Re: [PSES] List of Common Misuses

[David Nyffenegger]

Brian,

Sounds like a NRTL engineer is asking for possible misuses whether or not
they may result in a hazard.  And perhaps this is just to ensure that
misuses have been considered and can be included in the listing report, to
satisfy the internal report reviewers, or their certifying auditors, not
necessarily to be listed in the operating manual.  For example, it could be
a misuse to sit the 400lb analyzer precariously on top of a sawhorse where
it may fall over, or on a 25lb rated plastic table, or plugged into an
underrated extension cord run across the floor.

-Dave


On Wed, Oct 5, 2022 at 2:01 PM Brian Kunde  wrote:

> My company manufactures Laboratory Equipment such as analyzers and
> determinators. They are highly specialized equipment, yet have an infinite
> range of uses.
>
> Even though all known residual risks are documented in the Safety Warning
> section of the manual, they will commonly request a list of Misuses.  There
> are no buttons, or settings that can be changed by the User that can cause
> a hazard.  The operational environment is clearly defined. So in most all
> cases, I am not aware of any "Misuse" that can cause a hazard. For some
> reason, this answer is not acceptable.  We are expected to come up with
> something.
>
> Is there a standard or common list of MisUses that seem to satisfy this
> requirement?
>
> How crazy are we to get with this?, e.g., don't use the 400lb analyzer
> while taking a bath?  Don't use it to mow your lawn?  Common
>
> I used to work for a computer company and I couldn't believe the stupid
> warnings we had to put in the manual.
>
> Thanks to all.
>
> The Other Brian
> -
> 
>
> 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
>
> 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:
> Mike Cantwell mcantw...@ieee.org
>
> For policy questions, send mail to:
> Jim Bacher j.bac...@ieee.org
> David Heald dhe...@gmail.com
> --
>
> To unsubscribe from the EMC-PSTC list, click the following link:
> https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC=1
>

-

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 


All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

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:
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 
_
To unsubscribe from the EMC-PSTC list, click the following link: 
https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC=1

Re: [PSES] UL Standards Effectivity Dates

[David Nyffenegger]

Hi Doug,

I assume what you are really asking about is an NRTL listing to a UL
standard.   The NRTL listing certifies that the original equipment met the
applicable standard when new as of the date of manufacture.  The
NRTL/certification makes no representation as to the state of the equipment
after it leaves the factory as the NRTL has no control of
repair/maintenance/refurbishing.  The exception is refurbishing done in a
facility specifically certified by the NRTL for refurbishing.  Therefore
whatever happens with equipment repair/maintenance/relocation/ownership
change etc is irrelevant to the original certification.  Typically AHJs and
OSHA will accept the original certification/label for the life of the
equipment.

The NRTL will work with the manufacturer to determine what standard needs
to be applied to the current product being manufactured and whether/when a
recertification is required to a newer standard.  Typically a product can
be manufactured and maintain certification under the standard it was
originally certified to provided the product itself is not changed.
Anytime the product is revised it opens the door for the NRTL to recertify
it to the current standard.

If there is a question or concern with the safety/certification of
installed equipment regardless of age or condition, the owner can have the
equipment "field inspected" and certified/labeled by an NRTL or other
agency accepted by an AHJ.  The NRTL would determine the applicable current
standard(s) to apply at the time when inspecting the equipment on site. The
certification is specific and applicable to only the equipment physically
inspected.  Typically the field label is only good for the location the
equipment is installed at when inspected.  The equipment need not have been
originally NRTL certified at the time of manufacturer for field inspection
but that typically makes for a smoother field inspection.

-Dave

On Thu, May 6, 2021 at 3:16 PM Douglas E Powell  wrote:

> Hello all,
>
> I would like to understand the use of effectivity dates, specifically for
> UL standards, when dealing with rather large leased equipment used in
> association with an energy production facility. The plan is that an
> original manufacturer will build, install, monitor, and maintain the
> equipment as a lease and not for sale. The idea is that the equipment is
> put into service with the required certifications of the day.
>
> If at some later time, possibly a few years later, the equipment is taken
> out of service, moved to a new location to be put into service once again
> (the ownership has not changed) and if in that interim period the
> applicable product standards have been revised, effectivity dates
> established, and the new edition of the standard is mandatory for new
> products, is it necessary to re-certify that equipment?
>
> In my scenario that equipment may or may not involve refurbishing or
> updating when it is relocated.
>
> Thanks, Doug
>
> --
>
> Douglas E Powell
> doug...@gmail.com
> http://www.linkedin.com/in/dougp01
> -
> 
>
> 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
>

-

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 


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 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] 21 CFR § 1040.10 - Laser products.

[David Nyffenegger]

 Hi Amund,
Yes, and it depends on the power of the laser and the complexity of the
product.  The requirements are more stringent for higher power lasers.  An
initial product report must be submitted to FDA for each laser product and
it can take some time to put that together depending on the complexity of
the product.  I recall there are some standard templates available
somewhere for the reports.  There are some basic requirements specified in
the regulations that must be met and described in the report such as
interlocks if applicable and labeling.

Presumably most folks are reporting on a product that includes a laser
rather than the actual laser.  This simplifies things a bit as you can rely
on the OEM documentation for some items and refer to their accession number
assigned to their reports.  Like everything else there are consultants that
specialize in creating the FDA reports.

You must submit an annual report due Sept 1 each year describing the
production volume of each product and any product issues or complaints that
may have been received.  The annual report doesn't take much time assuming
you are collecting the information throughout the year.

-Dave

On Tue, May 19, 2020 at 4:16 AM Amund Westin 
wrote:

> Anyone who have been through the process for complying to 21 CFR §
> 1040.10?
> Time consuming process?
>
> BR
> Amund
>
> -
> 
> 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 
> Mike Cantwell 
>
> For policy questions, send mail to:
> Jim Bacher:  
> David Heald: 
>

-

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 


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 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] **External**[PSES] Fwd: Emergency Stop Function

[David Nyffenegger]

Brian,



Depending on your requirement you may need a risk assessment to something
like ISO 12100 or ISO 13849-1.  From that would be determined the minimum
performance level of the safety control system.  A single contactor could
be used as the VFD manufacturer suggests. For higher performance levels two
contactors in series with monitoring of the contacts may be required.   But
the contactor is brute force and doesn’t allow for controlled shutdown as
you have noted.  A VFD with STO input is an easier and cleaner approach and
allows controlled shutdown providing the performance level of the STO is
adequate for your requirements.  There more books, white papers, and
seminars than you can imagine on this topic.  The OEMs of the safety
control system components are more than happy to share their view and
documentation on the subject.



Note that a fundamental general requirement for an E-STOP is that releasing
the E-STOP does not in itself restart any motion.  If you are dropping a
VFD with a contactor or STO it will probably not re-start when the E-STOP
is released.  But in other cases a safety controller may be appropriate to
use with the E-STOP and STO or contactors.


-Dave

On Thu, Mar 19, 2020 at 1:31 PM Jim Hulbert 
wrote:

> I think you need a VFD with Safe Torque Off (STO) function.
>
>
>
> Jim Hulbert
>
>
>
> *From:* Brian Kunde [mailto:bkundew...@gmail.com]
> *Sent:* Thursday, March 19, 2020 1:19 PM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* **External**[PSES] Fwd: Emergency Stop Function
>
>
>
>
>
> If any of you have a Case of Corrona, I hope it is the type that comes in
> bottles or cans.
>
>
>
> First, there is a guy in this group who I chatted with in the past who is
> like an expert in the E-Stop function.  He has a Blog or Website dedicated
> to this topic which I cannot currently find.  Can anyone help me get in
> contact with him?
>
>
>
> My area of need is with integrating the E-Stop function with a Variable
> Frequency Drive (inverter).  I have to meet the international requirements
> as well as the USA and Canadian requirements.
>
>
>
> What I have is 3-phase AC power, through a Contactor, to a VFD, which
> powers a 3-phase motor.  The VFD has the motor brake feature built in.
> Under a normal STOP command, the VFD engages the motor brake.  All is
> fine.
>
>
>
> The VFD manufacturer's documentation shows to connect the E-STOP to the
> motor Contactor which OPENs power to the VFD.  When the E-Stop is engaged,
> power to the VFD is shut down; the motor continues to spin for up to 30
> seconds or more before coming to a stop.  The motor Brake does not engage
> because it is a feature of the VFD which is powered down.  This makes no
> sense to me.
>
>
>
> The E-STOP is supposed to stop motion as quickly as possible without
> causing additional Risk (according to the MD and NFPA 79 cat.2).  So how is
> the E-Stop function supposed to work with a VFD?  How is this typically
> done?  Are we buying the wrong VFD?
>
>
>
> Thanks to all.
>
>
>
> The Other Brian
>
> -
> 
>
> 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)
> 

Re: [PSES] Mandatory certification

[David Nyffenegger]

Or typically the government organization, the AHJ, simply accepts the field
inspection label applied by NRTL or other recognized entity.  The
owner/operator of the product is ultimately responsible for the
inspection.  I’ve never known a government organization to hire a NRTL for
field inspection, unless of course the product in question is
owned/operated by said government organization (which is not unusual.)   In
my experience as a manufacturer we will often provide for a field
inspection/label of un-listed product as part of the sales agreement to the
customer.



-Dave

On Thu, Feb 20, 2020 at 1:59 PM Richard Nute  wrote:

>
>
> Hi Regan:
>
>
>
> While field inspection is not part of OSHA's NRTL program, OSHA rules
> allow another government (federal, state, local) organization to determine
> compliance with the NEC.  See:
>
>
>
> https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.399
>
>
>
> I would guess that such a government organization (not the manufacturer)
> would hire a NRTL to do a field inspection.
>
>
>
> Best regards,
>
> Rich
>
>
>
>
>
> *From:* Regan Arndt 
> *Sent:* Wednesday, February 19, 2020 10:46 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification
>
>
>
> Hello Dave/Bernd.
>
>
>
> Just a comment/clarification. The field inspection/label program is not
> part of OSHA's NRTL program despite some NRTL's that conducted this
> service. I know it can seem confusing but there are also some non-NRTL's
> that conduct these field evaluations, all of which are under state
> jurisdiction.
>
>
>
> Some may think they are abiding by OSHA rules with obtaining a field
> evaluation by an NRTL. That is not the case.
>
>
>
> Regan
>
>
> -
> 
>
> 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
>

-

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 


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 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] Purchase Mains Input Filters

[David Nyffenegger]

We use a lot of Corcom and Schaffner.

-Dave


On Tue, Jan 21, 2020 at 2:24 PM Amund Westin 
wrote:

> Any advice where to go when purchasing mains AC input filters? (for
> conducted emission purpose)
>
>
>
> BR
>
> Amund
>
>
>
> -
> 
>
> 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
>

-

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 


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 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: