Technical Committee on Electrical Equipment Evaluation ROC Meeting Agenda September 28-29, 2010 Providence, RI Item 10-09-1 Call to Order Item 10-09-2 Introductions Item 10-09-3 Staff Remarks Item 10-09-4 Approval of January 22, 2010 ROP Meeting Minutes Item 10-09-5 Review of Task Group Assignments and Work Item 10-09-6 Processing of Public and Committee Comments Item 10-09-7 Old Business Item 10-09-8 New Business Item 10-09-9 Adjourn
Report on Comments June 2011 NFPA 790 790-1 Log #1 EEE-AAA Technical Correlating Committee on National Electrical Code, 790-1 The Technical Correlating Committee advises that Chapter Scope statements are the responsibility of the Technical Correlating Committee and the Technical Correlating Committee Accepts the actions of the Technical Committee. In addition, the Technical Correlating Committee directs that the Technical Committee consider the following actions within this proposal: 1) Review the entire document and revise it to comply with 1.8.1 of the NFPA Style Manual which states that subdivisions shall contain at least two subdivisions. 2) In section 1.2, consider dividing the section into a purpose section and an application section to correlate with the NFPA 791 document. 3) Revise section 3.1, General, to include subsections 3.1.1 and 3.1.2 in accordance with the NFPA Style Manual, section 2.3.1.3.1. 4) In 3.3.1, the Technical Correlating Committee requests that the Technical Committee consider using the 2011 NEC definition of "Equipment. This is a direction from the Technical Correlating Committee on National Electrical Code in accordance with 3.4.2 and 3.4.3 of the Regulations Governing Committee Projects. 1
Report on Comments June 2011 NFPA 790 790-2 Log #11 Chuck Mello, Underwriters Laboratories 790-1 Revise the text from the ROP draft to read as follows. The This provisions of this standard shall address those requirements for the qualifications and competency of a body performing field evaluations on electrical products and assemblies with electrical components. These requirements shall be are based on ISO/IEC Guide 65 and ISO/IEC 17020 with adaptation for the unique characteristics of field evaluations. A field evaluation body (FEB) meeting the requirements of this standard shall be considered competent to perform field evaluations. These requirements shall apply to both the initial and continued competency of FEBs. The revised text provides better clarity to the user on the scope. The removal of the word those and changing the term qualifications to singular is to add clarity that this standard is the basis for qualification of third party testing bodies as a FEB. Section 1.1.1.2 was revised to return this text to a statement of fact as opposed to establishing a requirement as permitted in the NFPA Manual of Style section 2.3.1.5. This document is establishing the basis for the requirement and only used the ISO/IEC documents as a foundation. In the future there may be other standards that may be applied and this permits that expansion without limiting the technical committee to just these two documents. 2
Report on Comments June 2011 NFPA 790 790-3 Log #12 Chuck Mello, Underwriters Laboratories 790-3 Revise the text from the ROP Draft to read as follows: This standard shall provide the requirements for the competency of a FEB and for the recognition of an FEB by an authority having jurisdiction or other recognition body. in the application of evaluating the conformance of electrical equipment to the companion document. The revised text addresses the comments made during the balloting during the ROP process. In addition these revisions along with a companion comment to add a section 1.3 for application address the TCC comment number 2 to Proposal 790-1. 3
Report on Comments June 2011 NFPA 790 790-4 Log #22 Kenneth J. Rempe, Siemens Industry Inc. 790-1 Revise text to read as follows: This standard shall provide the requirements for the recognition of an FEB by an Authority Having Jurisdiction in the application of evaluating the conformance of electrical equipment to the companion document, NFPA 791, which will promote safety to life and property. The purpose of this document shall provide the requirements for applicants or third parties in applying for the services of an FEB, and any subsequent appeals, complaints and disputes on the evaluation report. The TCC recommended consideration of correlating the Purpose and Application of this document with the NFPA 791 document. In 1.2.1 it is not clear if the author of [790-3] intended for the underlined text to be deleted from the original document, since it was not deleted. It has been added back for consideration by the Technical Committee. 1.2.2 has been added to the Purpose, since applicants and users of the Services of an FEB also have requirements and remedies afforded by this standard. Reference companion proposal for 1.3. 4
Report on Comments June 2011 NFPA 790 790-5 Log #26 Wendell Whistler, Intertek Testing Service 790-3 This standard shall provide the requirements for the recognition of a Field Evaluation Body by an Authority Having Jurisdiction in the application of evaluating the conformance of electrical equipment to the companion document This words appear to only allow use of this document by the Authority Having Jurisdiction 5
Report on Comments June 2011 NFPA 790 790-6 Log #23 Kenneth J. Rempe, Siemens Industry Inc. 790-1 Add text to read as follows: An organization or part of an organization that desires to be recognized as an FEB is subject to a standardized application and review by an Authority Having Jurisdiction. The requirements of this Standard will provide a more consistent application process to an Authority Having Jurisdiction, and improve the evaluation and recognition of FEB s that are competent to conduct Field Evaluations. Applicants who require Certification, Listing, or Evaluation of equipment, or systems before energizing will have an approved method to document the compliance to safety standards and final approval by the Authority Having Jurisdiction. The TCC recommended consideration of correlating the Purpose and Application of this document with the NFPA 791 document. The added text provides the intent to apply this Standard to Field Evaluation Bodies applications, review by Authorities Having Jurisdiction, and Applicants for services by the FEB. This provides a level of correlation to NFPA 791 as recommended by the TCC comment. Reference companion proposal for 1.2. 6
Report on Comments June 2011 NFPA 790 790-7 Log #13 Chuck Mello, Underwriters Laboratories 790-1 Add the following text from the ROP Draft section 1.2 as new section 1.3. This standard shall be used by FEB s as the basis to seek recognition by an authority having jurisdiction or other recognition body in the application of evaluating the conformance of electrical equipment to the companion document. The text removed from section 1.2 of the ROP Draft was revised to provide complete sentences and for clarity. The revision resolves the TCC comment number 2 on Proposal 790-1. 7
Report on Comments June 2011 NFPA 790 790-8 Log #4 Chuck Mello, Vacouver, WA 790-1 Revise text to read as follows: National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169-7471. NFPA 791,, 2012 edition. Reserved The NFPA Manual of Style paragraph 2.3.10.3 prohibits recommended practices from being referenced in a standard; therefore, NFPA 791 cannot be referenced in the body of the document as it is a recommended practice. This effectively deletes Section 2.2 since there are no NFPA documents now referenced in the main body of the document. The reference is deleted and the term reserved put in place in accordance with the NFPA Manual of Style paragraph 2.4.1.4.2. The reference to NFPA 791 was moved to the Annex as A11.1.4 and Annex D.1.1 already has the necessary informational reference for NFPA 791 as provided in the ROP Draft. The changes to Clause 11.1.4 to delete the reference to NFPA 791 and create the Annex statement are in a companion comment. This comment was the result of the work of a Technical Committee task group to address several items arising from the editorial review. The TG consisted of Tim McClintock, Ron Chilton and Chuck Mello and this comment was unanimously agreed to by the Task Group. 8
Report on Comments June 2011 NFPA 790 790-9 Log #24 Kenneth J. Rempe, Siemens Industry Inc. 790-1 Revise definition to read as follows: Any device, appliance, or machine that generates, conducts, or utilizes electrical energy. A general term, including material, fittings, devices, appliances, luminaires, apparatus, machinery, and the like used as a part of, or in connection with, an electrical installation. [ 2011] The TCC recommended consideration of this Definition from the 2011 NEC. The term Electrical is an adjective intended to describe or modify a specific kind of equipment. The terms equipment and electrical equipment are used many times in the NEC and NFPA 79, with only the definition as modified above in both documents. It seems appropriate to change this definition to Equipment as requested by the TCC. 9
Report on Comments June 2011 NFPA 790 790-10 Log #14 Chuck Mello, Underwriters Laboratories 790-1 Add the definition of Equipment to read as follows: A general term, including fittings, devices, appliances, luminaires, apparatus, machinery, and the like used as a part of, or in connection with, an electrical installation. The definitions following this would be renumbered accordingly. This comment does not alter the existing definition for electrical equipment as published in the ROP Draft. The addition of this definition in NFPA 790 will make it consistent with the companion document NFPA 791 that has a definition of electrical equipment developed by the Technical Committee and the standard definition equipment taken from the NEC. NFPA 790 uses both the term equipment individually and the phrase electrical equipment several times throughout the document. The definition of equipment provided in this comment is the definition from the 2008 NEC with the accepted change that will appear in the 2011 NEC. The change in the NEC is the deletion of the term material which is vague and generally speaking field evaluations cannot be completed on materials. The use of this definition aligns this document with the NEC. Acceptance of this comment may require moving to section 3.2 and renumbering all succeeding definitions. 10
Report on Comments June 2011 NFPA 790 790-11 Log #5 Chuck Mello, Vacouver, WA 790-6 Revise to read as follows: Equipment or materials to which has been attached a label, symbol, or other identifying mark of a FEB. Application of the label the the FEB indicates indicating the equipment or materials were evaluated and found to comply with requirements as described in an accompanying field evaluation report. The revised text corrects a typographical error with the term the used twice in a row. The revisions also put this definition into one single sentence statement which provides more clarity in the use of the term Field Labeled. This comment was the result of the work of a Technical Committee task group to address several items arising from the editorial review. The TG consisted of Tim McClintock, Ron Chilton and Chuck Mello and this comment was unanimously agreed to by the Task Group. 11
Report on Comments June 2011 NFPA 790 790-12 Log #3 EEE-AAA Technical Correlating Committee on National Electrical Code, 790-7 The Technical Correlating Committee directs that the committee reconsider this definition with respect to the use of the term "adequate", and also reconsider the list of organizations included in the definition. This is a direction from the Technical Correlating Committee on National Electrical Code in accordance with 3.4.2 and 3.4.3 of the Regulations Governing Committee Projects. 12
Report on Comments June 2011 NFPA 790 790-13 Log #25 Kenneth J. Rempe, Siemens Industry Inc. 790-7 Revise definition to read as follows: A document that specifies the safety requirements for specific equipment or class of equipment and is recognized by a regulatory authority in the United States or Canada, as applicable, as a safety standard providing an adequate designated level of safety; compatible with and maintained current with periodic revisions of applicable national codes and installation standards; and developed by a standards developing organization under a method providing for input and consideration of views of industry groups, experts, users, consumers, governmental authorities, and others having broad experience in the safety field involved; or currently designated as an American National Standards Institute (ANSI) safety-designated product standard or an ASTM International test standard used for evaluation of products or materials. The TCC directed the Technical Committee review the use of the term adequate in this definition. Replacing adequate with designated indicates that Standards provide prescriptive evaluation and test methods in order to comply with a specified purpose. 13
Report on Comments June 2011 NFPA 790 790-14 Log #27 Wendell Whistler, Intertek Testing Service 790-7 A document which specifies the safety requirements for specific equipment or class of equipment and is: Rrecognized by a regulatory authority in the United States or Canada, as applicable, as a safety standard providing an adequate level of safety, and Ccompatible with and maintained current with periodic revisions of applicable national codes and installation standards, and Ddeveloped by a standards developing organization under a method providing for input and consideration of views of industry groups, experts, users, consumers, governmental authorities, and others having broad experience in the safety field involved, or Ccurrently designated as an American National Standards Institute (ANSI) safety-designated product standard or an American Society for Testing and Materials (ASTM) test standard used for evaluation of products or materials. The term adequate is not easily defined and leaves a lot to interpretation and corrected the capitalized word in document 14
Report on Comments June 2011 NFPA 790 790-15 Log #6 Chuck Mello, Vacouver, WA 790-1 Revise to read as follows: Access shall not be conditional upon the size financial status of the applicant or membership of any association or group, nor shall the decision to issue a FEB Statement of Conformity be conditional upon the number of such certificates already issued. The revised text is to clarify what is meant by size. The intent is that service is to be provided equally and without regard to the applicant for a Field Evaluation being a large or small company. The term size is too vague and could be interpreted to mean attributes other than financial net worth as intended. This comment was the result of the work of a Technical Committee task group to address several items arising from the editorial review. The TG consisted of Tim McClintock, Ron Chilton and Chuck Mello and this comment was unanimously agreed to by the Task Group. 15
Report on Comments June 2011 NFPA 790 790-16 Log #2 EEE-AAA Technical Correlating Committee on National Electrical Code, 790-14 It was the action of the Technical Correlating Committee that further consideration be given to the negative comment expressed in the voting. This is a direction from the Technical Correlating Committee on National Electrical Code in accordance with 3.4.2 and 3.4.3 of the Regulations Governing Committee Projects. 16
Report on Comments June 2011 NFPA 790 790-17 Log #15 Chuck Mello, Underwriters Laboratories 790-14 Continue to accept the proposal as written and published in the ROP Draft. With respect to the negative ballot item, the intent is for the FEB to be a legal business entity registered with a government organization such as a proprietorship, partnership, corporation or similar entity. For example a corporation with Articles of Incorporation in the State of Delaware. Corporations are only established in one location but the corporation is recognized outside the area where an FEB actually establishes an office or place of business to conduct operations. When establishing the business location, they would have to comply with the local State, Provincial, County, and/or City regulations for business licenses or tax requirement. The text removed could be construed that as part of recognition, the FEB would have to prove they were registered as a business in every locality that they provide service in without regard to if they have in fact established a business location or office in that locality. 17
Report on Comments June 2011 NFPA 790 790-18 Log #16 Chuck Mello, Underwriters Laboratories 790-1 Revise the text in 5.2.1(8) from the ROP Draft to read as follows: (8) Have a quality management system giving confidence in its ability to perform Field Evaluations This section establishes a requirement for a quality management system which is further defined and described in Section 5.5. In section 5.5, all the references are to a more generic management system and the term quality is not used there. There are other aspects to having a management system beyond quality and it would add clarity and consistency to this document by using only the term management system in Section 5.2 and 5.5. 18
Report on Comments June 2011 NFPA 790 790-19 Log #29 Wendell Whistler, Intertek Testing Service 790-20 (2) Give advice or provide consultancy services for methods of dealing with matters which are barriers to the Field Evaluation requested except to identify and discuss with the Authority Having Jurisdiction the specific areas of the applicable product standard where a non conformance is identified As written it would preclude any discussion by the FEB with the Authority Having Jurisdiction 19
Report on Comments June 2011 NFPA 790 790-20 Log #17 Chuck Mello, Underwriters Laboratories 790-1 Delete section 5.4.1 and renumber succeeding sections as needed. Where a FEB sub-contracts any part of the Field Evaluation, the work shall be placed with a subcontractor complying with the requirements in this document. The reference to this document is confusing since the entire document cannot be applied to a subcontractor. For example the appeals, complaints and disputes requirements in Section 7 would not apply to subcontractors since the FEB must perform activities in this area. Also, citation of this document permits a subcontractor to pass work on to another subcontractor, and then on to another subcontractor, etc. This does not seem to be the intention of this document. In the absence of specifying what requirements in the document apply, this clause should be deleted as it does not add anything to the requirements for being recognized as a FEB. 20
Report on Comments June 2011 NFPA 790 790-21 Log #18 Chuck Mello, Underwriters Laboratories 790-1 Revise the text of section 5.4.6 from the ROP Draft to read as follows: The FEB shall record and retain details of its investigation of the competence and compliance of its subcontractors and maintain a register of all subcontractors. The document already specifies the characteristics of subcontractors that the FEB must investigate. Repeating those words here is only confusing. Also, the wording suggests that competence and compliance with subcontractor requirements are two separate things but 5.4.3 directly contradicts that. 21
Report on Comments June 2011 NFPA 790 790-22 Log #19 Chuck Mello, Underwriters Laboratories 790-29 Revise the text of section 6.2.1 from the ROP Draft to read as follows: In order to ensure field evaluation activities are carried out effectively and uniformly, the minimum relevant criteria for the competence of personnel involved in field evaluation activities shall be defined by the FEB. The revised text is to clarify and to distinguish from the more general requirement in 6.1.1. As stated someone could interpret that competence requirements must be established and documented for the legal staff, the admin staff, the accounting staff etc. of the FEB when none of these individuals conduct a field evaluation nor need to have competence into the technical aspects of how to conduct a field evaluation. 22
Report on Comments June 2011 NFPA 790 790-23 Log #28 Wendell Whistler, Intertek Testing Service 790-33a *A10.2 In specific situations where accessibility to a premisis is limited the AHJ may grant written authority to the FEB to apply a field label to the equipment at other than the final installation site such as the manufacturer s facility or other intermediate site Where access is limited due to security related issues or a remote location this is necessary 23
Report on Comments June 2011 NFPA 790 790-24 Log #20 Chuck Mello, Underwriters Laboratories 790-1 Revise Section 11.1 from the ROP Draft to read as follows: The FEB shall adopt reporting procedures that suit its needs, the needs of the applicant, and the needs of any other affected parties.. Personnel contributing to and responsible for the evaluation of conformance of a product shall provide the FEB with a report of findings as to the conformity with all the applicable requirements of the standard(s). The full report on the outcome of the evaluation shall be brought to the applicant s notice by the FEB, identifying any nonconformity that has to be corrected in order to comply with the applicable requirements of the standard(s).. The report shall further state what additional activities are required to complete the evaluation.. The format and content as defined in NFPA 791, shall be used. Field evaluation reports, as well as all information needed to understand and interpret them, shall be reported correctly, accurately, and clearly.. A process of checking completed reports shall be established to confirm that this requirement has been met. Renumber the Annex section 11.1.5 to 11.6. The revisions are to bring the text into the correct style of the NFPA Manual of Style Section 1.8.1 that requires when there is one division in a chapter or section, there must be a second division. This action will require the renumbering of Annex item 11.1.5 from the ROP Draft to 11.6. 24
Report on Comments June 2011 NFPA 790 790-25 Log #7 Chuck Mello, Vacouver, WA 790-1 Revise to read as follows: The format and content as defined in NFPA 791, shall be used of the field evaluation technical report shall follow accepted industry guidelines. Add new appendix A11.1.4 as follows: A.11.1.4 The report format and content as found in NFPA 791,, should be used for all field evaluation technical reports. The NFPA Manual of Style paragraph 2.3.10.3 prohibits recommended practices from being referenced in a standard; therefore, NFPA 791 cannot be referenced in the body of the document as it is a recommended practice. This will also effectively delete Section 2.2. Clause 11.1.4 was rewritten to establish the requirement and the reference to NFPA 791 moved to the Annex as A11.1.4. The change to section 2.2 is covered in a companion comment. Annex D.1.1 already has the necessary informational reference for NFPA 791 as provided in the ROP Draft. This comment was the result of the work of a Technical Committee task group to address several items arising from the editorial review. The TG consisted of Tim McClintock, Ron Chilton and Chuck Mello and this comment was unanimously agreed to by the Task Group. 25
Report on Comments June 2011 NFPA 790 790-26 Log #21 Chuck Mello, Underwriters Laboratories 790-36 Revise the text of section 12.2 of the ROP Draft to read as follows: The decision to issue a statement of conformity shall be made by the FEB employee responsible for the completion of the inspection, testing, and evaluation process. The activities of testing and inspection have not been broken out as separate from evaluation heretofore in the document. Doing so here at the end is confusing especially since it seems obvious that testing and inspection are sub-activities within the more general evaluation process. 26
Report on Comments June 2011 NFPA 790 790-27 Log #8 Chuck Mello, Vacouver, WA 790-1 Revise to read as follows: The FEB shall not delegate authority for issuing or withdrawing a statement of conformity to an outside person or body, except as specified under the subcontracting procedures above in Section 5.4. Using the term above is too vague. References within the document should be to specific applicable sections. The revised text provides the direct section reference for this paragraph. This comment was the result of the work of a Technical Committee task group to address several items arising from the editorial review. The TG consisted of Tim McClintock, Ron Chilton and Chuck Mello and this comment was unanimously agreed to by the Task Group. 27
Report on Comments June 2011 NFPA 790 790-28 Log #9 Chuck Mello, Vacouver, WA 790-1 Revise to read as follows: The FEB shall exercise proper control over the ownership, use and display of FEB Statements of Conformity. The title was not consistent with the text. In the title Statement of Conformity was singular but in the text the term Statements of Conformity was used. The text revision makes the title consistent with the text. The plural use is correct as a FEB will be issuing more than one Statement of Conformity and this clause is applicable to all of them. This comment was the result of the work of a Technical Committee task group to address several items arising from the editorial review. The TG consisted of Tim McClintock, Ron Chilton and Chuck Mello and this comment was unanimously agreed to by the Task Group. 28
Report on Comments June 2011 NFPA 791 791-1 Log #1 EEE-AAA Technical Correlating Committee on National Electrical Code, 791-1 The Technical Correlating Committee advises that Chapter Scope statements are the responsibility of the Technical Correlating Committee and the Technical Correlating Committee Accepts the 791 Technical Committee actions. In addition, the Technical Correlating Committee directs that the Technical Committee consider the following actions within this proposal: 1) Review the entire document and revise it to comply with 1.8.1 of the NFPA Manual of Style which states that subdivisions shall contain at least two subdivisions (example, 1.1.1 should be followed by 1.1.2). 2) Revise section 2.1, General, to comply with 2.4.1.4.1 of the NFPA Style Manual to remove mandatory requirements. 3) Revise section 3.1, General, to include subsections 3.1.1 and 3.1.2 in accordance with the NFPA Style Manual, section 2.4.1.5.1. 4) In 3.3.5, the Technical Correlating Committee requests that the Technical Committee consider using the 2011 NEC definition of "Equipment. This is a direction from the Technical Correlating Committee on National Electrical Code in accordance with 3.4.2 and 3.4.3 of the Regulations Governing Committee Projects. 1
Report on Comments June 2011 NFPA 791 791-2 Log #15 EEE-AAA Chuck Mello, Vacouver, WA 791-6 Add relocated text from 1.3.1 as new section 1.2.3 to read as follows: 1.2.3 The purpose of the evaluation is to assist regulating authorities who make product and related installation approval decisions. The last sentence in 1.3.1 of the NPFA 791 ROP Draft does not fit the style or set a recommendation for application of the document. Since it states a purpose this sentence fits into Section 1.2 as one of the purposes for the document. The deletion of the text for 1.3.1 is completed in a companion comment. This comment was the result of the work of a Technical Committee task group to address several items arising from the editorial review. The TG consisted of Tim McClintock, Ron Chilton and Chuck Mello and this comment was unanimously agreed to by the Task Group. 2
Report on Comments June 2011 NFPA 791 791-3 Log #21 Chuck Mello, Vacouver, WA 791-6 Add relocated text from 1.3.1 as new section 1.2.3 to read as follows: 1.2.3 The purpose of the evaluation is to assist regulating authorities who make product and related installation approval decisions. The last sentence in 1.3.1 of the NPFA 791 ROP Draft does not fit the style or set a recommendation for application of the document. Since it states a purpose this sentence fits into Section 1.2 as one of the purposes for the document. The deletion of the text for 1.3.1 is completed in a companion comment. This comment was the result of the work of a Technical Committee task group to address several items arising from the editorial review. The TG consisted of Tim McClintock, Ron Chilton and Chuck Mello and this comment was unanimously agreed to by the Task Group. 3
Report on Comments June 2011 NFPA 791 791-4 Log #4 Chuck Mello, Vacouver, WA 791-6 Delete the last sentence of 1.3.1 in the ROP Draft and relocate to a new section 1.2.3 so Section 1.3.1 reads as follows: New or used electrical equipment not listed or labeled as a complete unit or assembly is considered to be unevaluated by a third party and will be subject to an evaluation as required by the AHJ. The purpose of the evaluation is to assist regulating authorities who make product and related installation approval decisions. The last sentence in 1.3.1 of the NPFA 791 ROP Draft does not fit the style or set a recommendation for application of the document. Since it states a purpose this sentence fits into Section 1.2 as one of the purpose statements for the document. The addition of the text as new section 1.2.3 is completed in a companion comment. This comment was the result of the work of a Technical Committee task group to address several items arising from the editorial review. The TG consisted of Tim McClintock, Ron Chilton and Chuck Mello and this comment was unanimously agreed to by the Task Group. 4
Report on Comments June 2011 NFPA 791 791-5 Log #3 Nancy W. Gunderson, Square D Company/Schneider Electric 791-9 Revise text to read as follows: 3.3 [new] Clearance Distance. Shortest distance through air between two conductive parts. 3.3.1 Creepage Distance. Shortest distance along the surface of the insulating material between two conductive parts. Action on Proposal 791-9a removed the definition for creepage distance when section 4.2 was deleted in response to Proposal 791-11, and there was no longer a reference to the term. Accompanying comment requests to add creepage and clearance requirements into Construction Inspection which was section 6, and thus a definition, would be appropriate. Additionally, definition for clearance distance should be added to assist in distinguishing the terms. 5
Report on Comments June 2011 NFPA 791 791-6 Log #22 Kenneth J. Rempe, Siemens Industry Inc. 791-1 Delete the following definition: Any device, appliance, or machine that generates, conducts, or utilizes electrical energy. The TCC recommended consideration of this Definition from the 2011 NEC. The term Electrical is an adjective intended to describe or modify a specific kind of equipment. Delete the Definition of 3.3.3 and renumber remaining definitions. Definition in 3.3.5 Equipment is the Definition of Equipment in the 2011 NEC, and is the same as proposed for NFPA 790 (paragraph 3.3.1). The terms equipment and electrical equipment are used many times in the NEC and NFPA 79, with only the definition in 3.3.5 in both documents. 6
Report on Comments June 2011 NFPA 791 791-7 Log #16 Chuck Mello, Underwriters Laboratories 791-1 Replace the definition of Electrical Equipment from the ROP Draft to read as follows: A general term, including fittings, devices, appliances, luminaires, apparatus, machinery, and the like used as a part of, or in connection with, an electrical installation. This is the definition from the 2008 NEC with the accepted change that will appear in the 2011 NEC. The change in the NEC is the deletion of the term material which is vague and generally speaking field evaluations cannot be completed on materials. The use of this definition aligns this document with the NEC. Acceptance of this comment may require moving to Section 3.2 and renumbering all succeeding definitions. 7
Report on Comments June 2011 NFPA 791 791-8 Log #17 Chuck Mello, Underwriters Laboratories 791-1 Revise Section 3.3.8 from the ROP Draft to read as follows: An identifier used A recognition issued by the United States Occupational Safety and Health Administration (Fed OSHA) of laboratories that perform testing per nationally recognized standards and certify products as stipulated in the. Federal OSHA does not use the term identifier when referring to Nationally Recognized Testing Laboratories. OSHA recognizes NRTLs with as suitable to provide testing and certification services to specified standards. The term identifier has a different application within OSHA and if OSHA were to use or adopt this document, this term could create confusion as to how it is intended to be applied in this document. 8
Report on Comments June 2011 NFPA 791 791-9 Log #18 Chuck Mello, Underwriters Laboratories 791-1 Revise the text of Section 4.1.1 in the ROP Draft to read as follows: The following information should be provided for all inspections evaluations: Items 1 to 4 in the list below this section are not intended to be changed by action on this comment. The revised text is to be consistent with the use of the general term evaluation in both NFPA 790 and NFPA 791. 9
Report on Comments June 2011 NFPA 791 791-10 Log #9 Chuck Mello, Vacouver, WA 791-1 Revise to read as follows: Evaluating used equipment involves should include additional considerations and preparation. Normal wear, intentional modification, and abnormal events that can cause mechanical and electrical changes that affect conformity should be considered. The ROP Draft text does not comply with the NFPA Manual of Style Sections 2.4.1.1 and 2.4.1.2 because there are no recommendations stated. As published there are only explanatory materials which can only be in an Annex. The revised text provides the language necessary to provide this information as recommendations. This comment was the result of the work of a Technical Committee task group to address several items arising from the editorial review. The TG consisted of Tim McClintock, Ron Chilton and Chuck Mello and this comment was unanimously agreed to by the Task Group. 10
Report on Comments June 2011 NFPA 791 791-11 Log #5 Chuck Mello, Vacouver, WA 791-19 Revise to read as follows: (1) Damaged Components. Inspection of Mmechanical components, such as enclosures, conduit, and fittings, and electrical devices should be completed to identify any that are visibly damaged or deformed which often render a product noncompliant andor require replacement. Those items known to be damaged should be reviewed with the evaluating body in advance when possible. The ROP Draft text does not comply with the NFPA Manual of Style Sections 2.4.1.1 and 2.4.1.2 because only the last sentence has a recommendation stated. As published the first sentence only provide explanatory material which can only be in an Annex. The revised text provides the language necessary to provide this information as a recommendation. This comment was the result of the work of a Technical Committee task group to address several items arising from the editorial review. The TG consisted of Tim McClintock, Ron Chilton and Chuck Mello and this comment was unanimously agreed to by the Task Group. 11
Report on Comments June 2011 NFPA 791 791-12 Log #6 Chuck Mello, Vacouver, WA 791-19 Revise to read as follows: (2) Equipment Not Suitable for Use. An assessment of Tthe environment surrounding equipment should be completed to observe often changes that have occurred over time. Changes to building construction, moving the equipment, and installing other equipment close by should be reviewed for any by can affect on compliance in the changed environment. Enclosure ratings, devices that penetrate enclosures, and the environment surrounding the equipment should be reviewed in advance when possible. The ROP Draft text does not comply with the NFPA Manual of Style Sections 2.4.1.1 and 2.4.1.2 because only the last sentence has a recommendation stated. As published the first two sentences only provide explanatory material which can only be in an Annex. The revised text provides the language necessary to provide this information as recommendations. This comment was the result of the work of a Technical Committee task group to address several items arising from the editorial review. The TG consisted of Tim McClintock, Ron Chilton and Chuck Mello and this comment was unanimously agreed to by the Task Group. 12
Report on Comments June 2011 NFPA 791 791-13 Log #7 Chuck Mello, Vacouver, WA 791-19 Revise to read as follows: (3) Absence of Drawings. Availability of technical drawing or schematics should be ensured in advance when possible. A lack of technical drawings or schematics may increase the complexity or greatly hinder an evaluation until and accurate drawings should be produced. The ROP Draft text does not comply with the NFPA Manual of Style Sections 2.4.1.1 and 2.4.1.2 because the one sentence did not have a recommendation stated. The revised text provides the language necessary to provide this information as recommendations. This comment was the result of the work of a Technical Committee task group to address several items arising from the editorial review. The TG consisted of Tim McClintock, Ron Chilton and Chuck Mello and this comment was unanimously agreed to by the Task Group. 13
Report on Comments June 2011 NFPA 791 791-14 Log #8 Chuck Mello, Vacouver, WA 791-19 Revise to read as follows: (4)* Absence of Manufacturer or Technical Support. Access to the original equipment manufacturers technical information or technical support should be ensured in advance where possible. Add new annex item as follows: A.4.2.2(4) Access to the original equipment manufacturer data simplifies the evaluation process. At times the manufacturer can supply information needed to determine conformance, which is not necessarily commonly known to others. Without the original manufacturer s support, extra time and testing could be necessary to complete an evaluation. The ROP Draft text does not comply with the NFPA Manual of Style Sections 2.4.1.1 and 2.4.1.2 because the text did not have a recommendation stated. The revised text provides the language necessary to provide this information as recommendations. The original text was relocated to a new Annex items as A.4.2.2(4) so that information is captured for use. This comment was the result of the work of a Technical Committee task group to address several items arising from the editorial review. The TG consisted of Tim McClintock, Ron Chilton and Chuck Mello and this comment was unanimously agreed to by the Task Group. 14
Report on Comments June 2011 NFPA 791 791-15 Log #10 Chuck Mello, Vacouver, WA 791-1 Revise to read as follows: The primary standard to be used should be a nationally recognized product safety standard written and maintained by a standards development organization that issues product safety standards such as Underwriters Laboratories, Factory Mutual Research Corporation, and Institute of Electrical and Electronic Engineers. These standards are generally adopted by the American National Standards Institute. Supplementary standards can include ones from manufacturing organizations such as the National Electrical Manufacturers Association or general safety bodies such as the National Fire Protection Association. Add new annex item as follows: A.4.3.2 These primary standards are generally adopted by the American National Standards Institute. Supplementary standards can include ones from manufacturing organizations such as the National Electrical Manufacturers Association or general safety bodies such as the National Fire Protection Association. The ROP Draft text does not comply with the NFPA Manual of Style Sections 2.4.1.1 and 2.4.1.2 because the second and third sentences in the text did not have a recommendation stated. The explanatory text was relocated to a new Annex item as A4.3.2 with an editorial change for clarity so that information is captured for use. This comment was the result of the work of a Technical Committee task group to address several items arising from the editorial review. The TG consisted of Tim McClintock, Ron Chilton and Chuck Mello and this comment was unanimously agreed to by the Task Group. 15
Report on Comments June 2011 NFPA 791 791-16 Log #11 Chuck Mello, Vacouver, WA 791-1 Revise to read as follows: This chapter provides an overview of typical construction requirements that should be considered in the evaluation. The ROP Draft text does not comply with the NFPA Manual of Style Sections 2.4.1.1 and 2.4.1.2 because the sentence does not have a recommendation stated. The revised text now provides this information in the form of a recommendation. This comment was the result of the work of a Technical Committee task group to address several items arising from the editorial review. The TG consisted of Tim McClintock, Ron Chilton and Chuck Mello and this comment was unanimously agreed to by the Task Group. 16
Report on Comments June 2011 NFPA 791 791-17 Log #12 Chuck Mello, Vacouver, WA 791-1 Revise to read as follows: (1) Correct color code or other identification used [Where color is used, the grounded (neutral) and grounding (equipment grounding and bonding) conductors have specified colors.] The ROP Draft text does not comply with the NFPA Manual of Style Sections 2.4.1.1 and 2.4.1.2 because the sentence in brackets does not have a recommendation stated. The revised text deletes this information since it is commonly published in the applicable product standards and the NEC. The revised text provides the necessary information to alert the user that there may be color coding requirements to consider. This comment was the result of the work of a Technical Committee task group to address several items arising from the editorial review. The TG consisted of Tim McClintock, Ron Chilton and Chuck Mello and this comment was unanimously agreed to by the Task Group. 17
Report on Comments June 2011 NFPA 791 791-18 Log #13 Chuck Mello, Vacouver, WA 791-1 Revise to read as follows: The electrical testing program should follow the applicable standards as closely as practical considering the limits of a nonlaboratory setting and the need for the equipment to perform its needed function after the test. The following typical tests and measurements on complete units or subassemblies should be completed as specified in the applicable standard are often performed on complete units or subassemblies: (1) Insulation resistance test on power circuit with all sensitive electronic components such as line filters and Rf filters disconnected (2) Ground continuity of bonded parts to supply equipment grounding conductor termination point (3) Measurement of the input voltage while under maximum design load (4) Measurement of the input full load current while at the maximum design load normal operation (5) Temperature rise testing of terminals and heat producing devices (transformers, power supplies, coils, heaters) and components that could be affected by an elevated ambient caused by other heat producing components (6) Safety interlock circuit function testing (6) Safety interlock circuit function testing (7) Emergency stop The ROP Draft text does not comply with the NFPA Manual of Style Sections 2.4.1.1 and 2.4.1.2 because the second sentence does not have a recommendation stated. The revised text provides that each sentence includes a recommendation as required by the NFPA Manual of Style. This comment was the result of the work of a Technical Committee task group to address several items arising from the editorial review. The TG consisted of Tim McClintock, Ron Chilton and Chuck Mello and this comment was unanimously agreed to by the Task Group. 18
Report on Comments June 2011 NFPA 791 791-19 Log #23 Wendell Whistler, Intertek Testing Service 791-23 Ensuring the product can be installed in accordance with the electrical code including but not limited to the following: (1) Verifying presence of complete equipment nameplate(s). Nameplate is complete including the applicable information based on the standard and the NEC (2) Verifying that equipment construction provides for a compliant code installation. according to Provisions for mounting in accordance with the NEC (3) Verifying iinstallation instructions include sufficient detail (showing raceway entry points, supply conductor wiring methods, supply conductor types, field wiring torque values, and installer supplied overcurrent protection) (4) Verifying adequate wire bending space is provided for all field wiring terminals in accordance with the standard and the NEC. The AHJ is used to verifying information in accordance with the NEC and this is the gold standard used by the jurisdictions 19
Report on Comments June 2011 NFPA 791 791-20 Log #24 Wendell Whistler, Intertek Testing Service 791-27 6.4 Main Overcurrent Protection Device (OCPD). Main overcurrent protection supplied by the manufacturer or field installed should be verified as suitable for the loads involved, voltage, and interrupting rating. either supplied internally or specified by the installation instructions. Main overcurrent protection that is field installed and specified by the installation instructions should be verified as suitable for the loads involved, voltage, and interrupting rating. This would allow for field installed MAINS overcurrent devices to be evaluated as part of the equipment installation 20
Report on Comments June 2011 NFPA 791 791-21 Log #25 Wendell Whistler, Intertek Testing Service 791-32 (8) Separation of low voltage, Class 2 or Class 3 conductors circuit from power conductors The word conductor needed to be made plural 21
Report on Comments June 2011 NFPA 791 791-22 Log #2 Nancy W. Gunderson, Square D Company/Schneider Electric 791-11 Add new text to read as follows: 6.12 Distances between exposed energized parts. Inspect distances between exposed energized parts for adequate creepage and clearance distances for the voltage involved. Action on Proposal 791-11 deleted Chapter 4 as most all was redundant to material in Chapter 6, Construction Inspection. However, the requirement to inspect the clearance and creepage distances was not in the chapter 6 material. Add new item to the Construction Inspection section to retain requirement to inspect the adequacy of basic spacings. 22
Report on Comments June 2011 NFPA 791 791-23 Log #19 Chuck Mello, Underwriters Laboratories 791-1 Revise the text numbering from the ROP Draft of Chapter 7 to read as follows: Each evaluation should result in a complete report detailing the results of the evaluation and a statement of conformity made from the results. Discrepancies and nonconformities that have to be resolved in order to comply with requirements should be promptly brought to the client s attention. Where successful correction of nonconformance occurs, the report should include detail of the corrective action. Discrepancies and nonconformities brought to the client s attention, per Section 7.1.1, should be brought to the AHJ s attention. A copy of the report, per Section 7.1, should also be provided to the AHJ. The title page should include the following items: (1) The identification of the company performing the evaluation (2) A general description of the equipment that was evaluated (3) The identity and location of the site where the evaluated equipment is or will be installed (4) The identity and location of the AHJ where the evaluated equipment is or will be installed (5) A report date (6) The project number or identifier (7) The identity of the person preparing the report, typically the evaluator The report contents should include a summary containing the following information: (1) The individual that initiated the project and company affiliation (2) The location of the preliminary inspection (3) The location of the final inspection and testing if different from the preliminary site location (4) Name(s) of the evaluator(s) (5) The date(s) of the preliminary inspection (6) The date of the final inspection, testing, evaluation, and application of the label (7) A summary statement of the findings (8) The name of the AHJ responsible for the final approval A statement or series of statements establishing specific conditions of acceptability to be adhered to in order to maintain the label as valid should be included. The complete citations of the primary and any contributing support standards used to complete the evaluation should be included. The citation should be complete that any subsequent audit can clearly identify the exact edition and revision of the standard(s) used. The equipment nameplate information should be documented for each manufactured unit that was evaluated as follows: (1) Product name (2) Product manufacturer s name (3) Model identification (4) Serial number for each unit evaluated (5) Electrical ratings (6) Mechanical ratings as applicable (7) FEB label serial number The detailed procedures used to inspect, test, and evaluate the product should be documented. The evaluation procedures should be separated into the major category areas as detailed in Chapters 6 and 7 with sufficient explanation for clear understanding to all parties involved including client, AHJ, and the end user. The evaluation section should include the following: 23
Report on Comments June 2011 NFPA 791 (1) A brief product description of the equipment function and its intended operation (2) Construction evaluation results found acceptable from Chapter 6 (3) Electrical testing results found acceptable from Chapter 7 (4) Discrepancies for each item found nonconforming including a description of the nonconformance, explanation of the hazards, the standards citation, the remedial action to resolve the nonconformance, and final resolution (5) Test instrumentation calibration information The following details should be included as appendices or attachments to the report: (1) Reference drawings used for the evaluation (2) Data sheet(s) documenting the test results from each of the electrical tests (3) The bill of material (critical components list) (4) Photographs of the discrepancies found, the resolution, and the overall equipment (5) Field notes, checklists, or other supporting data that would benefit the client The revised text provides for renumbering so the text in this Chapter is in compliance with Section 1.8.1 of the NFPA Manual of Style. The text as published in the ROP Draft did not have a second section correlating with Section 7.1 as required. No technical changes were intended by this comment. It is noted that any correlating annex text may require reference paragraph number changes also. 24