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FAQ – Explosion protection worldwide

We are pleased to share our knowledge with you – Simply send your questions to us at info@schienle.de

North America/Canada

01 All electrical equipment must be approved/tested as follows:

  • In the USA, by a nationally recognised test laboratory (NRTL), accredited by the OSHA.
  • In Canada, by a certification body accredited by the SCC (Standards Council of Canada).
  • Proof of certification must be applied to the equipment in the form of the certification body’s symbol or label.

02 The certification body issuing the certification must inspect each factory (defined as the place where the product was manufactured and labelled) four times a year.

  • This applies to each certification body, and each one must carry out their own inspections.
  • This is a considerable difference to ATEX and IECEx. In the ATEX system, a Quality Assurance Notification (QAN) is issued, and in the IECEx system, a Quality Assurance Report (QAR) is issued. Both the QAN and QAR are mutually recognised by other certification bodies that test a product in accordance with the ATEX Directive or the IECEx system.

03 Ex equipment must be tested/assessed according to both the applicable Ex standard and also the generally applicable standards for ‘electrical safety’. The tests must be carried out by the same certification body that issues the certification.

The following applies in both Canada and the USA: The local law-making authorities (Local Authority Having Jurisdiction – AHJ) is the decisive authority regarding the installation of electrical devices and equipment.

There are many AHJs in Canada and the USA, but they all follow the general rules and regulations set out in the installation codes.

USA: The ‘National Electrical Code’ – also known as NFPA 70, NEC or NEC500

Canada: he ‘Canadian Electrical Code, Part I’ – sometimes known as CEC or Part I.

In the USA, regulations for approving electrical products comprise:

01 Occupational Health and Safety regulations issued by the Occupational Safety and Health Authority (OSHA)

The OSHA regulations are federal laws, and stipulate that all equipment (that will be used in the workplace) must be approved/certified by a recognised test laboratory (NRTL) that is accredited by the OSHA.

02 Installation requirements in accordance with NFPA 70, National Electrical Code (NEC)

Similarly, the NEC demands that electrical equipment is either ‘approved’ by the responsible authority (AHJ) or ‘listed’ or ‘labelled’ by an NRTL.

03 Regulations issued by respective municipalities.

Additional requirements apply for certain legal systems. These requirements are handled by the accredited certification bodies.

In Canada, product approvals in relation to electrical safety are subject to the jurisdiction of the provincial government. These normally stipulate: “Nobody may manufacture or install electrical equipment, nor offer it for sale or dispose of it, unless the equipment bears a label accepted by the Standards Council of Canada (SCC), and which also features the sign of an accredited certification organisation.”                                                                                                                                                                                                                                                     

NO!

This is actually a fallacy that has its roots in the past, and is also one of the most misleading in relation to certification for North America.

When looking at the regulations stated above, it becomes clear that manufacturers in the USA and Canada have a range of different NRTLs and certification bodies to choose from, which are all equally recognised.

As a result:

  • In the USA, products bearing the labelling of an NRTL fulfil both local and federal regulations.
  • In Canada, a product bearing the sign of a certification body accredited by the SCC is acceptable to all local regulatory authorities.

This is similar to ATEX, in that it enables manufacturers to engage the services of one of the many well-known certification bodies in order to receive a certification of conformity.    

No

This is a major fallacy that came into being in the past, and which was caused by an incorrect interpretation of the North American regulations and/or standards.

In North America, there are numerous ‘Standards Developing Organizations’ (SDOs):

  • In the USA: UL, ISA, FM etc.
  • In Canada: ‘Canadian Standards Association’ (not CSA International, which is a CB!!)

National standards are indicated by:

  • In the USA: ‘ANSI’ – prefix for the names of standards; this is ANSI/ISA12.12.01
  • Canada: ‘CAN’ – prefix for the names of standards; this is CAN/CSA C22.2 No 60079-0

Relatively few bodies define the explosion protection standards – CSA in Canada and UL, ISA and FM in the USA.

It is important to note that all NRTL certification bodies must fulfil the same national accreditation criteria, and that the products must be tested under the same conditions.

This is similar to the situation in Europe, where the various notified bodies test/assess the product according to the same applicable harmonised standards, and where their certificates are recognised throughout the EU.

Old habits die hard! The statement above originated in the old days when the UL and CSA had a monopoly. Back then, manufacturers had no choice but to use both certification bodies. This is also partially strengthened by the fact that the UL and CSA publish most of the national standards.

In virtually all cases where a customer tells you that ‘CSA and/or UL certification’ is required, he or she means that the product must be certified and labelled by an accredited (by the SCC) certification body in Canada and/or by the OSHA in the USA.
In short, there are no regulations, standards or codes etc that stipulate that equipment must only be certified by the CSA or the UL.

Yes and no

If under the area of responsibility of the USCG (US Coast Guard), then yes. But if under the area of responsibility of the BSEE (Bureau of Safety and Environmental Enforcement), no. Because it is not always clear under which area of responsibility a unit falls, it is not possible to make a generally applicable statement about IECEx acceptance.

Situation:

01 The USCG and BSEE work together at a regulatory level.

02 On 31 March 2015, the department responsible for the USCG (Department of Homeland Security) published new regulations in the Federal Register. These relate to expansion of the national and international Ex standards accepted by the USCG.

To summarise:

The IECEx certificate is accepted where the following conditions apply: Only systems and ships that were built after 2 April 2018.

Not directly

However, the door has opened a bit wider since the new CPL-01-00-004 directive came into force on 1 October 2019.

In short, this can be summarised as follows:

New procedure for recognising inspections and test data from companies operating within the framework of the International Electrotechnical

Commission System for certifying standards for equipment used in explosive atmospheres (IECEx scheme).

But broadly speaking, this still only occurs when working with an NRTL, and depends on their willingness to recognise the particular ExTR submitted as the basis for an assessment, ie also to assume risk. However, this does not apply to use in areas classified in divisions.

Future recognition of the IECEx QAR is unlikely, if not impossible, as the OSHA issues clear guidelines to the NRTLs. For example, the cycle of compulsory monitoring audits once a quarter, which are not announced in advance.

Yes!

All equipment intended for use in potentially explosive atmospheres must also comply with the general safety standards applicable to electrical equipment. Although this sounds straightforward, it can have a drastic bearing on the time required and the costs bound up with obtaining certification. In some cases, a redesign of the equipment can even be necessary. One example of this is CSA 22.2. No 139 ‘Electrically operated valves’, according to which the valve solenoid must also be tested.

In Division 1 Class 1, only threaded rigid/solid conduit or threaded steel-sheathed conduit solutions are permitted to be used.

Anything else is an exception, and exceptions are subject to application-specific restrictions, and so must be clarified on a case-by-case basis.

Approval of a cable for Division 1 Class 1 does not mean that it can be used anywhere in this area. The application-specific exceptions and conditions must always be taken into account.

(For more information see NEC 501.10(A) for Division 1 and NEC 501.10(B) for Division 2)

Example:

Cable of type TC-ER-HL is permitted as a flexible wiring method in industrial operations where access by the public is restricted. This is provided that the servicing and monitoring conditions guarantee that only qualified people can enter the installation, or that the installation is protected against mechanical damage, either on the basis of its location or other safety measures. Cable of type TC-ER-HL must feature an overall sheath and one or more separate device earthing conductors.

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ATEX

In the European Union, notified bodies are private inspection bodies (auditing and certification bodies) that are designated and monitored by member states. On behalf of manufacturers, they supervise and monitor conformity assessments for the widest range of goods that manufacturers produce.

Here you can find a link to all notified bodies in relation to Directive 2014/34/EU Equipment and protective systems intended for use in potentially explosive atmospheres (recast).

Double certification in accordance with IEC 60079 (for IECEx) and EN 60079 (for ATEX) is not only advisable on economic grounds, but has also meanwhile become usual practice.

If you are interested in the US market, or a market dominated by US companies, you will need to consider this. We would be pleased to answer your questions in this regard in a personal discussion.

An IECEx ExTR (Technical Report) from an IECEx ExCB of your choice can be of assistance when applying for an ATEX EU type examination.

Apart from the labelling, the technical requirements are virtually identical. An IECEx QAR (Quality Report) from an IECEx ExCB of your choice can be of assistance when applying for an ATEX QAN (Quality Assurance Notification).

The requirements are absolutely identical (ISO/IEC 80079-34).

A European ExCB (these are all also ATEX NBs) will usually issue both sets of documentation together for a small additional fee.

Since 20 April 2016, Directive ATEX 2014/34/EU has been in force, replacing Directive 94/9/EC.

Even after 20 April 2016, products whose conformity was confirmed before Directive 2014/34/EU came into force, and so when Directive 94/9/EC still applied, can be put on the market. All equipment a manufacturer introduces or puts into operation after 20 April 2016 requires a Declaration of Conformity in accordance with Directive 2014/34/EU.

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IECEx

An IECEx ExTR (Technical Report) from an IECEx ExCB of your choice can be of assistance when applying for an ATEX EU type examination.

Apart from the labelling, the technical requirements are virtually identical. An IECEx QAR (Quality Report) from an IECEx ExCB of your choice can be of assistance when applying for an ATEX QAN (Quality Assurance Notification).

The requirements are absolutely identical (ISO/IEC 80079-34).

A European ExCB (these are all also ATEX NBs) will usually issue both sets of documentation together for a small additional fee.

As of 2020, there are five countries which have integrated the IECEx scheme into their national regulations:
(Please note: There are some very specific restrictions.)

  • Australia
  • New Zealand
  • Singapore
  • India
  • Israel

Many other countries whose law does not prescribe any particular certification systems also accept IECEx in preference to all other regional or national systems.

All regions and countries with an IECEx ExCB are obliged to indirectly recognise IECEx certificates via their own certification bodies. In some cases, this is also set out in law: in Brazil and the Eurasian Customs union (Armenia, Belarus, Kazakhstan, Kyrgyzstan and the Russian Federation).

The sole exception is the USA where the division applies. The US division system must not be mixed up with the US zone model, as classification is based on different approaches. But in any case, the IECEx certificate represents the key to obtaining local approval.

Yes and no

If under the area of responsibility of the USCG (US Coast Guard), then yes. But if under the area of responsibility of the BSEE (Bureau of Safety and Environmental Enforcement), no. Because it is not always clear under which area of responsibility a unit falls, it is not possible to make a generally applicable statement about IECEx acceptance.

Situation:

01 The USCG and BSEE work together at a regulatory level.

02 On 31 March 2015, the department responsible for the USCG (Department of Homeland Security) published new regulations in the Federal Register. These relate to expansion of the national and international Ex standards accepted by the USCG.

To summarise:

The IECEx certificate is accepted where the following conditions apply: Only systems and ships that were built after 2 April 2018.

Not directly

However, the door has opened a bit wider since the new CPL-01-00-004 directive came into force on 1 October 2019.

In short, this can be summarised as follows:

New procedure for recognising inspections and test data from companies operating within the framework of the International Electrotechnical

Commission System for certifying standards for equipment used in explosive atmospheres (IECEx scheme).

But broadly speaking, this still only occurs when working with an NRTL, and depends on their willingness to recognise the particular ExTR submitted as the basis for an assessment, ie also to assume risk. However, this does not apply to use in areas classified in divisions.

Future recognition of the IECEx QAR is unlikely, if not impossible, as the OSHA issues clear guidelines to the NRTLs. For example, the cycle of compulsory monitoring audits once a quarter, which are not announced in advance..

All regions in Australia accept ANZEx. In Fällen, bei denen Normen zur Anwendung kommen, die nicht durch IEC-Normen abgedeckt sind, ist ein ANZEx Zertifikat vorgeschrieben.

Die Anwendbarkeit eines IECEx – Zertifikates richtet sich danach, ob dieses von einer NATA (National Accredited Testing Station) akkreditierten Test Station oder von einem internationalen IECEx CB (Certification Body) erteilt wurde.

The oil and gas industries in all Australian states and territories accept IECEx certificates issued by certification bodies in countries other than Australia. But for underground use, the coal mining industry in the state of Queensland only accepts IECEx certificates issued by a NATA-accredited IECEx CB. NATA-accredited approval bodies include for example Simtars, TestSafe Australia, Ex Testing and Certification Pty Ltd and the Mine Safety Technology Centre.

Everything, because this did not exist until now!

  • IEC-Ex has incorporated non-electrical standards IEC 80079-36 and -37.
  • At the time of writing, there are only a few certification bodies inspecting this standard in the IEC process.
  • Applicable to purely mechanical equipment as well as equipment with clearly mechanical parts (solenoid valve).
  • Conformity assessment procedure will be applied in accordance with ATEX/IECEx.
  • IECEx sees the expansion as a ‘proposal’!

In the valve sector, the first approvals are already taking place. What effects this will have on the acceptance of mechanical equipment that has not been inspected to IEC standards is open to speculation.

In the IECEx scheme, inspection by a third party is obligatory. This applies to both the product and the quality process.

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Australia

All regions in Australia accept ANZEx.

All regions in Australia accept IECEx provided the certificate was issued by a NATA (National Accredited Testing Station)-accredited IECEx CB.

In Fällen, bei denen Normen zur Anwendung kommen, die nicht durch IEC-Normen abgedeckt sind (z.B. zurückhaltende Behälter für den Untertage-Kohlebergbau), ist ein ANZEx Zertifikat sogar vorgeschrieben.

The oil and gas industries in all Australian states and territories accept IECEx certificates issued by certification bodies in countries other than Australia. But for underground use, the coal mining industry in the state of Queensland only accepts IECEx certificates issued by a NATA-accredited IECEx CB. NATA-accredited approval bodies include for example Simtars, TestSafe Australia, Ex Testing and Certification Pty Ltd and the Mine Safety Technology Centre.

If an ANZEx certificate is required, this can be issued on the basis of an Ex TR and Ex QAR issued by an IECEx CB in a country other than Australia. Here too, it is the case that the latest standard simplifies the process. The NATA-accredited certification body decides whether further tests are necessary.

Please note:

Although the series AS/NZA 60079 is a direct adoption of the IEC 60079 series, some standards in this series were adopted with national deviations (AS/NZS 60079.14, AS/NZS 60079.17 and AS/NZS 60079.10.1). In most Australian states and territories, the relevant electrical safety laws and regulations require compliance with AS/NZS 3000 (known as the wiring regulations). Section 7.7 of AS/NZS 3000 prescribes that a hazardous area as defined by AS/NZS 60079.10.1 or AS/NZS 60079.10.2 must be classified. Furthermore, the wiring regulations stipulate that electrical equipment for use in potentially explosive areas must be selected and installed in accordance with AS/NZS 60079.14.

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Eurasian Economic Union

This comprises Armenia, Belarus, Kazakhstan, Kyrgyzstan and the Russian Federation.

Conformity with the TR ZU012/2011 must be confined by an EAC Ex certification. Certificates are valid for five years.

The Eurasian Customs Union has a common set of rules governing the safety requirements for electrical and also non-electrical equipment used in potentially explosive areas. This set of technical rules is TR ZU 012/2011. Although it was harmonised on the basis of ATEX Directive 2014/34/EU, it is not identical. Compliance with these rules is compulsory when putting a product on the market.

An existing ATEX certificate in accordance with Directive 2014/34/EU can be used to obtain an EAC Ex certificate via EAC certification.

In this situation, it should be noted that an EAC certificate is required. This should not be confused with an EAC declaration.

With effect from 15 March 2015, TR ZU 012/2011 replaced existing national regulations (GOST_K, GOST-R, TR-Ex) in the countries forming the Eurasian Customs Union. The previous regulations are no longer valid.

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India

Manufacturers outside India can use their IECEx certificate directly if they have an Indian representative or agent who can demonstrably assume responsibility for servicing of the equipment. This does not apply to products falling under the area of responsibility of PESO (PETROLEUM AND EXPLOSIVE SAFETY ORGANISATION) or the DGMS (Directorate General of Mines Safety). In these two cases, the complete procedure for applying for installation consent is required. Both IECEx and ATEX certificates can serve as the basis for this. You can find a relevant data sheet on PESO’s website: Approval of Ex (Electrical) Equipment for Use/Installation in Hazardous Areas.

For products not manufactured in India, PESO insists on IECEx certification according to the currently applicable version of the standards.

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China

Products intended for use in mining must have an SACMSS (Safety Certificate of Approval for Mining). As is the case with industries other than mining, the accrediting body is the SAWS (State Administration of Work Safety). Only MA (Mining Products Safety Approval and Certification Center) is accredited for certifying mining products in China. Products must be certified, and their manufacturers must undergo periodic quality audits. As the basis for approval, they can require an existing certificate, for example ATEX or IECEx. However, the applied standards are not directly comparable with the IEC standards.

In the mining industry, a local certificate is required. The only accrediting certification body is the MA (Mining Products Safety Approval and Certification Center).

Equipment not intended for use in the mining industry is certified by test laboratories, not by certification bodies.

Every test laboratory that is active as an ExTL in the IECEx scheme accepts an ExTR from outside China as the basis for issuing a local certificate.

China has its own standards, which with the exception of mining are closely based on the IEC 60079 range.

In industries other than mining, you can obtain approval for China on the basis of an IECEx TR and IECEx QAR, with the help of a test laboratory accredited by the SAWS (State Administration of Work Safety).

No!

NEPSI is not a certificate, but like CQST or PCEC merely a test laboratory accredited by the SAWS (State Administration of Work Safety), whose label confirms that the requirements for approval of a product have been fulfilled.

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Brazil

Electrical equipment intended for use in potentially explosive areas must also be tested by an independent certification body. As a consequence, the equipment’s conformity is guaranteed by INMETRO Regulation No 179.

The certification body must be accredited by the INMETRO system (National Institute of Metrology, Standardization and Industrial Quality).

The INMETRO Directive (Portaria 179) enables the Brazilian certification bodies to carry out INMETRO certification on the basis of IECEx documents. Portaria 179-2010 covers three different certification models.

Directive 179-2010 covers there certification models:

01 Type examination and evaluation of the manufacturer’s quality system, combined with monitoring audits.

The product receives approval and can be used and marketed. The type examination, certification and manufacturing facilities monitoring are undertaken by an INMETRO-accredited certification organisation. Directive 179 permits an existing IECEx TR to be taken into consideration.

If the IECEx CB is also accredited by INMETRO, monitoring audits based on ATEX, IECEx and INMETRO can be combined/merged. ATEX reports can also be used, but compared with the IECEx TR, additional time is involved.

02 Certification of a product batch

A limited/single delivery can be certified without a monitoring audit, on the basis of an existing certificate (IECEx).

Proviso: The product being sold represents the product tested. In this procedure, 6 % of a product’s production batch is supplied to a certification organisation in Brazil for test purposes.

03 Imported products, using the new CSE procedure

The product is certified by an independent body that is not accredited by INMETRO. This applies to a quantity of maximum 20 pieces, once only in a six-month period. The application is made by an INMETRO-accredited certification organisation, upon submission of defined documents and confirmations. Upon submission of the products, they are inspected and assessed. No monitoring of the manufacturing facilities takes place.

INMETRO stands for Instituto Nacional de Metrologia, Normalização e Qualidade Industrial (National Institute for Metrology, Quality and Technology), and is a Brazilian governmental authority.

INMETRO is not a certification organisation that carries out tests and issues certificates.

The legal regulations governing equipment in potentially explosive areas are found in Directive Portaria INMETRO/MDIC Number 179, dated 18 May 2010.

These are applicable to all electrical equipment or components that are intended for use in potentially explosive areas in Brazil.

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