And I'll throw in one more twist, We have customers who relocate existing equipment they have had in operation for many years that to a new facility. The new facility often must have all the equipment installed for final inspection before COO is issued. The AHJ will fail the inspection when they find the older equipment does not have a listing mark on it. Then the customer has a mad rush to get the equipment field labeled that they assumed was fine all along.
-Dave From: Pete Perkins [mailto:00000061f3f32d0c-dmarc-requ...@ieee.org] Sent: Monday, December 15, 2014 1:27 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Certification of Unique Equipment Rick, et al, You have produced an itch that has already provided some good comments regarding how to handle them. Here's a little more info based upon my experience. The US rules are quite clear and well described by Kevin Robinson; the US enforcement is the key issue and depends quite heavily upon whether or not your customer gets a permit for electrical changes that might be needed to install your equipment in that location. If the formal permit process is invoked then the AHJ electrical inspector will be looking at your equipment to see if it is 'listed & labeled' before accepting it as part of the installation. This 'small detail' catches up quite a few installation projects; it's quite frustrating to have to deal with all of this long after the equipment has been shipped away. A common solution is to get an acceptable NRTL or state(-by-state) approved lab to do a Field Inspection and label the product as being acceptable under the NEC. This activity transfers the equipment inspection away from the AHJ inspector to another body which claims to have more experience in determining adequacy of equipment. This Field Inspection & Labelling can only be done at the installation site. A common requirement is to evaluate the equipment to NFPA 79, Electrical Standard for Industrial Machinery; this standard is harmonized with EN 60204, Electrical Safety of Machines. The difference in the Euro and the NA practices need to be understood to properly apply the requirements for each respective market. It is possible, working the a Field Labeling supplier who has National (or international) offices to get them to do a preliminary inspection at the factory to ensure that there are no outstanding issues that will 'bite you' during the installation on-site inspection and labeling (the preliminary results/report are shared with the person doing the final inspection to smooth the path). The technical report developed (which describes the machine and includes some test results) is provided to the local AHJ inspector as proof of conformance to the needed requirements. Finally, this Field Labeling only applies to that one particular machine and the process will have to be repeated for any other similar unique machines. Hopefully the unique equipment customer knows ahead of time that the installation will be AHJ inspected and will let the unique equipment supplier know up-front that the equipment will be subjected to inspection and that a proper NEC certification will be required. In the same way that it is quite a bit of work to CE mark one unique machine, this is a similar process. If this needed certification comes up after the fact at the point of installation there is a lot of unhappiness on both sides; the customer is chagrined in having the installation stalled while these details are being straightened out and the manufacturer is unhappy to have to spend the additional, unplanned $$$ to get this certification done before being paid for the fine work to provide this unique capability to this customer. I'd be surprised if most equipment manufacturers don't get caught up in this problem from time to time. To insure adequacy of the equipment that your company buys the purchasing process should include wording in the procurement specification that the equipment must be properly Listed and Labelled as compliant with the NEC requirements. Hopefully this provides some detail that will be helpful as the cases arise. :>) br, Pete Peter E Perkins, PE Principal Product Safety Engineer PO Box 23427 Tigard, ORe 97281-3427 503/452-1201 fone/fax p.perk...@ieee.org<mailto:p.perk...@ieee.org> From: Rick Busche [mailto:rick.bus...@qnergy.com] Sent: Sunday, December 14, 2014 12:33 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Certification of Unique Equipment It is always my desire to provide products that are CE Marked for Europe and NRTL listed for North America. That said, I continue to find products delivered for our own production environment that carry no safety marking that I can identify. I have discussed this concern with other engineers who worked in previous companies who indicated that they NEVER were required to have certification on their products. As I understand it I could deliver a one of a kind system to a unique customer without certification in North America. At what point is certification required? Is it based on the quantity of systems, the customer, the AHJ, OSHA or marketing? Is it allowable to ship a unique, prototype system to a specialized customer, without NRTL? Thanks Rick - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org<mailto:emc-p...@ieee.org>> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe)<http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org<mailto:sdoug...@ieee.org>> Mike Cantwell <mcantw...@ieee.org<mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher <j.bac...@ieee.org<mailto:j.bac...@ieee.org>> David Heald <dhe...@gmail.com<mailto:dhe...@gmail.com>> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org<mailto:emc-p...@ieee.org>> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe)<http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org<mailto:sdoug...@ieee.org>> Mike Cantwell <mcantw...@ieee.org<mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher <j.bac...@ieee.org<mailto:j.bac...@ieee.org>> David Heald <dhe...@gmail.com<mailto:dhe...@gmail.com>> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
