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 and design, CE Marking evaluations, and general engineering safety consulting questions.

Question:

Hi Lewis Bass,

I recently had a machine fail a third party electrical evaluation in my facility. While I understand how to fix and address the other items that were found to be non-compliant, one of the failures was unusual to me because it references my machine’s nameplate not being durable enough for the environment it is being used in (a clean room). Is this something that your company would also flag my machine for as a non-compliance as well?

 

Asked by Morgan in Fremont, CA

Lewis Bass:

Yes, we would.

This non-compliance comes up often in our evaluations of unlisted machinery that is usually of a self-made or custom nature to a particular client’s use case. Often times in the course of our evaluations we have seen situations where a machine’s nameplate is not even present and even others where a white adhesive sticker has been haphazardly placed on the unit with sharpie pen answers scribbled on it.

In your case, I can only surmise that the label may be seen as temporary or of a type of material that may not withstand the environment in which it is being used. In this case, a clean-room with lots of air circulation and a controlled environment. We often times recommend to our clients to laminate or engrave their machine nameplates to fix this non-compliance.

If you are curious as to where this requirement is specified in NFPA 79, please reference NFPA 79-2021 16.1.2, which states that: Safety signs, nameplates, markings, and identification plates shall be of sufficient durability to withstand the physical environment involved. It must be noted that shall is used in this section, which means it is not a suggestion but a requirement per your local AHJ.

 

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