The 2015 Edition of NFPA 70E plans on eliminating HRC/Category 0. Does your company (or clients) presently have arc flash labels with Category 0 listed?

• Yes
• No

This will be a big problem. What do we put on the labels instead of Category 0? Do we put "No PPE Required"?? which is what NFPA's new table would state for some cases?

Do they realize what a liability nightmare that would be if someone was injured and the label stated no PPE required?

Is this another case of someone's good idea that they did not completely think through? What were they thinking?

How will others handle "no PPE" instead of "Category 0" on their labels after the 2015 version comes out? At least Category 0 still had some minimal requirements.

I don't think it should say "no PPE". It should either say "Category 1" or state what the actual Cal/cm2 is

I totally agree the label should NOT say "no PPE". The problem is that is exactly what the new NFPA 70E table says:

Arc Flash PPE Required? Yes / No

So if a line item in the table states "No" then technically someone could place this on the label. Really BAD idea.

I've been reading some of the forum discussion about the 2015 Edition of NFPA 70E. So far, this sounds like it will be another case of "what did they mean by that/what were they thinking" except this time, it will be on a much larger scale.

I've been reading some of the forum discussion about the 2015 Edition of NFPA 70E. So far, this sounds like it will be another case of "what did they mean by that/what were they thinking" except this time, it will be on a much larger scale.

Since the Qualified Person must utilize the minimum PPE which is stipulated on the Arc Flash Label, 'No' PPE would create confusion in cases where the PPE is reduced to that of '0' level due to the activity (in cases where the equipment has higher level PPE requirements during the "work on" evolution. Also, what would then become unclear, would be if the working distances and flash boundaries would still be applicable.

HRC 0 usage just makes more sense to to keep in use.

The 2015 draft makes "H/RC 0" the standard minimum PPE required for ALL energized work. So "0" has not gone away. It's just the bare minimum required no matter what the work is. Then additional PPE is required if the incident energy exceeds 1.2 cal/cm^2.

This somewhat answers an age old question. That for certain tasks either there is simply no arc flash hazard at all or the likelihood is so miniscule that it does not apply. This seems to suggest that an "H/RC -1" should exist to cover this condition. Instead of going in this direction, the new 70E draft moves the line up on minimum required PPE to be what was typically known in the past as "H/RC 0".

The real trick will be the "buy my PPE" crowd that are going to try that "H/RC 0" is some kind of special work required PPE/uniform that the company is mandating and thus they have to be compensated. We've been dealing with this one for years when it comes to requiring even basic work boots. Fortunately OSHA has ruled on that one even though it is a bit more all encompassing on what work boots must be supplied by the employee than I would have guessed.

We don't necessarily have a "required uniform" other than shirt and pants must be natural fibers, and you can't wear a conductive lab coat if you're going to be working around electricity.

There is a separate requirement for steel toe shoes, eyewear and hearing protection.

Larry, I agree with your sentiment. I was referring to OSHA 1910.132 which specifically requires an employer to pay for required PPE. OSHA exempts "normal work boots" and "ordinary clothing". The work boot clause is about as vague as it gets. Employers do not have to pay for logging boots, lineman's boots, and leather steel toe boots. They do have to pay for metatarsal boots, and rubber steel toe boots, and any other "specialty" boots. Where this gets messy is for instance...what about static dissipative, conductive, or nonconductive (EH or DI) boots? How about requiring puncture resistant boots? There is no specific ruling on those specialty features. There are rulings that suggest that something as simple as insulated clothing for work inside coolers and freezers must be paid for by the employer, even though we all wear virtually the same stuff in winter time as "ordinary" clothing.

Although the "natural fiber" requirement seems, well, natural, and seems to leave the clothing requirement wide open, if you approach it from the perspective of an employee who sees an opportunity to get the employer to pay for something, you can see where this leads down a rocky road. If insulated clothing counts as "specialty", then certainly cotton work shirts and pants should be considered "specialty clothing" since if you've went clothes shopping lately, even in Walmart just about everything in the clothing aisles intended as "work clothing" is a blend of some kind of synthetic with the exception of blue jeans and carpenter's pants. As silly as the argument sounds, I know that if I'm working in a union environment, once 70E-2015 comes out, there will be at least one grievance filed, no matter how silly or contrived it is. We'll go through the "steps" and perhaps even have to go to arbitration to talk about how cotton shirts are "ordinary clothing". Or we can just punt and do what many utilities and union factories have done...start requiring company uniforms. This is expensive but at least it guarantees that employees are wearing natural fiber clothing.

I must have missed this or it wasn't obvious to me. Do you know where the 2015 70E sets a minimum requirement? That would certainly be much better.

I forgot the exact location and I'm not sure where you can find a current draft but I believe if you carefully read through the PPE sections (130.7 in the current edition), you will find the new requirements in there. When I noticed the removal of "H/RC 0" from almost everywhere in the standard, it definitely got my attention because I was concerned if they had gone for a 4 cal standard across the board. This is more or less the direction that NESC has gone.

Annex H is the only reference I could find to PPE use <1.2 calcm2

OSHA is definitely pushing for an "arc rated PPE standard". The new .269 rules clearly state that whenever employees are working around exposed conductors over 600 V, arc rated PPE must be worn. They leave it up to the employer to specify what PPE must be worn. There was some commentary suggesting that in cases where the arc flash hazard was below the minimum (OSHA also set the floor at 2.0 cal/cm^2 rather than 1.2 cal/cm^2, following an earlier NESC edition), that nonmelting work clothes would be acceptable. This was rejected.