Code Corner
[1_TD$IF]Codes, standards and electrical listing of equipment
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s principal investigators search far and wide for the most innovative and state-of-the-art equipment, we are often confronted with the question ‘‘is the equipment labeled and listed?’’ What does ‘‘labeling’’ and ‘‘listing’’ actually mean? What are the applicable codes and standards? I have found this to be a confusing area to navigate and learned some new information while researching this article. The information that was new to me is that there is a North Carolina General Statute (§66-24 Identification marks required, and §66-25 Acceptable listings as to safety of goods) that addresses labeling and listing so you may want to search the state law in which you are located to see what it says. North Carolina General Statute states: [2_TD$IF]§66-24: Identification marks required. All electrical materials, devices, appliances and equipment shall have the maker’s name, trademark, or other identification symbol placed thereon, together with such other markings giving voltage, current, wattage, or other appropriate ratings as may be necessary to determine the character of the material, device, appliance or equipment and the use for which it is intended; and it shall be unlawful for any person, firm or corporation to remove, alter, change or deface the maker’s name, trademark or other identification symbol. [3_TD$IF]§66-25: Acceptable listings as to safety of goods. All electrical materials, devices, appliances, and equipment shall be evaluated for safety and suitability for intended use. This evaluation shall be conducted in accordance with nationally recognized standards and shall be conducted by a qualified testing laboratory. NFPA 70 (National Electrical Code) is generally incorporated into local building and fire codes and it too specifies labeling requirements. The definition section of the National Electrical Code states: Labeled. Equipment or material to which has been attached a label, symbol, or other identifying mark of an organization that is acceptable to the authority having jurisdiction and concerned with product evaluation, that maintains periodic inspection of production of labeled
1871-5532/$36.00 doi:10.1016/j.jchas.2011.07.013
equipment or materials, and by whose labeling the manufacturer indicates compliance with appropriate standards or performance in a specified manner. OSHA General industry Standard 1910.399 Subpart S – Electrical also discusses listing and labeling. Acceptable. An installation or equipment is acceptable to the Assistant Secretary of Labor, and approved within the meaning of this Subpart S: (1) If it is accepted, or certified, or listed, or labeled, or otherwise determined to be safe by a nationally recognized testing laboratory (NRTL) recognized pursuant to §1910.7 or (2) With respect to an installation of equipment of a kind that no nationally recognized testing laboratory accepts, certifies, lists, labels, or determines to be safe, if it is inspected or tested by another Federal agency, or by a State, municipal, or other local authority responsible for enforcing occupational safety provisions of the National Electrical Code, and found in compliance with the provisions of the National Electrical Code as applied in this subpart; or (3) With respect to custom-made equipment or related installations that are designed, fabricated for, and intended for use by a particular customer, if it is determined to be safe for its intended use by its manufacturer on the basis of test data which the employer keeps and makes available for inspection to the Assistant Secretary and his authorized representatives. Accepted. An installation is ‘‘accepted’’ if it has been inspected and found by a nationally recognized testing laboratory to conform to specified plans or to procedures of applicable codes. The OSHA standard also defines who or what constitutes a Nationally Recognized Testing Lab (NRTL). See www.osha.gov/dts/ otpca/nrtl/. A NRTL is an independent agency with no connections to the equipment manufacturer other than to ensure the equipment meets certain safety standards. Some common NRTLs
ß Division of Chemical Health and Safety of the American Chemical Society Elsevier Inc. All rights reserved.
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you may encounter are Underwriters Laboratories (UL), The Canadian Standards Association (SA) and ETL Testing Laboratories (ETL). Underwriters Laboratories Inc. is an independent nonprofit organization that writes standards and tests products for safety and certifies them. UL has developed more than 800 standards for safety, and millions of products and their components are tested to ULs safety standards. ULs website is at http://www.ul.com. The Canadian Standards Association (CSA) is a nonprofit association serving business, industry, government and consumers in Canada and the global marketplace. Among many other activities, CSA develops standards that enhance public safety. According to OSHA regulations, the CSA-US Mark qualifies as an alternative to the UL Mark. ETL testing Laboratories has been conducting electrical performance and reliability tests since 1896. Intertek Testing Services (ITS) acquired ETL from Inchcape in 1996. ITS is recognized by OSHA as a Nationally Recognized Testing Laboratory (NRTL). Just as Underwriters Laboratories (UL), Canadian Standards Association (CSA) and several other independent organizations are recognized. There is also another mark (CE) that you may encounter. A CE Marking is a European marking of conformity that indicates a product complies with the essential requirements of the applicable European laws or directives with respect to safety, health, environment and consumer protection. Generally, this conformity to the applicable directives is done through self-declaration. The CE Marking is required on products in the countries of the European Economic Area (EEA) to facilitate trade among the member countries. The manufacturer or their authorized representative established in the EEA is responsible for affixing the CE Marking to their product. The CE Marking provides a means for a manufacturer to
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demonstrate that a product complies with a common set of laws required by all of the countries in the EEA to allow free movement of trade within the EEA countries. Unlike the UL Mark, the CE Marking: Is not a safety certification mark Is generally based on self-declaration rather than third-party certification Does not demonstrate compliance to North American safety standards or installation codes including the National Electrical Code or OSHA 1910.399 Subpart S A product that bears a CE Marking may also bear a certification mark such as a UL Listing Mark. However, the CE Marking and the UL Mark are not associated. The UL Mark indicates compliance with the applicable safety requirements in effect in North America and is evidence of UL certification which is accepted by model North American installation codes such as the National Electrical Code (NEC) and the Canadian Electrical Code. All equipment installed on your campus should be listed and labeled by a nationally recognized testing laboratory (NRTL). A list of approved labeling agencies can be obtained from the OSHA website. To facilitate the smooth installation of new, used or donated equipment the labeling status of equipment should be determined prior to arrival on campus. When available, [4_TD$IF]listed equipment should be purchased. Equipment available as a listed product but purchased without a listing or label The manufacture should provide documentation describing the standard to which the equipment is built to substantiate any safety testing that has been performed on the equipment. A field evaluation by a NRTL at the expense of the purchaser of
the equipment may be required. The field evaluation is best done on the vendor’s site to allow for corrections, if required, to be performed by the vendor prior to delivery. NRTL listed or labeled but modified Labeled equipment is approved for use as labeled. Modification to the system may void this labeling. The extent of modification could mandate a field evaluation by a NRTL. At a minimum an inspection by a qualified equipment inspector should be performed prior to equipment being placed back into service. Preferably the user would involve the equipment inspector in the design phase of the modification to ensure compliance, safety and to minimize downtime. Custom build or donated equipment by an equipment manufacturer Equipment built to a PI’s exact functional specifications should be designed and built to your campus electrical equipment design specifications. The specification should be provided to the builder as early as possible in the build process to insure compliance. Documentation should be provided by the manufacturer verifying compliance. Based upon the complexity of the equipment being built field labeling may be required or an inspection by a qualified equipment inspector may be performed prior to equipment being placed into service. In-house built or prototype equipment Those wishing to build research equipment in university labs for university use should contact their respective EHS department for a review early in the design phase of the project. The electrical controls and interconnects of the equipment should be built to applicable standards and all changes in design should be reviewed by the review team. Sign off of EHS and research PI should be a requirement prior to start-up.
Journal of Chemical Health & Safety, September/October 2011