Is UL listing required for a battery powered portable instrument?

Status
Not open for further replies.

Steve Merrick

Member
Location
Anchorage, AK
We have an application where we need to run a small instrumentation package through an oil and gas pipeline to inspect the inside for corrosion, etc. The instrument package is housed in an explosionproof case about the size of a shoebox and runs on D cell batteries. It runs completely submerged in the oil except when it is being launched or extracted, during which time it is exposed to Class I conditions. the instrument is ATEX certified, but no UL listed device is available from any manufacturer. Is a US NRTL listing required for this application? Thanks!
 
The whole idea of explosion proof enclosures at least for the most part, is so you can put stuff in it that's not identified for use in classified areas. So I don't think you have an issue.
 
Technically, ATEX is meaningless as a US certification. Without an NRTL certification, how would you know it's explosionproof?

As a long shot, Section 500.8(A)(3) might apply (that's what ATEX actually is).
 
Technically, ATEX is meaningless as a US certification. Without an NRTL certification, how would you know it's explosionproof?

As a long shot, Section 500.8(A)(3) might apply (that's what ATEX actually is).

I think he meant the instrument was atex but it was in an XP box.
 
I think he meant the instrument was atex but it was in an XP box.
That is certainly a reasonable alternate interpretation. However, I do find it difficult to believe that an instrument that is only ATEX identifed is installed in an identifiable explosionproof enclosure.

BTW, OSHA would still likely require the instrument to be NRTL certified.
 
no UL listed device is available from any manufacturer. Is a US NRTL listing required for this application? Thanks!

BTW, OSHA would still likely require the instrument to be NRTL certified.

I don't see how OSHA could require something that does not actually exist.

I suppose it is possible another manufacturer might have something listed by some NRTL other than UL.

Personally, I don't think this is subject to the NEC anyway as it has no connection to the premises wiring system, not even as a utilization device. It is more akin to something like a portable tool or a volt meter.
 
The Scope of Article 500 [Section 500.1] covers Articles 500 to 504. It recognizes equipment in hazardous locations are covered by by the Articles. It makes no distinction about premises wiring. Portable and mobile equipment are covered by the Articles.

OSHA does not necessarily require NRTL certification; but the distinction is whether a NRTL can certify a product not whether any manufacture has, in fact, obtained such a certification. If it can be shown the product can be NRTL certified, it must be. [See FedOSHA definition of Acceptable] There are plenty of UL product standards for certifying electronic instruments for Class I. (I have no idea why GP motors still seem to be an exception; there is definitely a UL product standard for them too.)
 
More info

More info

The unit is called a "pig tracker." It is about the size and shape of a flashlight and is powered by from 2 to 5 C or D-cell batteries, depending on the model. The electronics are encased in a sealed stainless or titanium cylinder rated for pressures up to 7500 psi. Neither the cylinder nor the electronics are UL listed for hazardous areas; nevertheless, this unit is widely used in the US oil and gas industry as well as worldwide without any issues.

What I have been told is that such a battery powered sensor package is not covered by the NEC under Article 90.2, primarily because such small battery powered devices are not being "installed." From that perspective, the pig tracker is really not practically different from carrying a flashlight, a multimeter, or a Motorola radio into the hazardous area. This is standard practice industry wide, but if it violates Code then the industry should be made aware.
 
You need to be aware of the relationship of Chapters 5 to 7 to Chapters 1 to 4. See Section 90.3. "Installation" is not necessarily a consideration in classified locations.

With regard to ,"...carrying a flashlight, a multimeter, or a Motorola radio into the hazardous area", you should contact API's Subcommittee on Electrical Equipment (SOEE) to get their opinion about such unsafe practices; i.e., the industry is already aware.
 
What I have been told is that such a battery powered sensor package is not covered by the NEC under Article 90.2, primarily because such small battery powered devices are not being "installed." From that perspective, the pig tracker is really not practically different from carrying a flashlight, a multimeter, or a Motorola radio into the hazardous area. This is standard practice industry wide, but if it violates Code then the industry should be made aware.

I'd be willing to bet the flashlights, multimeters, and radios are intrinsically safe or protected in some other way if they are being carried into classified areas. There are some places that won't even let you bring a battery powered watch in.
 
The Scope of Article 500 [Section 500.1] covers Articles 500 to 504. It recognizes equipment in hazardous locations are covered by by the Articles. It makes no distinction about premises wiring. Portable and mobile equipment are covered by the Articles.

OSHA does not necessarily require NRTL certification; but the distinction is whether a NRTL can certify a product not whether any manufacture has, in fact, obtained such a certification. If it can be shown the product can be NRTL certified, it must be. [See FedOSHA definition of Acceptable] There are plenty of UL product standards for certifying electronic instruments for Class I. (I have no idea why GP motors still seem to be an exception; there is definitely a UL product standard for them too.)

500.1 Scope — Articles 500 Through 504. Articles 500
through 504 cover the requirements for electrical and electronic
equipment and wiring
for all voltages in Class I,
Divisions 1 and 2; Class II, Divisions 1 and 2; and Class
III, Divisions 1 and 2 locations where fire or explosion
hazards may exist due to flammable gases, flammable
liquid–produced vapors, combustible liquid–produced vapors,
combustible dusts, or ignitible fibers/flyings.

Equipment. Ageneral term, including fittings, devices, appliances,
luminaires, apparatus, machinery, and the like used as a
part of, or in connection with, an electrical installation.

Since the very definition of equipment requires it somehow be associated with an electrical installation, I don't see how a device like a flashlight or a volt meter can be considered to covered by article 500-504.

It might be a good place to look for guidance though on dealing with such items. They still present a hazard.
 
You need to be aware of the relationship of Chapters 5 to 7 to Chapters 1 to 4. See Section 90.3. "Installation" is not necessarily a consideration in classified locations.

With regard to ,"...carrying a flashlight, a multimeter, or a Motorola radio into the hazardous area", you should contact API's Subcommittee on Electrical Equipment (SOEE) to get their opinion about such unsafe practices; i.e., the industry is already aware.
Permit me to be more specific: From API RP 540:

10.4 COMMUNICATION SYSTEMS

10.4.1 Radio Systems

Fixed radio equipment is used extensively in processing
plants for communication between other fixed equipment,
portable equipment, and mobile equipment. The fixed equipment
is typically located in operation or maintenance centers
and is used for dispatching, security, and process-unit communication.

Portable radio equipment is available in two forms, the
hand-held, two-way communication device and the beltmounted,
call-pager system. The call-pager unit alerts its
carrier, who, in turn, uses a telephone to communicate with
the caller. Some call-pager units allow a more detailed messaging
capability. Portable radio equipment that will be used
in classified locations must be approved for use in such
locations.

Mobile radio equipment is provided in vehicles used for
deliveries, maintenance, security, and fire protection, and is
also provided in vehicles used by facility management

This is typical for several classes of equipment.
 
Last edited:
I'd be willing to bet the flashlights, multimeters, and radios are intrinsically safe or protected in some other way if they are being carried into classified areas. There are some places that won't even let you bring a battery powered watch in.
A few are nonincendive - and marked as such if properly used in classified locations.
 
About the only things that the SOEE is hesitant about requiring specific approval for classified locations are pacemakers and hearing aids.
 
Thanks for the feedback, guys. I agree with your Code citings which is why I am asking the question.

If indeed small portable instruments, radios, and the like are required to be UL listed, then Industry must be either unaware of the requirement or it is being ignored. For example, Fluke just recently (within the last 5 years) came out with a hazardous area rated multimeter listed as intrinsically safe by Intertek, but I have never actually seen one used in the field. Most electricians carry a traditional DMM such as a Fluke 179. The Motorola handheld radio universally used by everyone from fire fighters to construction workers claims to be intrinsically safe, but is not listed as such as required under 504.4. Still, our personnel are required to carry one with them whenever they enter a Classified area, as there is nothing else comparable that is listed. As to flashlights, I found only one high-end headlamp/flashlight manufacturer that advertises its product as approved for Class I Div 1 and 2 areas, but when you look closely at their product it is only UL "Classified" and not "listed." Most workers wear a Princeton headlamp or similar on their hardhat, with no thought at all to listing requirements.

My point is that there are many applications where Class I listed devices are technically required, but are simply not available in the US. Work has to get done, so the Code requirements are universally ignored ion those cases. In our case, we are going to bite the bullet and pay the manufacturer many thousands of extra dollars to have their pipeline internal inspection system unit UL listed. As hundreds of these units are already in use in the US, this seems to be another area where the listing requirements for equipment in hazardous areas has been ignored.
 
I would suggest there are several alternate NRTLs than UL. They are quite competent and reasonably priced.
 
OSHA's list of appropriate NRTL test standards

OSHA's list of appropriate NRTL test standards

The best place I've found to determine if a NRTL listing is required for a piece of equipment is here: https://www.osha.gov/dts/otpca/nrtl/list_standards.html. It covers more than just electrical equipment, but at least you can consider it an exhaustive list for electrical purposes. If it is not obvious whether a particular standard applies to a particular piece of equipment, UL's standards website (search on the standard number) will let you see a summary of the standard and the standard's table of contents.
 
Thanks for the feedback, guys. I agree with your Code citings which is why I am asking the question.

If indeed small portable instruments, radios, and the like are required to be UL listed, then Industry must be either unaware of the requirement or it is being ignored. For example, Fluke just recently (within the last 5 years) came out with a hazardous area rated multimeter listed as intrinsically safe by Intertek, but I have never actually seen one used in the field. Most electricians carry a traditional DMM such as a Fluke 179. The Motorola handheld radio universally used by everyone from fire fighters to construction workers claims to be intrinsically safe, but is not listed as such as required under 504.4. Still, our personnel are required to carry one with them whenever they enter a Classified area, as there is nothing else comparable that is listed. As to flashlights, I found only one high-end headlamp/flashlight manufacturer that advertises its product as approved for Class I Div 1 and 2 areas, but when you look closely at their product it is only UL "Classified" and not "listed." Most workers wear a Princeton headlamp or similar on their hardhat, with no thought at all to listing requirements.
I had an interesting email exchange with UL last month about seeing products described only as Classified.
It seems that UL is trying to switch over to the more general word Classified as an overall category for Listed, Recognized, etc.
They did not seem at all concerned that there are codes and ordinances that specifically mention "listed".

Chances are that if you look up the file number for the classified product you will find that it indeed meets the requirements for listing.

I wish UL had not so blithely disregarded existing codes and gone off on their own nomenclature change.
 
Status
Not open for further replies.
Top