Does all fixed/portable/mobile equipment that is installed or enters a Hazardous Location (HAZLOC) have to be “certified” and “labeled” as being acceptable for that specific HAZLOC?
The blunt answer is YES!
But in today’s working world and global economy, I am seeing a lot of foreign approvals for electrical equipment that is not by one of OSHA’s NRTLs. I am also, for the first time in my career, being provided with “certificates” from FM and UL that state in the “fine print”…
“This Certificate of Compliance does not provide authorization to apply the UL Mark.”
If this fixed/portable/mobile equipment does not carry the UL or FM (or any other NRTL) mark and the Class/Div/Grp it is approved for, then how will we know/inspect/audit this equipment as to its ability to safely operate in the specific HAZLOC.
OSHA summarized the 1910.307 requirements nicely in a 1993 LOI…
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Therefore, in summation, before any battery power operated cleaning (sweeper/scrubber) equipment can be used in a hazardous (classified) location within OSHA’s jurisdiction, it must have 1) been certified by an OSHA accredited third-party certifier (NRTL) for the specific hazardous (classified) location, and 2) so identified. |
Source: https://www.osha.gov/laws-regs/standardinterpretations/1993-10-12
Using OSHA’s baseline HAZLOC standard (1910.307) we can see the following: (emphasis by me)
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1910.307(c)(2) Approved for the hazardous (classified) location. 1910.307(c)(2)(i) Equipment shall be approved NOT ONLY for the class of location, but also for the ignitable or combustible properties of the specific gas, vapor, dust, or fiber that will be present. Note to paragraph (c)(2)(i) of this section: NFPA 70, the National Electrical Code, lists or defines hazardous gases, vapors, and dusts by “Groups” characterized by their ignitable or combustible properties. 1910.307(c)(2)(ii) Equipment shall be marked to show the class, group, and operating temperature or temperature range, based on operation in a 40-degree C ambient, for which it is approved. The temperature marking may not exceed the ignition temperature of the specific gas or vapor to be encountered. However, the following provisions modify this marking requirement for specific equipment: 1910.307(c)(2)(ii)(A) Equipment of the nonheat-producing type, such as junction boxes, conduit, and fittings, and equipment of the heat-producing type having a maximum temperature not more than 100 ºC (212 ºF) need not have a marked operating temperature or temperature range; 1910.307(c)(2)(ii)(B) Fixed lighting fixtures marked for use in Class I, Division 2 or Class II, Division 2 locations only need not be marked to indicate the group; 1910.307(c)(2)(ii)(C) Fixed general-purpose equipment in Class I locations, other than lighting fixtures, that is acceptable for use in Class I, Division 2 locations need not be marked with the class, group, division, or operating temperature; 1910.307(c)(2)(ii)(D) Fixed dust-tight equipment, other than lighting fixtures, that is acceptable for use in Class II, Division 2 and Class III locations need not be marked with the class, group, division, or operating temperature; and 1910.307(c)(2)(ii)(E) Electric equipment suitable for ambient temperatures exceeding 40 ºC (104 ºF) shall be marked with both the maximum ambient temperature and the operating temperature or temperature range at that ambient temperature; and 1910.307(c)(3) Safe for the hazardous (classified) location. Equipment that is safe for the location shall be of a type and design that the employer demonstrates will provide protection from the hazards arising from the combustibility and flammability of vapors, liquids, gases, dusts, or fibers involved. Note to paragraph (c)(3) of this section: The National Electrical Code, NFPA 70, contains guidelines for determining the type and design of equipment and installations that will meet this requirement. Those guidelines address electric wiring, equipment, and systems installed in hazardous (classified) locations and contain specific provisions for the following: wiring methods, wiring connections; conductor insulation, flexible cords, sealing and drainage, transformers, capacitors, switches, circuit breakers, fuses, motor controllers, receptacles, attachment plugs, meters, relays, instruments, resistors, generators, motors, lighting fixtures, storage battery charging equipment, electric cranes, electric hoists and similar equipment, utilization equipment, signaling systems, alarm systems, remote control systems, local loud speaker and communication systems, ventilation piping, live parts, lightning surge protection, and grounding. |