Pete, Rich, all PSTC members,
thanks a lot for your detailed information. Its sometimes difficult to
understand the US system in comparison to the EU system:
If a importer or manufacturer places a product on the EU market the product
shall comply with the "CE marking regulations" like EMC, low voltage,
machine, toys, medical device directives.
For the operation the end user is responsible. The applicable EU directive
is 2009/104/EC "DIRECTIVE 2009/104/EC OF THE EUROPEAN PARLIAMENT AND OF THE
COUNCIL of 16 September 2009 concerning the minimum safety and health
requirements for the use of work equipment by workers at work (second
individual Directive within the meaning of Article 16(1) of Directive
89/391/EEC)"
In my understanding...
29 CFR 1910 Subparts S "Electrical" and O "Machine guarding" are more
similar to our "OSHA" Directive 2009/104/EC and NOT to the "CE marking
directives" because the main goal of these CFRs is "occupational health and
safety at WORK". Therefore the US customer has the goal to "buy safe
equipment like ITE or machines" from the German manufacturer.
I have a detailed example:
A German manufacturer produces "pasteurizers to raw milk" (users are
FARMERS). Technical data of the KompactPasteur:
Processor control with temperature sensors and process records
Electrical connection 230 V / 400 V
Heating capacity 8.1 kW
Combined coiled tube heat exchanger to heat and hold the heat
Two-stage heat recovery
Stainless steel milk pump
Capacity approx. 180 L/h with 8.1 kW heating capacity
Dimensions:
Width: 500 mm
Height: 1200 mm
Depth: 400 mm
This KompactPasteur complies with the European Low Voltage Directive
(electrical safety), machinery directive and EMC directive. Up to now the
German manufacturer are labelling the KompactPasteur with the following
important notice:
"This product complies with the requirements of the European Machinery
Directive 2006/42/EG, Annex II, 1.A and bears the CE sign. However it is NOT
UL/CSA approved. It is therefore imperative for the end user to have an
individual approval carried out!"
My questions are:
1. Is the involvement of an AHJ mandatory? If yes, who is responsible to
involve the AHJ? The FARMER or the "IMPORTER"? My understanding: the FARMER
in each county is responsible to involve the AHJ. To ensure that the machine
is safe it is recommended for the FARMER to specify the "fulfillment of the
NEC, 29 CFR 1910" together with a field evaluation by a NRTL in the
contract.
2. What is an AHJ doing? I understood the mails of Pete and Rich that an AHJ
approves each electrical installation BEFORE operation.
Best regards
Dipl.-Ing. Michael Loerzer
Managing Director
Regulatory Affairs Specialist
Das neue Buch zum Thema "Product Compliance":
http://www.beuth.de/sc/produktkonformitaet (Produktkonformität, Prozesse,
Risikomanagement, CE-Kennzeichnung, Fallbeispiele für Geschäftsführung,
Konstruktion, Normenabteilung, Vertrieb, Einkauf, Produktion, QM)
_________________________________________
Globalnorm GmbH
Alt-Moabit 94
10559 Berlin
Fon +49 30 3229027-51
Mobile +49 170 3229027
Fax +49 30 3229027-59
Mail michael.loer...@globalnorm.de
www.globalnorm.de
www.globalnorm.ca
www.product-compliance.com
_________________________________________
Globalnorm GmbH, Sitz der Gesellschaft: Alt-Moabit 94, 10559 Berlin
Geschäftsführer: Dipl.-Ing. Michael Loerzer
Amtsgericht Berlin-Charlottenburg HRB 105204 B, USt-ID-Nummer: DE251654448
-----Ursprüngliche Nachricht-----
Von: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Im Auftrag von Pete
Perkins
Gesendet: Freitag, 23. Dezember 2011 20:33
An: 'Michael Loerzer'; EMC-PSTC@LISTSERV.IEEE.ORG
Betreff: RE: [PSES] Electrical installation - Approval or required
permission by an AHJ in the US (29 CFR 1910 subpart S, NFPA 70/79)
Michael & PSNet,
The US system involving the AHJ includes something on the order of
10,000 separate jurisdictions in the US -including states, counties within
the states and cities within the counties.
They control electrical installations according to local regulations
(not uniform among all jurisdictions). Most invoke the NEC as the basis for
electrical installation requirements. Historically, electrical inspectors
have only looked at the fixed wiring within the installation but, more
recently, have been also looking at the installed equipment. Permanently
wired equipment is usually installed earlier and is more likely to be
included in the final inspection for any facility.
In any case the NEC (National Electrical Code) is invoked as being
applicable by jurisdictions. Article 100 defines Listed and Labeled to show
adequacy for the application and environment of use. Article 110 provides
the basis for the requirements: 110-2, conductors and equipment required or
permitted ... shall be acceptable only if approved (see Listed & labeled).
Article 110-3, ... Equipment ... Suitable for use and in conformity with ...
this Code. Installation & Use, Listed or labeled equipment installed in
accordance with the specified instructions from the Listing/labeling.
NFPA79 (which is harmonized with IEC 60204 since ~2000) is
applicable to industrial machines. At this point in time it is not a
specific certification category by test houses but individual machines are
evaluated and labeled as being in compliance (usually a field inspection).
The Listed/labeled equipment provides assurance to the local
inspector that a piece of machinery is acceptable to be installed and
operated as part of this operation. Local inspectors will push for this
further evaluation since they do not have the full experience nor time to
evaluate all the machinery used in enough detail to determine if it is
adequate.
The local inspector must approve the installation (including any
machinery that might be installed) before it can be operated by the factory.
Finally, I repeat what I've said on this PSNet many times before:
Americans are good at writing requirements (which are usually called
voluntary but it is more complicated than that) but have not develop an
integrated approval system that implements the requirements in the same way
all over the US.
I'm sure that there will be more comments; hopefully this help you
to understand the situation in America.
:>) 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
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