Machinery Inspection Requuirements

[whebi]

We are moving into an existing factory that is re ltively modern and the electrical systems are in good condition. Our process uses manufacturing equipment that is portable plug-in 110V and 220V. The equipment has been sold, and is in use, all over the US without incident. The equipment is properly labeled under NEC section 110.3(A)(1). The equipment has been operated for 4 years in another location, manufacturing millions of parts without incident.

The local building inspector is insisting that we hire a UL inspection company (at great expense of money and time)to inspect and "LIST" the equipment. When asked to document the requirement, he cited NEC 90.7 and 110.1 through 110.3 as well as NC Administration & Enforcement 143-139.1, 303.2.1, and 66-25. He is using it to potentially prevent a CO being issued.

The code cited does not seem to apply or support his interpretation. Any enlightenment on this?
I need some help please.

WHEBI

 

[charlie b]

Re: Machinery Inspection Requuirements

Although I cannot speak to the ?NC Administration? stuff, I think your Inspector is way out of line here. The NEC covers the permanent electrical installation: the service conductors, main panel, feeders, sub-panels, switches, transformers, and, of course, the outlets into which you may plug your equipment. It does not cover anything that you plug into an outlet.

 

[petersonra]

Re: Machinery Inspection Requuirements

Specifically, the NEC does NOT cover the equipment itself in any regards.

HOWEVER, there are a number of localities across the country that have adopted rules requiring control panels to be UL listed. This is becoming, if not common, at least not unheard of.

Its can be a real PITA not the least of which is the expense to get a UL listing on older control panels. Often you have to rework them to do so, including some seemingly silly things (like stickers or some other legend plate listing the torque requirements for every field connection).

The company I work for builds Ul listed control panels and every now and then we run across a similar situation. Its not always pretty, however for new panels its relatively simple. For existing panels that may not have had all UL listed stuff in it, it could be more painfull.

BTW, I don't believe UL will "list" the equipment itself, only the control panels.

[ November 20, 2004, 12:18 PM: Message edited by: petersonra ]

 

[inspectelec]

Re: Machinery Inspection Requuirements

I think someone needs to read thier code book more often. 90.2 states "Scope(A) Covered. This Code covers the installation of electric conductors, electric equipment, signaling and communications conductors and equipment, and fiber optic cables and raceways for the following:"
See the word electric equipment. Now lets go to the definition of equipment. " Equipment. A general term including material, fittings, devices, appliances, luminaires (fixtures), apparatus, and the like used as a part of, or in connection with, an electrical installation."
See the word appliance. Now lets go to the definition of appliance. "Appliance. Utilization equipment, generally other than industrial, that is normally built in standardized sizes or types and is installed or connected as a unit to perform one or more functions such as clothes washing, air conditioning, food mixing, deep frying, and so forth."
Look closely at this definition. It says generally not always. Now lets see the definition for Utilization equipment. "Utilization Equipment. Equipment that utilizes electric energy for electronic, electromechanical, chemical, heating, lighting, or similar purposes."
This will include cord and plug connected equipment. Now study section 90.7. "90.7 Examination of Equipment for Safety.
For specific items of equipment and materials referred to in this Code, examinations for safety made under standard conditions provide a basis for approval where the record is made generally available through promulgation by organizations properly equipped and qualified for experimental testing, inspections of the run of goods at factories, and service-value determination through field inspections. This avoids the necessity for repetition of examinations by different examiners, frequently with inadequate facilities for such work, and the confusion that would result from conflicting reports on the suitability of devices and materials examined for a given purpose.
It is the intent of this Code that factory-installed internal wiring or the construction of equipment need not be inspected at the time of installation of the equipment, except to detect alterations or damage, if the equipment has been listed by a qualified electrical testing laboratory that is recognized as having the facilities described in the preceding paragraph and that requires suitability for installation in accordance with this Code."
This clearly states that the purpose of having 3rd party listing is to avoid the necessity for repetition of examinations by different examiners, frequently with inadequate facilities for such work, and the confusion that would result from conflicting reports on the suitability of devices and materials examined for a given purpose.
If this does not clear it up, read the handbook for this section. Lets be sure what is posted is correct. I feel this inspector knows what he is talking about. Study, study, study.

 

[petersonra]

Re: Machinery Inspection Requuirements

Industrial machinery generally does not have UL listings (other than some common hand tools, drill presses, etc.).

Are you suggesting a typical local inspector has even a vague clue as to whether typical industrial machines are safe? Most of them seen to never even heard of NFPA79, much less understand it.

By your logic, anything without a UL sticker on it is subject to AHJ inspection. is that what you are suggesting?

[ November 24, 2004, 01:00 PM: Message edited by: petersonra ]

 

[roger]

Re: Machinery Inspection Requuirements

Inspectelec, with all that said, how do you propose to go into a facility and inspect any new piece of equipment that is bought and plugged in at a later date? :roll:

This clearly states that the purpose of having 3rd party listing is to avoid the necessity for repetition of examinations by different examiners, frequently with inadequate facilities for such work, and the confusion that would result from conflicting reports on the suitability of devices and materials examined for a given purpose.

Yep, it clearly states that, but it doesn't require it.

Let's look a little closer,


90.7, Note the second and third words, "Specific items", these items are stated in the applicable articles, and relieves the AHJ of having to judge an item safe.

Now, notice the wording in your message,

"if the equipment has been listed by a qualified electrical testing laboratory that is recognized as having the facilities described above ..."

This would simply relieve the AHJ of having to judge an item safe.


With the exception of the items called for to be listed in the specific articles, there is no mandatory rule that requires all items to be third party tested.

Also take note of the last words in the definition of Equipment, where do you cut off an "electrical installation", would you make someone show all the items they intend to use in their home all the way down to say a heating pad?

Now, I would suggest you do some studying and read the first few pages of the handbook, you will find that there is a disclaimer pointing out that the comentary in the handbook is only opinions and therefor not enforcible.

Roger

[ November 24, 2004, 01:15 PM: Message edited by: roger ]

 

[rbalex]

Re: Machinery Inspection Requuirements

If you go to the Joe Tedesco's web page and review the UL General Information Directory, you will find that "PRGY" is the UL Category Code for ?motors.?

Next, go to this web page and enter PRGY as the keyword. It will return all the manufacturers of UL "listed" motors.

Many electrical items are NOT listed. Read the preamble of Annex A (2002). It ??provides a list of product safety standards used for product listing where that listing is required by this Code.? [ Italics mine] Find ?Motors.?

Note: I know Annex A now lists ?Electric Motors? in the 2005 Edition. It?s an error. It?s addition was buried in a Proposal that wasn?t properly correlated and I didn't discover it until late April of this year. When I brought it to the attention of several of my former CMP11 colleagues and my key TCC contact, they were shocked. They should have been ? it was a Panel Proposal. It turns out it isn?t completely erroneous because the UL Standard is used in certain fire pump applications. Rather than generating a TIA on the issue the CMP has opted for, ?Oh well, it isn?t really enforceable.?

If you go through Art 500 through 516 you will find many cases where "listed" or "labeled" could have been used but ?identified? is the term used instead. This was a deliberate effort by CMP14 to remove the term ?approved? in many locations. But the CMP specifically rejected making ?listed? or ?labeled? a general requirement - in hazardous locations no less. ?Identified? is NOT equal to ?listed? or ?labeled.?

 

[inspectelec]

Re: Machinery Inspection Requuirements

Simply read 90.4." 90.4 Enforcement.
This Code is intended to be suitable for mandatory application by governmental bodies that exercise legal jurisdiction over electrical installations, including signaling and communications systems, and for use by insurance inspectors. The authority having jurisdiction for enforcement of the Code has the responsibility for making interpretations of the rules, for deciding on the approval of equipment and materials, and for granting the special permission contemplated in a number of the rules.
By special permission, the authority having jurisdiction may waive specific requirements in this Code or permit alternative methods where it is assured that equivalent objectives can be achieved by establishing and maintaining effective safety.
This Code may require new products, constructions, or materials that may not yet be available at the time the Code is adopted. In such event, the authority having jurisdiction may permit the use of the products, constructions, or materials that comply with the most recent previous edition of this Code adopted by the jurisdiction."

What do you think this means?.."The authority having jurisdiction for enforcement of the Code has the responsibility for making interpretations of the rules, for deciding on the approval of equipment...."

This topic was discussed at the 2004 IAEA Southern section meeting.

The AHJ uses 3rd party agencies just as it is discussed in 90.7. I have never seen an AHJ with a testing laboratory. Have you? To answer your question about new equipment. If the AHJ does not know it is going in a building, then they can not do anything about it. But in time, this equipment will be relocated or a service upgrade to relocate equipment happens, at this time the unlisted equipment will be addressed.

 

[rbalex]

Re: Machinery Inspection Requuirements

Originally posted by inspectelec:
Simply read 90.4." 90.4 Enforcement.
...
What do you think this means?.."The authority having jurisdiction for enforcement of the Code has the responsibility for making interpretations of the rules, for deciding on the approval of equipment...."

...

It means the AHJ has a duty to perform - it does not give a general grant of prerogative.

 

[inspectelec]

Re: Machinery Inspection Requuirements

Thank you for mentioning that rbelex. The AHJ is responsible for making sure article 90.1 is enforced.
90.1 Purpose.
(A) Practical Safeguarding. The purpose of this Code is the practical safeguarding of persons and property from hazards arising from the use of electricity.

Sometimes people have to be protected from themselves.

Some people have an extremely hard time accepting the word NO.

 

[roger]

Re: Machinery Inspection Requuirements

inspectelec, let's do look at 90.4

The authority having jurisdiction for enforcement of of the Code has the responsibility for making interpretations of the rules,

You don't interpret that to mean the inspector is allowed to make his/her own rules do you?

for deciding on the approval of equipment and materials, ...

this specifically allows an inspector to approve an installation (may be the key word) on his judgment, regardless of the absence of a listing as long as the items in the installation (note that word) are not specifically required to be listed in an article. I ask again where do you think the installation (note that word again) ends

BTW, I don't recall ever seeing in the NEC where an article specifically requires a heating pad to be listed.

Some people have an extremely hard time accepting the word NO.

might this be a self portrait type of statement?

Roger

[ November 24, 2004, 03:23 PM: Message edited by: roger ]

 

[rbalex]

Re: Machinery Inspection Requuirements

I agree with the other Bob.

One of the things I have greatly appreciated about this site is the general civility we show each other. Both Roger and Bob will tell you we have had our own, fairly strong, disagreements in the past, but I have never had the slightest doubt about our mutual respect.

I can assure you, that Roger is a genuine student of the NEC, as are most of our regular contributors. None of us "knows it all," but you will find many extremely knowledgeable members. We look forward to sharing our knowledge, both giving and receiving.

 

[charlie]

Re: Machinery Inspection Requuirements

Gentlemen, I have removed a couple of flaming posts that were out of bounds. It is OK and encouraged to disagree with each other, that is what lively discussion is all about. It is not acceptable to attack each other. If you wish to do that, please take it somewhere else. I have had enough with the Pacers and Pistons, we don't need it here.

 

[tom baker]

Re: Machinery Inspection Requuirements

Perhaps the 2005 NEC can be of some use here. It has a new article 409 on industrial control panels.
In Washington State we have specific rules, developed with the industry (machinery mfgs)
that allows unlisted equipment to be used. There is a lot of equipment that comes into the US that is not listed to US standards.

 

[petersonra]

Re: Machinery Inspection Requuirements

Originally posted by tom baker:
Perhaps the 2005 NEC can be of some use here. It has a new article 409 on industrial control panels.
In Washington State we have specific rules, developed with the industry (machinery mfgs)
that allows unlisted equipment to be used. There is a lot of equipment that comes into the US that is not listed to US standards.

There is also a lot of euqipment made in the US that does not have UL listed control panels. In fact, I would venture a guess that the majority of indutrial control panels are not UL listed at present.

The other thing is that UL only lists the control panel - NOT the rest of the equipment or the connections between the panel and the field equipment.

 

[roger]

Re: Machinery Inspection Requuirements

Thank you Bob and Bob for the words of support, it means alot coming from people of your expertise, and Charlie, thank you for keeping the peace, I have the upmost respect for you guys as well as many other members here.

I went out for dinner with out of town guest and didn't respond earlier.

Iinspectelec, as Rbalex says, we may have spirited conversations but shouldn't resort to attacking each other with name calling or cheap shots.

Now, I will ask you to answer the direct questions I asked in my earlier posts simply out of courtesy.

#1 where do you cut off an "electrical installation"

#2 would you make someone show all the items they intend to use in their home all the way down to say a heating pad?

#3

The authority having jurisdiction for enforcement of of the Code has the responsibility for making interpretations of the rules

You don't interpret that to mean the inspector is allowed to make his/her own rules do you?

#4 I ask again where do you think the "installation" ends?

If this is putting you on a spot, don't answer and I won't pursue this thread any further.

BTW, I don't feel that old.

Roger

[ November 24, 2004, 07:56 PM: Message edited by: roger ]

 

[whebi]

Re: Machinery Inspection Requuirements

Thanks to everyone that has responded to my question. After reading all the responses so far, it seems clear to me that there is not a "requirement" to have every industrial machine filed inspected by UL and listed.

The references in NEC to "equipment" seem to clearly refer to items that are "installed" to make up the electrical system of a building/structure. The definition under Article 100 says"...used as a part of, or in connection with, an electrical installation"

The definition for appliance in Article 100 clearly states "generally other than indstrial". This would certainly give the distinct impression that it was meant to generally exclude industrial machinery from being included or referred to as an "appliance".

Article 670 clearly defines what "Industrial Machinery" is and specifically states that "[The associated electrical equipment, including the logic controller(s)....together with the machine actuators and sensors, are considered as part of the industrial machine.]" Furthermore, it is definetly devoid of a requirement to have it third party inspected or listed. It seems clear that the any control panel that is part of the industrial machine, is not part of the building/structure electrical system.

The idea proferred that every "control panel" has to be field inspected and listed/labeled seems quite overbearing and not very business/commerce friendly. If everyone that took a UL listed enclosure (box) and installed UL listed components into it (making it into a machine controller (control panel) and made it part of an industrial machine, had to get it field inspected and UL listed, the implications to business would be overwhelmingly disastrous.

If that were the case, someone that built a "control panel" out of UL listed components for a simple custom industrial machine that cost a $1,000.00 or some nominal amount (we have some that cost less than that), would have to have a UL field inspection and listing that would cost $5,000-10,000. If that were an actual requirement, it would further encourage the great flight of American manufacturing offshore where such a burdensome regulation is not required.

There comes a point where the regulatory environment in this country must have some simple common sense applied to it. If not, we will all have move to another country to get a job where industry can afford to do business without over-regulation.

It was stated that most industrial machinery manufactured in this country is not UL listed. From my experience, that is definitely the case. If business had to have every piece of industrial machinery field inspected and listed, it would definitely put most small manufacturing plants out of business.

I would appreciate all comments on my posting.

Thanks much...WHEBI

 

[petersonra]

Re: Machinery Inspection Requuirements

Keep in mind a couple things.

There is no reason why you would need a UL field inspection if a UL listed control is required by a local jurisdiction as is the case in some areas.

The cost of getting it built by a UL panel shop and having them apply the UL label to it is minimal, and often will result in a lower cost panel than if you tried to build it yourself (trust me on this one - there are a couple reasons for it that are not real obvious).

If you need a lot of UL listed panels, and want to do them yourself, there is no reason you can't become a UL shop yourself. It does not cost all that much and except for some minor things, you won't do things much different then you would otherwise (if you do things in a quality manner now). The biggest difference is labeling, drawings, and component sourcing. many time field fabricated panels do not have adequate drawings and don't meet UL labeling requirements.

The other thing is that UL requires most (but not all)components used in a UL listed panel be UL listed. This can be a problem since many people use UL recognized components, or even unlisted components. You can do this in many cases, but its not intuitively obvious when you can and when you can't, and you have to get your paper work right.