NFPA-70E 2018 Edition--130.5(H) Equipment Labeling Exception No. 2

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.

Would this lead me to believe that the arc flash labels will no longer be required to be installed on each piece of equipment? That individuals would be able to acces the required information from the documented study in the engineering office, as long as they meet the maintenance and engineering supervision requirement?

If this is the interpretation of the exception no. 2 it would be a huge cost savings. The labor cost of removing and installing new labels is about 20% of the update labor cost.

The label requirement comes out of NEC (NFPA 70E). 70E can make it optional but until it's optional under NEC, it's not optional.

110.16 Flash Protection. Switchboards, panelboards, industrial control panels, and motor control centers in other than dwelling occupancies that are likely to require examination, adjustment, servicing, or maintenance while energized, shall be field marked to warn qualified persons of potential electric arc flash hazards. The marking shall be located so as to be clearly visible to qualified persons before examination, adjustment, servicing, or maintenance of the equipment.
The new requirement is intended to reduce the occurrence of serious injury or death due to arcing faults to workers who work on or near energized electrical equipment. The warning label should remind a qualified worker who intends to open the equipment for analysis or work that a serious hazard exists and that the workers should follow appropriate work practices and wear appropriate personal protection equipment (PPE) for the specific hazard.

"The label requirement comes out of NEC (NFPA 70E[sic]). 70E can make it optional but until it's optional under NEC, it's not optional."

Yes Paul, however it would seem to lift the requirement for the detailed incident energy method labels and allow for a cheaper NEC generic to be placed. A label would still be required, but not the expensive 70E style.

"generic labels" is already true. You can't for instance use IEEE 1584 to address say a 120 VAC lighting panel or a golf cart battery because the calculations aren't aren't even valid.

Even some lighting panels actually come with "generic" arc flash labels pre-installed on them.

Granted this applies specifically to cases where incident energy can't be "calculated" but has to be determined.

But I never thought we needed "permission" from 70E because it's a voluntary standard. By way of example although OSHA 1910.269 doesn't make 70E or even NESC mandatory (indeed it now even contradicts it when it comes to arc flash), both 70E and NESC are recognized engineering standards in 1910.269 jurisdictions and utilities are free to adopt either/both/neither to some degree. Similarly although NEC may be mandatory in most U.S. jurisdictions and thus an arc flash label is mandatory it does not in any way make 70E or any other standard specifically mandatory in terms of what label is used as long as there is some label. Similarly 70E doesn't really make their labels mandatory but just says that something similar to what is described with specific content (or simply a local standard such as an alternative HRC/PPE system) can be used, which is done a lot.

So all that it's doing is giving "permission" to an existing practice.

Even though 70E seems to imply that labels are not required if the information is readily available, I would always recommend putting an AF Label on the equipment. This makes it much easier and more likely that the electrician or operator will wear the proper PPE. It is a visual reminder of what level of PPE a person must wear when the interact with the equipment. Asking these people to go to the AF study report and look up the information is asking a lot unless they have it in their tool bag or cart. I think that it would be more likely that somebody would be lazy and not look up to see what the energy level is.

Three counter examples:

1. Outdoors. Even with a UV overlabel, quite often getting labels to survive more than 6 months or so is very problematic, at least in a Southeastern U.S. coastal location. It quickly becomes more practical to put the documentation somewhere accessible and give up on labels.

2. The vast majority of locations (10 times more) of locations at utilization locations such as disconnects, lighting panels, etc., fall under whatever the local plant "minimum PPE" (1.2 cal/cm2, 2 cal/cm2, or 4 cal/cm2 depending on local rules) matches. For these locations, operators, electricians, etc., the plant minimum PPE generally covers this. So there is no additional PPE requirement. Choices are to either label it with a full (though pointless) label, a "generic" label such as that given in the NEC Handbooks, or to simply eliminate labels and have a "minimum PPE" rule instead.

3. In some smaller plants it is practical and a good deal more reliable to issue prints of the entire distribution network with that information printed on it, especially again in aggressive environments such as ports, wood products plants, some petrochemical plants, utility substations, etc., where labels don't survive for any length of time at all.

4. In some jurisdictions, specifically nuclear and some other types of generating plants, there are permit writers that put together all the details and issue a per-task procedure/permit where all the information can be supplied on the permit document. Thus the information is issued very easily and practically per job. Granted this is only to meet specific regulatory requirements and doesn't exist in your average industrial operation but in specific circumstances looking at arc flash hazards for instance is part of the pre-task review.

Yes, the new exception IS intended to permit not having labels (based on NFPA 70E) if all of the conditions in the exception are met. i.e.

“In supervised industrial installations where conditions of maintenance and engineering supervision ensure that only qualified persons monitor and service the system” I confirmed this with a couple of NFPA 70E colleagues.

Arc flash labels of course can still be used and remember as Paul stated, the National Electrical Code still has its arc flash label requirements - just not the detail found in NFPA 70E 130.5(H).

Some of the rationale provided includes the possibility of different operating scenarios that are not reflected on the label – the system could be in the wrong configuration at the time of energized work (which of course should be discouraged). Also, labels are lower on the hierarchy of risk control methods.

My personal opinion (nothing official) is that it is good to still have labels - echoing what Bob Fuhr mentioned – I would also add - I can see where the possibility exists that this could become a liability issue if someone is injured or worse. Not having a label when it was an option and could have helped, may be difficult to defend. I've had quite a few questions about this since publishing the article addressing the 2018 NFPA 70E Changes and releasing the DVD about the changes.

Yes – this could be a game changer!

The usual disclaimer: this does not reflect any official position of NFPA or any other standards organization.

Jim,
Thanks for getting back to me on your answers and personal opinions to my questions. Very informative.

I appreciate the input and opinions of everyone who replied to the issue. I personally feel that every piece of electrical equipment should have a label applied directly on the cover.

I did purchase the new DVD and found it very informative about the new changes in 2018. Thanks for taking the time to put it together.

Thanks