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October 18, 2018

NFPA 70E-2018 Conformity Assessment–What Does it Mean?

NFPA 70E Electrical Safety in the Workplace made a change in 2018 that directly affects PPE and how conformity may be determined.

The mandatory requirement is a little different from the previous versions in the following ways:

  1. The standard now requires that the level of conformity be issued by the manufacturer; it can be level 1, 2 or 3.  ANSI/ISEA 125 is cited as a reference for conformity assessment, but it is a non-mandatory citation.
    1. Level 1 is self-declaration of conformity—this is the least stringent and what has historically been used for arc flash PPE.  This allows the garment manufacturer to make the claim that a garment meets all requirements of any listed standard (ASTM F1506 or IEC 61482-2 are common for clothing) and requires minimum testing intervals of 5 years, or as required by the specification used.
    2. Level 2 requires accredited test data and a registered quality management system (if you are using the ANSI/ISEA 125 document, this means using an ISO 17025 accredited laboratory and having an ISO 9001 QMS)
    3. Level 3 (most-stringent) requires third-party certification which includes testing and site audits (for example; what is currently required for compliance with NFPA 2112). Some companies have been putting NFPA 70E in a label with only an arc rating test (ASTM F1959) without fully meeting ASTM F1506; the added levels of conformity assessment may make it more challenging for manufacturers to label compliance without full test results.
  2. Previously, the requirement was to evaluate to a specific standard (like ASTM F1506), but the level of conformity required was deferred to the ruling ASTM standard body. Certification to NFPA 70E is not recommended since it now has VERY limited PPE requirements (no flame tests, etc). Compliance should be determined after evaluation to standards appropriate to the hazard listed in Table 130.7(C)(14) Informational Note: Standards For Personal Protective Equipment.  This includes footwear, insulated PPE, and arc flash PPE.  The committee indicated that they wanted to assure all testing was occurring which is why all three levels were allowed.  The standards listed for most of the PPE in the table have NO third-party certification requirements.
  3. All non-NFPA standards have been removed from the mandatory language to allow local, provincial/state and federal standards to rule, but the ASTM standards are still present in informational notes for guidance. This also allows for manufacturers to use the IEC equivalent and still comply with NFPA 70E. Be aware that IEC has a limited amount of published arc flash standards, but our company participates in all of the IEC arc flash standard development and the IEC TC78/WG15 is working diligently to address and cover all arc flash PPE.
  4. It is important to note in specifying PPE that at the time of this post, NONE of the following PPE products were available as “third-party ISO 17065 certified products” (as of October 2018)
    1. No arc rated balaclavas
    2. No arc rated face shields
    3. No arc flash suits or arc flash hoods
    4. No arc flash protective gloves
    5. No rubber insulating gloves
    6. No hot sticks
    7. No footwear
    8. Little or no arc flash fall protection

5. There are NO IEC standards for arc flash gloves, face shields or hoods. Compliance for these products should be chosen based on the ASTM standards until the IEC draft standards enter the market through publication in the next few years.  Almost all the garments in the non-EU market are currently Level 1 certified since ASTM ruling standards allow self-declaration for compliance.

6. Other levels of certification are VERY rare today in arc flash PPE, so beware of citing a specific level unless you want your choice to be VERY limited. Currently from the US market, there are 8 small manufacturers which are certified by a “Third Party Certifying” body (one which meets ISO 17065 and uses ISO 17025 lab competence). We recommend vetting your supplier and checking for the use of ISO 17025 lab data for arc and other testing in any self-certifed product.  Many of the top US suppliers have in-house ISO 17025 accredited labs, but all arc ratings will come from an ISO 17025 test lab like ours or Kinectrics.

7. We issue ISO 17025 accredited test reports which may be used for ANSI 125 Level 1, 2 or 3.

8. The appendix contains a short outline of the three levels as required by ANSI 125 National Consensus Standard for Conformity Assessment of Safety and Personal Protective Equipment.

 

One relevant section from NFPA 70E-2018 is as follows with an additional annex:
“NFPA 70E 130.7(C)(14)

(a) General. PPE shall conform to applicable state, federal, or local codes and standards.

Informational Note No. 1: The standards listed in Table 130.7(C)(14), which is part of this Informational Note, are examples of standards that contain information on the care, inspection, testing, and manufacturing of PPE.

Informational Note No. 2: Non–arc-rated or flammable fabrics are not covered by any of the standards in Table 130.7(C)(14), Informational Note. See 130.7(C)(11) and 130.7(C)(12).

 

(b) Conformity Assessment. All suppliers or manufacturers of PPE shall demonstrate conformity with an appropriate product standard by one of the following methods:

(1) Self-declaration with a Supplier’s Declaration of Conformity

(2) Self-declaration under a registered quality management system and product testing by an accredited laboratory and a Supplier’s Declaration of Conformity

(3) Certification by an accredited independent third-party certification organization

Informational Note: Examples of a process for conformity assessment to an appropriate product standard can be found in ANSI/ISEA 125, American National Standard for Conformity Assessment

of Safety and Personal Protective Equipment. See Informative Annex H.4.

(c) Marking. All suppliers or manufacturers of PPE shall provide the following information on the personal protective equipment, on the smallest unit container, or contained within the manufacturer’s instructions:

(1) Name of manufacturer

(2) Product performance standards to which the product conforms

(3) Arc rating where appropriate for the equipment

(4) One or more identifiers such as model, serial number, lot number, or traceability code

(5) Care instructions

 

We have seen very few fakes or non-conforming garments on the market in the US (most non-conformance we have seen in the US market has been label mistakes rather than failing fabric).  The trade off in third party certification is that it limits choice of all products but especially specialty products because the start up cost means that adequate volume has to be in place to justify the certification and ongoing auditing requirements.

We recommend an end user look at the options, specify a level of conformity ONLY after deciding the best product and with consult from the manufacturer.  Pay careful attention to accredited test reports.  This prevents most issues. Lastly, choose quality manufacturers, our legal system and the market does an excellent job of “policing” the market in the US.  Report any issues to the test lab which performed the testing and the customer.  We also work to police the industry.

 

See the PPE Suppliers who use ArcWear for testing.  We are happy to review for end users any test reports from us and verify the fabric and the report.

Arc Rated PPE suppliers of repute

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