The 2012 Edition of NFPA 70E 130.5(C) Equipment Labeling states that the equipment label shall have

(1) At least one of the following:
a. Available 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

Although the 2012 edition helped clarify previous confusion by permitting posting incident energy and PPE levels, having the HRC in the same list had the potential to still create confusion. i.e. listing HRC with calculated incident energy etc.

It is proposed that the 2015 Edition will further clarify the requirements by changing the language to:

(3) At least one of the following:
[INDENT=2]a) Either the available incident energy and the corresponding working distance, or the arc flash PPE category in Table 130.7(C)(15)(b) or Table 130.7(C)(15)(d) but not both
b) Minimum arc rating of clothing
c) Site specific level of PPE[/INDENT]

Here is this week’s question: Do you think the proposed 2015 NFPA 70E language for equipment labeling helps further clarify the requirements?

Yes
No
Not Sure

There were some bizarre interpretations given previously about labels NOT being allowed to specify both the Available Incident Energy and HRC for PPE. 2012 seemed to clear this up, but the proposed verbiage above goes right back to this senseless banning of information. The plants we have labelled include both, which gives the workers an appreciation not just for PPE but also the amount of energy available, and was requested by the (different) plant owners, when we discussed label format. Note that the PPE HRC was based on the max Available Incident Energy and not discounted by some additional risk factor.

I am at a loss why both would not be "allowed", and also feel that after discussion with the plant safety officers, the places we work at will not change this information. So NFPA might be charging into a future that these plants won't follow.

Something also to consider, is the cost of changing 550 specifically printed labels at each plant. Even though that theoretically is billable services for my company, as being messengers of this code, our credibility lags every time NFPA 70E includes what seems like an arbitrary change.

I like the revised wording better but I wonder about the extra information on the label. Can I get some feedback on wording it to say...

"only one of the following"

I could still have a label that reads the incident energy rating and the minimum arc rating clothing. I could bring this up in the 2018 cycle. ;-)

A person is not supposed to be in there inless they are quilified and a qualified worker should be able to determine proper PPE with any of the provided information. I'm going with simple is better here.

As to only allowing one of the above items: No. For instance I may want to list both the incident energy and the plant-specific PPE requirement. That way an outside contractor who may have different equipment and can dress accordingly.

As to the confusion and need to specify all of the above: no confusion at all here either. There are two paths to follow for ar flash PPE. With the first path, you are on your own. You have to determine your own ratings right down to the PPE. In determining correct PPE, the recommendation in Annex O is to consult PPE manufacturers. Specific requirements are also listed in 130.7. In the second method based on the equipment and task chosen, the PPE is specified as an H/RC level. This table was not intended to be used independently of the equipment/task tables. In fact if you follow this approach you will end up with much greater levels of PPE required than the "do it yourself" approach. Thus to be technically correct I may have a piece of medium voltage switchgear rated 3 cal/cm^2 and thus specify FR shirts and pants, and yet the task tables would list H/RC 4 for most tasks on the same equipment. I cannot then rerate the H/RC level to a "1" and put that on the label because H/RC levels are not incident energies...they are just arbitrary H/RC levels. This is where the confusion lies.

To be honest this second 'mix and match" approach is simply adopting the already specificed PPE criteria straight from 70E rather than DIY recreating it. In the 2015 edition when the task tables get further divided into three tables (is PPE required, level of PPE required, PPE specifications), the tendency with most sites is probably going to be adopting the 1st and 3rd tables. Technically as long as management has reviewed this and the implications and uses it as a shortcut (copy/paste) instead of rollling their own, this can/should be acceptable. The key though is that it has to be a documented, conscientious decision, not simply an arbitrary pick-and-choose among the rules to enforce.