Field Label

What is a field label?

Sample-AE-field-label-2014

There are two ways to certify a product: listing and labeling.

Listing is where the manufacturer provides a machine to an OSHA approved nationally recognized testing laboratory (NRTL) who will test the machine and destroy it in the process, and charge a lot of money. The manufacturer must test products as they come off the manufacturing line. The entire process is subject to NRTL audit.

Recognition is for a component internal to a listed machine. On its own, the part would be considered restricted or incomplete. Example: power supply. It is almost but not quite as good as a listing.

Labeling refers to a product certified after installation.

High volume consumer products are listed. Expensive, highly customized industrial products are labeled.

Where did listing and labeling come from?

OSHA is the origin of listing and labeling. OSHA chartered the Nationally Recognized Testing Laboratories (NRTL) which includes the brand names like UL, CSA, Intertek, MET, SGS, TUV, etc. OSHA also chartered the American Council for Electrical Safety (ACES), which recently evolved into NFPA 790 and 791, the standards for field labeling.

Companies that do field labeling are knows as Field Evaluation Bodies (FEB). Different states have different rules. In California and Arizona, the individual cities approve the FEB. In Idaho, Oregon, New Mexico, Minnesota, and Washington, for example, the state handles all electrical inspection including the FEB. Idaho requires either NRTL or accreditation. New Mexico requires either a New Mexico PE license or accreditation.

A field inspectionWhy do I need a field label evaluation?

Three reasons: building permits, OSHA, and insurance.

The NEC says that listed equipment does not need further inspection and testing.

The NEC also says that the inspector has the responsibility for making interpretations and for granting “special permission” for alternative methods. Reference NEC 90.4 & 90.7. Local city inspectors come from the building trades and their job is to inspect construction. Industrial machines are very complex requiring specialized knowledge usually beyond the capability of most city inspectors. Therefore, machinery is usually inspected by a Professional Engineer with demonstrated competence.

Once machines are labeled, they can generally be moved around without re-inspection if three conditions are met:
• The labeling company is approved by the city where the machine is going,
• The machine has not been disassembled and put back together, and
• The machine has not been modified since the earlier inspection.

Should machinery be inspected if it is not required by the city?

Yes. OSHA regulations require that all electrical equipment in the workplace be certified or subjected to a complete and thorough evaluation before use. OSHA delegates safety enforcement to 27 states including California (Cal-OSHA).
Reference: OSHA 29CFR 1910.303 and 1910.399 and Cal/OSHA.

California Code of Regulations (CCR) title 8, section 3206 specifically states: “When the term “approved” is used in these orders, it shall refer to products, devices, systems, or installations that have been approved, listed, labeled, or certified as conforming to applicable governmental or other nationally recognized standards, or applicable scientific principles. The approval, listing, labeling, or certification of conformity, shall be based upon an evaluation performed by a person, firm, or entity with appropriate registered engineering competence or by a person, firm, or entity, independent of the manufacturer or supplier of the product, with demonstrated competence in the field of such evaluation.”

What are the consequences of not having an inspection?

• Can’t use the machinery for production
• Insurance might not pay in an accident
• Building inspector might “red tag” the building
• A “negligence” lawsuit instead of workers compensation
• A “disclosure” lawsuit if the property is sold

Is a CE Mark as good as a listing or field label?

The CE Mark means the product conforms to the requirements of the European Union Directives and Standards. CE Mark safety assessment includes both a conformity checklist and a hazard analysis based on a well know scientific method. The CE Mark is recognized in many countries outside of the EU. However, the CE Mark carries no legal jurisprudence in the United States for two reasons. 1) Difficult to trace the CE Mark to an inspection agency, if any. 2) Confusion with the China Export mark. Can you tell which is which? The CE Mark is on the left.

CE MarkChina Export Mark

http://icqc.co.uk/en/china-export.php

What safety issues are being addressed?

Laboratories and industrial factories are concerned with the following hazards:
• Electrical shock
• Energy release
• Mechanical
• Fire
• Corrosive
• Toxic
• Ergonomic

Various jurisdictional agencies have the legal responsibility to ensure safe construction (building department), occupancy (fire department), employment (OSHA), environmental protection (EPA), etc.

Field labeling is concerned primarily with the hazards of electricity (shock and fire). However, most field label companies also include basic mechanical and chemical
• UL web site – not defined, but the white book refers to OSHA
• Intertek web site – includes mechanical hazards
• MET web site – includes mechanical hazards
• ETI web site – just electrical

Model code books

In the US, various code writing organizations get together and, by consensus, decide on the best way to implement safe construction. There are dozens of trade organizations producing thousands of model code books. The organizations are sustained by membership dues and by the sale of the books. The American National Standards Institute (ANSI) acts as a librarian for the development of thousands of consensus standards. Model code books are the basis of the inspector’s work. Here are some of the code book categories:

Construction standards

Construction standards protect occupants. Primary standards include:
• International Code Council (ICC) standards for residential building code, commercial building code, fire code, mechanical code, plumbing code, etc. Supersedes the three original regional building codes in the US known as the National Building Code (NBC), Uniform Building Code (UBC), and Southern Building Code (SBC)
• National Fire Protection Association (NFPA) standards for the national electrical code (NEC), gas codes, chemical codes, fire code, etc.
• Institute of Electrical and Electronics Engineers (IEEE) standards for industrial wiring, also known as the color books (red book, orange book, etc.)
• American Society of Civil Engineers (ASME) for construction and seismic

Product standards

Product standards protect consumers. Primary standards include:
• UL white book with ~1000 product categories
• UL standards used for testing and listing, determined by the product category
• National Electrical Manufacturers Association (NEMA) standards for enclosures and hazard warning labels
• Robotics Industry Association (RIA) standard R15.06 for industrial robots
• American Society of Mechanical Engineers (ASME) for pressure tanks
• Semiconductor Equipment and Materials International (SEMI) for semiconductor tools

OSHA regulations

OSHA regulations protect workers.
• Numerous OSHA regulations and guide books
• American Society of Safety Engineers (ASSE) developed the LOTO procedures.
• American Council for Electrical Safety (ACES) developed the field labeling procedures.

What is a typical permit procedure?

1. The company has a budget for construction.
2. The building architect draws up a plan.
3. The building contractor takes the plan to the AHJ to pull a permit.
4. The plan checker adds a condition for third party label on “unlisted” machinery.
5. The electrical contractor installs the wiring up to the machine (disconnect point).
6. A competent third party inspects the machinery and adds a label.
7. The AHJ gets a report and signs off the permit. All done.

Typical scope of work:

Abstraction Engineering will conduct professional engineering services to provide:

  • A third party electrical evaluation and field labels.
  • A brief review of safety labels, manuals, procedures, etc, if available.
  • A brief review of the guarding per Cal/OSHA and RIA standards, if necessary.
  • Multiple visits to the site for inspection and meetings
  • A list of recommended corrective actions (“punch list”), if necessary
  • A field label for each machine
  • A final report provided to Client and the City

My professional discipline is primarily a conformity review and some electrical safety tests. Aspects of safety analysis can require numerous disciplines including structural (seismic calculation and fall protection), industrial hygiene (ventilation), electromagnetic compliance (emissions & susceptibility), comprehensive HazOp (chemical), ergonomic, etc. I will advise you if any of these areas need a secondary expert opinion.

Abstraction Engineering is a professional engineering for safe machinery, with FEB credential in many California cities, plus Oregon and Minnesota. Other cities can be confirmed as needed. We specialize in competent, high speed, no hassle service.

References

1. NFPA 79, Electrical Standard for Industrial Machinery
2. NFPA 70, National Electrical Code, Article 670 for Machinery
3. EN 60204, Safety of Machinery, Electrical
4. ANSI B11, Safety of Machinery, General Requirements and Risk Assessment
5. UL508, Industrial Control Equipment
6. UL508A, Industrial Control Panels
7. UL White Book
8. RIA R15.06 Industrial Robots and Robot Systems
9. European Machinery Directive, 2006-42-EC
10. OSHA regulations
11. SEMI S2


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