The NFPA 70E labeling requirements are about the change again.

2004 - Basic Arc Flash Warning Label
2009 - Warning label with either the available incident energy or required level of PPE

2012 - The proposed new labeling requirements for the 2012 Edition of NFPA 70E include:

(1) Only one of the following: Available incident energy or minimum arc rating of clothing
(2) Date of arc flash hazard analysis
(3) Nominal system voltage
(4) Equipment Identification
(5) Arc Flash Boundary

Question:
Are your existing labels already in compliance with the 2012 proposal?
If not, will you / your clients be re-labeling?

• Our existing labels already comply
• Our existing labels won’t comply, we will re-label
• Our existing labels won’t comply, we might re-label
• Our existing labels won’t comply, we won’t re-label
• We don’t have labels - yet

As always, comments are always welcomed and encouraged.

Fortunately we used the complete labels that our software created which covered all of these latest changes to the label requirements. I can see this has the potential to become a very big headache if the requirements continue to change with each edition.

We use Easypower which lists both a PPE level (HRC) and the IE (unsure if I could or would change this).

Also, our first plant to have the AFHA completed did not include the analysis date and I do not believe that re-labeling for this reason is a justifiable use of time and resources.

I feel like we dodged a bullet with this one. Some in our group wanted only to post the PPE Arc Rating per the 2009 Edition of 70E. I dug my heals in and pushed for more detail based on what the software can provide.

I think I feel a bit vindicated but now I am concerned that everytime a new 70E is in the works, we will be fretting over how much time / money we will need to spend to change what we did previously.

I assume that "minimum arc rating of clothing" is not the PPE or HRC category, but is the Arc Rating expressed in cal/cm² per the definition in Article 100. As such, the new labelling requirements would not prohibit having IE and a PPE category. They would prohibit listing both the calculated IE cal/cm² and the Arc Rating cal/cm².

The problem with dating the label is that after five years, most labels will not have to be changed for increased IE, but will show a date over five years old. This will cause questioning of the label validity.

Surely the intent is not to have to relabel everything just because the date on the label does not reflect the latest study date. Or is it?

I did not think that far ahead. Still trying to digest it all. In the absense of any direction, I imagine one approach might be to add a small label on the warning label stating something like "Re-validated - Month / Year"

Yes we did only post the PPE arc rating, not the calculated PPE. I have seen some of the other posts / debate about mixing categories etc.

I now wish I spoke a bit louder. We went with the 2009 Edition requirements - Arc Rating (cal/cm^2) on the label. Thought we were doing good.

Not sure if we have the time/budget to do this again. I think the info is still in our arc flash software database so perhaps all we need to do is reconfigure our labels. Still going to be a bit of a pain.

130.3 says that the AFHA shall be updated when major modification or renovation takes place and that it shall be reviewed periodically, not to exceed five years to account for changes. I would think as long you document that a review has occurred, one-line diagrams are up-to-date and the IE results have not changed, you would not be required to relabel.

We already comply.

Primary customer wanted as much information available for the workers, and therefore did not agree with 2012 limitation of ONLY cal or HRC. But we have relabelled the entire plant when other minor changes occurred in the recommended PPE.

The NFPA committee should be aware of the expense these 'little' changes cause, understanding that the standard's credibility goes down with each revision.

We also use Easy Power and probably will not change PPE and HRC.
I include the dates in the comments section.

The standard does not say ONLY cal or HRC.


Arc rating of clothing is not the HRC, it is the rating of clothing expressed in cal/cm².

I am new to the forum and also attempting to understand 70E fully. Are the labels required be Red, Orange or does it matter?

This short article of mine about label colors might help. It is based on ANSI Z535, NFPA 70E and a survey question on this forum a while ago.