Archive for March, 2012
RCM Labeling of Electrical Products in Australia & New Zealand to Coincide with New EESS Safety Requirement
As detailed in Compliance Today before, the Australia C-Tick and A-Tick regulatory compliance markings will be phased out, replaced by the existing Regulatory Compliance Mark (RCM).
The RCM mark will be the only mark to indicate compliance with the Australian Communications and Media Authority’s (ACMA) regulatory arrangements for telecommunications, radio, EMC and electromagnetic energy (EME).
The new arrangement will commence July 1, 2012, in concert with the implementation of the new Electrical Equipment Safety System (EESS). Many regulatory observers believe the start date may slip to later in the year.
All new devices that are physically labeled for the first time from July 1, 2012 will need to be labeled with the RCM. The use of the C-Tick and A-Tick marks on all legacy products will be phased out by June 30, 2015. Devices that have already been labeled with the C-Tick or A-Tick mark but not sold (e.g. stock products) prior to the end of the transition period may continue to be offered for sale beyond that date.
The EESS is not a national requirement; it was created by state and territory electrical equipment safety legislation, and is not yet adopted across all of Australia and New Zealand.
The EESS marks a fundamental change to the electrical safety landscape for products sold in Australia and New Zealand. In-scope electrical equipment suppliers will be required to register their details on a national database and must make a declaration that all the equipment they sell meets relevant standards and is electrically safe. Evidence of compliance is required and is graded, based on risk.
Risk-based classifications of equipment are:
- Level 1 = low risk
- Level 2 = medium risk
- Level 3 = high risk
Level 2 and level 3 equipment are defined in AS/NZS 4417.2. All other types of in-scope electrical equipment are level 1.
In-scope is defined as all new electrical and electronic equipment that is designed or marketed as suitable for household or personal use whose voltage is greater than 50 V AC RMS or 120V ripple-free DC, and less than 1000V AC RMS or 1500V ripple-free DC.
For more information, see ACMA’s extensive FAQ on the changes (.docx).
Get educated on how to gain access to multiple markets – including Australia and New Zealand – by joining a free International EMC Homologation webinar on April 10, 2012.
2011 National Electrical Code (NEC) Updates Standard for the Safe Installation of Electrical Equipment
The National Electrical Code (NEC) – or NFPA 70 – was updated in 2011, as part of its 3-year change cycle. The NEC is published by the National Fire Protection Association (NFPA), and is commonly adopted by U.S. state or local political subdivision, and enforced by the Authority Having Jurisdiction (AHJ).
Many NEC requirements refer to “listed” or “labeled” devices, as defined in Article 100 of the NEC. The NRTL (Nationally Recognized Testing Laboratories) program accredits those organizations – like MET Labs – that, by whose labeling, the manufacturer indicates compliance with appropriate standards or performance in a specified manner.
Following are some of the key changes that were incorporated into the 2011 edition:
- 110.24 Electrical service equipment must now be marked in the field, with the maximum available fault current at the incoming terminals of the equipment and the date that the fault current calculation was made.
- 110.3(A)(1) Any special conditions that may be essential to the safe use or functioning of the equipment could be included as a part of the listing and labeling.
- 200.4 Neutral conductors shall not be shared unless they are specifically permitted to be shared, as indicated elsewhere in the code.
- 210.8 Ground-fault circuit interruption for personnel are required to be installed in a readily accessible location.
- 210.8(B)(5) GFCI receptacles are now required to be used near sinks in healthcare facilities. Exception No. 2, for receptacles located in patient bed locations of general care or critical care areas of health care facilities other than those covered under 210.8(B)(1), GFCI Protection shall not be required.
- 210.12(A) Types MC (metal clad) and, steel armor type AC (armor clad) cable may now be used between the panel and the first device, when arc-fault circuit interrupter (AFCI) protection is required for that circuit.
- 210.12(B) When modifications or extensions are made to an existing branch circuit in a residence and the code requires that the area have AFCI protective devices, the modified or extended branch circuit must now have an AFCI device installed.
- 230.44 If cable trays contain service entrance conductors (types SE (service entrance), MC, MI (mineral insulated), and IGS (integrated gas spacer)), then the trays must be labeled with the wording “Service Entrance Conductors.”
- 250.92(B) Bonding conductors are required around reducing washers and concentric or eccentric knock-outs for all service entrance conduit connections at the service entrance equipment.
- 300.4(E) Cables, conduits, boxes, and other raceways are not permitted to be installed closer than 1½” in exposed or concealed locations under metal-corrugated sheet roof decking.
- 300.5(C) Type MI and MC cables that are listed for direct burial or in concrete are permitted to be installed within the concrete, below buildings.
- 300.11(A)(1)(2) When independent electrical equipment support wires are installed within dropped-ceiling areas, they shall be distinguished by color, tagging, or other permanent effective means.
- 300.50(B) The interior of underground raceways shall be considered to be wet locations. Therefore, any connections and splices shall be approved for wet locations.
- 310.10(H)(1) Conductors smaller than 1/0 are no longer permitted to be paralleled for increased ampacity.
- 348.42 angle connectors for flexible metal conduit (FMC) are not permitted to be concealed.
- 392.18(H) Cable trays containing conductors over 600 volts are now required to be marked “Danger–High Voltage–Keep Away”.
- 406.4(D)(5) For installations in which tamper-proof receptacles are required and receptacles are being replaced, the installer is now required to install “listed” tamper-proof receptacles.
- 406.13 Tamper-resistant receptacles are now required in all guest rooms and guest suites.
- 410.16 Luminaires in clothes closets are permitted to be either surface or recessed LED, with completely enclosed light sources, fluorescent, or totally enclosed incandescent fixtures.
- 410.130(G)(1) For existing installed luminaires without disconnecting means, at the time a ballast is replaced, a disconnecting means shall be installed.
- 450.14 Transformers other than Class 2 or Class 3 are required to have line-side disconnecting means within sight of the transformer, or the disconnecting means must be lockable, and the location shall be field marked on the transformer.
- 500.2 A definition has been added to define the parameters, or make up of, combustible dusts.
- 501(B)(5) This new code paragraph clarifies the differences between Class 1, Division 1, and Division 2 installations, where metallic conduit does not provide sufficient corrosion resistance, listed flexible conductors, factory elbows and associated fittings shall be permitted, where restricted public access and only qualified persons service the equipment.
- 517.13(B) The requirement for redundant grounding conductors has been clarified and states that the insulated bonding jumper from the metallic box to the equipment grounding conductor is permitted.
- 517.16 Isolated ground receptacles are not permitted to be installed within any patient care areas.
- 517.17(B) If there is only one level of overcurrent protection between the incoming service entrance and transfer switches, the second level of ground fault protection that is normally required for healthcare facilities shall not be installed downstream of the transfer switches.
- 517.18(A) Receptacles in patient bed locations shall not be a part of a multi-wire branch circuit (i.e., have a neutral in common with another phase conductor).
- 517.160(A)(5) Conductors for an isolated power system shall be identified by a continuous, distinctive colored stripe other than white, green, or gray along their entire length.
- 547.5(G) For engineers designing barns, the code no longer permits deleting GFCI protection on an outlet for a piece of dedicated equipment when that piece of equipment is within 3’ of another GFCI outlet.
- 620.53 Exception: Disconnects are required for elevator cab lights and ventilation, but if the ventilation motor is less than 2 HP or less an 300 volts, a general-use snap switch may be used as this disconnecting means.
- 645.17 The requirements for power distribution unit (PDU) panelboards used for information technology equipment, shall be permitted to have multiple panelboards within a single cabinet, if the power distribution unit is utilization equipment and is listed for information technology application.
- 690 Due to the wide popularity of photovoltaic (PV) systems, broad changes have been made in this section.
- 694 A new article to address wind-powered electric generating systems.
- 695 The code for electrically driven fire pumps has been modified to closely correlate to the requirements of NFPA 20.
- 700.10(D)(1) Feeder circuit cables for emergency systems must now be rated for a minimum 2 hours fire rating.
- 700.27 Exception: Selective coordination is no longer required for overcurrent devices that are installed in series if no loads are connected in parallel with the downstream device.
- 701.6(D) There is now a requirement for ground fault indication for legally required standby systems of 150 volts to ground and circuit protective devices rated 1000 amperes, which is similar to that previously required only for emergency systems.
This list was modified from a more detailed list featured in Consulting-Specifying Engineer.
For Canada, the Canadian Electrical Code was updated for 2012.
There was much discussion about the E3 Program (Energy Efficiency, Energy Performance & Energy Consumption), covered in Compliance Today previously.
The U.S. initially opposed the E3 Program because there is a lack of harmonization. As it stands, there is no assured reciprocity and there is no certificate issued, just a Statement of Test Results (STR). It is up to the reader of the STR to decide to accept or not.
UL and CSA have recently published harmonized versions of IEC 62368-1. It will, however, likely be a long time before this becomes a NRTL standard due to OSHA’s workload and their likely objection to its inclusion of hazard-based analysis. Major labs will list to it, but if a product is going into the workplace, then 60950 or 60065 must still be used.
Only the U.S., Sweden and Denmark have adopted 62368-1 in the Scheme per the CB website. Canada is to participate soon, as is France. The Netherlands may participate soon.
More about IEC 62368-1 is found in this Compliance Today post.
China is not currently accepting EMC within the Scheme. China’s objection may be that this was once voluntary and that the Scheme adopted EMC as mandatory and have not given China time to revise its standards.
At least one manufacturer thinks there is a need for motors to be in the safety CB Scheme. The only place a motor standard is covered is within the EMC Scheme. NEMA’s 1MG Section is continuing its conversation regarding the inclusion of electric motors as part of the E3 Program.
Next meetings are May 22-23, 2012 in Vancouver, Canada, and August 7-8, 2012 in Orange County, California.
Yesterday was the last full day of the 2012 ICPHSO Annual Meeting and Training Symposium.
- CPSC is being proactive at ports. In 2010 & 2011, 6.5M units of over 2,000 products were seized.
- Independent 3rd party testing is set up and running well.
- A strong CPSC is good for business – it provides a more level playing field.
- Standards development, recalls process, and federal rulemaking will be priorities in 2012.
- Successful Saferproducts.gov public database will have one year anniversary on March 11. It has had 6,300 unsafe product reports.
Penalties and Enforcement
Also featured was a panel on Penalties and Enforcement, featuring Cheryl Falvey, U.S. CPSC General Counsel. Some of the points made there:
In August 2009, the maximum penalty went from $1.8M to $15M.
If the duty to report occurred in 2008 but was not reported until 2010, the violation occurred in the higher penalty period.
A failure to report and the deliberate subsequent sale of recalled product doubles the maximum penalty to $30M.
There has been less self-reporting and more anticipated litigation since the penalty increase.
There is no formula to calculating a penalty. Statutory factors include:
- Extent and gravity of the violation
Other factors include:
- Safety/compliance program
- History of noncompliance
- Economic gain for noncompliance
- Failure to respond timely to staff requests
Every settlement is subject to approval by CPSC commissioners. Then it is listed in the Federal Register for public comment.
The CPSC is looking for a case that makes a statement. “This has a deterrent effect,” says Falvey.
Individuals are now being pursued for felony criminal penalties. This often happens with Subchapter S corporations, where the individual is virtually the same as the corporation.
The CPSC can be creative. E&B Giftware was given a $550,000 civil penalty, with all but $50,000 suspended if they met requirements of the settlement.
The whistleblower provision in the Consumer Product Safety Improvement Act (CPSIA) of 2008 has only been used once. Calls are more likely to be a trade complaint from a competitor.
The 2012 International Consumer Product Health and Safety Organization (ICPHSO) Annual Meeting and Training Symposium in Orlando moved into Workshop Day yesterday.
Some of the topics that were addressed:
- Global regulatory outlook
- Comparing Canadian and U.S. Consumer Product Safety Law
- EU Directives related to toys
- Effective recalls
- Risk management
- Global product safety strategies
- Hazardous substance regulations
The most interesting workshop looked at what product safety agencies will be focused on in 2012.
The U.S. market was covered by Kenneth Hinson, Executive Director of the U.S. Consumer Product Safety Commission. Following are staff-proposed 2012 priorities, although he emphasized that they have not yet been approved by the Commission.
Import surveillance. Expand Risk Assessment Methodology (RAM) pilot.
Global outreach to regulated community. Build capacity of regulators in producer nations. Lead standards harmonization efforts. Continue operations of Beijing office.
Market surveillance and enforcement.
IT modernization to bridge silos. CPSRMS (Consumer Product Safety Risk Management System) and ITDS RAM.
Key mandatory standards activities. Table saws, portable generators, durable nursery products, etc.
Connecting with consumers. NSN and CPCS 2.0 Social Media Initiative.
Work on potential testing and certification revisions. Opportunity to reduce 3rd party testing burden (P.L. 112-28). Small batch manufacturing exemption. ATV final rule.
A side note. The next ICPHSO meeting will be in Brussels, Belgium October 16-17, 2012. In 2013, there will be meetings in Arlington, Virginia and on the Gold Coast of Australia. Spain will host a 2014 meeting, followed by plans to return to Japan and China. ICPHSO organizers were encouraged by a successful Asia-Pacific Consumer Product Safety Symposium in Seoul, Korea in 2011.