How often in Canada perplexed distributors
or wholesalers of electrical equipment provided with various
trademarks or other symbols of identification hear from a
visiting inspector: "This equipment is not approved. It
must not be offered for sale." Electrical contractors can
also share some of their confusion, when an inspector rejects
a piece of electrical equipment for installation as being
"unapproved," although the equipment bears a
familiar certification monogram. So, where is the problem, and
why do "innocent" wholesalers or contractors
encounter such adamant actions from the Canadian electrical
inspectors?
Let’s establish some facts: Every
provincial/territorial Electrical Safety Act or Regulation
prohibits displays, advertisement or disposal of unapproved
electrical equipment.
Rule 2-024 of the Canadian Electrical Code,
Part I states that "Electrical equipment used in
electrical installations within the jurisdiction of the
inspection department shall be approved and shall be of a kind
or type and rating approved for the specific purpose for which
it is to be employed."
These two facts certainly shed some light
of this subject. But what does it actually mean "approved
equipment," and why in two earlier examples did an
inspector reject a piece of equipment that contains a
certification monogram?
Who makes such an approval: a manufacturer,
a supplier, a testing agency, an inspector?
As the electrical equipment in question is
intended to be used under installation rules of the Canadian
Electrical Code, definition of the CE Code could unravel this
mystery. The CE Code offers the following definition:
"Approved as applied to electrical equipment means, that:
(a) A certification organization accredited by the Standards
Council of Canada has certified such equipment in accordance
with the requirements of (i) CSA standards; or (ii) Other
recognized documents where such CSA standards do not exist or
are not applicable; or (b) Such equipment conforms to the
requirements of the regulatory authority." Do we feel
completely relieved after reading and digesting this
definition? Not exactly. It looks like we need some additional
work of "deciphering" this intricate terminology.
Let’s do it step by step. First of all:
What do we know about such a "certification organization
accredited by the Standards Council or Canada"? The
answer will yield some agencies that are very well known to
the industry. Certification organizations such as CSA, UL, ETL,
etc., have applied to the Standards Council of Canada for
accreditation to certify electrical equipment to the CSA
Safety Standards for Electrical Equipment (to Part II
standards that are listed in Appendix A of the Canadian
Electrical Code).
The SCC grants accreditation to a
certification body when all criteria and procedures for
accreditation are met (scope of accreditation is defined and
the acceptable certification mark is established). Thus, for
example, when the electrical equipment is certified by the
CSA, the SCC requires that the "CSA" monogram must
apply to the equipment. When the same electrical equipment is
certified by UL to a relevant CSA Part II standard, the "cUL"
mark must be shown on that equipment. [Note: small
"c" is a Canadian Identifier. In accordance with the
SCC requirements it must be located at 8 o’clock to the
registered trademark "UL." This small "c"
signifies that the equipment is, indeed, certified by the U.S.
based Underwriters Laboratories Inc. to the CSA Safety
Standards for Electrical Equipment - Part II standards].
Therefore, a certification mark appearing
on an electrical product is a testimonial provided by the
certification agency that the equipment has, in fact, been
subjected to a satisfactory testing by that accredited
Certification Organization to all applicable requirements of a
specific CSA electrical safety standard for the electrical
product that is intended to be installed under provisions of
the CEC, Part I.
Thus, the puzzle with the CEC, Part I and
Part II is now resolved: requirements that are covered in the
CEC, Part I—constitute provisions for safe electrical
installation, and conditions specified in an equipment
standard—represent design and construction criteria under
the scope of the CEC, Part II safety standard for that
specific electrical equipment (that will be installed under
rules of the CEC, Part I).
From a practical side this means that if,
for example, a panelboard installed in a dwelling unit is
marked "CSA," it implies that such a panelboard has
been tested by the CSA Certification experts for conformance
with the CSA standard C22.2 No. 29 (see Appendix A of the CE
Code) This panelboard will be most likely accepted by an
inspector as "approved electrical equipment." If the
same panelboard bears "cUL" monogram, the inspector
will also accept it for installation, as this monogram
signifies the fact that UL staff certified the panelboard for
conformance to the same CSA standard.
But what about paragraph (ii) of the
definition "approved electrical equipment" that
states that the equipment is approved if it is certified in
accordance with "other recognized documents, where such
CSA standards do not exist or are not applicable?" Where
can these situations be encountered? Perhaps a few following
examples might help:
If the life safety/fire alarm equipment is
installed in accordance with Section 32 of the CEC, this
equipment will not be certified to the CSA, Part II standards,
as CSA never developed standards for a fire alarm equipment.
Instead, such equipment (a smoke detector, a pull station, a
fire alarm bell, etc.) would be certified to applicable ULC
Standards. Appendix B Notes on Section 32 of the CEC provide
explanation on this subject.
If there is no CSA Standard available for a
specific type of electrical equipment (i.e., a unique control
or protection device, etc.) CSA Certification Division may
publish "other recognized document" (ORD). When the
CSA publishes such ORD, it is called Technical Information
Letter (TIL). This TIL provides interim certification
requirements for such specialty equipment, until a complete
standard is developed by a technical committee of experts via
a CSA consensus based process.
And finally, paragraph (b) of the
definition indicates that the equipment is deemed to be
approved if it "conforms to the requirements of the
regulatory authority." This, latter condition could be
met, when a unique electrical equipment is constructed for
which no applicable CSA Part II Standard exists and no
certification program has been developed (no ORD has been
published). In this case, inspection authorities may consider
such equipment as "approved" if it meets criteria of
a special inspection, provided by the testing agencies on
behalf of the regulatory authority in conformance with SPE
1000, Model Code for the Field Evaluation of Electrical
Equipment, or with other documents acceptable to the
regulatory authority.
So, it looks like all aspects of the CEC
definition have now been clarified, and the wholesalers’ and
contractors’ confusion mentioned at the outset of this
article can now be explained. Let’s check out a few
examples: Let’s say, that a distributor sells a reel of a
cable marked "UL." Is this approved equipment? The
answer is "No." Not for use in Canada under rules of
the CEC, Part I. If this cable is to be allowed to be sold and
installed in a Canadian market, UL must apply a Canadian
Identifier (small "c" to the "UL"
registered trademark). Only this "cUL" monogram will
signify that UL, in fact, tested this cable to the applicable
CSA cable standard listed in the Appendix A of the CE Code.
This is the reason many wholesalers and distributors are
ordered to remove the equipment that is not appropriately
marked. It should be noted that Rule 2-100 of the CE Code,
Part I lists markings that are required to be provided on each
piece of electrical equipment to ensure that the equipment is
suitable for the particular installation.
If, for example, an inspector checks
electrical installation in a paint spray operation (Class I;
Zone 1 hazardous location) and finds a motor, or a panelboard
marked "CSA." Does this equipment meet the inspector’s
acceptance? The answer is "No." Because in addition
to the CSA monogram this equipment must be "approved for
specific gas, vapors, etc." and marked accordingly as
required by Section 18 of the CE Code. Referenced earlier,
Rule 2-024 of the CEC is very helpful in understanding this
additional requirement of being "approved for the
specific purpose for which it is to be employed."
There are numerous situations where
inspectors reject electrical equipment, although this
equipment has been impeccably tested and bears an acceptable
certification monogram. These situations are well described by
Rule 2-026 of the CE Code, which grants an inspection
authority power of rejection under the following conditions:
(1) if the equipment is substandard with respect to the sample
on which approval was granted; or (2) if the conditions of use
indicate that the equipment is not suitable; or (3) if the
terms of the approval agreement are not being carried out.
It is unfortunate, but lately inspectors
encounter these situations more and more often. With a huge
supply of offshore equipment ranging from heavy industrial
circuit breakers to basic consumer oriented power bars and
extension cords many substandard or outright counterfeit
pieces of electrical equipment find their ways to wholesalers,
distributors, contractors and, ultimately, to consumers.
Therefore, today like never before electrical inspectors must
exercise their vigilance in auditing electrical equipment that
is intended for use in Canada. Thus, a mutual commitment and
diligence by all stakeholders of the electrical industry in
understanding of the facts and confusion about
"approved" equipment, and acting upon this subject
effectively is paramount in our successful efforts to uphold
electrical safety in Canada.
Ark Tsisserev, P.Eng., is the chief
electrical inspector for the city of Vancouver, Canada.
He is a registered professional engineer, with a master’s
degree in electrical engineering. He is currently the
chairman of the technical committee on the Canadian
Electrical Code and represents the CE Code Committee on
NEC CMP-1 as the CMP-1 non-voting member. Ark is
presently the third vice president of the Canadian
Section.
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