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|On-Site Solutions: A Guide to Field Evaluations and Labelling|
News & Research / IAEI Magazine / 2020 / 2020 September October / Columns / Certification Insights
According to federal regulations, electrical equipment in the workplace must be approved, identified, listed, or labeled by an OSHA-accredited Nationally Recognized Testing Laboratory (NRTL). If an inspector or authority having jurisdiction (AHJ) finds installed equipment or components that do not bear a valid certification mark, they are often obligated to “red tag” the equipment, taking it out of service. This can delay the finalization of a project, as the product or parts must be replaced or the situation otherwise remedied.
It is possible that a product may not appear to be listed due to labeling errors or because the certification process was not completed prior to shipment. These instances can often be cleared up through a field verification with the NRTL. However, in many cases, equipment imported to the U.S. from other countries has not been submitted for certification, and the product is not approved for use. In these cases, an urgent field evaluation can help get the project back on track by ensuring the product’s essential compliance with adopted and enforceable codes and standards.
Field evaluations allow for an on-site, non-destructive compliance assessment and labeling (if compliant) of a red-tagged item. They can also be used for one-of-a-kind, custom equipment or prototype equipment not intended to be mass-produced. Field evaluations are also useful to assess whether modifications made to previously listed equipment are compliant. Following an inspector’s red tag, a field evaluation body can be quickly be dispatched to evaluate the equipment in question on-site. This inspector will assess the equipment for fire, shock, mechanical, and any other hazards outlined by the applicable product standard.
A field assessment includes, but is not limited to, making sure critical components are appropriately certified, properly sized, and used within their conditions of acceptability. Enclosures are reviewed carefully, as are overcurrent and overload protection. Accessibility to hazardous voltages, hot surfaces, dangerous energy sources, pinch points, and moving parts are concerns as well. A review of nameplates, ratings, indicators, and caution markings also helps ensure the installed equipment is compliant. In addition to a construction review and non-destructive tests performed in the field, safety features such as interlocks, light curtains, and emergency stops are reviewed and demonstrated to be functioning.
If a product is found to be compliant, the unit is labeled with the mark of the field evaluation body, and a detailed report is issued, with the inspector copied, to illustrate compliance. Among other things, this report states: inspection location, specific equipment inspected, standards used in the evaluation, performance tests conducted, label number(s) applied, and a controlled report number.
If a product is found to be non-compliant, a non-compliance report is issued. This report provides an explanation of each non-compliant issue, as well as any test failures. The information can be used as a guide for the customer as they determine the corrections needed to comply. Once these corrections are made, the field evaluation body will request another site visit for a review of the fixes. If the corrections are found to be acceptable, the evaluator will field label the equipment and issue the corresponding compliant report to the AHJ.
One of the most important aspects of the field evaluation is that it considers the specific surrounding environment, as well as the individuals who will operate, service, or be in contact with the product. It is important to understand that the field label should be applied on the equipment after it is installed. NFPA 790, The Standard for Competency of Third-Party Field Evaluation Bodies, specifically states the field evaluation “shall be completed at the final installation site.” Remote field labeling or any other deviation from this process should only occur with the prior consent of the AHJ if they have the ability to allow for this exception in their jurisdiction, and only if they are comfortable with the conditions under which this arrangement is being considered.
It is also important to understand that while preliminary inspections may be performed prior to equipment shipment, the application of the field label associated with a compliant field evaluation is intended to be performed with the equipment installed in the field. Additionally, the field label may only be affixed by the field evaluation body and should at no point be handled by anyone outside of that organization.
Field evaluations offer the electrical industry an opportunity to quickly solve problems with unlabeled equipment in the field. With an understanding of how they are properly executed and good communication between all parties involved, the AHJ and the field evaluation body can work together to promptly address compliance issues in the field.