Codes & Standards
Stop wasting time and money during hazloc product certification
By Behzad Nejad, P.Eng.
By Behzad Nejad, P.Eng.
The formal approval of electrical equipment for use in Canada was introduced in the Canadian Electrical Code, first published in 1927. While there have been many changes to the code and related regulations since then, Canadian-made electrical products continue to require the approval of a certifying body (e.g. CSA Group, Underwriters Laboratories of Canada Inc., QPS) to assure their safety.
Certification by an impartial third-party or certification agency is an attestation that minimum relevant safety and performance standards have been met.
The certification of electrical products being designed and manufactured for use in hazardous locations and explosive atmospheres (Ex equipment) is especially stringent because of the associated risk of explosion should those products fail. Such a catastrophic event could result in loss of life and the destruction of property, not to mention damaging the reputations of the designer, manufacturer, installer—even the certifying agency.
“Certification by an impartial third-party or certification agency is an attestation that minimum relevant safety and performance standards have been met.”
The requirements for hazloc certification have also become more complex since their introduction. Given today’s global marketplace, the chances are high that a new product must also be approved by authorities in other jurisdictions. Manufacturers of products intended for use outside their country of origin face a few daunting challenges, which can include dealing with foreign engineering firms and unfamiliar equipment distributors, gaining the approval of unfamiliar certifying agencies, meeting additional regulations, and even overcoming language barriers.
No matter how complex, the certification process cannot be avoided, and is a requirement for manufacturers aspiring to have their electrical products Approved for Use. Certification translates into consumer confidence in both the manufacturer and its products. It enables a product’s end user to procure the correct equipment for a specific application.
Certification, and its enforcement by the appropriate authority having jurisdiction, gives manufacturers comfort in knowing their products continue to comply with relevant safety standards—from design and installation, to use in the field. Certification gives the AHJ the right to inspect and enforce the requirements of the applicable codes, regulations and standards. Liability is no longer solely borne by the manufacturer.
“No matter how complex, the certification process cannot be avoided, and is a requirement for manufacturers aspiring to have their electrical products Approved for Use.”
So if certification is such an integral part of getting a product to market, why do so many manufacturers spend more time and pay more money than necessary for this process?
Really know your product
In my experience, manufacturers aren’t always as prepared as they should be for each stage of the application process. An efficient certification process can take between two to four months, while an ill-prepared or unprepared application can easily extend the process to a whole year, with double the cost.
To begin with, an application for certification requires an understanding of where the product will be sold, installed, and used.
Knowing where the equipment is intended to be sold (which country/ies) helps identify applicable certification requirements and standards, which vary from one jurisdiction to another. The certification process for electrical products designed for use in hazardous locations in North America, for example, is different than the requirements for international (IECEx) and European certification (ATEX). In some cases, manufacturers wish to secure all three marks and certifications so they can sell their product anywhere in the world. Naturally, this adds cost and possibly time to the certification process—especially if the manufacturers are unfamiliar with and/or unprepared to meet each of these requirements.
The manufacturer needs to know which directives, regulations/Code of Practice apply in each jurisdiction where the product will be purchased, installed and used, in addition to the standards for that specific product. They also need to anticipate the impact of those standards with regard to:
• product design,
• relevant technical guidelines,
• appropriate protection techniques for installation,
• required hazardous location markings, and
• expectations at each phase of the certification application, including testing and sampling.
Any time spent ensuring a product meets standards and technical guidelines is time wasted if the correct standard/guideline was not identified and referenced at the outset. The standards themselves are complex and may require interpretation. The language in standards include statements such as “applies only to” or “except as permitted by Subrule[…]” or “unless otherwise specified”. Rules are typically numbered (e.g. Rule 10-212 or Article 18.104.22.168) and often refer to Subrules, Notes and Appendices that may also apply.
Manufacturers do not always speak the language found in these documents.
“An efficient certification process can take between two to four months, while an ill-prepared or unprepared application can easily extend the process to a whole year, with double the cost.”
Forewarned is forearmed
The certifying agency controls the process: the manufacturer submits documents and waits for a response. Manufacturers begin the process by initiating a Request for Quotation from the certifying agency. At this stage, their proposal documents need only contain enough information to obtain an accurate quote quickly. However, when critical information is missing, or the product is described insufficiently, the certifying body will need more time to obtain the required details before providing a quote. This adds time to the process.
The initial request should include a general description of the product (main and safety parts), electrical ratings, hazardous location markings, list of applicable standards, type(s) of certification requested, and protection techniques. In some cases, more than one method of protection is needed. Each protection technique needs to be separately designed by the manufacturer, and individually evaluated and tested by the certifying agency.
Upon receipt of the quote, the manufacturer will be able to anticipate subsequent requirements. This information is spelled out in checklists that certifying agencies use to better to understand a product, thereby more quickly completing their assessment and evaluation to determine compliance. It is in the manufacturer’s best interest to access, use and submit the checklist(s) as a self-assessment. Those who are prepared for this stage will accelerate their process.
The scheduled drawings should be separated from manufacturing drawings, and must contain information critical to the product’s compliance with applicable hazardous location standard(s). This separation will be helpful when internal documentation and non-safety details need to be updated (such updates can then proceed without engaging the certifying agency).
As a general principle, it’s important to anticipate what will be involved in maintaining hazloc product certification while preparing for its certification.
Manufacturers also need to anticipate the certifying body’s requirements for testing (e.g. preparing the correct number of samples, in the correct configuration). Manufacturers can begin preparing them right away so that, when samples are requested, they can be provided immediately.
Failure to consider and anticipate the certifying agency’s requirements may lead to redesigning the product, repeating certain steps, redoing documentation, creating new drawings—all of which add time and cost unnecessarily to the process.
For example, let’s take the certification process for a hazloc LED fixture, Zone 1 application. The certification process should take 3 months to complete. However, if the manufacturer is not prepared to design the LED arrays, driver and internal PCB components based on requirements in the standards, the process can easily take up to 6 or 8 months!
He who hesitates… adds cost
As a manufacturer, it is in your best interest to move your products quickly through the design, testing, approval, and production stages into the marketplace to keep pace with rapidly changing technology. The certification process takes time: it involves assessing the required technical documentation, testing the product against the relevant standards, and ensuring compliance with the applicable legal framework, and all the certification rules and procedures.
It is wiser to be well-prepared for success than to receive notice that a certification application has failed. Know your plans for your product in advance; know the applicable standards and technical guidelines; know which documents you will be expected to provide to the certifying agency; anticipate the need to provide samples. Delays are never pleasant—especially ones that could have been avoided.
Behzad Nejad, P.Eng., is the director and a consulting engineer at Hazcon Inc., where he provides hazardous location consulting services (IECEx, ATEX, Canadian Electrical Code and National Electrical Code) for manufacturers of electrical products. He has a Master’s degree in Electrical Engineering and has been a member of Professional Engineers Ontario since 2013. Behzad’s experience in the industry also includes seven years at CSA Group’s certification agency. He has published and presented technical articles and tutorials on hazardous locations at several IEEE/PCIC conferences, and is also a part-time instructor at Seneca College, teaching electrical courses since 2014. You can reach him at email@example.com, and visit hazcon.com.