What to You Need to Know When Limited Production Certification is Your Hazardous Locations Compliance Strategy

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1 What to You Need to Know When Intertek 70 Codman Hill Road Boxborough, MA WORLDLAB

2 Introduction Complying with safety standards and requirements involves every level of the organization and spans multiple functional roles from executive management to sales, marketing, engineering, purchasing, and manufacturing. Leveraging these roles to have a cohesive approach to product certification is essential to have a smooth, efficient process in place. Product Certification may be legally mandatory or voluntary. Even if not legally mandated, other market requirements (including Customer and Utility regulations) may dictate the necessity for Certification, as is currently often the case with industrial electrical machinery and support systems in the US and Canada. Once it has been determined that product certification(s) will be necessary, as an Original Equipment Manufacturer (OEM) you need to put in place the structure, policies and procedures that will ensure a timely and efficient process for gaining Certification. This white paper discusses the aspects to consider for a successful entry into the market and offers constructive solutions to compliance. You should gain valuable insights into utilizing flexible certification options to offer improved turnaround times on new product designs or product assemblies for use in hazardous locations. Back to Basics - Certification and Product Safety Standards Certification for products made in limited quantity or custom-ordered is almost always based on compliance with harmonized national product safety standards. In order to create a compliant design in the most efficient manner, one must design with the standards in mind. For simple electrical devices, a single standard will often address all of the safety concerns; more complex products may necessitate the use of two or more product standards. In either case, design engineers should familiarize themselves with the standards upon which certification is based before trying to create a complete detailed product design. Some compliance requirements are very straightforward and easily understood, while others may require interpretation in order to properly apply them to the product under review. Under the latter circumstance, a design engineer may want to consult with a third party certification engineer in order to ensure the correct interpretation and design approach. In general, under almost any product safety standard, the compliance requirements can be divided up into three categories: intertek.com/hazloc 2

3 1. Design Specific features that must be incorporated, and can be examined through the drawings and specifications for the product in question; 2. Construction The hardware employed in the product, and the way in which it has been assembled. These features are assessed through physical inspection; 3. Testing The list of tests that must be passed in order to be fully compliant with the product standards. Usually, this involves reviewing the comprehensive list of required tests and test methods to determine which ones are applicable to the specific product under investigation, based on the construction and manufacturer ratings. In some cases, the manufacturer may be able to conduct the testing, but generally the certification agency will either witness or conduct the tests in a controlled [laboratory] environment. In order to obtain a limited production certification, the manufacturer will have to be compliant in all three aspects. Clear understanding of these obligations makes it simpler to organize the necessary documents and samples and the corresponding design and manufacturing schedule. The more organized the manufacturer, the easier it is for the certification agency to create a corresponding resource plan and project completion schedule. Knowing Your Market is Key to Successful Market Entry It would be ideal to have a complete understanding of all of the possible applications for the product being designed at the concept stage and meet the requirements of all your customers and prospects. But this is unrealistic. It is also not reasonable to design all products for a worst-case scenario, as the real cost of the hardware would result in noncompetitiveness for less stringent applications. But as far as possible, it is necessary to obtain from the customers and prospects clear specifications for the equipment and the intended installation zones. These technical specifications should include: 1. Required electrical ratings, including voltage, frequency and current; 2. Ambient operating temperature ranges; 3. Location surface or mining; 4. Type of explosive atmosphere present (gas, dust, fibers); 5. Hazardous Area designation (Zone, or Class and Division); intertek.com/hazloc 3

4 6. Preferred method of protection, when applicable. Lacking any technical specification from a customer, the manufacturer should surmise the potential applications for the product, and select a method of protection (and thus, the applicable product standard(s)) that will encompass the anticipated hazardous areas into which the equipment will be installed. In some cases, it may be that multiple applications will be intended, and therefore it may make more sense to create multiple designs to encompass the entire range of expected hazardous areas. Schedule a Preliminary Review One of the best ways for a manufacturer to ensure success under any certification program is to engage with the agency early on in the design process. By presenting the product concept and application information to the agency during the initial stages of development, the manufacturer will know the standards that will be used to evaluate the product, the constructional requirements that have to be met, and the list of tests that will need to be conducted prior to gaining certification. This Preliminary Design Review (PDR) service allows the manufacturer to confidently proceed with the detailed product design and to schedule any activities necessary to ensure that when the agency engineer arrives to conduct the evaluation, there will be no surprises that may cause re-work or additional schedule delays. Experience has proven that the likelihood of success on the first try increases significantly when the manufacturer starts with the PDR plan laid out by the agency engineer. The Preliminary Design Review culminates in the issuance of a PDR report. With this PDR report in hand, the manufacturer can confidently complete the detailed equipment design and component selection, and schedule the other necessary testing and inspection activities. Confirmation that the design and constructional criteria have been met takes place upon the arrival of the agency engineer at the manufacturing site. If minor non-compliances are identified, they might be resolved during the same inspection visit more major changes may necessitate a second visit, after allowing time for the manufacturer to make the necessary product modifications. Once the constructional compliance of the equipment has been assured, and subsequent to successful completion of whatever test program has been dictated, the certification label is applied, and the equipment is ready to ship. intertek.com/hazloc 4

5 Understanding the Electrical code Once the hazardous location technical requirements have been identified, and whether the product is destined for Canada or the US, the next step is to ensure that the equipment selection, installation method, and wiring techniques are compliant with the applicable end-product standard and the Electrical Code in force. Keep in mind that different (older) editions of the Code are in force in many jurisdictions, and the AHJ will utilize that version of the Code during his inspection. The acceptable wiring methods, mechanical securement and protection requirements, and shock and fire protection techniques may vary slightly between editions of the Code, but in all recent editions, the requirements for equipment certification or listing are fairly consistent and all of the product standards contain a requirement that the product must be equipped with the necessary features to allow for installation and connection in accordance with the Code. Differences in US and Canadian Electrical Codes Although most of the requirements are identical, there are some differences between the US and Canadian Electric Codes that must be addressed in order to ensure acceptance by either an agency engineer or an AHJ. Equipment Grounding: Although this is not specific to hazardous locations products, equipment grounding has resulted in equipment being found noncompliant, for both ordinary and classified areas. In Canada, the size of the ground conductor is slightly larger than is required under the US NEC. Bi-lingual Product Warning Labels: The laws in Canada mandate that product warning labels be provided in both French and English as both languages are considered national languages. Although these are relatively minor non-compliances that can be fairly easily addressed in the field, they have been known to hold up equipment approval until supplemental or replacement parts could be shipped and installed. Other more significant technical matters can dramatically increase the difficulty of the product retrofit. In any case, if the equipment will be shipped to both countries, the design and construction must meet the compliance requirements contained in the national standards for both markets. intertek.com/hazloc 5

6 Product Nameplates and Labels The first thing that nearly any electrical inspector looks at is generally the product nameplate. Understanding in advance what the requirements of the application are, from a quick review of the markings and ratings contained therein, the inspector can determine whether or not the item is suitable for use in the location in which it has been installed. Whether identified by the agency engineer, customer quality assurance representative, or the AHJ, fully 90% of the compliance challenges start with product markings, or lack thereof. With this in mind, it s easy to see why determining the necessary contents of the product labels and nameplate is a critical step in the design and manufacturing process. One way to look at it is that if you determine the necessary product markings at the beginning of the project, you can reverse engineer your way to compliance, because those markings will tell you what standards must be met and what [minimum] product ratings must be achieved, including temperature ranges, enclosure ingress protection ratings, explosion protection methods and other conditions for use. After reviewing the nameplate for the product, the next likely visual inspection point will be related to safety labels (Danger, Caution, Warning). Most product standards contain specific requirements for such hazard communications, and some specify the exact wording that must appear, and the location in which it must be placed. Again, this is an easy catch for an experienced certification engineer or AHJ, either identifying the lack of a required marking, or noting that the warning has not been properly communicated; i.e. incorrect location, language, text, or visibility level. It should be noted that many product standards require that any safety labels present on the product should be identified and further explained in the product technical instructions. Realities of the Limited Production Certification Process Third party certification is typically neither easy nor straightforward, whether you are pursuing a full listing or limited production. It is more than just hiring a certification agency and receiving a certificate. Significant internal resources may be required. The less focus the project receives, the more it will likely cost and the longer it will likely take. intertek.com/hazloc 6

7 Nearly every company function has a role to play in certification task identification and appropriate division of responsibility is a key to success. If the product isn t originally designed to meet the standards, re-design will likely be necessary. Preliminary design reviews and pre-testing can significantly reduce direct and indirect certification costs. Suppliers play a key role in meeting certification requirements and timelines the more knowledgeable and experienced the supplier, the greater likelihood of receiving a properly certified part. Technical documentation deficiencies can negatively impact completion schedule content requirements should be identified early in the process. Selecting the best certification services provider depends on the product and markets involved check agency accreditations carefully. Successful certification efforts involve managing all the details a clause-byclause understanding of the requirements of the standard is necessary. Functional Roles and Responsibilities A comprehensive and streamlined product compliance program involves a cohesive effort from the organization as a whole. Some of the key functional roles and tasks for certification are listed below. Determining who is responsible for each of these and scheduling the necessary activities will not only improve your internal efficiencies, but also lead to improved communications and success with any and all of your compliance and certification services providers. Executive Management Establish goals, policies, procedures and measurements for certification management; budget and assign resources to ensure that they re met. Establish communication systems that ensure significant (business plan impact) certification-related issues will be visible. Establish company philosophy toward compliance and certification. Sales and Marketing intertek.com/hazloc 7

8 Gather market regulatory intelligence from customers and competitors. Ensure accuracy of certification marketing claims. Offer alternative (non-certification) options to customers, when appropriate. Capture and calculate certification costs and timelines in project bids. Take part in the certification process to help ensure timelines and customer demands are met. Design Engineering Purchasing Provide performance and safety specifications. Confirm product design compliance with applicable standards. Compile technical file containing all information relevant to demonstrating product compliance. Review supplier parts documentation to ensure appropriate ratings and certifications. Select vendors with approved components; i.e. certified for target markets. Require suppliers to prove their ratings and certifications (documentation). Provide engineering with alternate component selections, when necessary. Inquire as to certification lead times for uncertified components. Obtain cost and schedule for component evaluations from agency when no properly certified or rated product is available. Manufacturing Ensure understanding of certification requirements and inspection techniques. Conduct required production line testing in accordance with certification report. Maintain test equipment calibration and production records and have available for review by the Certification agency inspector. intertek.com/hazloc 8

9 Tips for Certification Success Define the product Application, ratings, options, accessories. Identify all Target Markets, and the specific requirements for each. Consider both Legal and Voluntary [Market] Requirements for each. Schedule a Preliminary Design Review to ensure that all applicable standards have been identified prior to proceeding with the detailed design work. Obtain copies of standards, and design to meet the constructional and testing requirements contained therein solicit interpretations, as necessary. Create ordering specifications for vendor supplied parts that contain sufficient technical detail to ensure vendor understanding of their obligations, a list of the evidence that they must provide prior to qualifying for a purchase order for their equipment, and any documentation due upon delivery. Identify potential certification providers, and select based on their accreditations, product expertise, abilities to assist with other markets, and their responsiveness and clarity of communications. Assign a Single Point of Contact (SPOC) for your organization, and ask the certification agency to do same. Establish a certification project management system that will detail where you are in the process (RAIL Rolling Action Items List). Prepare a documentation submittal package containing all technical information relevant to demonstrating compliance with the standards. Prepare and provide test samples required by certification agency. Establish requirements for product markings and technical instructions (Installation, Operation and Maintenance manuals). intertek.com/hazloc 9

10 Manufacture in accordance with certification report, and conduct required production line testing. Review certification impact of potential design changes, and monitor changes to market requirements and product standards. Partnering with a Third Party Agency By partnering with a knowledgeable and experienced agency, a manufacturer will over time increase their internal understanding of the requirements for certification, and the number of non-compliances will likely decrease. Similarly, the agency engineer will become more familiar with the various product types and configurations, and the amount of time spent on the engineering evaluation will also decrease to some extent. Eventually, the two parties arrive at an expeditious and efficient LPC program that can be executed in a cost-efficient and timely manner on whatever specific product is presented for evaluation. If any of the designs become standard product to be produced in large quantities, a Listing Report can be created, a factory audit completed, and the manufacturer can then produce and label units without having to undergo unit-specific inspection. Contact Us If you d like to connect with an expert to answer your technical questions, or obtain a quote for a new testing project, contact Intertek at WORLDLAB or at icenter@intertek.com intertek.com/hazloc 10