CSA standards to be met by european supplied machine

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Thread Starter

mike

I am working on a project that has seen 2 systems of machinery imported to Canada from Switzerland..I have recieved a document from the customer asking if the systems comply with CSA under section 7 of the regulations for industrial establishments......This states, I have to make a report that shows the apparatus and protective elements have been both purchased and manufactured to meet current applicable standards I take it this has to come from the Swiss company that made the equipment.....I know they operate to UL and CE standards but these are the first systems to be imported to Canada so they possibly dont know the specs for CSA what are the differences.....And what should I write Circuit breaker references,earth bonding,earth leakage,and does this include the cover protection system and NOT stop system....regards mike

 
Mike,has the equipment you speak of been tested and recieved the CE and UL mark? If so obtaining that information would be a step in the right direction. The CSA certification should be easy to obtain assuming the equipment already has the UL and CE marks. I suggest you contact CSA directly to enquire about what documentation they require. I have used EMC Testing Laboratories (770)781-9228 in the past to solve similar problems.
 
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Bob Peterson

First off I would make sure of what they are asking. If they are asking only that the machine controls meet the CSA electrical specifications (which is probably what they are asking) you are probably out of luck. Most
European machines are poorly designed (electrically and control wise anyway) by US/Canadian standards and would never make the requirements. Even if the components meet UL standards, they won't meet CSA standards, unless the components are all labeled CSA or CUL.

Secondly, there really is no such thing as a CE standard. Its really your statement that the machine meets ALL the required European standards and is meaningless in the USA or Canada. Its actually quite meaningless in Europe as well, other then as a dodge to restrict imports (which is all it really is).

I would start with a copy of NFPA79 which is the bible for control systems for machines made in the US. Canadian standards are a little more rigourous but I think you will find that your machine controls are woefully inadequate, and its highly unlikely there is anything inexpensive you can do to "fix" it, unless the machine has been designed to these standards.

Your best bet is to just tell the customer that what they ought is what they get and it is their problem if they buy something without understanding what they bought (although this would obviously need to be done in a more tactful
way then I have put it). Unless the controls have been specially designed to meet US/Canadian standards, it just won't because European standards are so much less rigourous.

And BTW, unless I am seriously mistaken, the report you are refering to has to be made by a registered PE in Canada and basically states that the machine is in accordance with all the Canadian requirements. I do not believe you
can just sign a letter to this effect, particularly since you obviously do not have a clue what those requirements are (not to be mean or anything, but its just obvious).

Bob Peterson
 
M

Michael Griffin

mike wrote:
<clip>
>I am working on a project that has seen 2 systems of machinery imported to
>Canada from Switzerland..I have recieved a document from the customer
>asking if the systems comply with CSA under section 7 of the regulations
>for industrial establishments......This states, I have to make a report
>that shows the apparatus and protective elements have been both purchased
>and manufactured to meet current applicable standards I take it this has
>to come from the Swiss company that made the equipment.....I know they
>operate to UL and CE standards but these are the first systems to be
>imported to Canada so they possibly dont know the specs for CSA what are
>the differences.....And what should I write Circuit breaker
>references,earth bonding,earth leakage,and does this include the cover
>protection system and NOT stop system....regards mike
>
<clip>
"Section 7 of the regulations for industrial establishments" is not a CSA standard (although it makes use of such standards), nor is it solely (or even primarily) concerned with electrical issues. Rather, section 7 is a
section of the Ontario Health and Safety Act and applies to equipment in a workplace in the Province of Ontario. Your customer is expected to have a report that states that the machine meets all relevant requirements regarding the safety of equipment. One of these requirements is that the
equipment has passed a special inspection of the electrical system. Most of the requirements concern machine guarding, lock-out, and other similar issues though.

The actual report though must be written by a qualified person ("qualified" as defined under the act). These reports are normally prepared by an engineering company which specialises in this subject and can be expensive. One of the things the perons preparing such a report will look at is whether the electrical system has passed a special inspection. You
yourself cannot perform such a special inspection. You will need to provide a complete set of electrical schematics in order for a special inspection to be performed though.

I believe that you need to clarify what is expected of you. Are you being asked to produce a section 7 report of the entire machine, or are you being asked to arrange a special inspection of the electrical system which will be used in such a report? These are two completely separate issues.

I also suggest that you review what your contract with your customer required of you. The "employer" (your customer) is required to have such a report. You are not not legally required to provide it, unless it was stated
so in your contract. If you do not provide one, the customer would have to arrange for a report from a qualified company at their own expense.

If this report was not provided for in the original contract, then it is up to you whether you feel your relationship with your customer means you should still undertake to pay for this.

We had a discussion of something which included this matter on the 2nd of August under the subject "Re: INFO: CUL and Ontario Hydro". You may wish to refer to this in the archives for more information.

If you can clarify what you are being expected to provide (a section 7 report, or an electrical inspection), I can perhaps make some more specific suggestions.



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Michael Griffin
London, Ont. Canada
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M

Michael Griffin

Mr. Peterson was rather kind to offer his advice to "mike <[email protected]9.co.uk>" with regards to this subject, but I thought that his comments perhaps needed a bit of clarification on several points. I have included Mr. Peterson's points with some additional comments of my own which I hope that "mike" will find helpful.

Bob Peterson wrote:
<clip>
>First off I would make sure of what they are asking. If they are asking
>only that the machine controls meet the CSA electrical specifications (which
>is probably what they are asking) you are probably out of luck. Most
>European machines are poorly designed (electrically and control wise anyway)
>by US/Canadian standards and would never make the requirements.
<clip>

Perhaps Mr. Peterson has had some particularly bad experiences, but I've really had no more difficulty with European equipment than with American equipment. Describing equipment as "European" may be overly broad though, as there seems to be a considerable difference depending upon which actual country it came from.

>Even if the
>components meet UL standards, they won't meet CSA standards, unless the
>components are all labeled CSA or CUL.

There is some difference between not meeting a standard, and not being certified to meet a standard. CSA goes to great lengths to avoid creating any new standards of their own. Rather, they look around for an existing standard elsewhere in the world and try to adopt it. The objective is to avoid creating unnecessary barriers to trade. Only if there is no suitable standard already existing somewhere will they attempt to write a new one.

What these means is that a component may "meet the standard" without being certified to do so. The question then becomes whether it is more economical to dig up the relevant test data, or to simply replace the component with a certified one. Transformers and power supplies can cause the most trouble here.

In some cases with certain types of components, the inspector can conduct certain tests himself to make a ruling on it. We have had to do this with some American components (weld controls, instruments) which will sometimes have no certifications of any type.

Generally though, it is simply easier and more economical to use components which are certified to CSA standards. This is easy to do, as
virtually all the major automation component manufacturers sell their hardware in Canada, and consequently have taken the trouble to have most of their product line certified. For example, the Entrelec terminal blocks which I use are made in France and are sold everywhere. You just need to be careful which product models you select as some are *not* certified.


>Secondly, there really is no such thing as a CE standard. Its really your
>statement that the machine meets ALL the required European standards and is
>meaningless in the USA or Canada. Its actually quite meaningless in Europe
>as well, other then as a dodge to restrict imports (which is all it really
>is).
>
>I would start with a copy of NFPA79 which is the bible for control systems
>for machines made in the US. Canadian standards are a little more rigourous
>but I think you will find that your machine controls are woefully inadequate,
>and its highly unlikely there is anything inexpensive you can do to "fix" it,
>unless the machine has been designed to these standards.

If are interested in the Canadian electrical code, I would suggest a copy of the Canadian Electrical Code which is published by CSA. Get the version which comes with explanations as this can be a great help in
deciding whether a rule applies to a particular situation.


>Your best bet is to just tell the customer that what they ought is what they
>get and it is their problem if they buy something without understanding what
>they bought (although this would obviously need to be done in a more tactful
>way then I have put it). Unless the controls have been specially designed to
>meet US/Canadian standards, it just won't because European standards are so
>much less rigourous.

I would like to mention that if a machine meets American standards (electrical code), it won't necessarily meet Canadian standards as the two are not the same. With a bit of care though, you should be able to design most typical equipment to meet European, Canadian, and American standards. I'm not at all sure what the situation is in Japan, so I won't attempt to
comment on them.

It would be nice if everyone would work towards a single set of global standards. I think any sort of "regional standards" would be a step
backwards rather than an improvement.

As to what the customer bought, that is a matter of what was in the contract, and I can't advise "mike" on that.

>And BTW, unless I am seriously mistaken, the report you are refering to has
>to be made by a registered PE in Canada and basically states that the machine
>is in accordance with all the Canadian requirements. I do not believe you
>can just sign a letter to this effect, particularly since you obviously do
>not have a clue what those requirements are (not to be mean or anything, but
>its just obvious).
<clip>

My above comments discussed electrical inspections. Now we are to the meat of the issue. Mr. Peterson is correct in that an electrical
inspection is not a "section 7 engineer's report" (also known as a PSR), and that you cannot provide either. Any "letter" you may write is meaningless.

The question then becomes:
a) Who arranges for the electrical inspection and engineer's report?
b) Who pays for them?
c) Who is responsible for correcting any deficiencies?

I have discussed this subject to some extent in a previous letter, but I think some additional background information may be helpful in dealing with your customer.

Matters relating to health, safety, employment, and other similar subjects are the responsibility of each province. Section 7 applies to the Province of Ontario and refers to a section of the Ontario Health and Safety
Act. I'm not sure what the equivalent regulations in other provinces are, but Ontario has by far the greatest concentration of population and
industry, so most European companies would be dealing with customers located in Ontario.

For many years, workplace safety in Ontario has been based on something called a "responsibility" system. Everyone who works in Ontario, from the loftiest company director to the lowliest employee has certain responsibilities assigned to them with regards to safety. Violations of the Ontario Health and Safety Act can carry penalties of up to two years in jail, and fines of up to $500,000. The Ontario Ministry of Labour is responsible for enforcing the provisions of the Act.

Recently (within the past couple of years) there has been a change in how the Act is enforced. Rather than having the Ministry of Labour inspectors simply investigating accidents and handing out punishments, the "section 7" ammendments to the act require an "employer" to aquire an engineer's report to prove that the equipment is safe before it is used.

When the new provisions were introduced, there was considerable confusion as there were no guidelines issued with them to tell how this
system was to work in detail. Things are beginning to go more smoothly now though, and the provisions are beginning to "bite".

Many people though are still unfamiliar with the process. If your customer sounds confused and uncertain about what is required, quite likely they are. To be clear, the "employer" (your customer) is obligated to *have* such a report. This does not mean the company selling the equipment (you) is required to provide such a report. Your customer can choose to arrange this (as well as the electrical inspection) themselves.

Most customers typically require such a report (and electrical inspection) to be provided with any new equipment by the equipment vendor as
part of the contract. The reason for this is to ensure that the responsibility for correcting any deficiencies rests squarely with the supplier.

If you find that under the terms of your contract you can decline to provide the requested report, you may still have a few problems. If any
deficiencies were found in the equipment, your customer will likely ask you to make good on them. The normal procedure is to consult the company who will be preparng the report early in the design process to ensure that the design will meet the requirements before it is built. This is another reason for the supplier to arrange for the report.

If you find yourselves arranging for an engineer's report, you may wish to ask your customer to recommend a company who can do this.



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Michael Griffin
London, Ont. Canada
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