NRTL Inspections are not Field Label Evaluations
The sales team at Lewis Bass often receives calls from interested clients asking about our “NRTL Inspection” services.
What they really mean to say (and are actually referring to) is a, “Third Party Electrical Evaluation” also known in our industry as a field label evaluation for unlisted equipment.
It is quite easy to see how this can get confused given the variety of machinery certifications out there, so this blog is being published to confront this discrepancy and describe the difference between a NRTL Inspection and a Field Label Evaluation.
The main reason behind this confusion lies with the fact that there are two primary participants in the engineering safety consulting industry that offer the same services of field labeling for unlisted equipment: Field Evaluation Bodies (FEB) like Lewis Bass and Nationally Recognized Test Labs (NRTL) like TUV, QPS, and Eurofins/Metlabs (that’s where NRTL inspections comes from).
Now, let’s go over the differences between FEBs and NRTLs below.
An LBIES Engineer Performing a Field Evaluation
Field Evaluation Bodies Only Evaluate Unlisted Machines
According to the official NPFA website a Field Evaluation Body evaluating unlisted equipment must follow NFPA 790 standards:
Installed electrical equipment that has not been previously certified, listed, recognized, or classified undergo a “field evaluation” to ensure compliance. This standard provides qualifications and competencies for third parties performing field evaluations and specifies how they are to be completed.
There are two sets of guidelines from the NFPA that FEBs adhere to in performing their work on behalf of AHJs:
- NFPA 790, which guides our company’s management process.
- NFPA 791, which guides our third party electrical evaluation processes.
To qualify as an approved Field Evaluation Body there are requirements and documentation requests from the FEB that need to be met before being cleared to provide these services on behalf of local AHJs. These application documents are reviewed for approval to allow that FEB to conduct third party electrical evaluations in that AHJ’s region.
While any NRTL applying for permission to provide a field label evaluation must also do the same, an NRTL lab is also not limited to just this evaluation function.
For example, if a machine has been previously listed by an NRTL and the label is found to be missing or another listed component is removed and replaced with a similar, also listed component, an NRTL can perform an inspection on the machine at that facility without notifying the AHJ in that particular city or county.
FEBs are not allowed to perform services along these lines and must also work on behalf of the local AHJ as the neutral 3rd party between the AHJ and the FEB’s client. The AHJ also requires a formal report of the electrical evaluation per tool evaluated by the FEB.
FEBs Cannot Address Found Non-Compliance in Machines
In certain situations when a non-compliance is found in the components of a machine or combinations of listed machines, a FEB cannot perform the work necessary to bring that machine to compliance. As, per NFPA 790 5.2.7 guideline:
The FEB shall not engage in the implementation or design of corrective measures resulting from evaluation of a product.
NRTLs, however, can evaluate unlisted machinery AND conduct the fixes deemed necessary to bring the machine to full compliance with the local AHJ.
An LBIES Field Label for evaluated equipment
Nationally Recognized Test Labs Can Inspect and Evaluate Unlisted Machines
NRTLs like QPS can both inspect qualified existing or newly-manufactured machinery in actual lab conditions (think earthquake shakers, liquid/acid baths, etc) and also evaluate unlisted machinery as an FEB would in the field.
When a request for a NRTL inspection is asked in our industry by potential clients we must narrow down the request by asking the following questions:
- Is the tool already listed by a known NRTL lab (qualifies for a re-inspection/labeling by the same lab)?
- Does the tool have a previous label on it from another FEB?
- Are the components in the machine/combination of machines NRTL-listed?
- Is this tool being installed in its final location with no expectation of being moved in the near future?
Once we have received answers to the above questions we can either direct the client to our field label department at Lewis Bass for a field label evaluation quote or we can refer them to our trusted partners QPS or Eurofins/Metlabs for an LPC evaluation or an in-field re-labeling for compliance with the local AHJ requiring the inspection.
An example NRTL (QPS) Field Evaluation label for evaluated equipment
Lewis Bass is here to help if you need equipment evaluated for compliance.
Are you uncertain if your equipment is unlisted or not at your facility?
Lewis Bass has you covered! Download our free unlisted equipment self-identification flyer here.
Do you have a need for an urgent machinery evaluation?
Please reach out to us using our contact form here or call us directly at our office line 408-942-8000. We are always available to help with rush jobs and permit-blocking safety situations at your facility.
