OK, you’ve done all the engineering, installation and commissioning and have field electrical and electronic equipment that is certified for the hazardous location in which it operates. In North America, this equipment has been tested and approved to appropriate codes and standards by OSHA-accredited NRTLs (Nationally Recognized Testing Laboratories) like FM Approvals, UL, CSA, and MetLabs to name a few. Other countries may have similar requirements through entities such as PTB of Germany, LCIE of France, KEMA of the Netherlands, and UC (formerly UCIEE) of Brazil.
So what about the certification if the equipment has been salvaged from a plant that has been shut down, and then refurbished, reconditioned, or remanufactured and resold? Or what about equipment that is resold as “new surplus” or after installed equipment has been repaired?
Bob Baker, a Safety Consultant to Emerson Process Management presented with FM Approvals‘ Cheryl A. Gagliardi at the recent Mary Kay O’Connor Process Safety Center 2006 International Symposium. Their presentation, Maintaining Certification Compliance of Equipment Used in Hazardous (Classified) Locations, discusses what happens (or should happen) should a device be changed in some way, even unknowingly.
When ownership transfer occurs, as in the case of equipment that has been resold as new surplus or after being salvaged, refurbished, remanufactured, or reconditioned, there typically is no historical awareness of whether or not a device has ever been “changed” in any manner by the prior owner, resulting in potential non-compliance. Such a “change” could have been as simple as touching up the threads of an explosion-proof device’s galled terminal box housing or cover, or it could be the use of non-OEM parts, the accidental scratching of a flame path surface or damage to a flame arrestor, etc. These same types of issues could also occur during the repair of a device even though it may never leave an original owner’s site.
The FM Approval mark is a statement of conformity that a product is in compliance with defined standards at the time the product leaves the manufacturing and/or repair facilities audited and approved by FM Approvals. Once the equipment is placed into use, continued compliance with the applicable codes and standards becomes the responsibility of the process manufacturer, i.e. the end user.
FM Approvals listed its definition of repair as “work performed to the unit that would bring it back to its original condition approved by FM Approvals, with repair including refurbished, remanufactured, reconditioned, salvaged, and new surplus.” FM Approvals also presented that process manufacturers have several choices when making repairs on equipment with hazardous area approval certifications including:
- Returning the equipment to an original equipment manufacturer (OEM) or any of its repair facilities that are approved and audited by FM Approvals. The OEM has the design control and knowledge of the FM Approvals certification requirements to return the equipment to its originally certified condition
- Having the equipment repaired by a third party facility that is approved and audited by FM Approvals in accordance with its repair standard 3606:1998 – Repair Service for Process Control Equipment Used in Hazardous (Classified) Locations
- Performing the repair in-house if the process manufacturer’s repair facility is similarly approved and audited by FM Approvals to its repair standard 3606.
FM Approvals recommended that its certification marks be removed from non-compliant equipment resulting when the repair work is done by a facility which is not audited and approved by FM Approvals. Since the burden is on the process manufacturer that the equipment is approved for the hazardous location in which it operates, the process manufacturer should insist that either:
- The repair (all types as noted above) be done by a facility that is audited and approved by FM Approvals to recertify the equipment (and prove it, by submitting FM Approvals documentation to the end user, that is specific to the brand and model)
- Have the FM Approvals certification mark removed if the facility is not an FM Approved repair facility.
Removing the certification mark or the entire nameplate should help eliminate confusion about a device’s NRTL approval status, and reduce the chance of inadvertent installation into a hazardous location that requires an NRTL approved device.
Bob recommends that process manufacturers develop corporate policies and guidance directing inspection, engineering, maintenance, and procurement to ensure the installation of compliant devices for their intended hazardous locations. He also recommends that stringent supplier qualifications be established to prevent introduction or re-introduction of non-compliant equipment, and that identification and abatement processes be developed for potentially non-compliant equipment already installed.
In summary, it is important that industry understand whether the purchase of products for use in hazardous locations, as defined by the National Electric Code and OSHA, can give rise to product safety and regulatory compliance issues.
Ms Gagliardi and Mr. Baker will again be presenting this topic on Thursday, January 25, 2007 at the Texas A&M Instrumentation Symposium (Jan 23-25).