You've hit on a common point of confusion and debate within the electrical safety community regarding the 2021 update to NFPA 70E Table 130.5(C). Let's break it down

Understanding the Change and Intent
The 2021 Addition

The explicit listing of "Operation of a CB or switch the first time after installation or completion of maintenance in the equipment" with a "Likelihood: Yes" was a significant change.

Why the Change? The intent was to recognize the increased risk of an arc flash during the initial operation or re-energization of a circuit breaker/switch. This higher risk is due to several factors: Foreign Objects

During installation or maintenance, there's a greater chance of debris (metal shavings, wire scraps, etc.) being left within the equipment, which can cause a fault.

Loose Connections

New or reconnected conductors and terminations may not be properly tightened or seated, leading to arcing faults.

Damaged Insulation

The process of installing or working on the equipment could damage insulation, creating a potential short circuit path.

Undetected Issues

Problems such as wiring errors may not be discovered until the breaker is energized and loaded.

Is it for All Breakers Regardless of Incident Energy? Yes and No (It's Nuanced)

The table, as written, appears to apply to all circuit breakers and switches. However, the key is how you use the table in conjunction with the rest of NFPA 70E.

The Hierarchy

NFPA 70E operates on a hierarchy of risk assessment. You can't just rely on the table alone.1.

Hierarchy of Controls

The first step is always to eliminate the hazard.2.

Arc Flash Hazard Analysis (130.5(A))

After eliminating the hazard if possible, you

must conduct an arc flash hazard analysis. This analysis is the foundation for determining the required PPE.

Common Interpretations and Best Practices

You've described the common interpretations accurately. Here's a refined view: The "40 Cal Suit for Everything" Approach

This is the most conservative and likely overzealous approach, particularly for low-energy circuits. It can create significant inefficiencies and, arguably, introduce new safety risks (decreased dexterity, visibility, and fatigue).

The "Leather Protectors and Stand to the Side" Approach

This is a more reasonable approach that acknowledges the risk but doesn't overreact to low-energy situations. Leather protectors are generally inadequate for significant arc flash events. Standing to the side is always a good practice.

The "Ignore It" Approach

This is the most dangerous and clearly violates NFPA 70E.

The Balanced Approach (Recommended)

This is the most difficult to implement but also the most effective and compliant:1.

Arc Flash Hazard Analysis

This is mandatory. Perform an arc flash hazard analysis. This calculation will tell you the incident energy for each piece of equipment.2.

Risk Assessment

Consider the specific conditions of the installation or maintenance. Has the equipment been thoroughly inspected? Are you confident in the quality of the work? What is the likely level of possible incident energy, if an arc flash were to occur?3.

Qualified Person's Judgement

A qualified person (someone with the skills and knowledge related to the construction and operation of the electrical equipment and installations and has received safety training to recognize and avoid the hazards involved) should assess the risk.4.

Use the Table as a Starting Point

Table 130.5(C) tells you that there is a Likelihood of Occurrence during the initial energization of a breaker or switch. You must decide what safety precautions to take if there is an arc flash hazard present.
5.

Apply Hierarchy of Controls

After that initial energization, you can assess the breaker or switch as it normally operates.

Addressing Your Specific Situation (1000 Breakers) Prioritize

Don't treat every breaker the same. Focus on larger breakers, breakers feeding critical loads, and breakers that have undergone significant maintenance or alteration.

Consider Reduced Incident Energy Techniques



Current Limiting Fuses/Breakers

If upstream protection includes current-limiting fuses or breakers, document the reduced incident energy at the panel.

Zone Selective Interlocking (ZSI)

If the system has ZSI, ensure it's enabled and tested. This can significantly reduce clearing times for faults.

Maintenance Mode/Reduced Energy Let-Through

Some equipment has settings to temporarily reduce incident energy during maintenance.

Remote Racking

If the breakers can be operated remotely (e.g., with a remote racking device), consider using this method to minimize worker exposure during the initial energization.

Documentation

Document your hazard analysis, risk assessment, and the rationale for the PPE and work practices you've chosen.

Important Considerations



Definitions

Ensure a clear understanding of "installation" and "completion of maintenance" in your company's safety program. This will help determine when this table entry applies.

Training

Ensure that all electricians and qualified persons receive thorough training on NFPA 70E, arc flash hazard analysis, and risk assessment.

Company Policy

Develop a clear company policy on arc flash safety, including how to interpret and apply Table 130.5(C) in different situations. This will help ensure consistency and compliance.

In summary, while the 2021 change to Table 130.5(C) does appear to apply broadly, it's not meant to be applied blindly. A thorough arc flash hazard analysis, a proper risk assessment, and the application of the hierarchy of controls are essential for determining the appropriate level of PPE and safe work practices. Focus on a risk-based approach that addresses the specific hazards present in each situation. Flag for review