So today my e-mail box overflowed with questions regarding the use of medical devices such as hearing aids, noise canceling hearing protection, and medicine pumps in HAZLOCs. And yes, there is a solution for these VERY LIMITED opportunities to use a device that is NOT certified for use in these HAZLOCs by a 3rd party NRTL. I want to be up-front with you, I am not a fan of this RAGAGEP, but because we may find ourselves in a legal binding situation I will offer this solution, but I implore upon anyone who takes this path to do so with GREAT CAUTION and VERY SOUND RISK ASSESSMENTS for the actual need. In other words, I have applied this method to ONLY medical devices that were absolutely required by the employee or for the employee’s safety.
ANSI/ISA-12.12.03-2011, Standard for Portable Electronic Products Suitable for Use in Class I and II, Division 2, Class I Zone 2 and Class III, Division 1 and 2 Hazardous (Classified) LocationsSuitable for Use in Class I and II, Division 2, Class I Zone 2 and Class III, Division 1 and 2 Hazardous (Classified) Locations is a relatively unknown standard that was written by the International Society of Automation to provide guidance for the use of portable electronic devices in HAZLOCs. It ONLY applies to “body-worn” and “hand-held” portable electronic products for use in HAZLOCs which are NOT available listed or labeled for use in HAZLOCs.
The standard provides a list (Appendix B) of devices in which there are AVAILABLE listed/certified equipment for HAZLOCs – meaning that there are devices available that carry a 3rd Party Certification for use in HAZLOC and therefore the standard should NOT be applied to these devices. In other words, when there is a device that is certified by an NRTL for use in an HAZLOC, we USE those devices! This standard is NOT intended to be a cost savings path, but instead, it is a path of last resort for those devices we need to use but can not find one that carries a certification we need.
The standard breaks these portable devices into two (2) categories:
- Portable Electronic Product -1 (PEP 1)
- Portable Electronic Product -2 (PEP 2)
The standard has a set of criteria for BOTH classes and it takes a multi-tiered approach, meaning that ALL PEPs must meet design criteria, then there are criteria for a PEP-1 device and then a PEP-2 device will meet ALL of the requirements that a PEP-1 device will and then some. The standard then establishes which type of device can be used in which type of HAZLOC(s). I can say this about the standard, it does NOT permit either PEP-1 or PEP-2 devices to be used in Class I Division 1 HAZLOCs! If a non-rated device is needed to be used in a Class 1 Div 1 HAZLOC, the standard PROVIDES and REQUIRES a Gas Free Work Permit (GFWP) process that will allow these devices in a Div 1 HAZLOC. This GFWP acts as sort of a Hot Work Permit that will ensure the area is “gas free” before the device enters the area AND the standard requires “sampling to confirm the continued absence of a flammable gas or vapor“, as well as a contingency plan for emergencies. But the standard does permit PEP-1 and 2 devices to be used in Class 1 Div 2 HAZLOC under certain conditions:
Risk Category C – Portable electronic devices (PEPs) including PEP-1 & PEP-2
Example: watches, hearing aides, identified cell phones.
I MUST state it again, ALL other uses in all other HAZLOCs REQUIRE the GFWP!
So what makes a non-rated device fitting to be used in an HAZLOC? There is actually some pretty sound rationale involved and all joking aside, there are NOT many PEP-2 devices around seeing how most people do not like the idea of their device(s) being dropped six (6) times from the height of 6’6″ to see if it can pass the “drop test”! Yes, that is correct, the “drop test” is 6 feet, 6 inches and is done six (6) times. So if you want to use your i-pad in my HAZLOC, you have to let me drop it from 6’6″, six (6) times to see if the integrity of the enclosure is not compromised, the cell or battery does not fall out or become disconnected, and the i-pad still works as intended. But before the DROP TEST, we can ELIMINATE some devices based on their design… “Any product with a power on-off switch with contacts that directly interrupt battery current is not acceptable for PEP 2 because the switch may cause an ignition-capable arc.” So as you can see, there are not many PEP-2 devices! The standard also uses another metric called “radio frequency energy” to establish the type of device that can be used in HAZLOC’s based on their Groups (e.g. A, B, C, and D). It is this metric that we see how most “cell phones” that are not rated for HAZLOCs are stated to be “safe” for use in a Class 1 Division II, Group D HAZLOC. The standard states that most cell phones are not considered to be ignition sources because their power is equal to or below 2 W maximum output averaged over 20 microseconds. But here is the catch, a PEP-2 device MUST PASS ALL three (3) criteria:
- Drop Test,
- Power on-off switches, AND
- Radio Frequency Energy
And for the record, I have dropped my cell phone from 3′, just once, and it did not operate as intended, so good luck with approving a cell phone as a PEP-2 device!
But for a device to meet the requirements of a PEP-1, it is not so daunting. Here are criteria for a PEP-1 device:
- No available listed apparatus suitable for the area classification and capable of performing the intended function
- Radiofrequency energy transmission limited in accordance with the standard
- NO provisions for forced ventilation
- NO sparks visible during normal operation
- NO excessive temperatures during normal operation
- NO camera flash
- NO motors (unless the motor incorporates non-arcing technology)
- NO visible damage to device
- Powered by a MAXIMUM of two (2) button cells
- Body-worn AND in direct contact with the skin
- NO electrical connections accessible outside the product
So as we can see, there is a method that we could use to accommodate CERTAIN electronic devices that do NOT carry a 3rd Party Certification for use in an HAZLOC. I am NOT 100% on how OSHA would view this standard and its application, but in reality, there are some electronic devices that need to be used by workers in HAZLOC and there are no available listed apparatus suitable for the area classification and capable of performing the intended function(s). If we use the standard sparingly and ONLY when necessary and we FOLLOW IT to the core, then we have a viable argument for these devices. I can say this… trying to apply this standard to a device when there is an available listed apparatus built for use in an HAZLOC and we just don’t want to spend the $ to obtain it and instead try to apply this standard to a non-certified device we should expect some serious trouble.
And lastly, a “fitness band” is OUTSIDE the scope of this standard as it does NOT play a role in the employee performing their necessary functions within the HAZLOCs! The standard is obviously intended to apply to those devices that the employee(s) need for medical reasons or for work-related task(s) and I am of the opinion that a “fitness band” is neither! But that is my personal opinion. I can even see how a watch may be necessary for some work related tasks, but not a fitness band. But there is an argument to be made that the standard can be applied to any portable electronic product, as it even mentions “key fobs” in Appendix B. And for those who thought I was surely joking about the “key fobs”, spend the $40 for this standard and you will see that I was NOT joking… Key Fobs would have to be tested to be a PEP-2 device meaning they would have to pass the “Drop Test” if they are to be used in an HAZLOC!