Cannot disagree more. This is a typical and very incorrect response from the “most conservative” crowd who believe they do the world a favor by providing essentially worthless information,
Most practitioners of arc flash studies produce multiple scenarios. One may be all motors off. Another all motors on at full load. Yet another may be a more typical diversity. It may also reflect both mains and a tie closed with an MTM system and under emergency backup generator power. Many of these cases, particularly emergency backup generators due to much lower available fault current result in much higher incident energy values. However many of them are useful for short circuit concerns but are unrealistic for incident energy purposes under normal operation and often all operational conditions. So if you put unrealistic values on the label because it is “conservative” you are not conveying realistic, valuable information at all. Garbage in, garbage out.
Second, the vast majority of use cases would NOT ever invoke an EEWP. If it does you are doing it wrong. You should not issue an EEWP fir every LOTO or you just pencil whip what is designed to be a rare event. The whole reason for the EEWP is the justification line…forcing people to really think if doing energized work is necessary or a good idea. The rest is just conveying work order details. Every electrical lockout for instance requires testing for absence of voltage, an energized task because we assume it is energized until proven dead. Most general electrical maintenance activities such as troubleshooting is often energized work (testing for voltage). The EEWP procedure recognizes and exempts these activities specifically because they always require energized work and requiring an EEWP would be wasteful and dilute the value of the procedure. I know of one plant actually doing this and the result is that they just fill one out for every single electrical task whether needed or not. So it just becomes a bureaucratic firm that just gets pencil whipped. Thus your methodology completely fails in most use cases, or abuses what should be a rare and onerous process.
Still we need to document it somewhere.
One option is to document the incident energy in separate procedure such as if the plant posts detailed LOTO procedures per machine as some do. Another option is to post the alternative values as part of the label. This is also where often you would document WHICH breaker gives the reduction. Many electricians mistakenly believe that using the maintenance switch of the breaker in front of them reduces incident energy where the correct breaker is the one upstream of the one they are about to work on. This may also be a way of conveying the alternative incident energy values when under emergency power conditions.
As to the 2020 NEC prohibition against changing settings what I have seen is plants turning on instantaneous and setting it on distribution breakers to the lowest setting. It often gets forgotten and left that way or the lowest setting causes nuisance tripping where the lowest setting needed to get below the arcing current is the best option. Granted this is exactly the same thing as changing settings but just flipping a switch prevents mistakes and this is likely what the NEC is after. I doubt they mean to lockout setting changes though electricians often just jack up settings without any consideration for the result of “fixing” what they assume is simply a nuisance trip.
