UL or Third Party listing

[pdmtn]

would you share your thoughts on the requirement of 110.3 b for listing & labeling . The City of Chattanooga requires that all electrical equipment have a UL or third party listing by one of the 10 Tennessee approved agencies . We have a new auto plant under construction and this has been a PAIN. Thanks for shareing how you handle this.
Chief PDMTN

 

[e57]

Seems straight forward & painless to me - one of ten agencies to list stuff - I'm not sure how many agencies there are but it seems that most all would be covered if ten are acceptable??? Or is it that some of the equipment you plan to use have no listing at all?

 

[augie47]

For those of you who work areas where there is a requirement for all equipment to be listed by a NRTL (from DRM2-IMC posts NRTL listing seems to be a NRTL requirement), are there exceptions where you do not require a NRTL listing, such as foreign equipment ?

 

[don_resqcapt19]

would you share your thoughts on the requirement of 110.3 b for listing & labeling . The City of Chattanooga requires that all electrical equipment have a UL or third party listing by one of the 10 Tennessee approved agencies . We have a new auto plant under construction and this has been a PAIN. Thanks for shareing how you handle this.
Chief PDMTN

Is this a pain because they are wanting to use equipment with a CE marking in place of an evaluation by a NRTL?

 

[Cold Fusion]

... The City of Chattanooga requires that all electrical equipment have a UL or third party listing by one of the 10 Tennessee approved agencies . We have a new auto plant under construction and this has been a PAIN. ...

Well, I certainly have an opinion.

*********************************************
(Following is in a John Wayne voice, dressed as Rooster Cogburn, with an American Flag waving in the background)

Yes, it is a pain when the AHJ can't figure out how to handle this - since there is not NRTL listing for a lot of industrial equipment.

The blanket NRTL requirement for industrial equipment is expensive and useless. It does not increase safety what so ever.

But, I can see why the AHJ wants to do it. All you have to hire are poeple trained to say,"No sticker, failed. Why? Because I said so, 110.2."

Americans are plenty smart and hard working. We can compete with anyone. But we can't do it while packing around bureaucratic deadwood.

********************************************

For those that didn't read it all, I didn't say no NRTL listings. The NEC has a list of the equipment that is required to be listed or labeled.

And I don't have an issue with consumer electrical equipment being required to be listed or labeled.

I mostly have a problem with the requirement for industrial equipment wher not required by the NEC.

e57 -
Plenty of equipment does not have a listing - because there is no listing available.

Just so I am clear:
I absolutely do not apoligize to the wizzards of the Great State of Tennessee, nor the wise men of Gotham residing in the Munincipality of Anchorage

cf

 

[augie47]

CF, I'll help you with the flag all day, but a comment, please..... When an inspection is completed at a facility, the facility looks at that inspection in light of 90.1 ( The purpose of this Code is the practical safeguarding of persons and property from hazards arising from the use of electricity).
No inspector has the knowledge, time, or testing facilities to recognize the hazards that might be present with a piece of pre-wired equipment. If the goal is to provide reasonable protection from electrical hazards, equipment must meet some guideline just as the general wiring must meet NEC.
The governing body and the customer look to the inspector for that assurance, and I don't know of a practical way to attain that without a "NRTL" label. It takes engineers like yourself and not inspectors to accomplish this.
What other choices does an inspection program have ?

(Note. Some forumites have stated that in order to meet OSHA requirements the equipment must bear the label of an OSHA approved NRTL, but I am aware of some jurisdictions that will
accept a Professional Engineers letter)

 

[Cold Fusion]

Gus -
I picked out pieces of your comment. I'm not trying to mis-quote you, just gather up the parts that matter to me. So if you see anything that looks like a mis-quote, I'll back right off.

...No inspector has the knowledge, time, or testing facilities to recognize the hazards that might be present with a piece of pre-wired equipment. ...

...The governing body and the customer look to the inspector for that assurance ...

I think a lot of my issues start right here. These two are mutually exclusive. With having the knowledge, time, testing facilities, the AHJ/Inspection agency can not supply assurance. In most of the stuff i work on, that NRTL label won't help a bit (I'll show why later)

...The governing body and the customer look to the inspector for that assurance, and I don't know of a practical way to attain that without a "NRTL" label. ...

Let's look at an installation, perhaps similar in complexity to the OP.

Say the installation is:
Service point is on the primary, 69kv
Two 10mva xfm
Plant distribution is HRG 13.8kv
5 Parallel feeders to double ended 100kva, 480V NGR substations

Two black start, 1750kva, HRG, 13.8kv DGs tied in at the main 13.8kv distribution.

Several 120V UPS, one 480V, 3ph UPS

We are bringing this thing up in pieces. As each section gets done, the inspection/commissioning gets completed and it gets turned on.

So the 69kv is completed, transformers are completed, 13.8kv substation is in, DGs are in, we are commecting the 13.8kv feeders. We are ready to commission/energize right up to the 13.8kv main.

AHJ/Inspector walks in and says:
"I don't see a label on the:
69/13.8 transformers
13.8Kv airbreaks on the transformer secondaries;
13.8kv circuit breakers;
Diesel Generators;
480V battery charger"

Engineer:
The transformers are ansi rated not UL. I don't think I have ever seen a 69kv xfm with a UL sticker.

The 13.8kv equipment is generally used by utilities. Listings are not available cause the utilities don't need it or want to pay for it.

The UL listing for generators, UL2200, stops at 600V.

The UL listing for battery chargers stops at 150V.

There is nothing in the NEC that requires any of this equipment to be listed.

AHJ/Inspector:
The State of Tennessee requires it.

Engineer:
We can certainly spend $200K and get a UL field evaluation - except for the 69kv gear and the transformer. Those two I don't know about. For the generators, the only part we can get listed is the control equipment. There won't be a field evaluation for the generator itself.

However I am curious as to your opinion:
1. After we spend this money, just how much safer do you think the installation will be?

2. If the 69kv CB, transformers, 13.8kv cbs (the substation) belonged to the utility, none of it would have a UL sticker. Would it be less safe then?

3. Say we have an agreement with the utility: After the substation is completed, commissioned, operational, we are going to give it to them. They will own it and maintain it. Our service point will be on the load side of the 13.8kv feeder CBs. Metering is still primary - the utility is not going to eat the cost of heating the transformers. Does the equipment still require a sticker? If not, is it still safe?

******************************************

...What other choices does an inspection program have ? ...

Two options I can see:
1. Take some of the money charged for the permit and hire out for a competent plans review. Take the rest of the permit money and inspect that the installation is per plan. Keep 10% of the money to pay for the overhead. Of course that would mean that the city/state doesn't get all the money to bloat the bureaucracy.

2. For the cookie-cutter NEC designed parts, inspect to the NEC, require all NRTL listed equipment if the state wishes. For the non-cookie-cutter designed parts, the ones where the inspector does not have the knowledge, time, facilities, keep the money and believe the stamped drawings. Require listed equipment where the NEC has specific requirements.

Where would I draw the line?

If there are no stamped drawings, require all NRTL listed equipment. This relieves the inspector for the time, knowledge, facilities part.

If there are stamped drawings then require listed equipment where the NEC has requirements. And if the NEC requires a listing, then a letter from a PE does not change that.

Just an opinion

cf

 

[Cold Fusion]

CF, I'll help you with the flag all day, ...

Thanks. I knew there were a lot of sharp teeth in my comment. I was hoping to lighten it up a bit.

(Deleted Second Amendment comments)

cf

 

[iwire]

For the non-cookie-cutter designed parts, the ones where the inspector does not have the knowledge, time, facilities, keep the money and believe the stamped drawings.

I have a real problem with leaving it up to any PE that comes along.

PEs, like anyone come in all levels of ability and judging from some of the ideas I have seen posted on this forum from PEs not all are capable of separating what they want to accomplish from what should be done.

 

[augie47]

a valued opinion and one that is much appreciated.....

I, like pdmtn, face this situation often and have found no easy answers.
A great deal of the equipment I inspect does have a NRTL label and our State requires NRTL lasting.

On occasion, we have equipment which I am told is "unique" to the industry. We will have stamped drawings for the job but they only go as far as the feeder to such equipment.

The State puts the inspector and customer in a dilemma. They are not going to pay for any testing or engineering study (there % of the permit fee is seldom over $100) and they require NRTL listing and the inspector is held responsible if the job is approved without it.

In your reply you stated: "If there are no stamped drawings, require all NRTL listed equipment. This relieves the inspector for the time, knowledge, facilities part."
As far as the equipment itself is concerned, what type of drawing would you accept ? The State isn't going to review and stamp individual machine drawings.

Understand, i am not being argumentative. I am looking for methods others have used in approaching this issue. I have the feeling in most cases it is ignored.

 

[mpd]

I have a real problem with leaving it up to any PE that comes along.

PEs, like anyone come in all levels of ability and judging from some of the ideas I have seen posted on this forum from PEs not all are capable of separating what they want to accomplish from what should be done.

i agree, i deal with a lot who are excellent, and i deal with some that are not and never even visit the site

 

[Cold Fusion]

Originally Posted by Cold Fusion For the non-cookie-cutter designed parts, the ones where the inspector does not have the knowledge, time, facilities, keep the money and believe the stamped drawings.

I have a real problem with leaving it up to any PE that comes along.

PEs, like anyone come in all levels of ability and judging from some of the ideas I have seen posted on this forum from PEs not all are capable of separating what they want to accomplish from what should be done.

I agree with all of your comment. I just don't think that "all equipment is required to be NRTL listed" fixes or makes safer a bad design.

cf

 

[Cold Fusion]

a valued opinion and one that is much appreciated..... ...

Gus -
Stop that. I'll never get my hat to fit.:roll:

On occasion, we have equipment which I am told is "unique" to the industry. We will have stamped drawings for the job but they only go as far as the feeder to such equipment. ...

... In your reply you stated: "If there are no stamped drawings, require all NRTL listed equipment. This relieves the inspector for the time, knowledge, facilities part."
As far as the equipment itself is concerned, what type of drawing would you accept ? The State isn't going to review and stamp individual machine drawings. ...

I'm not sure of your question. Here are my translations:

If the job requires an off the shelf piece of equipment, say like a Joslyn 13.8Kv air break, or an ABB 69kv sf6 CB, neither of these are listed. So, the engineer puts them on the drawings, includes the cut sheets. The MFG says it is suitable for the application, the engineer selects the equipment, and stamps the drawing.

Job requires a piece of equipment that no one makes or there is little history. The piece of equipment must be fabricated. (this is definitely "unique to the industry"). In this case specifications, fabrication drawings, acceptance test parameters, all get stamped. Test data is included with the delivered item. Item gets included on stamped drawing as above.

Both cases this is good to go build.

...The State puts the inspector and customer in a dilemma. They are not going to pay for any testing or engineering study (there % of the permit fee is seldom over $100) and they require NRTL listing and the inspector is held responsible if the job is approved without it. ...

I don't like that. Never have. This is not the inspectors' problem. This is a case of the management giving the responsibility, but not the resources nor authority to make the job right. Shame on the management.

Personal Opinion: I think it is a case of "politically connected" trumps "technical competence" any day. The mere fact that a project either works poorly, or is grossly over priced is of no concern.

.... I am looking for methods others have used in approaching this issue. I have the feeling in most cases it is ignored.

I'd agree with the ignored part.

And I'm not sure how to fix it. Once the bureaucracy is entrenched, I suspect they are harder to move out than Al-Queada.

I keep gently reminding the AHJ, 'The NEC does not discuss this. That means the code panels consider this a design issue, not a requlatory issue." Sometimes that works, sometimes I get the 600lb ape with a badge and a gun response.

In any case, squeezing an inspector with a responsibility but no authority or resources is just disgusting - the response of an arrogant, demeaning management.

cf

 

[augie47]

Gus - ...............................
Job requires a piece of equipment that no one makes or there is little history. The piece of equipment must be fabricated. (this is definitely "unique to the industry"). In this case specifications, fabrication drawings, acceptance test parameters, all get stamped. Test data is included with the delivered item. Item gets included on stamped drawing as above.


cf

excuse my ignorance, but, as an inspector, I see zero "stamped drawings of equipment". When you refer to these "stamped drawings", whose stamp ?
Are we accepting the manufacturer's engineer ?

 

[pdmtn]

ul third party listing

ul third party listing

thank you all for your comments....I can tell some of you like the listing & some do not....Where the RUB starts is we have the Third Party Listing from the State and the City we have stood our ground and said NO LISTING ...NO POWER.....untill someone with a higher pay grade than mine we will stick to the guidelines......right or wrong..... thanks for your comments

 

[Cold Fusion]

excuse my ignorance, but, as an inspector, I see zero "stamped drawings of equipment". When you refer to these "stamped drawings", whose stamp ?
Are we accepting the manufacturer's engineer ?

I think I'm not translating your questions correctly. My answers are too simplistic - cause I highly suspect you already know all of this. So, if that's true, disregard and I'll try again.

First, my bad. "Stamped" is slang. "Sealed" is the correct term.

Whose Stamp?
Most states have laws requiring "product of engineering" to be performed by or under the direction of a registered engineer. There are exceptions for engineers that work for the company getting the product. The product of engineering, drawings, reports, specifications, is to be sealed. Sealing is usually an ink stamp, embossed seal, or seal printed on the drawing. The seal is then wet signed by the engineer. And, I'm thinking you already knew all of this.

So, Acme Petroleum wants a molecular, re-fusing, oleofin cracker with a flux capacitor energy adsorber. But nobody makes one that fits exactly what Acme wants. They contract with Flux'R'Us to design and build one to their specs. Since F'R'U is doing engineering for hire, all of their work has to be sealed showing that it was performed by or under the direction of a registered engineer. The final revision of the drawings, final specs, reports, maybe even test documents, all show up with a signed seal. Again, I'm thinking you knew all of this.

So, "Whose stamp?" is who ever did the engineering for hire.

"Are we accepting the manufacturer's engineer?" If they did the engineering then yes. Why wouldn't we?

As to why you are not seeing the drawings, I don't know. If the AHJ/inspector asked me for drawings, I'd get them and sit right there going through them to her satisfaction. There's nothing to hide. Why would't I?

cf

 

[augie47]

actually, you gave an ole dummy too much credit. I assumed you were referecning the mfg engineer (as a possibility).
As of now, those areas who expand the TN irequirement of accepting drawings/letters from PEs are not real partial to PEs other than those registered with the State.

 

[Cold Fusion]

... As of now, those areas who expand the TN irequirement of accepting drawings/letters from PEs are not real partial to PEs other than those registered with the State.

That is as it should be. TN should only accept PEs registered in TN. If I were selling equipment in TN then I'd either have someone with a Tennessee PE or I would contract with a Tennesse registered engineer to provice the services.

cf