Welcome to another blog in our ongoing series, Ask Lewis Bass!

This series features actual submitted questions from companies in the industries we provide engineering safety consulting services to.

Topics covered include those associated with our work in 3rd party field labeling, SEMI S2/S8/EMC/F47 testing, CE Marking evaluations, and general engineering questions.

Question:

Hi Lewis Bass,

We recently had some of our company’s legacy production equipment pre-evaluated for NFPA 79/791 compliance prior to our planned move to a new facility later this year. Unfortunately, in the course of these pre-evaluations, we ran into some problems with some non-compliances on a few pieces of our equipment that we need to address to receive our field labels and reports for the city at our new location.

One of the key issues brought up in our list of non-compliances that we need to address concerns the removal of “Start / Stop” switches and the recommended installation of an EMO or E-Stop. Is this a critical path for Field Labeling pursuant to NFPA 79:2024?

In NFPA 70 (National Electrical Code) items that are required are phrased as “Shall”, we can provide these items, however it will introduce more complex controls to our machines to achieve this functionality, and this seems not to be required. Is this a NFPA 79 requirement or another evaluation standard requirement that can be worked on once installed at the new site?

Asked by Ricardo in Santa Clara, CA

Lewis Bass:

Hello Ricardo,

Yes, “recommended” is just a suggestion from the engineer performing that field evaluation service on your equipment. For legacy machinery already in service, engineers tasked with performing field evaluations can only recommend unless they see gross negligence. When a Lewis Bass engineer performs a field evaluation, our recommendation in situations like this is more based off of OSHA 1910.147 and what we see in our industry in general. For a handy resource on this topic please read this article here. While this non-compliance won’t necessarily be a show stopper from your getting an NFPA 79 Field Label from that engineer that performed the work, remember that the final say remains with the AHJ in your city and if he/she is accepting of this non-compliance in the final field report for those affected systems.

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