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July 1, 2021
Field Evaluation: Dealing with “Red Tagged” Equipment in the Field
Written by: Gary Richards
OSHA requires all electrical equipment that is used in the workplace to be in compliance with the appropriate safety standards. Most new equipment arrives from the factory with a listing label that declares this compliance. This type of listing is performed by an NRTL (Nationally Recognized Testing Laboratory) in their laboratory and is listed at the factory. If a local Authority Having Jurisdiction (AHJ) finds installed equipment at a site they are inspecting that does not bear the NRTL marks to show compliance with the appropriate electrical safety standards, the AHJ could "red tag" the equipment, and take it out of service.
There are many reasons for equipment to “red tagged” in by the AHJ:
- Unique one-of-a-kind products, which make formal certification impractical.
- Limited production of a product, which makes formal certification impractical.
- An NRTL listed product that has been modified in the field.
- Components are marked, but the end system hasn’t been evaluated.
- Equipment only marked with a “CE” Marking.
- Older equipment that has been moved and the label is no longer visible.
- NRTL marking was accidentally not applied at the factory.
When equipment encounters a “red tag” by the local authority, a Field Evaluation Body (FEB) can be promptly dispatched to the site to address the issue. The FEB will send an evaluating engineer to inspect the equipment and determine essential compliance to an applicable safety standard. Final field evaluations are typically performed at the end customer location. However, Nemko also offers preliminary evaluations at the manufacturer’s facility. This is often an invaluable approach, as this allows any non-conformance issues to be addressed at the factory before the equipment has been shipped. As an NRTL, Nemko’s mark is well-known to most AHJs and accepted throughout the US and Canada as an approved FEB.
If the equipment is found to be non-compliant, the Nemko engineer will provide a letter of findings / bunch list that outlines the issues that need to be addressed. These discrepancies must be remediated before a field label can be applied. Examples of common non-conformances include use of non-approved, safety critical components, use of fuses or breakers that are not properly rated for the installation, use of name plates that do not include all of the rating information that is required by the applicable standards, etc. Often, simple issues can be resolved while the Nemko engineer is onsite. However, it is possible that a second trip may be required. Once any non-compliances are resolved, the engineer applies a field label and issues a report that explains the results of the evaluation. This document is often provided to the AHJ as well, thus giving them the proof of compliance and the ability to sign off on the installation.
Conformance to the relevant standards and field labeling requirements is a prerequisite for local authorities to grant permission for your equipment to be placed into service. Nemko is a flexible and service-oriented provider, with the expertise to support your needs. Driven by a genuine intention to help make the world a safer place. We aim to develop services that can help our clients deploy compliant products that meet local and national requirements.
Gary Richards is the key account manager of Field Evaluation Services for Nemko USA. Gary has over 19 years of experience working in and around the regulatory compliance industry. With a focus on Field Evaluation and Machinery projects, his motivation and passion is working with manufacturers to help them quickly and...
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