Submersible Turbine Pump - Hazardous Location

[nhee2]

In a landfill gas condensate pump application (knockout pot in the gas flowstream), I've come across a couple vendors nearly identical statements providing what I assume is 'self-evaluation' of their equipment for hazardous location installation.

https://www.epgco.com/wp-content/uploads/2016/10/0385c-Class1Div1.pdf

Assuming the installed location is Class I, Division 1 (although this is under some internal debate), do you think the design described in the document meets the intent of 501.125(A)(4), and/or the self evaluation requirements of 500.8((A)(3). Am I correct in stating that if this evaluation is sufficient, the equipment would still need to be marked as required in 500.8(C)?

If the area is Class I, Division 2, then I believe the design/documentation is probably sufficient for 501.125(B). But for Div 1, I think they need to label the equipment - is this correct?

Using the 2017 NEC.

 

[Bwas]

I would require the equipment to be labeled. I would not consider a statement from a manufacturer that their equipment "meets the intent of the code" to be sufficient.

 

[EET#3]

Agreed - Use properly 3rd party certified products for anything going into a hazardous location

 

[nhee2]

Thanks. I don't disagree with that approach, but note that 3rd party listing is not a code requirement, 500.8(A)(3) allows 'evidence acceptable tot eh authority having jurisdiction such as a manufacturer's self-evaluation or an owner's engineering judgement' as a means to determine suitability of identified equipment.

In this case I don't think the manufacturer's statement justifies the design meets the 501.125(4) criteria.

 

[EET#3]

Wile it may not be a code requirement, there is a liability factor to consider

 

[rbalex]

In a landfill gas condensate pump application (knockout pot in the gas flowstream), I've come across a couple vendors nearly identical statements providing what I assume is 'self-evaluation' of their equipment for hazardous location installation.

https://www.epgco.com/wp-content/uploads/2016/10/0385c-Class1Div1.pdf

Assuming the installed location is Class I, Division 1 (although this is under some internal debate), do you think the design described in the document meets the intent of 501.125(A)(4), and/or the self evaluation requirements of 500.8((A)(3). Am I correct in stating that if this evaluation is sufficient, the equipment would still need to be marked as required in 500.8(C)?

If the area is Class I, Division 2, then I believe the design/documentation is probably sufficient for 501.125(B). But for Div 1, I think they need to label the equipment - is this correct?

Using the 2017 NEC.

Thanks. I don't disagree with that approach, but note that 3rd party listing is not a code requirement, 500.8(A)(3) allows 'evidence acceptable tot eh authority having jurisdiction such as a manufacturer's self-evaluation or an owner's engineering judgement' as a means to determine suitability of identified equipment.

In this case I don't think the manufacturer's statement justifies the design meets the 501.125(4) criteria.

I apologize for the late response. The fact that I didn't have COVID-19 doesn't mean I felt all that good.

Section 500.8(A)(3) indeed avoids requiring listing or labeling IF you can't get a listed or labeled product. FedOSHA and most StateOSHAs will still require listing or labeling if it can be obtained. See FedOSHA 29 CFR 1910.399. Read the definitions of Approved, Accepted, and Acceptable. If you read them together carefully, you will see an installation under an OSHA jurisdiction (just about any industrial installation) would only allow Section 500.8(A)(3) if the first two options were unavailable. That said, I doubt you could get an NRTL to substantiate any appropriate Standards to certify the product[EDIT ADD] to Section 501.125(A)(4).

Next, I usually don't set too much store on a manufacturer's sales literature, especially when they don't cite the Code correctly. (There is no "... paragraph (a) of the National Electric Code (NEC), or Article 501.125".) I would want a much more substantial evaluation and documentation of how they achieved compliance with Section Article 501.125(A)(a)(4) to justify "self-certification".

 

[nhee2]

I apologize for the late response. The fact that I didn't have COVID-19 doesn't mean I felt all that good.

Section 500.8(A)(3) indeed avoids requiring listing or labeling IF you can't get a listed or labeled product. FedOSHA and most StateOSHAs will still require listing or labeling if it can be obtained. See FedOSHA 29 CFR 1910.399. Read the definitions of Approved, Accepted, and Acceptable. If you read them together carefully, you will see an installation under an OSHA jurisdiction (just about any industrial installation) would only allow Section 500.8(A)(3) if the first two options were unavailable. That said, I doubt you could get an NRTL to substantiate any appropriate Standards to certify the product[EDIT ADD] to Section 501.125(A)(4).

Next, I usually don't set too much store on a manufacturer's sales literature, especially when they don't cite the Code correctly. (There is no "... paragraph (a) of the National Electric Code (NEC), or Article 501.125".) I would want a much more substantial evaluation and documentation of how they achieved compliance with Section Article 501.125(A)(a)(4) to justify "self-certification".

Thanks, hope you are feeling better.

Agree on value of manufacturer's sales literature - their description of how their motor works really doesn't line up with the verbiage of 501.125(A)(4) anyway.

 

[nhee2]

Wile it may not be a code requirement, there is a liability factor to consider

I agree, was just pointing out what the code allows. Thanks for the response.

 

[rbalex]

I agree, was just pointing out what the code allows. Thanks for the response.

Just curious, what liability do you think listing or labeling would absolve and who would it absolve?

 

[nhee2]

Just curious, what liability do you think listing or labeling would absolve and who would it absolve?

Probably, not much, and not many.

I'm not sure the labelling of a 'self-certification' would absolve anything, it would just follow the code.

I think specifying a 3rd party listing from a NRTL would demonstrate a reasonable 'standard-of-care' by an engineer, if a charge of negligence were ever brought up. But we're never free of liability, unfortunately.

 

[rbalex]

Anyone that carried a liability before still does. Read all the Standards of Care required for the installation's given location. Fed or State OSHA is almost always an AHJ for industrial installations. The facility's insurer is usually a good source for discovering what the Standards of Care might be. In and of itself, nobody gets off the hook. The very best one might hope for is to be cleared of criminal negligence.

It needs to be established whether or not the product can be NRTL certified in the first place AND what it can be certified for. Plenty of NRTL certified products are misapplied very day.

 

[nhee2]

Anyone that carried a liability before still does. Read all the Standards of Care required for the installation's given location. Fed or State OSHA is almost always an AHJ for industrial installations. The facility's insurer is usually a good source for discovering what the Standards of Care might be. In and of itself, nobody gets off the hook. The very best one might hope for is to be cleared of criminal negligence.

It needs to be established whether or not the product can be NRTL certified in the first place AND what it can be certified for. Plenty of NRTL certified products are misapplied very day.

I'm not sure if we are arguing or agreeing?

Liability was the wrong word to use. We'll always have liability for our designs. I did not intend to suggest we are not liable if we use a NRTL listed product.

Using a listed product provides more assurance to me as the designer that the product will perform, more so than a self-evaluation does. We always have to make sure we apply the listed product correctly - whether its an explosion-proof device, a circuit breaker, or a wire nut.

 

[rbalex]

I don't want to belittle listing or labeling but I believe they often give unwarranted "warm-fuzzies" that have very little or nothing to do with anyone's liability. They simply mean that a qualified organization certifies that a product conforms to a specific set of Standards. (Read the definitions of listed and labeled in Article 100) If those product standards don't apply to the contemplated installation, listing or labeling is irrelevant.

So - are you aware of any organization that could certify the applicability of the product(s) via Section 500.8(A)(1) or (2)? Do you know the Standard(s) they could properly apply? (BTW they still wouldn't warrant performance even if they did certify the product(s) in question AND the products were installed properly.) So what option(s) do you have other than Section 500.8(A)(3)? I would however require far more documentation from the manufacturer than their sales literature. It would need to demonstrate how their product met Section 501.125(A)(4).