2012 NFPA 70E - Incident Energy OR Arc Rating

Say it isn’t so!

I was reviewing a draft of the new 2012 Edition of NFPA 70E labeling requirements. It states:

(1) Only One of the Following:

(a) Available Incident Energy

(b) Minimum Arc Rating

Only ONE of the following? What does NFPA have against placing more information on the label? Last time it was Category OR Incident Energy, this time it is Arc Rating OR Incident Energy.

Am I missing something?

Both are listed in cal/cm^2.

Minimum Arc Rating is different from HRC.

I can see how having 2 different cal/cm^2 values could pose problems when somebody else comes to work there.

I was wondering the same thing.

It seems like the 2012 edition is saying you can post the rating OR you can post the incident energy (which gets compared to the rating) but don't post both

i.e. don't compare the arc rating to what's available on the label. Isn't that what the study is used for? You really have to wonder about this.

The new rule allows you to establish a simplified scheme of requiring a couple levels of PPE requirements without having to create categories. For instance, you could provide 1.2 cal/cm², 8 cal/cm², and 40 cal/cm² rated PPE and label with only these levels. If the calculated IE was 16.54 cal/cm² the label would show minimum 40 cal/cm² rated PPE. The new standard would not allow putting both 16.54 cal/cm² and 40 cal/cm² on the label.

You could still establish a PPE category system and put the category on the label and the IE. If you established Category 4 as between 25 and 40 cal/cm², and if the IE was 32.45 cal/cm², you could put both PPE Cat 4 and IE = 32.45 cal/cm² on the label.

NFPA70E uses HRC categories to establish a minimum cal/cm² rating of PPE to be worn.

Many in the industry have misapplied table 130.7(C)(11) to determine the maximum cal/cm² in which a specific Category rated PPE can be worn.

Q) I just looked at my "HRC2" PPE, none of it has an arc rating of less than 11 cal/cm², so why can't I wear it when the calculated incident energy is 9.2cal/cm²?

I believe you could wear it if you are actually calculating the incident energy. However, if a HRC is assigned based on T130.7(C)(9) then the incident energy listed in T130.7(C)(11) is the required minimum arc rating.

We post the calculated IE and PPE level on the label. The ATPV of the clothing and equipment worn must be greater than the calculated IE on the label. The PPE level is determined by the calculated incident energy and you must wear the equipment associated with that PPE level (see attachment).

So if the calculated incident energy is 9.2 cal/cm^2, you may wear your 11 cal/cm^2 FR pants and shirt but since the incident energy falls into PPE level 3 a flash suit hood is required instead of the face shield and balaclava.

That is my point, HRC levels 0, 1, 2, 3, and 4 are integral to the use of T130(C)(9) which is task oriented.

Using HRC, on labels, as a choice of PPE equipment based on calculated incident energy appears to not be the intent of NFPA70E.

I understand the simplicity of utilizing and enforcing of limiting PPE based on categories. But, I have just worked with a company about lowering the incident energy from 8.4 cal/cm² to <8cal/cm² because their corporate policy is to contract out work based on using the minimum values in T130.7(C)(11) as absolutes.

I think everyone might have missed my point.

It appears that according to the 2012 edition of NFPA 70E, you list only one of the following:

Either IE OR Arc Rating not both.

They don't even mention categories anymore.

So if you calculate 9.2 cal/cm^2 and use an arc rating of 11 cal/cm^2, you can not list both on the label. You either list 9.2 or you list 11.

I'm not sure why you're confused. Listing both would probably lead to even more confusion. Never forget KISS (Keep It Simple Stupid).

But it doesn't say you cannot list a category in addition to the IE.

Let me try this one last time.

Why doesn't NFPA 70E stick with what is required to be on the label instead of also dictating what we are NOT permitted to put on the label?

We should be able to put as much info as we want on it. Although sometimes it can be confusing if there is too much info, however that should be up to the user.

2009
Either Ei OR Category - Not allowed to use both

2012
Either Ei or Arc Rating - Not allowed to use both.

I'm fine with a list of what is required, that should be dicated by some authority such as NFPA 70E. What doesn't make sense is for them to dictate what I can not put on the label.

Where does NFPA 70E - 2009 say you can't use both IE and Category?

130.3(C) Equipment Labeling. Equipment shall be field marked with a label containing the available incident energy or the required level of PPE.

It is my understanding (and there were quite a few posts on the forum about this issue) that NFPA really means Ei OR level not both. Now it seems they no longer mention "level" not sure why, but they now indicate it is Ei OR Arc Rating.

The NFPA 70E 2009 Handbook says that "only cal/cm² incident energy available or cal/cm² requirement for the PPE are acceptable" to meet the label requirements for incident energy or level of PPE. So the intent is the same as the new requirements. The new requirements clarify this by using the term "arc rating" of the clothing which is defined in Article 100.

The Handbook also says that additional information, such as the available fault current, can be provided on the label. I see nothing that indicates that a PPE category cannot be part of this additional information. Example labels furnished by SKM, used by their customers, include both PPE category and incident energy.

Here is the history of the Ei vs. Category issue on the forum.

http://arcflashforum.com/showthread.php?t=655

I've seen labels with so much info printed using 6 point type it's impossible to read without a microscope. To me that's worthless for the customer. Funny thing is.... the company that did the survey had their name in 20 point type. So to me the label is nothing more that a sales pitch.

Where is this table from? I haven't been able to find it in the NFPA, and Table 130.7(C)(9) only has tasks not incident energy values.

I haven't read it, but does the restriction apply to each piece of equipment individually- or (hopefully) the entire facility? I can see further confusion arising from different choices within the same building/campus.

The attached table was based on T130.7(C)(11).

The actual 2012 NFPA does not say "Only One of the Following". 130.5(C) says:

(1) At least one of the following:

a. Avaliable incident energy and the corresponding working distance
b. Minimum arc rating of clothing
c. Required level of PPE
d. Highest Hazard/Risk Category (HRC) for the equipment
...