Can You Still Use the Term “Hazard Level,” Hazard Risk Category or HRC on an Equipment Label for NFPA 70E 2015?

red background with burning question

 Q.  We supposedly had an incident energy analysis done; however, the majority of our labels indicate Hazard Risk Category level 0 at an 18-inch working distance.

After reading your newsletter question, can you even use the term “hazard level” or HRC on the label? Can the level of protection only be defined by terms “PPE category” or “ARC category” and not “hazard level”?

A.  In the 2015 70E® an equipment label can have a PPE Category (2012 70E® called this a Hazard/Risk Category, or HRC) if there is NO incident energy calculations and the PPE Category tables are used for the assessment.

In 2015 NFPA 70E®there is no PPE Category called 0.  Earlier editions of 70E® stated that PPE for HRC 0 is non-melting, natural fiber clothing.  However, non-melting, natural fiber clothing is not PPE; it is clothing.  Therefore, we recommend labels that state that if the PPE Level is 0, the clothing is non-melting, natural fiber clothing.  We base this recommendation on 70E®, Table H.3(b) which states non-melting, natural fiber clothing is used for incident energies equal to and less than 1.2 cal/cm2.  Table H.3(b) is part of Annex H which is an informative annex and not a required part of the standard.

The references in the 2015 70E® that require electrical workers to wear non-melting, natural fiber clothing are in the context of what clothing to wear under arc rated PPE.  Since there is no ARC PPE Category 0, there is no reference to non-melting, natural fiber clothing as PPE, except as noted above.  Many companies have moved to providing AR garments for all electrical operations rather than take the risk of workers wearing melting clothing which is still prohibited when PPE is required.

 

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Hugh Hoagland

Hugh Hoagland

Hugh Hoagland is the foremost tester of clothing and PPE exposed to electrical arcs and is an arc flash expert. Read more about Hugh.

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