Altered Machinery

[c gat]

I am currently in a dispute over a piece of machinery that is wanting to be installed and need some more info on this. What we have is a log splitter that has been altered into a weld bend test machine. I refused to install this machine due to obvious liability issues and the fact it is not a listed and approved piece of machinery as described in Art 100 Definitions. I am still receiving pressure to install this machine after I had made it clear that this was against code and would like to know where I can find more information regarding this situation or just your thoughts. Also in my opinion, Art 110.2 and 110.3 come into play here as well...

 

[zbang]

Have the electrical sections been modified or only the mechanical? Was it originally NTRL listed (do they list them at all? didn't check)? If it's listed as a log splitter, then they're going outside the listing, but if there's no listing at all.... I'd be more worried if it has the interlocks and safety features required of a test machine- things like guards, hydraulic over-pressure switches/relief, operator protection, etc. All that depends, too, on the expected load and whether it's higher or lower than splitting a seasoned hardwood log.

If the electrical system is safe, why not hook that up but put your other concerns in a memo (keep a copy, of course) and let other people sweat over them. Are you an employee or contractor? Makes a difference in how to present the concerns.

 

[petersonra]

I am currently in a dispute over a piece of machinery that is wanting to be installed and need some more info on this. What we have is a log splitter that has been altered into a weld bend test machine. I refused to install this machine due to obvious liability issues and the fact it is not a listed and approved piece of machinery as described in Art 100 Definitions. I am still receiving pressure to install this machine after I had made it clear that this was against code and would like to know where I can find more information regarding this situation or just your thoughts. Also in my opinion, Art 110.2 and 110.3 come into play here as well...

what makes you think there is a requirement that a weld bend test machine has to be listed?

If there is some need for it to be approved, that would be up to the AHJ. Why would the AHJ care what the original purpose of the machine was as long as there is no code violation in the way it is currently being used?

I do not see any clear code issue. There is certainly no code violation in modifying a machine to do whatever you want it to do. That is a very common thing.

 

[c gat]

Have the electrical sections been modified or only the mechanical? Was it originally NTRL listed (do they list them at all? didn't check)? If it's listed as a log splitter, then they're going outside the listing, but if there's no listing at all.... I'd be more worried if it has the interlocks and safety features required of a test machine- things like guards, hydraulic over-pressure switches/relief, operator protection, etc. All that depends, too, on the expected load and whether it's higher or lower than splitting a seasoned hardwood log.

If the electrical system is safe, why not hook that up but put your other concerns in a memo (keep a copy, of course) and let other people sweat over them. Are you an employee or contractor? Makes a difference in how to present the concerns.

There were never any previous electrical sections on the original log splitter, it was a gas engine that ran the hydraulic pump. Now it has been modified, an electric motor added to run the pump. No interlocks, pressure switches, operator protection, guards, no nothing. According to our state AHJ, any modified or constructed piece of equipment must be approved before installed and how would he be able to approve such equipment that has not been listed for use as a bend test machine. Also OSHA Reg 1910 addresses this as well.

 

[c gat]

what makes you think there is a requirement that a weld bend test machine has to be listed?

If there is some need for it to be approved, that would be up to the AHJ. Why would the AHJ care what the original purpose of the machine was as long as there is no code violation in the way it is currently being used?

I do not see any clear code issue. There is certainly no code violation in modifying a machine to do whatever you want it to do. That is a very common thing.

Do you not think that a piece of machinery, especially one that is going to preform tests needs to be evaluated and tested to operate safely and properly. I agree that this is very common but not proper if your trying to avoid a law suit.

 

[zbang]

According to our state AHJ, any modified or constructed piece of equipment must be approved before installed and how would he be able to approve such equipment that has not been listed for use as a bend test machine. Also OSHA Reg 1910 addresses this as well.

Sounds like they're the ones that should be saying NO.

IMHO, there's only so far one person can go with this. Make the objections, preferably in writing, maybe drop a dime and call the AHJ, connect the power in as safe a manner as possible, move on. Is your job worth the pushback?

That said, in addition to whatever motor controller/overloads are required by the NEC (How big a motor, anyway? Is it internally protected?), I'd put a lockable safety switch on the machine. They should also have a lock-out policy for using the machine.

Sounds like the company policy is safety by putting one's head in the sand...

 

[iceworm]

I am currently in a dispute over a piece of machinery that is wanting to be installed and need some more info on this. What we have is a log splitter that has been altered into a weld bend test machine. I refused to install this machine due to obvious liability issues and the fact it is not a listed and approved piece of machinery as described in Art 100 Definitions. I am still receiving pressure to install this machine after I had made it clear that this was against code and would like to know where I can find more information regarding this situation or just your thoughts. Also in my opinion, Art 110.2 and 110.3 come into play here as well...

There were never any previous electrical sections on the original log splitter, it was a gas engine that ran the hydraulic pump. Now it has been modified, an electric motor added to run the pump. No interlocks, pressure switches, operator protection, guards, no nothing. According to our state AHJ, any modified or constructed piece of equipment must be approved before installed and how would he be able to approve such equipment that has not been listed for use as a bend test machine. Also OSHA Reg 1910 addresses this as well.

Do you not think that a piece of machinery, especially one that is going to preform tests needs to be evaluated and tested to operate safely and properly. I agree that this is very common but not proper if your trying to avoid a law suit.

c gat -
This has all the earmarks of a cat-fight twix the engineer (or maybe the research Phd) and the electrician. I suspect there is "the rest of the story". Do we get to hear it - or just your side?

In either event, a couple of questions:
Was this unsafe when it had a gas engine running it?
Did adding the adapter to do the bend test make it unsafe?
Did adding swapping the gas motor for an electric motor make it unsafe?

How does the application of "to perform tests" make a difference on "needs to be evaluated and tested to operate safely and properly"? Who do you want to perform this evaluation? No question overloads, disconnects, short circuit and GF protection are needed - same as any motor installation. Past that, what is any AHJ going to know about a bend test machine?

What if you were asked to install a receptacle and the machine was cord and plug?

Is this offered for sale, or is this for use in a lab?
(Edit) Thought of another Q: Is this open to the public?

Are bend test machines commercially available? If so, what do they have that this one doesn't?

I'm not saying you are wrong - just looking for the rest of the story

ice

 

[petersonra]

Do you not think that a piece of machinery, especially one that is going to preform tests needs to be evaluated and tested to operate safely and properly. I agree that this is very common but not proper if your trying to avoid a law suit.

I think it should be safe. I do not think that what you are describing by itself constitutes a violation of the NEC.

 

[Cow]

I think there are a million such gas driven log splitters out there, my father made one for the farm himself. What automatically makes it more dangerous once it's electrically driven rather than gas?

 

[suemarkp]

If this machine was cord-and-plug connected, would you even be seeing that machine? We have a similar law in Washington where basically anything that plugs in needs to be UL or NRTL listed. More and more states are adding these rules. I don't believe it is a requirement of the NEC or else they wouldn't have had to pass new rules to cover this. It is typically the electrical inspector that catches/enforces this, especially if it is hard wired. But we have had cord connected drill presses and light fixtures we've had to disconnect because the inspector noticed the unlisted unit near what they were inspecting.

It is especially onerous in that the company wants to follow the law and tries to discover if something is listed/tested before we order it. Sometimes that is easy to find out, other times it is not. Then there are things that throw them like "UL Recognized". This can hold up ordering items, but I think they've given up in trying to answer that question for many of the smaller items. A large generator or UPS is one thing, but a $50 cord connected light fixture is just easier to buy again if it turns out the unit isn't listed.

 

[zbang]

I think there are a million such gas driven log splitters out there, my father made one for the farm himself. What automatically makes it more dangerous once it's electrically driven rather than gas?

Probably not much, unless a 5hp gas motor & pump is replaced with a 5hp electric pump or when it's not used as a log splitter.

Assume for a moment that any log will split by the time a given hydraulic pressure is reached, this limits the system pressure and stresses Now substitute a big steel beam for the log. It's possible that the beam will bend first, but it's also possible that a hose bursts, the cylinder shaft bends, or then entire thing comes apart. Since we don't know the magnitude of force needed to test these welds or what, if any, engineering study went into the mod's, we're all making guesses about what might happen. I tend to be a pessimist on this.

 

[mgookin]

If you purchase and modify something, that makes you the manufacturer. Are you saying that guy is not allowed to fabricate a bending machine? That's your answer.

 

[c gat]

c gat -
This has all the earmarks of a cat-fight twix the engineer (or maybe the research Phd) and the electrician. I suspect there is "the rest of the story". Do we get to hear it - or just your side?

In either event, a couple of questions:
Was this unsafe when it had a gas engine running it?
Did adding the adapter to do the bend test make it unsafe?
Did adding swapping the gas motor for an electric motor make it unsafe?

How does the application of "to perform tests" make a difference on "needs to be evaluated and tested to operate safely and properly"? Who do you want to perform this evaluation? No question overloads, disconnects, short circuit and GF protection are needed - same as any motor installation. Past that, what is any AHJ going to know about a bend test machine?

What if you were asked to install a receptacle and the machine was cord and plug?

Is this offered for sale, or is this for use in a lab?
(Edit) Thought of another Q: Is this open to the public?

Are bend test machines commercially available? If so, what do they have that this one doesn't?

I'm not saying you are wrong - just looking for the rest of the story

ice

Ok, let me try to answer you questions. When the gas engine was on it, it was still a log splitter, who ever manufactured the log splitter" I dont recall the brand" made that machine to be a log splitter with what ever safety requirements are required for that piece of equipment to be sold to the public. A couple of guys got together and built this so called bend test machine, from scratch, using some of the parts from the log splitter. There was no adapter. As far as having the machine evaluated and tested, someone has to be able to prove that the machine is safe and operates properly and to certain standards, Art 90.7 talks about this. You cant just start building machinery and put it into use with out having inspected and and approved for anyone to use, if you do, your just asking for a lawsuit. Maybe I should also say that this will be used by students and in a classroom setting. Here is my whole issue, it's not safe, it was conjured up in someone's head and pieced together using parts from a machine that was designed for a completely different purpose and according to out AHJ, if I do anything to this thing I could be held liable and i'm not going to chance that.

 

[kwired]

Ok, let me try to answer you questions. When the gas engine was on it, it was still a log splitter, who ever manufactured the log splitter" I dont recall the brand" made that machine to be a log splitter with what ever safety requirements are required for that piece of equipment to be sold to the public. A couple of guys got together and built this so called bend test machine, from scratch, using some of the parts from the log splitter. There was no adapter. As far as having the machine evaluated and tested, someone has to be able to prove that the machine is safe and operates properly and to certain standards, Art 90.7 talks about this. You cant just start building machinery and put it into use with out having inspected and and approved for anyone to use, if you do, your just asking for a lawsuit. Maybe I should also say that this will be used by students and in a classroom setting. Here is my whole issue, it's not safe, it was conjured up in someone's head and pieced together using parts from a machine that was designed for a completely different purpose and according to out AHJ, if I do anything to this thing I could be held liable and i'm not going to chance that.

Lots of things are fabricated in the field, some completely from scratch, some using components of an item that was made by someone else.

Listing is just a third party investigation of that item that says it meets certain criteria for them to list it, and it is still listed for a certain purpose, if you are not using it for that purpose the listing doesn't really mean anything.

How would we ever have all the millions of things we have these days if every single piece needed to be "listed"

UL does evaluate more then just products that are electrically operated - though electrical seems to get the lions share of recognition in UL listed products, and of course is a big topic of discussion in a forum for electrical professionals.

Whether or not something is required to be listed is a whole other issue. If the motor installed on this rebuilt machine is a general purpose AC motor - it likely isn't listed, or at least required to be listed. About only ones that I am aware of that are required to have listing are ones use in some hazardous locations.

When it comes to electrical design of the machine - the general rule in most cases is if it has a listing and is used per the listing requirements- it is ok as is. If it doesn't have a listing or is built by a UL approved control panel building shop, etc. then it usually has to be designed in a way that complies with NEC, which may be more restrictive on many things then a NRTL listing for a similar final product.

If there is no AHJ to reject the machine's installation or use, then nobody cares - until someone is injured by this machine - then litigation procedure ends up putting blame on someone, and if at a place of employment safety policies start to get tighter.

 

[c gat]

Lots of things are fabricated in the field, some completely from scratch, some using components of an item that was made by someone else.

Listing is just a third party investigation of that item that says it meets certain criteria for them to list it, and it is still listed for a certain purpose, if you are not using it for that purpose the listing doesn't really mean anything.

How would we ever have all the millions of things we have these days if every single piece needed to be "listed"

UL does evaluate more then just products that are electrically operated - though electrical seems to get the lions share of recognition in UL listed products, and of course is a big topic of discussion in a forum for electrical professionals.

Whether or not something is required to be listed is a whole other issue. If the motor installed on this rebuilt machine is a general purpose AC motor - it likely isn't listed, or at least required to be listed. About only ones that I am aware of that are required to have listing are ones use in some hazardous locations.

When it comes to electrical design of the machine - the general rule in most cases is if it has a listing and is used per the listing requirements- it is ok as is. If it doesn't have a listing or is built by a UL approved control panel building shop, etc. then it usually has to be designed in a way that complies with NEC, which may be more restrictive on many things then a NRTL listing for a similar final product.

If there is no AHJ to reject the machine's installation or use, then nobody cares - until someone is injured by this machine - then litigation procedure ends up putting blame on someone, and if at a place of employment safety policies start to get tighter.

The listing thing came strait from the AHJ.

 

[kwired]

The listing thing came strait from the AHJ.

My guess is he doesn't like what he sees, but can't find any other way to reject it. There is all kinds of unlisted machinery out there, both sold in standardized mass produced units as well as on of a kinds fabricated on site. If he is an electrical inspector all he can do is inspect to NEC, unless he runs into an item that NEC says must be listed.

I was looking for some examples of things and here is one of first things I found - look through art 422 - Appliances. I never seen anything stating anything covered in 422 needs to be listed. Now go to art 424 -Fixed electric space heating and 424.6 mentions some specific heaters that must be listed. So if in your case you had someone build an electric space heater - it likely could be rejected because it isn't listed.

Now if mechanically is doesn't meet some other standard - whoever built it, and maybe you are at least partly liable should someone get injured by it, but I don't see how an EI can reject anything other then what doesn't comply with NEC plus amendments or any other code he is tasked with enforcing.

 

[petersonra]

The listing thing came strait from the AHJ.

As other people are trying to tell you there are all kinds of things that have wires and electricity associated with them that are just not available with a listing. And there is generally no code anywhere that says they have to be listed.

Inspectors do not have the authority to arbitrarily red tag an installation just because they feel like it. They have to be able to back that up with more than "I don't like it". It has to be a violation of some code they are authorized to enforce. if the problem is with an inspector, he has a boss. And that boss has a boss.

It sounds to me like you have a problem with the machine for some reason, maybe even a legit reason. But trying to gin up a NEC code violation where there is none is not the way to go about dealing with your issue with the machine.

Incidentally, the inspector is never the AHJ. He may say he is, he may act like he is, and he may have people fooled into thinking he is, but he is merely an employee or agent of the AHJ. Your local building department might not even be the real AHJ.

 

[petersonra]

Ok, let me try to answer you questions. When the gas engine was on it, it was still a log splitter, who ever manufactured the log splitter" I dont recall the brand" made that machine to be a log splitter with what ever safety requirements are required for that piece of equipment to be sold to the public. A couple of guys got together and built this so called bend test machine, from scratch, using some of the parts from the log splitter. There was no adapter. As far as having the machine evaluated and tested, someone has to be able to prove that the machine is safe and operates properly and to certain standards, Art 90.7 talks about this. You cant just start building machinery and put it into use with out having inspected and and approved for anyone to use, if you do, your just asking for a lawsuit. Maybe I should also say that this will be used by students and in a classroom setting. Here is my whole issue, it's not safe, it was conjured up in someone's head and pieced together using parts from a machine that was designed for a completely different purpose and according to out AHJ, if I do anything to this thing I could be held liable and i'm not going to chance that.

The inspector is giving you legal advice now? Is he also a lawyer?

read carefully what 90.7 actually says. It starts out with

For specific items of equipment and materials referred to in this Code ...

In other words, only those items of equipment and materials SPECIFIED within the code require what we call "listing". If the code doesn't say it is required to be listed, it is not required to be listed.

 

[PetrosA]

I'm a little confused by this. There have been a number of threads about how custom made lamps are now required to get a UL sticker. If a customer wants to convert a log splitter into a weld testing machine for use by students, he doesn't need any kind of sticker or review of it but if they converted an old microphone stand into a floor lamp to light the work they're going to do on the test equipment they would need a UL sticker for the lamp? Something seems very illogical about that.

 

[petersonra]

I'm a little confused by this. There have been a number of threads about how custom made lamps are now required to get a UL sticker. If a customer wants to convert a log splitter into a weld testing machine for use by students, he doesn't need any kind of sticker or review of it but if they converted an old microphone stand into a floor lamp to light the work they're going to do on the test equipment they would need a UL sticker for the lamp? Something seems very illogical about that.

luminaires are required to be listed. log splitters converted into weld test machines are not.

in any case, the old microphone stand is a support for a luminaire, not the luminaire.