This document has been prepared to set out the guidelines /rules regarding the differences between ‘Ex equipment’ and ‘Ex component’, in regards to the use of empty flameproof Ex d enclosures by third parties to manufacture Ex equipment.
It has been noted that certain service facilities have been purchasing empty flameproof enclosures, fitting and wiring the electrical equipment and supplying ‘new’ explosion protected equipment into the industry.
This practice is in breach of the IEC Ex standards and scheme. Whilst it might not be a safety issue, it is like driving a car on a public road without a license. It is not necessarily going to make the roads unsafe, but it is against the law and a criminal act attracting penalties.
The following scenario can be used to illustrate what is happening in the industry:
1. Company ‘A’ is a manufacturer, has a QAR and is the holder of an IECEx equipment certificate for an Explosion protected product. (Flameproof Ex d).
2. Company ‘B’ is a separate company registered as a service facility.
3. Company ‘A’ manufactures an Ex d. enclosure and sells the empty enclosure to company ‘B’.
4. Company ‘B’ installs the internal electrical components, completes the electrical wiring and conducts functional tests.
5. When complete, company ‘B’ sells this Ex equipment to the end user using the original company ‘A’s certificate number and marking label.
Extracts from standards, Coal Mines Health and Safety Act and Gazette No. 10. Extracts available from the ExTA website: http://www.exta.org.au/
The scenario provided in the example above is in breach of the IECEx rules due to the following;
· As company ‘A’ sells an empty enclosure to company ‘B’, company ‘A’ is classed as a supplier and the empt
Therefore, company ‘A’ is required to have an Ex component certificate (identified by the suffix ‘U’) for this enclosure as they are selling an empty enclosure. The enclosure in question is not certified as an Ex component.
· Company ‘B’ is considered to be a manufacturer as it is manufacturing Ex equipment using an Ex component obtained from another manufacturer. If an empty enclosure with an Ex component certificate is supplied to a third party, this does not eliminate the need for an Ex equipment certificate to be obtained by the third party.
· As company ‘B’ is classed as a manufacturer of Ex equipment it must have its own QAR and be the holder of a Certificate of Conformity for the end product, now Ex equipment. Company ‘B’ does not have a QAR. Company ‘B’ does not own any Ex certificates for the product supplied. Company ‘B’ is not listed as a manufacturer on the Ex certificate. The end product is labelled with the original company ‘A’s Ex equipment certificate number.
· This is in contradiction to the standards and the Ex certificate.
The new Ex equipment certificate as required above, will identify the empty enclosure as an Ex component by the Ex component certificate number.
· There is no Ex component certificate from the original manufacturer and
· There is no Ex equipment certificate for company ‘B’.
NOTE: Company ‘B’ is a service facility and not a manufacturing facility recognised by the IECEx scheme.
As the above indicates the equipment does not have a valid AUSEx, ANZEx or IECEx certificate, therefore it is in breach of the Coal Mines Health and Safety Regulations both in NSW and Queensland.