Arc Flash label exceptions

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powerpete69

powerpete69

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Northeast, Ohio
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Professional Electrical Engineer
Wanted to chat a bit about the exceptions written below by the fine folk on NFPA 70E.
I'm on a site with over 1,200 busses. 40 plus substations.
Our safety guy suggested that I update all our arc flash labels because they are getting past 5 years.
Then I've noticed the exceptions below. It says update labels every 5 years unless either of the exceptions below apply.

Here's my thing. I have the arc flash model from 5 years ago and can prove that the calorie levels of each bus haven't changed compared to todays current model. We also have professional electricians onsite that suit up when needed. I am also the engineer onsite that supervises it all. Have a few items been added to the system? Sure, so they have new arc flash labels on them and things around them haven't changed.

Here's another question? Why did the fine folk at NFPA 70e write those exceptions? Per my opinion, they wrote them so people don't waste time and money putting stickers over older stickers that read the same thing.

What are other peoples thoughts on the exceptions below? Why not use them if they are legitimate? It would take me at least 6 months to update the arc flash stickers on site. Why would I waste unnecessary time doing that when we are arc flash sticker compliant per the exceptions below?




NFPA 70E 130.6(H) Equipment Labeling. Electrical equipment such as switchboards, panelboards, industrial control panels, meter socket enclosures, and motor control centers that are in other than dwelling units and that are likely to require examination, adjustment, servicing, or maintenance while energized shall be marked with a label containing all the following information: (1) Nominal system voltage (2) Arc flash boundary (3) At least one of the following: a. Available incident energy and the corresponding working distance, or the arc flash PPE category in Table 130.7(C)(15)(a) or Table 130.7(C)(15)(b) for the equipment, but not both b. Minimum arc rating of clothing c. Site-specific level of PPE

Exception No. 1: Unless changes in electrical distribution system(s) render the label inaccurate, labels applied prior to the effective date of this edition of the standard shall be acceptable if they complied with the requirements for equipment labeling in the standard in effect at the time the labels were applied.

Exception No. 2: In supervised industrial installations where conditions of maintenance and engineering supervision ensure that only qualified persons monitor and service the system, the information required in 130.5(H)(1) through 130.5(H)(3) shall be permitted to be documented in a manner that is readily available to persons likely to perform examination, servicing, maintenance, and operation of the equipment while energized. The method of calculating and the data to support the information for the label shall be documented. The data shall be reviewed for accuracy at intervals not to exceed 5 years. Where the review of the data identifies a change that renders the label inaccurate, the label shall be updated. The owner of the electrical equipment shall be responsible for the documentation, installation, and maintenance of the marked label.
 
I think you're okay to leave the label as is if the information is still accurate. As far as the old date being listed, I think it's on the facility that they train their folks to recognize the label regardless of the date, knowing that the label is still accurate. It could also be listed in their Electrical Safety Program that the labels are verified every 5 years consistent with 70E's recommendation.
 
At the end of the day, I probably will just go ahead and update them. But those code exceptions have always really intrigued me!!
 
We're an engineering consulting firm who does Arc Flash Studies, so we like to relabel after 5 years. However, if it was my facility, and it would take 6 months to relabel, I'd pass on that - as long as the labels were accurate as listed. 👊 :)
 
After all that whining, I took care of it. All updated to 2023. Took me about a month and half. All good till 2028.
The reality is that all the labels changed just slightly. Like from 2.3 calories to 2.4 calories! But that is clearly a change.
Expect me to whine about it again about 5 years from now.
 
powerpete69 said:
After all that whining, I took care of it. All updated to 2023. Took me about a month and half. All good till 2028.
The reality is that all the labels changed just slightly. Like from 2.3 calories to 2.4 calories! But that is clearly a change.
Expect me to whine about it again about 5 years from now.
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This is why many customers create their own 'levels' for PPE selection purpose with some rounding the calculated calories to a fixed number like 4 cal/cm2 without decimal places. This helps them not have update labels as often. Their official report contains the calculated value with a written explanation of the rounding up and labeling rational.

With the amount of estimating used in the incident energy calculations, do people really think any digits after the decimal point are important? I have reviewed reports where someone wanted the label to read 39.94 instead of 40 cal/cm2. believing the lower number was significantly safer.
 
mayanees said:
I think you're okay to leave the label as is if the information is still accurate. As far as the old date being listed, I think it's on the facility that they train their folks to recognize the label regardless of the date, knowing that the label is still accurate. It could also be listed in their Electrical Safety Program that the labels are verified every 5 years consistent with 70E's recommendation.
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I agree.
The data shall be reviewed for accuracy at intervals not to exceed 5 years.
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It doesn't actually say you have to relabel every 5 years, only that the data is reviewed every 5 years. If nothing changed, you don't need to relabel.
 
jim dungar said:
This is why many customers create their own 'levels' for PPE selection purpose with some rounding the calculated calories to a fixed number like 4 cal/cm2 without decimal places. This helps them not have update labels as often. Their official report contains the calculated value with a written explanation of the rounding up and labeling rational.

With the amount of estimating used in the incident energy calculations, do people really think any digits after the decimal point are important? I have reviewed reports where someone wanted the label to read 39.94 instead of 40 cal/cm2. believing the lower number was significantly safer.
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Great points! I'll remember that in the year 2028!
 
Can you set a program like Easypower to round up to 4, 8, 25 and 40 calorie? Like you say, there are SO Many potential errors that can made when making the model that something like 3.7 calories doesn't make any sense.
Is the standard still 4, 8, 25 and 40 or have they changed that too?
 
powerpete69 said:
Can you set a program like Easypower to round up to 4, 8, 25 and 40 calorie? Like you say, there are SO Many potential errors that can made when making the model that something like 3.7 calories doesn't make any sense.
Is the standard still 4, 8, 25 and 40 or have they changed that too?
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I export to Excel and then can filter and display the data any way I want versus how some 'never been in the field' software expert thinks I should have it. The printing programs all accept an Excel file.
 
If you are calculating the incident energy levels, rather than using the "Categories Method" in 70E, the PPE Categories 1-4 aren't relevant. There is a separate table that describes required PPE when incident energy level is calculated. Since the new 2024 edition is out, this would be a good time to get a new copy. of NFPA 70E.

Having said that, I believe that the conditional formatting for AF labels in EasyPower would probably allow you to round up the Incident Energy values shown on the labels as you describe. EasyPower tech support should be able to help with that.
 
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