It started with a simple label that required certain equipment that is likely to require examination, servicing, maintenance, or adjustment while energized to be marked to warn workers of potential arc flash hazards.
However, over the years, the marking required by NEC section 110.16 has evolved into more than just simple awareness of arc flash possibility. In 2017, this section split into an (A) & (B) with 110.16(B) requiring the arc flash hazard marking to also provide additional information on service equipment at 1200A and higher that would assist those performing an arc flash risk assessment. Mainly, we needed to include the nominal system voltage, available fault current at the service, the clearing time of the service overcurrent protective device, and the date the label was applied.
This was a good amount of information to get started on a risk assessment. However, there was an exception that allowed labels applied in accordance with “acceptable industry practice.” Or, in other words, if the equipment was labeled based on NFPA 70E® section 130.5(H), there was no need to have both labels.
Fast forward to the 2023 revision cycle, and we will see the next evolution of safety for the worker in the National Electrical Code. The exception that allowed the label based on “acceptable industry practice” or NFPA 70E® will be the rule.
Circuit Size and Addition of Feeder Equipment
But the changes don’t stop there. There is also a reduction in the size of the circuit from 1200A to 1000A. However, possibly the most important change in this section comes from the addition of feeder supplied equipment to the purview of 110.16(B). That’s right – when the 2023 NEC goes into effect, all service and feeder level equipment at 1000A and higher will require a label in accordance with applicable industry practice for such a label, or, as we already discussed, section 130.5(H) of NFPA 70E®.
So, how will this affect the end user or the equipment owner? Well, electrical contractors will now be required to provide this label at the time of new equipment installation in order to pass inspection. But the NEC is not retroactive, so existing equipment won’t be required per the NEC to replace labels. However, if a facility is following NFPA 70E® for their electrical safety policies and procedures, they are already required to have this label per section 130.5(H).
As for existing equipment, keep in mind that certain jurisdictions might require equipment that is serviced or altered in any way to be brought up to the latest and greatest codes and standards. It is best to check with your local authority having jurisdiction (AHJ) as to how to approach this.
Another important requirement to keep in mind is that this label must also comply with NEC 110.21(B), which requires the following:
- field applied hazard markings on equipment to be permanently affixed,
- of sufficient durability for the environment involved,
- use effective colors, symbols, and words to effectively communicate the seriousness of the message, and
- must not be handwritten.
There is an exception to allow certain variable components of the label to be handwritten, but it is up to the AHJ on what exactly meets the intent of that exception. For example, an AHJ might view the date on the label as being variable since the equipment owner will need to periodically verify the accuracy of the information and if the parameters have not changed could simply write in a new date as opposed to replacing the whole label. However, I think most experts would agree that for the purposes of the new label requirement in 110.16(B), handwritten information is certainly not best practice, even if an AHJ permits this practice.
Any way we look at this, arc flash risk assessment labels installed on equipment make the workplace a much safer environment and bring it more in alignment with OSHA’s mandate that an employer provide a workplace free from known and recognized hazards or provide work methods to mitigate the risk from hazards that cannot be satisfactorily reduced. We can either wait until we are forced into compliance with this important safety upgrade or be proactive and start making this approach standard practice.
Either way, e-Hazard is ready to take on this monumental effort by providing trusted guidance and partnering with the electrical industry to roll this into the mainstream.
For additional information or to inquire about upcoming revisions to the NEC, send us an email at email@example.com and stay tuned for an upcoming episode of e-Hazard’s “Plugged into Safety” podcast where we’ll explore this revision a bit more in depth.
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This is certainly advancing electrical safety of workers in the right direction by better aligning the NEC with 70E for labeling.
However, it would be a HUGE step forward if the NEC started mandating the installation of arc resistant equipment and/or arc reducing technologies.
In any case let’s be grateful for what the 2023 NEC will provide.