Determination of areas • Code File, June 2019
June 14, 2019 - When an authority having jurisdiction (AHJ) such as myself asks, “What is your area classification or designation?’ what are we really asking? Most people assume we are looking at a section 18 requirement for a hazardous location. There are, however, several sections in which a determination from a third party is required and, in most instances, it must be in writing.
By way of example: is there a hazard due to the equipment you are installing? More specifically, is there a hazard to people due to both the type of equipment and how it interacts with them? Is the process you are planning to perform creating an atmosphere that may interact with people, equipment or other process and lead to the failure of a piece of equipment?
We are asking what your process entails and what type of research and background information have you obtained regarding it. If you hired an electrical engineer, did they do their due diligence to ensure the process and the wiring methods are compatible?
If your customer is designing a health care facility, have they been in contact with the health authority or made a ‘determination of area’ in accordance with CSA Z32? Have they been made aware of the maintenance requirements under the choice of processes or wiring methods? As an inspector, if I don’t have the determination of areas in writing from the owner or health authority describing the patient care environment, then I must assume the worst-case scenario, which can be a disadvantage to the customer in terms of higher costs, especially if after the fact.
What about the installation of lighting in an area where, say, they have always done the painting this way and it hasn’t been a problem? Does this make it okay for the contractor to assume the area is normal?
This is the type of scenario where the contractor needs to look closely at the CE Code, get an engineer involved or call the inspector for a site visit. The intent is to save the customer money in the long term. Maybe it is a normal area, but if the contractor is questioning it, then there is a good chance the inspector will be questioning it as well. Replacing equipment and wiring after the fact will always be costlier, especially when paint lines get shut down, processes get backed up and more expensive equipment needs to be ordered and installed.
What we need to understand is to which section of the code the area would be referenced. If it falls under section 18 to 24, then we have specific rules that come into effect and we should immediately check if the area has been designated as a hazardous location, flammable liquid, propane, or gasoline dispensing location, paint booth, repair garage, bulk storage, corrosive location, wet location or patient care area.
Often, the answer is clear-cut in the code and no further questions need be asked. Examples include service stations, bulk storage plants and automotive paint mixing rooms.
Other times, however, there may be methods for mitigating hazards, such as poor ventilation, in which case the areas are no longer classified. And unless it is in writing that the hazard has been removed, inspectors will keep on the safe side and call it a hazardous location.
When engaging the services of an engineer, it is also important to ensure they understand what the process involves. The code is not a design document, but an installation document. With this is mind, Appendix L was added to provide guidelines engineers would require in performing hazardous area classifications. This section has been beneficial to many people who have wondered, “How do I do this? Where do I find the relevant information?’
Remember, if you aren’t sure, a quick call to your local AHJ could save you time and your customer money.
This column originally appeared in the June 2019 issue of Electrical Business magazine.
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