The last face shield advertisement I looked at showed an ATPV of 12cal/cm². It contained a note that said a balaclava was also needed in order to meet HRC2.

My point is: if half of the PPE we wear is not chosen by HRC, then why the big deal over not having this value on the label?
Tthe vast majority of PPE can chosen simply by incident energy (cal/cm²) so shouldn't this be a more universal number?

If Incident Energy and Categories are no longer linked, how will someone know when a face-shield, balaclava, arc-rated gloves, etc. are required? Seems like this will require arc flash labels to list all PPE required, which is essentially listing the required PPE of a Category without actually labeling the Category.

The labels are too simplistic. Different tasks already require different levels of PPE, at least according to the tables. But the label would lead you to believe that everything requires the same PPE, because there is only one value on the label (or even if there are multiple numbers, they are all usually functionally equivalent.)

Only qualified individuals are allowed to work on equipment, and they need to be trained in what level of PPE is required for whatever task. I am curious to see how the next edition of 70E is going to recommend that labeling be done to achieve this, or if they are just going to leave it open ended.

as a user, we've just lumped it into 2 basic catagories anyway to keep the method simple to the craft, cat 2 and 4. otherwise they seemed to get all confused. what I've seen that confuses our engineers more than anything is that their is life above 40 cal/cm2. I've actually got labels from engineering that said we counldn't do work.

Yes, there are samples of these labels directing "Do not work energized" greater than 40 cal/cm2 right in the 70E Handbook (exhibit 130.2).

130.7(A) Information Note No. 3: States that "when incident energy exceeds 40 cal/cm2 at the working distance, greater emphasis may be necessary with respect to de-energizing before working within the limited approach boundary of the exposed electrical conductors or circuit parts."

The handbook notes that accompany that note state that the pressure wave generated from an arc flash greater than 40 cal/cm2 "might injure any employee who is near."

The handbook note for 130.7(C)(6) Body Protection furthers the point that the pressure wave at greater than 40 cal/cm2 can injure, even if someone is wearing an arc blast suit rated for the specific incident energy. It further states you should only use the blast suit to de-energize the circuit, and all other tasks should only be done de-energized.

70E may not state that you can't work at greater than 40 cal/cm2, but they make a point of pointing out that you should be trying harder to de-energize when you get to that cut off.