10 Common Issues to Address Before a Field Evaluation
Field evaluations play a vital role in confirming that equipment complies with required safety codes and standards, particularly when traditional product certification isn’t an option. Whether it’s for modified, custom-made, or limited-production products, these on-site inspections are key to identifying potential compliance risks. However, the process comes with its own set of challenges. Our team faces a variety of obstacles during field evaluations, and we’re here to highlight the top 10 to keep you informed and ready for your next evaluation.
1. Improper Planning: Money Locked in Unusable Equipment
The equipment we evaluate often plays a crucial role in larger projects, whether in industrial processes or field installations. With so many interdependent components, even a small delay can disrupt the entire operation. If field evaluations are not prioritized, the local Authority Having Jurisdiction (AHJ) may identify the absence of a valid third-party marking from a recognized Field Evaluation Body (FEB) when one is required. In such cases, the AHJ may issue a red tag, removing the equipment from service entirely, which can delay the entire project timeline.
This issue can be avoided by proactively notifying the FEB of all equipment being implemented, allowing them to identify which items require inspection. If your equipment is red-tagged, an NFPA Global Solutions expert can quickly be dispatched to perform a proper inspection. If the equipment meets compliance, we can apply our label, recognized by AHJs, leading to the removal of the red tag and keeping your project on track.
2. Unsuitable Environments for Proper Inspections
For an effective equipment inspection, the test area must be safe and properly prepared. The surrounding space should be clean, clear of debris, and free from vehicle traffic. To minimize potential hazards, ensure that no one is walking through the area during the inspection. Additionally, your product must be fully constructed and accessible for testing. You will need to open the equipment and provide clear access for inspection. A standard 120VAC, 15A power source (such as a wall outlet) will be required to plug in testing equipment, and in some cases, an extension cord may be necessary to bring power closer to the machine.
3. Improper Certification Requirements for Wiring/Cabling
Safety and protective components must be properly certified to ensure the safe operation of machinery. Prior to the field evaluation, be sure to review your components to confirm they have the proper certification marks. It is essential that these components are certified, correctly installed, and electrically rated for the specific circuit they serve. Examples of such components include circuit breakers, fuses, overload devices, thermal protectors, temperature controllers, high-temperature limit devices, safety relays, limit switches, and photo detectors used in access control systems. These parts perform essential functions that are crucial to the safety of both the machine and the surrounding environment, including people and the building in which the machine operates. If any part is found to be non-compliant or unsuitable, it may need to be replaced. To prevent this, always use certified components that meet the required electrical ratings. Additionally, ensure that all wiring and cabling are also certified, as these cannot be tested in the field.
4. Sticking to Tradition: “We’ve Always Done It This Way”
Requirements and standards evolve over time, making it essential to stay up to date on the latest developments. The standards used to evaluate products in the field are periodically revised, so it’s important not to become complacent, especially if you’ve been designing or building the same product for an extended period. What was once considered acceptable may no longer meet compliance standards. To avoid potential issues, such as equipment being red-tagged, NFPA Global Solutions offers a desktop engineering review. This review provides an opportunity to discuss the specific standards your equipment will be tested against. While we do not offer design services, we can help clarify the evaluation process and highlight key aspects and updates to standards that are relevant to your equipment.
5. Overlooking Jurisdictional Requirements and Permit Issues When Relocating Equipment
Certain jurisdictions have specific requirements for additional protection of motors and equipment, as well as regulations regarding the use of particular materials, which may be either required or prohibited. When equipment is moved from one location to another, the AHJ may mandate that the equipment be re-evaluated to ensure it meets current safety standards. For example, if equipment that was approved in Texas is being transferred to California, it may need to be re-evaluated to confirm it complies with the safety standards in its new location. At NFPA Global Solutions, we have extensive experience in overseeing factory relocations, validating that equipment is properly evaluated or re-evaluated to confirm safe installation and provide assurances to the AHJs that the equipment is safe for operation.
6. Unaddressed Mechanical Hazards
Our evaluation process extends beyond the electrical aspects of a design to include mechanical hazards, which are carefully considered in our final assessment. Electrical safety alone does not guarantee a machine's overall safety; mechanical safety is equally essential. This includes confirming hazardous components are properly guarded or covered and controlling access to potential risks. Other mechanical hazards include pressure vessels, pressure relief vents, lasers, and other components critical for the machine's safe operation. These elements must be certified for acceptance by the AHJ.
Additionally, stability is a key factor. If a stability hazard is identified, the equipment will undergo further testing, although this may be waived if the unit includes proper brackets and instructions for securing it during operation. Polymeric (plastic) enclosures must also meet flame-retardant standards. If the properties of these enclosures cannot be confirmed, they will be subject to further testing or review, such as a flame test, to confirm their safety.
7. Relying on Inaccurate or Incomplete Technical Data
For more complex systems, additional testing is required. Before our inspection, we request specific information regarding this testing. Please provide details on any third-party qualifications, if applicable, along with relevant test procedures or other documentation to confirm proper testing protocols are followed. Documentation of a quality system will help NFPA Global Solutions confirm that the testing has been conducted appropriately and meets the required standards.
Additionally, we require training records for the staff conducting the tests, or other evidence of their qualifications. Information on calibration procedures, including a list of test equipment and their calibration certificates, is also necessary.
8. Non-Compliant Warning Labels and Nameplates
A part of the field evaluation process involves confirming that caution, warning, and danger labels, along with nameplates, meet specific requirements to help ensure the safe operation of equipment. Nameplates must include essential electrical information such as voltage, current, and short-circuit current ratings, as well as the manufacturer’s name, model number, serial number, and other relevant product details.
In jurisdictions like Canada, these labels and nameplates must be provided in both English and French to comply with local regulations. If these labels are missing, incomplete, or non-compliant, operators may not be aware of critical hazards, such as moving parts, pinch points, or electrical shock risks. This oversight can result in non-compliance with safety standards like OSHA or NFPA 70E, creating potential risks for equipment owners and operators in maintaining a safe working environment.
9. Incorrectly Sized or Rated Fuses and Wires
Confirming that components are correctly rated for their specific application is a key part of our inspection process. Incorrect fuses or improperly sized wiring often leads to issues that must be addressed before a label can be applied. As wire sizes change, so do the required protections. Always adhere to regulations governing overcurrent protection for wires and follow any rules for tap conductors when they are used. Keep in mind that components like transformers, motors, and heaters may have specific overcurrent protection requirements. Wires can only handle a certain amount of current, and undersized wires carrying too much current can create safety hazards, potentially damaging both the wire insulation and the components it connects to. When selecting wire sizes, even if you opt for 90°C wire, remember that most terminals are rated for 75°C. Since machines often contain numerous terminals, use the 75°C column for sizing, regardless of using 90°C wire. Finally, ensure that all wiring is properly supported, neatly routed, and does not put unnecessary strain on their terminals.
10. Misuse of Supplementary Protectors for Branch Circuit Protection
Breakers and supplementary protectors may appear similar, but they serve different functions. As the name suggests, supplementary protectors are designed to be supplemental, used in conjunction with a pre-specified breaker, not as a replacement.
MCBs: Incorrect use of supplementary protectors instead of branch protectors.
MPCBs: Motor controllers with incomplete self-protection configurations (e.g., missing pole separators) or with an inappropriate scope of protection (such as using motor group protectors as self-motor protectors).
MPCBs: Motor protection circuit breakers used as branch protectors for transformers or other devices instead of MCCBs.
This information is not intended to cover every scenario, as each project is unique and may have specific or customized requirements based on product standards or codes. Rather, it serves as a guideline for the acceptance of custom or field-modified equipment or products, confirming they meet relevant codes and standards for AHJ acceptance.
