It depends largely on your ventilation. Are you maintaining between 65 and 75 degrees? If so, a 400 watt metal halide can be placed up to one foot away without risking damage to the plants. If the air is not vigorously circulated, the heat is exponentially increased, anything above 80 degrees slows down growth rate with virtually no increase in size at 90 degrees. In that case, 18 to 24 inches. We are talking about seedlings, which means that a lot more light exposure reaches each sprout at one foot. With a fully mature plant, you loose some usable light to the lower part of the plant at only one foot distance, so the larger they get, the better you'll be able to evaluate maximum efficiency of lighting.