The American Council for Electrical Safety
(ACES) is a collaboration that was formed by a variety of
regulators responsible for ensuring the safety of electrical
products sold in the United States. The council is sponsored
by the American Council of Independent Laboratories (ACIL).
Members of ACES include chief electrical inspectors,
accredited laboratories, government agencies involved with
regulation of electrical products, devices or installations,
and representatives from organizations involved in regulation,
such as IAEI. Membership is limited to such groups. The
purpose of the group is to provide a forum twice a year for
all parties involved in product testing, certification,
approval and recognition, in which they can discuss issues
relating to electrical safety.
Photo
1.
Photo
2. Machines used in industrial applications
Photo
3. Typical industrial control panels
Electrical products, both those made in the
United States and those imported, are sources of major concern
to electrical inspectors as they make decisions affecting the
safety of persons and property. The concern is justified; due
to the pressure to maintain competitiveness, some
manufacturers may perceive a need to reduce product costs by
sacrificing quality and safety. Also, some specialty
manufacturers build one-of-a-kind products without completely
understanding the requirements for electrical or fire safety.
In addition, new requirements are continually added to
standards, based on incidents that occur in the United States
revealing previously unrecognized hazards. A manufacturer may
or may not have the facility to keep up with these standards.
Certification laboratories, however, must
keep up with these standards in order to maintain their
governmental and other official recognitions. This
characteristic of listing laboratories ensures that a properly
listed product does comply with the current edition of the
applicable standard.
An electrical inspector must rely on some
credible source when inspecting installations. Inspectors must
know requirements in the local, state or national codes. To
perform the in-depth inspections necessary to determine that a
product complies with an applicable standard and the
installation meets requirements in the National Electrical
Code is a major time-consuming effort. It must be
performed by someone who is an expert in both the product
category and the National Electrical Code.
Additionally, most products call for the application of at
least one standard that requires some tests be conducted in a
laboratory to determine that the product complies with the
standard and is safe.
When the product is listed the inspector
can usually rely on the listing of the product to determine
that the product complies with the correct, applicable
standard. Also, the laboratory is accredited by OSHA and often
other accrediting bodies. Accreditation covers the various
standards that apply to the thousands of different electrical
products.
Some laboratories are only accredited to
evaluate compliance with a few standards while others may be
accredited to certify products against hundreds of standards.
During the accreditation process a
laboratory must prove to experts that the laboratory has the
knowledge and equipment to test to the standard. Accreditation
is a continuous process with reviews of the laboratory
performed every few years. Accreditation of a laboratory
usually takes a team of two to three experts from two to five
days per visit. This gives the inspector the assurance that
the product—if installed within the parameters of the
listing instructions—meets all relevant safety standards.
However, when a product is manufactured in
the field, or a product’s manufacturer was never reviewed by
a certification agency, or a product is modified, it is, or
has become, by definition an unlisted product. It often is the
case that a product’s manufacturer never is reviewed by a
U.S. certification agency when the product is imported or its
manufacturer is small or custom. In any of these cases, the
inspector has to either become the accrediting agency,
providing his own inspections and approvals, or else accept
only laboratories that already are nationally accredited. This
has been a dilemma for inspectors, especially the ones that
realized the significance of recognizing organizations to
perform these services. If an unlisted product goes undetected
and it causes a hazard, the electrical inspector could be held
accountable. This is an unreasonable burden to be placed on an
inspector. Also, if the hazard is in a workplace and results
in an OSHA investigation the employer can be fined from $7,000
to $70,000 for each violation.
The American Council for Electrical Safety
(ACES)’s development of a document that an inspection
authority can utilize in selecting organizations that can
perform these inspections is timely. Jurisdictions faced with
the responsibility to accept organizations for performing
field inspections of products are seeking help. Some
jurisdictions are attempting to write their own requirements,
or just feel forced to accept people who are claiming to have
the ability to perform product evaluations competently. The
responsibility is really enormous, given the liability
associated with allowing someone who may be unqualified to
perform these inspections. This document is titled
"Recommended Practice for Unlisted Equipment."
Inspection agencies that institute this
procedure in recognizing organizations for performing field
inspections and labeling take a lot of responsibility off
themselves and the jurisdictions where they work. The safest
and most responsible procedure for an authority having
jurisdiction is to adopt this procedure, "Recommended
Practices for Unlisted Equipment."
Meanwhile, additional help is on the way.
Right now, the only laboratories in which everyone can have
full confidence are the nationally recognized testing
laboratories (NRTLs) that the Department of Labor has
authorized to list products for workplace use. For several
years, ACES has been working to develop a means of judging
whether other, perhaps local labs are qualified to perform
just those field evaluations of unlisted equipment that are of
such concern. After all, on the one hand, if an incompetent
engineer attempts to apply recommended practices, they may not
be of any great use, and on the other, if a NRTL sends someone
out one would hope the "Recommended Practices. . ."
document would be superfluous. A draft of "Recommended
Competence Guidelines for Third Party Field Evaluation
Organizations" is being circulated for public comment as
you read this. It should complement "Recommended Practice
for Unlisted Equipment" nicely.
For more information concerning ACES or
these guidelines contact ACIL at 202/887-5872, or get in touch
with Leonard Frier, chairman of ACES, at MET Laboratories,
Inc. by phone at 410/354-3300 or email at lfrier@metlabs.com
Editorial assistance from David Shapiro.
Len Frier is a registered professional
electrical engineer in the state of Maryland. He founded MET
Laboratories in 1959. He initiated the Nationally Recognized
Testing Laboratory Program at OSHA in 1988, and is charter
member of the National Electrical Testing Association (NETA).
He is former chairman of the ANSI Z34 committee on "Third
Party Certification," chairman of the American Council on
Electrical Safety (ACES), member of the ANSI Accreditation
Committee, and the American Council of Independent
Laboratories (ACIL). Presently, he is director at MET
Laboratories, Inc. and is active in government affairs
relating to US Certifications of electrical products. |
