What is a Field Evaluation (AKA UL Recertification or Third-Party Approval)?
The National Electrical Code (NEC) requires that installed equipment be approved. The ideal method of demonstrating approval has always been for equipment to bear a listing mark from a Nationally Recognized Test Lab (NRTL – UL, CSA, TUV, etc.). However, when equipment is unlisted or modified from its original listed configuration, field evaluations and field labeling become the only viable alternative.
The NEC defines Approved as acceptable to the Authority Having Jurisdiction (AHJ). Until recently there were no accreditation programs for Field Evaluating Entities. Since many AHJs were familiar with NRTL listings and because it was the only yardstick for competency at the time, many AHJ’s began to require that field evaluations also be performed by NRTLs. As it became apparent that OSHA’s NRTL accreditation does not necessarily translate to competency for performing field evaluations, the National Fire Protection Agency (NFPA) wrote a standard for assessing the competency of Field Evaluation Bodies (FEBs). That standard is NFPA 790. Once that came out, accreditation bodies were able to properly assess and accredit FEBs for performing field evaluations. The FEB accreditation is currently the only credential that ensures oversight of a field evaluation program.
What is the Difference Between Field Evaluation and NRTL Listing?
Field Evaluation approvals often get confused with NRTL Listings/Certifications, so what is the difference?
An NRTL Listing is a factory level certification type where the evaluation of a representative test sample is conducted in a laboratory setting. Once the listing is issued, the manufacturer is permitted to apply the NRTL label on equivalent products at the factory. The factory is subsequently subject to ongoing periodic surveillance inspections.
Much like an NRTL listing, a field evaluation is intended to address safety hazards, most notably the risk of fire and shock. Other hazards may also be considered depending on the equipment type. Because of the limitations encountered with testing in the field, field evaluations typically rely on constructional requirements to provide a minimum level of safety. The requirements for safety are found in nationally recognized standards. A field evaluation is conducted to one or more nationally recognized standards applicable to the equipment under evaluation.
In contrast to an NRTL listing, a field evaluation is a one-time, installation level approval. The evaluation of the product(s) is intended to be conducted at the installation site. Since it’s conducted where the equipment is intended to reside, a field evaluator can identify the requirements in the standard that are applicable to the specific use environment. If the product is found to be compliant with applicable requirements the FEB applies a field label on the product. A field evaluation requires that:
- The Field Evaluation Body (FEB) is approved by the Authority Having Jurisdiction (AHJ).
- The product is evaluated in the field.
- Testing is conducted based on conditions encountered in the field.
- A report describing critical features and installation location is generated.
- A Field Label is applied by the FEB in the field.
Because they are different processes with different requirements, a field label is different than an NRTL listing label. A field label typically has the words “Field Evaluated” printed on it. See example below:
Who Requires Field Evaluations?
A Field Evaluation is generally required by an Authority Having Jurisdiction (AHJ) e.g., city inspector, utility, or other government agency. If the AHJ requests an outside evaluation, they will generally refer to the outside entity as a third-party. If third-party approval is requested, that is equivalent to a field fabel. A field evaluation could also be a customer requirement to confirm that equipment in the workplace meets a minimum level of safety. This last type of requirement would generally be part of the product’s purchase agreement.
When can a Field Label be Used in Lieu of an NRTL Certification Label?
An NRTL Listing can take several months to complete and is many times the cost of a Field Evaluation, so this question is worth asking. As previously mentioned, many people are not clear on the differences between field evaluations and NRTL Certifications. We find that most of the time the intent of a customer driven requirement is to have a credible, recognized, certification entity confirm that the product or limited production run meets basic safety requirements. In these cases, a field type of certification will generally suffice.
Does it Matter Who Performs a Field Evaluation?
Although NRTL mark recognition by potential customers provides some listing marks with greater acceptance, the same is generally not true for field labels.
A field evaluation is conducted when a product is already installed or about to be installed. At this point, the players are generally fixed: The customer, the building department, and the utility are all known. When it comes to selecting a Field Evaluation Body (FEB), the main question is: are they acceptable to the requesting party? This is generally easy to confirm. Once an FEB is confirmed to be acceptable, the remaining decision-making factors become more familiar: cost, availability, easy to work with, etc. Don’t limit yourself to the brand name options; smaller FEBs can be more flexible and cost effective.
G&M Compliance’s Credentials and Capabilities
G&M is accredited for Competency of Field Evaluation Bodies (FEBs) outlined in NFPA 790 by International Approval Services (IAS), one of the leading accreditation bodies in the United States. We follow NFPA 791 the standard for Recommended Practices for Equipment Evaluation. For more information on our accreditation see our IAS Online Certificate. Most importantly to our customers and local jurisdictions alike, G&M is a team of seasoned veterans, with experience to understand the intent of the specifications, and apply the concepts across a variety of equipment and installation conditions.
G&M field engineers have the experience and expertise to competently assess equipment in the field, and to quickly ascertain if it meets the intent of applicable safety standards. G&M specializes in the following areas:
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Recertification of UL Listed Switchgear
Almost all switchgear installed in the U.S. is UL Listed. Modifications made to an existing UL certified piece of switchgear invalidates the original listing. As a result, both utilities and local electrical inspectors will require a field inspection or recertification of panels where bus taps are made on the line or load side of the main circuit breaker. G&M has evaluated many different types of switchgear modifications. We will assist during the planning stage, so as to avoid surprises during the power shut-down. To see our blog regarding recertification requirements from the UL standard for switchgear, see Part I (UL 891 Requirements). To see our blog on NEC requirements click on Part II (NEC Requirements), and to see our blog on utility requirements, click on Part III (Utility Requirements).
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Third Party Approval of Factory Equipment
Machinery and industrial equipment generally do not carry NRTL certifications even if they are made here in the states. This is due to the limited production and the expense of listing large, complex equipment. This type of equipment is often “Red-Tagged” by building inspectors when moved into a new facility, even if it is brand new. We have worked on equipment from all over the world and always try to use a common-sense approach in evaluating the safety of these types of products.
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Field Evaluation of Products from Asia
Industrial products built in Asia, and particularly China, often are not NRTL listed or designed to meet U.S. safety requirements. Unlisted products are frequently Red Tagged by local electrical inspectors which prevents their use until a safety evaluation is performed. To avoid expensive delays and the costs of retrofitting and customization of equipment on site, it is best to have a compliant product delivered from the factory. G&M has an office in China with engineers that can perform preliminary field evaluation assessments. Our local field inspection experts in the U.S. work with our engineering team in China to communicate mandatory U.S. requirements and bring products into compliance before they ship.
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