We have a client who wants to 'streamline' their labeling for their 30+ manufacturing facilities. Their idea (pre-NFPA 70E 2015 adoption) is to label all equipment rated Category 1 and above and for facility personnel to assume that any equipment without a label is Category 0. Once they adopt the 2015 standard, they will likely not label all equipment with an IE<1.2.

Our concerns are: what if a panel is missed during field work or a label is removed or missing? I'm afraid of what might happen if anything is 'ASSumed' regarding electrical safety.

Comments?

NFPA 70E 2015 (this is similar for prior editions)
130.5(D)
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 field-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...
b. Minimum arc rating of clothing
c. Site-specific level of PPE


The code doesn't make an exception based on results, you are required to provide a label for all equipment specified. The incident energy is only one of three things required to be on the label, as listed above. The reason you site, something being missed when labeling, is part of the reason I believe that this is required.

Very typical to do this. Part of your risk assessment must address those tasks that do not require PPE as of 2015. This is even reinforced by the lack of a "PPE 0". Every plant has to establish both PPE and standard clothing requirements. As of now utilities require "PPE 1" and so do certain industries such as refineries, smelters, steel mills, and foundries. So it makes little sense for them to bother with "0" labels. Further with the removal of the "125 kVA rule" in 2011 edition the guidance for under 250 Volts is poor. Thus one must establish more or less a definition of what constitutes a minimum acceptable incident energy, and IEEE 1584 does not accurately predict results under 250 V or single phase. The NEC requirement can be satisfied with a simple "arc flash hazard exists" sticker...labelled but gives no guidance. In my plant with around 5000+ buses if everything was modeled on detail, it would be very expensive to label everything compared to around 800 buses that actually need a label.

The information make me understand. You helped me so much. Thanks paul for sharing this!

Good Comments. I am still seeing those that use incident energy calculations use Level 0 as a site specific PPE approach. Mostly because the elimination of Category 0 from the 2015 edition of NFPA 70E left a big hole in how to label equipment.