Dave, et al,
Thanx for that additional comment. This twist has caused a
large semi company to require that all new equipment carry the full
worldwide set of certifications on any equipment that they install in their
faciilties. They know that the equipment will be shipped to another
location when the processes move. That doesn't mean, of course, that
additional countires will have instituted technical requiremenents which
need to be met with another cert mark, but it clears a lot of obstacles in
preparation for that.
:>) 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
From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com]
Sent: Monday, December 15, 2014 10:44 AM
To: Pete Perkins; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] Certification of Unique Equipment
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
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>
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>
Mike Cantwell <mcantw...@ieee.org>
For policy questions, send mail to:
Jim Bacher <j.bac...@ieee.org>
David Heald <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) <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>
Mike Cantwell <mcantw...@ieee.org>
For policy questions, send mail to:
Jim Bacher <j.bac...@ieee.org>
David Heald <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>
