Ask Lewis Bass: Another Question About Field Labeling

Ask Lewis Bass: Another Question About Field Labeling

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.


Hi Lewis Bass,

I’m building a custom machine that I’ll be shipping out to the east coast next month and my client is asking me to have the machine evaluated for NFPA 79 compliance by a FEB or an NRTL. What does the process for evaluation look like if I’m building and testing the machine in my facility and then shipping it for use in a completely different location/jurisdiction?

Asked by Quentin in San Jose, CA


Lewis Bass:

This is a great question, Quentin.

Companies like Lewis Bass (FEBs) take a two part evaluation approach here.

First, we would draft up a proposal for services for a pre-evaluation of the machine at your facility. This would allow our engineering team to evaluate the compliance of the machine and notify you and your engineering team of any glaring non-compliances that would preclude the machine from successfully passing and gaining a field label. It’s best to have this type of pre-evaluation done at your facility before shipping to a client’s site as the non-compliances can be more readily addressed and mitigated ahead of shipment.

If any non-compliances are found with the machine, our engineering team will provide a punch-list of the items found to not be in compliance and will help guide your team toward fixing them. It must be noted that FEBs like Lewis Bass cannot fix non-compliances on a machine as according to NFPA 790’s design review section:

  “the FEB shall not engage in the actual design or completion… [and] actions shall not be performed by the FEB”

Lastly, once the punch-list items are addressed and the machine is found to be compliant, we will provide a proposal for a final field label evaluation at your client’s facility. This is where our engineering team will verify the equipment is installed in its final location and where we will perform our electrical evaluations to determine that the machine is in compliance and is safe to operate. We will then label the machine and submit our report to your client’s local AHJ/City.

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