# OSHA labeling ??



## sbrn33

I had one of my customers get fined for improper panel labeling.
All circuits are labeled correctly, they fined them on the spares not being marked. No wires hooked up to the breakers at all. I guess I have always left these blank so it can be added to when the customer adds something. What possible danger is there in not labeling an unused breaker a spare?
Thanks
Scott


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## HARRY304E

sbrn33 said:


> I had one of my customers get fined for improper panel labeling.
> All circuits are labeled correctly, they fined them on the spares not being marked. No wires hooked up to the breakers at all. I guess I have always left these blank so it can be added to when the customer adds something. What possible danger is there in not labeling an unused breaker a spare?
> Thanks
> Scott


When an OSHA inspector is looking at a panel that has circuit breakers that are being used as spares just to fill in the blanks and are not marked,he cannot just open the panel and see for himself that the breakers are not in use,So he must assume that those breakers are in use but not marked,and if they are not marked with their purpose then that violates the OSHA Rule being cited.
So the OSHA inspector is doing his job even though we both know those breakers are spares and harmless he cannot see that without opening the panel .



> _*..1926.403(h)*_
> *1926.403(h)*
> Identification of disconnecting means and circuits. Each disconnecting means required by this subpart for motors and appliances shall be legibly marked to indicate its purpose, unless located and arranged so the purpose is evident. Each service, feeder, and branch circuit, at its disconnecting means or overcurrent device, shall be legibly marked to indicate its purpose, unless located and arranged so the purpose is evident. These markings shall be of sufficient durability to withstand the environment involved.




.


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## Mulder

HARRY304E said:


> When an OSHA inspector is looking at a panel that has circuit breakers that are being used as spares just to fill in the blanks and are not marked,he cannot just open the panel and see for himself that the breakers are not in use,So he must assume that those breakers are in use but not marked,and if they are not marked with their purpose then that violates the OSHA Rule being cited.
> So the OSHA inspector is doing his job even though we both know those breakers are spares and harmless he cannot see that without opening the panel .
> 
> .



It is not a disconnecting means if there is no wire on the breaker. If a breaker is off it is not in use. If a breaker is on, and there is no wire attached, it is still not in use.


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## Big John

I know I normally defend OSHA, but that generally sounds like a crap rule. Breakers are not life-safety disconnects, and especially for general-purpose feeders and branch circuits, it's really rare that a description would be of much value to the average person. 

I'm having a hard time seeing how this has much to do with safety.


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## Wirenuting

Our facility was hit on the unlabeled breakers a few months ago. 
It wasn't OSHA that hit us as they have no authority here. It was a group we call NoShips. 
It's a federal Inspector General inspection team. 
Most of the panels that were hit were installed by outside contractors. 
We always write "Spare" in grease pencil next to the breakers.


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## HARRY304E

Mulder said:


> It is not a disconnecting means if there is no wire on the breaker. If a breaker is off it is not in use. If a breaker is on, and there is no wire attached, it is still not in use.


I agree with you, But how is the OSHA inspector supposed to know they're not in use if the panel cover is not off?


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## sbrn33

............


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## sbrn33

3 spare 120's is going to cost them $2,380. That seems a little steep when a warning would have done the same thing. All they found this and improper use of an extension cord. 
The worst part about this is that it makes me look bad since we just finished this building a year or so ago.


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## Michigan Master

There was a change in the '08 edition of the NEC 408.4. Spare positions that contain unused overcurrent devices or switches shall be described accordingly.

I once got a corrective action from our internal safety team for improperly labeled breakers in a lighting panel. They were labeled SPARE but they were in the ON position. Upon removing the cover, I discovered they were indeed spare. People just don't read the circuit directory; they want to turn them all on or all off. :cursing:


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## BBQ

sbrn33 said:


> 3 spare 120's is going to cost them $2,380.


They can and should fight it, often the fine will be reduced and sometimes you can get it tossed all together if you can show the situation has been fixed. 

Getting it tossed out is much more important than it seems as repeat offense fines are much higher than first time fines.


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## chicken steve

sbrn33 said:


> 3 spare 120's is going to cost them $2,380. That seems a little steep when a warning would have done the same thing. All they found this and improper use of an extension cord.
> The worst part about this is that it makes me look bad since we just finished this building a year or so ago.


*They* look bad busting on something that could not_ possibly _be an electrical hazard , when there are so many _existing_ energized electrical hazards out there they'll _walk right by_

~CS~


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## Wirenuting

Spoke with an OSHA instructor yesterday while they had a training group here. 
He told me that by not labeling spares you cause the potential to not be able to secure the correct one in case of an accident. 
He said that by flipping off the wrong ones, you run the risk of making a problem worse, ie; no lighting, ventilation, ect...
He didn't have the cfr number and would try to remember to sent it my way via email..


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## wendon

Why the spare breakers? Why not just sell them to them later at a higher markup?:laughing::laughing:


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## Big John

EDIT: Nevermind. I get jokes.


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## MDShunk

wendon said:


> Why the spare breakers? Why not just sell them to them later at a higher markup?:laughing::laughing:


In commercial work, you're often buying the panels loaded. 

I've been on sites where the spare stuff, and even disconnects that go to nothing, are required to be locked out (with a zip tie) and tagged out. That's a little excessive, in my opinion.


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## wendon

MDShunk said:


> In commercial work, you're often buying the panels loaded.
> 
> I've been on sites where the spare stuff, and even disconnects that go to nothing, are required to be locked out (with a zip tie) and tagged out. That's a little excessive, in my opinion.


I can see the sense in that if they're three-pole breakers or larger breakers in the MDP but I don't see the sense if they're single pole breaker. My cost is about the same either way.


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## Michigan Master

sbrn33 said:


> I had one of my customers get fined for improper panel labeling. All circuits are labeled correctly, they fined them on the spares not being marked. No wires hooked up to the breakers at all. I guess I have always left these blank so it can be added to when the customer adds something. What possible danger is there in not labeling an unused breaker a spare?
> Thanks
> Scott


Personally I don't think there is any danger with an unlabeled spare breaker (it's a dumb rule), however it _is_ code.


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## brian john

HARRY304E said:


> I agree with you, But how is the OSHA inspector supposed to know they're not in use if the panel cover is not off?


Because they are typical government employees can find their azz with a flashlight and a map.


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