One state, two electrical codes. Most bids are written as if there were one.
An arc flash hazard analysis, an arc flash assessment and an arc flash study are three names for the same deliverable. What is not the same is the code behind it. A plant in upstate New York and a building in the five boroughs are inspected against different editions of different documents, and the label that satisfies one does not automatically satisfy the other. This page is which applies to you, and what it changes.
New York does run its own occupational safety plan. For almost every industrial site in the state, it is not the one that applies.
PESH covers public employees only. The New York Public Employee Safety and Health programme covers state and local government workers · a municipal water plant, a county facility, a public authority. A semiconductor fab, a research campus or a private manufacturing site is not inside it.
Private sector New York is federal OSHA. The duty that binds your plant is 29 CFR 1910.132(d) · assess the hazard, and hold a written certification that the assessment was performed. The study is what makes that certification possible to write and defensible to produce.
Parts of upstate New York genuinely sit under both frames. Where a site operates an installation existing for the sole purpose of generating or distributing electric power, 1910.269 reaches it as well, alongside Subpart S for the utilisation system feeding process load. Those are separate frames and a competent study names which one governs each part of your plant rather than blurring them.
| Your site is… | Covered by | The duty that bites |
|---|---|---|
| A private plant, fab, campus or data centre | Federal OSHA | 29 CFR 1910.132(d)(1) hazard assessment and 1910.132(d)(2) written certification |
| A state, county or municipal facility | PESH, New York’s public employee plan | The same standards, enforced by the state rather than by federal OSHA |
| An installation for the sole purpose of generating or distributing power | 1910.269, alongside Subpart S | Named separately in the deliverable, because the two frames are not interchangeable |
Not sure which frame your site sits under? Tell us the plant type and we will name it, whether or not you invite us to bid.
Outside the five boroughs, the 2025 New York State Uniform Code references the 2023 National Electrical Code, applying to permit applications filed on or after 31 December 2025.
Inside New York City, there is a separate document. The 2025 New York City Electrical Code took full effect on 21 December 2025 and consists of city amendments to the 2020 edition of NFPA 70. The city amendments are frequently stricter than the national text, and they, not the state adoption, are what a New York City inspector holds.
Why this decides your labels. NEC 110.16(B) requires arc flash marking on service equipment to carry the nominal voltage, the available fault current, the clearing time of the service overcurrent devices and the date the label was applied. NFPA 70E does not require a date. A label built to 130.5(H) alone therefore does not satisfy the NEC, which is the single most common gap we find on an existing estate.
The threshold is not the same on both sides of the state. The 2023 edition upstate applies 110.16(B) to service and feeder supplied equipment rated 1,000 amperes and above. The 2020 base the city works from applies at 1,200 amperes and to service equipment. Same clause number, different reach · which is why an estate cannot be labelled to one rule and assumed compliant in both.
And New York City has put a clock on it. Under Local Law 128 of 2024, carried into the 2025 New York City Electrical Code, service equipment in a building electrical room at or above the threshold must carry an arc flash label to NFPA 70E, with one year from the code taking effect on 21 December 2025 to complete the work. A label is the output of a study, and a study takes six weeks. The arithmetic on that is not generous.
What binds every label in the state today is NEC 110.21(B) and NFPA 70E 130.5(H) · field-applied hazard marking must be durable enough for the environment it lives in, made explicit in the 2024 edition of 70E. A label that has faded is not a label, wherever it is.
We print an assessment date on every label regardless of jurisdiction, and we label to the lower threshold. It costs nothing, it satisfies both reaches of 110.16(B) outright, and it means an estate split across the state carries one label standard rather than two.
An estate with a plant in Buffalo and a building in Brooklyn is inspected against two different electrical codes, at two different thresholds. Ask any bidder which one they are designing each label to.
New York holds a wider spread of plant types than any neighbouring state, from new semiconductor capacity to buildings older than the code that governs them.
New capacity arriving on grid infrastructure that predates it by decades, and a facility that cannot take an unplanned outage at any price. The study is planned around tool-install windows and commissioning sequences rather than around a maintenance shutdown, because there is not going to be one.
Smaller and more numerous than the pharmaceutical estates further south, and usually with qualification protocols and change control wrapped around any label that goes onto a panel inside a controlled area. The engineering is straightforward. The access is not.
The city code, house service arrangements the rest of the state never sees, and no room to work anywhere. Equipment is opened in a live building at night, which makes the sequencing of the walkdown and the label installation the governing constraint.
Where 1910.269 and Subpart S genuinely both apply, to different parts of the same site. A study that names one frame and stays silent on the other has answered half the question.
Field work runs from our United States team, supported by the analytical bench in Hyderabad. Walkdown findings from a Tuesday afternoon are modelled overnight, so a study that would run eight weeks sequentially closes in six.
The report is delivered PE stamped, sealed by a Professional Engineer licensed for the jurisdiction. This matters more in New York than almost anywhere: public specifications in this state name a New York State registered Professional Engineer as a condition of the work, not as a preference. Every section additionally carries a named Chartered Engineer signature · the Practice Lead drafts, the Principal Reviewer independently cross checks.
No plant shutdown is required for the analysis. Only label installation needs brief access to each item, sequenced against your outage window, your tool-install schedule or your night-work permit, whichever governs.
The four stages, their durations and the sign-off gate at each one are the same wherever we work and are set out once on the United States page rather than repeated here.
Send your outage window and we will sequence the walkdown and the label installation against it.
On a New York estate the briefing usually has to run more than once · a day shift and a night shift, or an upstate plant team and a city building crew who will never be in the same room. We plan for that rather than treating it as an exception.
Where a crew is going to rack a breaker they have not racked before, they rehearse it in VR against a model of their own switchgear first. On a facility that cannot take an unplanned outage, the cost of learning it live is the whole argument. Retraining, label currency and the five year review run as a programme, set out on VB Arc360.
Send the sites, the voltage levels and the substation count. A Chartered Engineer comes back inside one business day with a scoped bus count and the code frame that applies to each location.
Sites both upstate and in the city? They are on two different codes.
Tell us the site, the date on your last hazard assessment certification, and your next outage window.