The U.S. constitution (theoretically) offers only enumerated powers. All else are domain of the individual states. Note the Ninth and Tenth amendments, and other such stuff. But some stuff is slowly being changed via adjudicated 'law'.
Brian -----Original Message----- From: John Woodgate [mailto:[email protected]] Sent: Tuesday, April 04, 2017 12:59 PM To: [email protected] Subject: Re: [PSES] E-Box Layout on Factory Machines Why do you continue to have a system like that? I know you can't alter it unilaterally, but perhaps the IEEE should consider advising the government to make approvals less of a lottery. The situation you have is more or less that every AHJ is a unique foreign country, to which you are trying to export. With best wishes DESIGN IT IN! OOO – Own Opinions Only www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England Sylvae in aeternum manent. -----Original Message----- From: Kunde, Brian [mailto:[email protected]] Sent: Tuesday, April 4, 2017 8:41 PM To: [email protected] Subject: Re: [PSES] E-Box Layout on Factory Machines Dave hit the nail on the head. In our type of products and market, we manufacturer many different products (50 or more families of products), but in very low quantity. Fifty of one model per year is a lot to us where some models we might not sell even one. We build to order one unit at a time. And we have products that have been "in production" for over 30 years. We have talked to many NRTL labs about a certification program but they all say the same thing; it makes no sense with the low quantity we produce. They consider our products "Custom" and we can provide a Test Report from our internal safety lab (we have a very nice facility). Some OSHA inspectors are OK with it, some are not. Same with AHJs. Some are ok, some require a label from an NRTL. Most government organizations, universities, and government contractors require NRTL marks on products these days. We do offer this through a local NRTL lab in the form of a Field Evaluation. No problem with these inspections. Where we run into trouble is with products that are inspected in the field. Customers will hire NRTLs to do field evaluations on location on new products or sometimes on products that have been in service for years, and some inspectors, not knowing what it is they are looking at, will inspect it to some standard or set of rules they pulled out of a hat. That is why I ask so many questions about Criteria. Nine out of ten inspections go fine. And most of those who have issues are happy with an explanation or a little information from us. But it is those stubborn close minded inspectors who won't budge that will send me to an early grave. These are the inspectors we are constantly trying to understand and design our products to satisfy to minimize the problems and costs. I know we will never be able to make everyone happy. But the more information we have the better things get. Thanks so much for your comments and advise. It is very helpful. The Other Brian -----Original Message----- From: Nyffenegger, Dave [mailto:[email protected]] Sent: Tuesday, April 04, 2017 3:09 PM To: Kunde, Brian; [email protected] Subject: RE: [PSES] E-Box Layout on Factory Machines The preceding may not have completely addressed the question. You are probably looking to identify what standards to apply while designing the product before an NRTL has a chance to evaluate and determine what they think is the appropriate standard(s). This is where experience and a working relationship with the NRTL comes in handy. We often design to a few different standards when possible. If there are conflicts, well then we have to make a judgment call. With some prior history we know what standards the NRTL has used on similar product. We can also get preliminary input from the NRTL on what standards they would apply. In particular during a preliminary quote cycle with basic product description the standards to be used for certification will have been identified in the NRTL certification quotes. -Dave -----Original Message----- From: Nyffenegger, Dave Sent: Tuesday, April 04, 2017 3:02 PM To: 'Kunde, Brian'; [email protected] Subject: RE: [PSES] E-Box Layout on Factory Machines Brian, I assume you're asking about US requirements and the inspectors you are asking about are local AHJs or OSHA. So OSHA and perhaps the AHJs have a basic rule that all equipment used in the workplace is NRTL approved/listed except for custom built equipment that can be certified as safe by the manufacturer on the basis of test data. I don't know if or how the exception may apply with local AHJs, no experience with that one. The first thing the local electrical/building/OSHA inspector is going to look for is the NRTL mark. They see that they are usually happy and done. That pushes your question off to the NRTL who gets to evaluate the product and determine what standards to apply. Basically the same procedure for a NRTL lab certified product or NRTL field inspected/marked product. If you don't have a listing of field inspection mark, well then you're going to be up for challenges with the local inspectors. The various standards have their own scope definitions and the NRTL is going to review to determine which standard(s) are most appropriate. In some cases it may not be simply black and white and it may be possible for the NRTL to choose between this standard or that standard. I have run into this on several occasions. The NRTLs cannot use NFPA 79 as a UL listing standard but they do use it as a reference standard alongside of a primary listing standard. Typically they will refer to it for anyt hing that qualifies as machinery. For large industrial equipment which has a "industrial control panel(s)" driving external motors and such, i.e. a system of multiple large components rather than a single self-contained product in a "box" , you may get away with an NRTL listing on the control panel assembly alone (i.e. UL 508A). The control panel must be installed and used according to conditions specified in the NRTL report. Some of those larger systems may be the ones that fall into the category of custom built and certified by the manufacturer. -Dave -----Original Message----- From: Kunde, Brian [mailto:[email protected]] Sent: Tuesday, April 04, 2017 1:55 PM To: [email protected] Subject: Re: [PSES] E-Box Layout on Factory Machines I never studied the VSA, but ships built for the Federation had panels in hallways that could be removed without a tool with high voltage plasma coils and flux capacitors behind them. And kids lived aboard these ships. Open Jeffares tubes without locked doorways where common. Space stations appeared to have locks on grain storage bins, but it didn't keep out domesticated pets (Tribbles). And there was that "one room" aboard the submarine Sea View that when anyone entered, we all knew that someone was going to get electrocuted. I guess the future makes no more sense than the present. I am interested in the criteria inspectors use to decide if a product should meet these requirements or not. Or is it completely voluntary. I would imagine if NECA, NEMA and NFPA 79 is involved then inspectors are going to require following what they say. Here is an example of what I'm looking for. You have two cut-off saws; one is about the size of a lunchbox, sits on a table, has a 1/8hp motor, and cuts 1/8" steel rods into 1 gram samples to be analyzed for carbon/sulfur content. The other is huge, weighs 1000lbs, floor mounted, 3-phase power, has a 35hp motor, and can cut an engine block into slabs for hardness testing and metallurgical analysis. Technically both do the same function. Both are considered "prep machines for analytical analysis". So then both can be considered "laboratory equipment" even though the big one is more messy and makes a lot more noise. Neither is marketed or sold for any other purpose even though they could be used to cut many things for many reasons. Now let's say there are 10 more saws of different sizes and hp that fit between the two I mentioned above. At what point (criteria) do we apply the NFPA 79 and the like? At what point will inspectors expect to see a different set of design rules applied, or again, is it all voluntary how you design a product? Thanks for the help. The Other Brian -----Original Message----- From: Brian O'Connell [mailto:[email protected]] Sent: Tuesday, April 04, 2017 12:01 PM To: [email protected] Subject: Re: [PSES] E-Box Layout on Factory Machines Agree vehemently, but also codified per NECA 1-2015, and the various workmanship standards of the Vulcan Science Academy. UL508A does not do much for 'workmanship', just materials and construction and performance. And do not want to see a safety standard that tells me stuff has to be built pretty. Brian From: IBM Ken [mailto:[email protected]] Sent: Tuesday, April 04, 2017 6:15 AM To: [email protected] Subject: Re: [PSES] E-Box Layout on Factory Machines I think those types of products are engineered once, and then built and serviced for decades. Overly neat designs lend themselves to less problems in production and service over the years, even when the original designers are no longer available to help. I don't think there are any criteria which require that type of construction (aside from tradition). It's like asking why every facilities engineer has a large keyring, a pocket protector containing no less than three writing instruments, and a AA mini Maglite on their belt. On Tue, Apr 4, 2017 at 8:54 AM, Kunde, Brian <[email protected]> wrote: I notice that most industrial factory machinery is designed with a large metal electronic box with a hinged door and some kind of keyed lock. Inside the components are DIN mounted and the wiring is all dressed very neatly in these gray plastic cable runs with snap-on lids. Every wire is labeled with a small tag. Why are these machines so similar in design? Even among different manufacturers, they look similar. Is there a standard or standards that dictate exactly how this is done? What criteria is used to determine if your product must follow these construction rules? Seems strange to me that they are so similar and if required to be that way, then standards and/or governments are dictating design. Even if it was for the “greater-good”, I thought that was a no-no. Dictate design, stifle creativity, invite those who would take advantage for financial gain. Just curious. I’m most interested in the criteria question, though. The Other Brian - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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Thank you. - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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Thank you. - ---------------------------------------------------------------- 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 <[email protected]> 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 <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher: <[email protected]> David Heald: <[email protected]> - ---------------------------------------------------------------- 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 <[email protected]> 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 <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher: <[email protected]> David Heald: <[email protected]> - ---------------------------------------------------------------- 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 <[email protected]> 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 <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher: <[email protected]> David Heald: <[email protected]>
