Beware of Safety Issues When Importing Equipment
Buying new equipment outside of Canada can cause frustrating problems when local safety regulations apply.
BY SIMON FRIDLYAND
Importing new equipment from another country isn’t so simple as setting it up and turning it on. Various regulations come into place, particularly regarding the safety of the equipment for those using it and working around it. It’s a problem that can prove very costly to those who ignore them.
Recently we were involved in a Pre-Start Health and Safety Review (PSR) for a printing press. The press was manufactured in Germany and was destined for installation in Ontario.
As far as the PSR was concerned, it covered machine guarding, flammable liquids and potentially explosive issues. Since the inks in the process were flammable, the PSR required a review from the point of view of the flammable liquids and the potentially explosive processes.
As the equipment was manufactured in Germany a special inspection needed to be arranged for a field evaluation of the electrical/electronic equipment on behalf of the provincial Authority Having Jurisdiction (AHJ) by a certification organization or an inspection agency recognized by the regulatory authority.
This process is outlined in the Canadian Standards Association’s SPE-1000-99, Model Code for the Field Evaluation of Electrical Equipment. The service provides the means for evaluating products on location and, if found in compliance with stated technical requirements, such equipment may be marked with a Special Inspection service label.
Special Inspections of electrical equipment involve a safety evaluation that is limited in scope to essential safety considerations, such as electrical shock and other hazards that would expose a user or operator to danger. In other words it addresses the minimum requirements for equipment as they pertain to electrical safety, but no more.
Special Inspections are primarily conducted on:
* custom-built equipment for special applications
* equipment manufactured on a non-repetitive basis
* equipment sold in limited quantities
* equipment not obtainable as ‘certified’ under a regular certification program
* equipment already installed and awaiting acceptance by the regulatory authority
* complete systems or subassemblies that are all available for examination and testing during the evaluation process, and
* other electrical equipment as determined by the AHJ.
A Special Inspection of electrical equipment may take place at various locations. The site may be the factory where the equipment is produced, a warehouse or distribution centre where the equipment is stored, or the actual site where the equipment is to be installed.
There are also limitations to which Special Inspections are applicable, as follows.
The Ontario Electrical Code does not apply to the field evaluation of:
* wire and cable products
* wiring devices
* equipment for use in hazardous locations
* electro-medical, radiation-emitting, and laboratory equipment used in health care facilities
* components that will require further evaluation as part of a complete assembly, such as switches, relays and timers
* any equipment that is not permitted to be field-evaluated as directed by a regulatory body (such as air cleaning equipment that intentionally produces ozone).
Since the printing press under consideration used flammable inks, areas where flammable vapours are present would be classified as a hazardous location. Electrical equipment and wiring would need to possess certain qualities so as to not produce sparks or overheat to ignite the vapours. The Ontario Electrical Code stipulates the requirements for labelling electrical equipment that is destined to be located in hazardous locations.
Hazardous-location electrical equipment is often of a unique nature or is custom-built for a specific application. The testing required to assess the safety of hazardous-location equipment is at a level that SPE-1000 does not cover.
In addition, hazardous-location equipment is outside the scope of accreditation for inspection bodies under the program accepted by the Standards Council of Canada and the province of Ontario.
As you can see, the PSR process includes flammable liquids and potentially explosive processes that require a Hazardous Location Classification for electrical equipment and wiring. Unfortunately, for the people who bought this printing press, the electrical equipment located in the classified area did not meet the Code requirements. Such a mistake is extremely costly to fix.
However, the process could have been easily managed had the issue of hazardous-location classification been addressed during the design stage. A PSR provider could have advised the original equipment manufacturer (OEM) of the local requirements and assisted in specifying the correct electrical components and wiring for the classified areas.
We, as PSR providers, see this unfortunate situation quite often. Once the equipment is installed in Canada, local requirements apply. The electrical codes differ from one jurisdiction to another. The equipment, originating outside of Canada and destined to be installed in Canada, must meet local provincial or territorial regulations.
Trade regulations mandate harmonization of equipment standards and, in many instances electrical equipment may be similar. Therefore, Special Inspections — as stipulated in the SPE 1000 document — apply. However, building- and fire-related codes will always be different from one jurisdiction to another. The reason for that is the difference in various locales in the construction techniques, architecture, construction materials and, therefore, the behaviour of fire.
Since the hazardous-location classification relates to the fire issue, there is no equivalency between the hazardous classifications in Europe and Canada.
Simon Fridlyand, P.Eng., is president of S.A.F.E. Engineering Inc., a Toronto-based company specializing in industrial health and safety issues and PSR compliance. He can be reached 416-447-9757 or firstname.lastname@example.org. For more information, visit www.safeengineering.ca.