Hi Michael:
Nice to hear from you. > 1. Is the involvement of an AHJ mandatory? If yes, who is > responsible to > involve the AHJ? The FARMER or the "IMPORTER"? My > understanding: the FARMER > in each county is responsible to involve the AHJ. To ensure > that the machine > is safe it is recommended for the FARMER to specify the > "fulfillment of the > NEC, 29 CFR 1910" together with a field evaluation by a NRTL in the > contract. In this case the FARMER is the employer. OSHA applies. The FARMER must provide either NRTL- certified equipment OR have the equipment inspected and tested by the AHJ (for OSHA). In addition, the local electrical code applies. The FARMER must provide either NRTL-certified equipment OR contact the local AHJ (for the electrical code) to have it inspected and tested. In both cases, the FARMER is responsible for providing certified equipment. > 2. What is an AHJ doing? I understood the mails of Pete and > Rich that an AHJ > approves each electrical installation BEFORE operation. In both cases, the AHJ for OSHA and the AHJ for the electrical code will require a "field" certification to inspect and test the equipment. If the FARMER is lucky, both AHJs will agree to the same lab for a single inspection and test. The AHJ specifies the acceptable labs, and orders that the FARMER must obtain and pay for the certification. For BOTH OSHA and the local electrical code, the equipment must be inspected and tested BEFORE the equipment can be put into use. I recall many years ago when a local printing company bought a nice, new German state-of-the- art printing press. It was installed and ready to go, but, since it was hard-wired to the building, and the building wiring had to be modified, the press and installation had to have the local electrical code inspection before it could be used. The inspector "red-tagged" the press; it couldn't be used until it met the local electrical code. The inspector required the press to be completely re-wired with UL-labeled wire with the correct colors. Very expensive and time-consuming. My advice is to apply for NRTL certification of the unit. Europe has several local labs that are NRTLs and that can do the job. Best regards, Rich > -----Original Message----- > From: Michael Loerzer [mailto:loerzer_mob...@globalnorm.de] > Sent: Monday, January 16, 2012 2:23 PM > To: 'Pete Perkins'; EMC-PSTC@LISTSERV.IEEE.ORG; ri...@ieee.org > Subject: AW: [PSES] Electrical installation - Approval or > required permission by an AHJ in the US (29 CFR 1910 subpart > S, NFPA 70/79) > > > Pete, Rich, all PSTC members, > > thanks a lot for your detailed information. Its sometimes difficult to > understand the US system in comparison to the EU system: > > If a importer or manufacturer places a product on the EU > market the product > shall comply with the "CE marking regulations" like EMC, low voltage, > machine, toys, medical device directives. > For the operation the end user is responsible. The applicable > EU directive > is 2009/104/EC "DIRECTIVE 2009/104/EC OF THE EUROPEAN > PARLIAMENT AND OF THE > COUNCIL of 16 September 2009 concerning the minimum safety and health > requirements for the use of work equipment by workers at work (second > individual Directive within the meaning of Article 16(1) of Directive > 89/391/EEC)" > > In my understanding... > > 29 CFR 1910 Subparts S "Electrical" and O "Machine guarding" are more > similar to our "OSHA" Directive 2009/104/EC and NOT to the "CE marking > directives" because the main goal of these CFRs is > "occupational health and > safety at WORK". Therefore the US customer has the goal to "buy safe > equipment like ITE or machines" from the German manufacturer. > > I have a detailed example: > > A German manufacturer produces "pasteurizers to raw milk" (users are > FARMERS). Technical data of the KompactPasteur: > > Processor control with temperature sensors and process records > Electrical connection 230 V / 400 V > Heating capacity 8.1 kW > Combined coiled tube heat exchanger to heat and hold the heat > Two-stage heat recovery > Stainless steel milk pump > Capacity approx. 180 L/h with 8.1 kW heating capacity > Dimensions: > Width: 500 mm > Height: 1200 mm > Depth: 400 mm > > This KompactPasteur complies with the European Low Voltage Directive > (electrical safety), machinery directive and EMC directive. > Up to now the > German manufacturer are labelling the KompactPasteur with the > following > important notice: > > "This product complies with the requirements of the European Machinery > Directive 2006/42/EG, Annex II, 1.A and bears the CE sign. > However it is NOT > UL/CSA approved. It is therefore imperative for the end user > to have an > individual approval carried out!" > > My questions are: > > 1. Is the involvement of an AHJ mandatory? If yes, who is > responsible to > involve the AHJ? The FARMER or the "IMPORTER"? My > understanding: the FARMER > in each county is responsible to involve the AHJ. To ensure > that the machine > is safe it is recommended for the FARMER to specify the > "fulfillment of the > NEC, 29 CFR 1910" together with a field evaluation by a NRTL in the > contract. > 2. What is an AHJ doing? I understood the mails of Pete and > Rich that an AHJ > approves each electrical installation BEFORE operation. > > Best regards > > Dipl.-Ing. Michael Loerzer > Managing Director > Regulatory Affairs Specialist > > Das neue Buch zum Thema "Product Compliance": > http://www.beuth.de/sc/produktkonformitaet > (Produktkonformität, Prozesse, > Risikomanagement, CE-Kennzeichnung, Fallbeispiele für > Geschäftsführung, > Konstruktion, Normenabteilung, Vertrieb, Einkauf, Produktion, QM) > > _________________________________________ > Globalnorm GmbH > Alt-Moabit 94 > 10559 Berlin > > Fon +49 30 3229027-51 > Mobile +49 170 3229027 > Fax +49 30 3229027-59 > Mail michael.loer...@globalnorm.de > > www.globalnorm.de > www.globalnorm.ca > www.product-compliance.com > > _________________________________________ > Globalnorm GmbH, Sitz der Gesellschaft: Alt-Moabit 94, 10559 Berlin > Geschäftsführer: Dipl.-Ing. Michael Loerzer > Amtsgericht Berlin-Charlottenburg HRB 105204 B, > USt-ID-Nummer: DE251654448 > - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
