Quick Guide: Field Labelling, Limited Product Certifications and Special Inspections for USA & Canada

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1 Quick Guide: Field Labelling, Limited Product Certifications and Special Inspections for USA & Canada Intertek Cleeve Road, Leatherhead, Surrey KT22 7SB UK

2 and Special Inspections for USA & Canada Introduction Ensuring that equipment is compliant with local mandatory North American and Canadian regulations seems a difficult process that would appear to require it to be shipped to a laboratory before installation for assessment. However, when single units of equipment are very large, very heavy, custom-built for site or even old and inherited with an existing site perhaps in an acquisition, shipping it to a laboratory for assessment isn t feasible. Also if equipment is perhaps smaller and can be shipped but is made in very low volumes then it may not be cost effective to pursue a traditional full certification - but it still needs to be assessed. Manufacturers and their customers should therefore be aware of Field Labelling, Limited Product Certifications and Special Inspections to demonstrate the compliance of their equipment. Field Labelling for North America Unless requested by a local Authority Having Jurisdiction (AHJ) to occur at a specific location, Field labelling activity is undertaken at the final installation site by an accredited expert known as a Nationally Recognised Test Laboratory (NRTL) against relevant product Standards. The NRTL is an expert body in one or more product types, accredited by the US Occupational Safety & Health Administration (OSHA) a federal body tasked with protecting people and workplaces. NRTLs use the expertise they have in the traditional laboratory environment and apply it on site to assess a piece of equipment in situ. European manufacturers seeking to export large equipment or custom industrial and engineering equipment to the US should be aware of the field labelling route to compliance. Preliminary inspection in the EU If the manufacturer wants to conduct field labelling activities for a piece of equipment before it ships to the final US destination, this can be done by the NRTL at the point of manufacture, at an interim distribution point or in the NRTLS facilities. This can help identify if some additional tweaks need to be made to the equipment before it is shipped to the client site. This test program follows as closely as practical the requirements of the applicable US end-product standard, taking into consideration the limits of the non-laboratory setting and the need for the equipment being evaluated to perform its intended function after the tests i.e. without damage or stress to the equipment. In many cases, a preliminary evaluation report is sufficient to satisfy US AHJs, however in the unlikely event that 2

3 an inspection of the final installation is required by the AHJ, your NRTL will ask one of their inspectors, to visit the installation site to make a final assessment. A successful assessment and certificate will include the following statement: A representative sample of the product covered by this report has been evaluated with respect to the requirements for Field Labelling. It has been found to be in essential compliance with the applicable requirements of the Standard for Safety Requirements for {insert Standard name} in so far as the limited examination and non-destructive nature of the Field Labelling evaluation allows. The installation methods and final approvals at the installation site are the responsibility of the Authority Having Jurisdiction (AHJ Local inspection authority). The equipment is then labelled by the NRTL a visible sign that it has been found to be compliant with the mandatory requirements that govern it. A label will contain a unique serial number and is only valid on that piece of equipment, in that location. Which laboratories are NRTLs? You can view a list of current NRTLs at and each NRTL has a specific product scope under which they can operate. In the area of industrial and engineering equipment the most famous NRTLs in the US and Canada are Intertek (issuing the ETL field label), UL and CSA. Benefits of Field Labelling Save time in the commissioning process by not having to ship equipment back an forth to laboratories Save money in shipping and handling fees to laboratories Assessors see the equipment in the real world operational context which aids evaluation Can typically be completed within a few days as NRTLs tend to have multiple sites across the US and can get assessor quickly to site Site staff are on hand to answer questions from the assessor which saves time rather than waiting for call backs and replies. No burden of ongoing surveillance costs and Listing fees a field label indicates that the equipment was compliant at time of assessment and providing the equipment is not altered it should remain compliant. 2

4 Ideal for custom built or very low volume equipment as each piece is treated individually. Sometimes field labelling is required after equipment has been installed and been in operation for some time. During a site inspection an inspector or building official can red tag an unlabeled product which means it is non-compliant and cannot be operated until all applicable product safety requirements have been met. Field labelling will satisfy the AHJ to clear the red tag. Limited Product Certifications for North America & Canada This certification applies when equipment is made within a limited 3 month run period, and it is not cost effective to undertake an ongoing product certification and inspection programme with annual fees and regular factory inspections, but where full testing to an appropriate Standard is mandatory. The evaluation is performed at your production location - using exactly the same product Standards and methodology you would use for a full product test and certification programme and includes an inspection of the equipment, the components used, the markings and the associated drawings. Once it has been certified and the LPC label has been attached, your product can be sold anywhere in the United States and Canada. At any time after the initial 3 month production period the manufacturer can request another visit from the NRTL to assess a further batch of the same models previously tested. At this point a 1-day visit is required to perform an audit. This is successful, another batch can be labelled. Eligibility Criteria Limited Production Certification may be used in any of the following situations. The product is unlisted. The quantity of units produced may run from one to several hundred. All production is scheduled within a continuous 3 month period. A limited "market test" run of a product that would normally be massproduced is planned. All production is scheduled within a continuous 3 month period. A significant modification to a Listed product will be made on a specific number of units Note: LPC may not be used where no published or draft standard exists 3

5 Characteristics of Limited Production Certification Full conformance to recognised standards Evaluation of a representative sample in the laboratory or applicant s facility Applied to a limited number of units, produced over a defined time period Certification marks are applied at the point of final assembly A Limited Product Certification Report is generated, detailing the scope and restrictions of the certification Surveillance and Labelling Procedures The NRTL will apply the labelling to the products following a successful visit, or manufacturers may apply the applicable certification mark to eligible products under the LPC program in the following situations: ISO 9001 Registered Manufacturer Existing manufacturer under Follow-Up Services (including the Certification Agreement, Initial Factory Assessment and regular Follow-Up audits) After a successful Factory Audit is performed Special Inspection Program for Canada A separate plant and machinery inspection scheme is run in Canada, known as the Canadian Special Inspection (SI). Assessments are undertaken by bodies accredited by the Standard Council of Canada (SCC). Whereas the US program uses the appropriate end-product standard, Canada s SI program utilises one specific standard: SPE-1000; Model Code for the Field Evaluation of Electrical Equipment, which allows for the accredited body to perform the SI at the manufacturer s facility or other specified location. The Model Code does not deal with type testing but permits an evaluation of the equipment by addressing minimal construction, marking and testing requirements. As such SI Inspectors must be established product reviewers familiar with Canadian requirements and under the control of a Canadian office. Serialised forms as well as serialised labels are allocated to each assessment engineer by the Canadian assessing authority office. The labels are only applied after a successful assessment by the reviewing engineer. 4

6 The following equipment is excluded from the Special Inspection programme: Equipment above 45KV Explosion proof electrical equipment and intrinsically safe apparatus for use in hazardous/classified locations Gas fired equipment Medical equipment Summary The availability of these different forms of product assessment ensures the manufacturer has a range of options available to him for his compliance activities, where products are heavy, large, built in-situ, or manufactured in a limited time production run. Acceptable to AHJs in North America and Canada, these routes to compliance save manufacturers time and money over traditional certifications that have ongoing annual fees and regular factory inspections and surveillance. Please contact your partner test and certification body for more information. 5

7 How Intertek Can Help Intertek is a Nationally Recognised Testing Laboratory, accredited by the US Occupational Safety & Health Administration (OSHA) and the Standard Council of Canada (SCC) to perform testing, certification, inspection, audit and field labelling services under our world renowned ETL certification scheme. With a global network of over 1000 offices and laboratories in over 100 countries, we have an office near you that can help. Our UK team can also provide Notified Body testing and certification services under a wide range of EU Directives, including the General Product Safety Directive, the Machinery Directive, the ATEX Directive, the EMC Directive and the Low Voltage Directive. For more information on specific testing and certification information, please contact Intertek at WORLDLAB, icenter@intertek.com, or visit our website at This publication is copyright Intertek and may not be reproduced or transmitted in any form in whole or in part without the prior written permission of Intertek. While due care has been taken during the preparation of this document, Intertek cannot be held responsible for the accuracy of the information herein or for any consequence arising from it. Clients are encouraged to seek Intertek s current advice on their specific needs before acting upon any of the content. 6