Brian, et al,
Lots of good discussion on this topic; shows wide level of experience.
Since you seem to be well organized on this one additional path you
could use in NA is a NRTL (or not) Field Inspection.
The best route is when you know ahead of time that a Labeled product is
needed you arrange for an inspection at the factory to show the innards (and
your competency) which provides a report for their inspector who reviews the
installed product and puts a Field Label on the product (can't be labeled at
the factory).
When you get caught up at the installation the Field Inspection can be
done there but best when supported with your data package with details to avoid
questions.
Some AHJs will also accept an independent Field Label from someone
authorized to do so locally - usually a US state-by-state list you need to
chase.
As you have noted, lots of variability in results in the field.
:>) br, Pete
Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 23427
Tigard, ORe 97281-3427
503/452-1201
[email protected]
-----Original Message-----
From: Kunde, Brian [mailto:[email protected]]
Sent: Tuesday, April 4, 2017 12:41 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
anything 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
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