Prevention trough Design. NIOSH web site
http://www.cdc.gov/niosh/topics/ptd/
[8] D. Mohla, L. Bruce McClung, N.R. Rafferty, Electrical
Safety By Design paper presented at the 1999 IEEE
Petroleum and Chemical Industry Conference,
IEEE/PCIC Conference Record, Paper No. PCIC-99-35,
pp. 363-369
[9] J . J ennings, G. Donner, R. Morris, Reduction of Arc-
Flash Hazards in Low Voltage Motor Control Centers
paper presented at the 2007 IEEE Petroleum and
Chemical Industry Conference, IEEE/PCIC Conference
Record, Paper No. PCIC-2007-17, pp. 000-000
[10] ANSI/UL 845 Standard for Motor Control Centers
[11] M. Capelli-Schellpfeffer, H Landis Floyd, K. Eastwood,
D. Liggett, How We Can Better Learn From Electrical
Accidents, IEEE Industry Applications Magazine,
May/J une 2000.
[12] IEEE Electrical Safety Workshop website
[13] NEMA Standards Publication MG 1-2006 Motors and
Generators, National Electrical Manufacturers
Association, Roslyn, VA
Appendix A: Low-Voltage MCC Electrical Safety Standards The Big Picture


(Informative) Operation and Maintenance in an Energized MCC
While a MCC designed in accordance with this standard is intended to enable safer work than MCCs not meeting this standard,
it is understood that safety depends also on the installation meeting the requirements of the NEC or other installation standard,
on installation, operation, and maintenance being done in accordance with the manufacturers instructions, and on all work being
performed by a qualified person in accordance with the requirements of the latest edition of NFPA 70E, Standard for Electrical
Safety in the Workplace.
Examples of activities which MCC owners might define as normal and for which they can develop safe work practices
and procedures in accordance with the requirements of NFPA 70E are as follows:
Work will be
"on or near live
parts" as
defined in
NFPA 70E-
2004
Normal
activities
intended in
UL845 with an
energized unit
Where a compartment or unit is energized and the door is closed:
o Operate door mounted controls including disconnecting device No Yes
o Reset tripped circuit breaker or overload relay. No Yes
o Perform infra-red scanning through grates or crystal windows. No Yes
Where a compartment or unit disconnect is closed and work will be done without deenergizing the unit by defeating the
interlock to open the door:
o Defeat the interlock and open the compartment or unit door Yes Yes
o Inspect the unit where the inspector does not penetrate the Restricted Approach Boundary No Yes
o Operate an infra-red scanning camera where the operator does not penetrate the Restricted Approach Boundary No Yes
o Adjust control settings where the qualified person is penetrating the Restricted Approach Boundary Yes No
o Replace blown indicator lamps where pilot light terminals are exposed in units where the control voltage is not more than
120 Volts
Yes No
o Troubleshoot for failed control and monitoring components in or connected to the unit where the control voltage is not
more than 120 Volts
Yes No
Where a compartment or unit disconnect is open, there is no other source of electricity in the unit, and work will be done with
the unit remaining deenergized
o Open the compartment or unit door Yes NA
o Verify the absence of voltage in the compartment or unit Yes NA
o Perform continuity tests on power and control fuses and replace blown fuses No NA
o Troubleshoot for failed components or faulted conductors in or connected to the unit No NA
o Reset protective devices No NA
o Torque power connections downstream from the unit disconnect No NA
o Insert or remove removable MCC units (Strongly discouraged in energized MCCs not meeting IEEE P1683) Yes NA
Where the MCC main disconnect is locked off and any alternate or control power sources of voltage are locked off, work in
sections other than the incoming section and the sections in which other sources of voltage enter the MCC may include:
o Install or replace conductors No NA
o Install or replace power components or No NA
o Splice MCC sections. No NA
The following activities should only be performed when the MCC feeder and any alternate or auxiliary sources of voltage are
locked off at their sources outside the MCC. (Only then is the MCC fully deenergized.)
o The last three activities above in the incoming section No NA
o Maintenance and servicing operations involving many units or in the incoming section or No NA
o Torque power circuit connections on any bus or on a main or unit disconnect. No NA