# Presentation: 932473

## NMA/MSHA Approval Workshop

- Electrical Safety Division Approvals
- May 21 and May 22, 2008

## Electrical Safety Division (ESD)

- Staff of 24
- Including Chief, Team Leader and OAA
- 21 Investigators
- 14 Engineers, 7 Technicians
- Product Approval PAR Duties
- Additional assignments include: Technical Assistance, Accident Investigations, Training, Litigation and Regulatory Support
- Explosion Gallery and Intrinsic Safety Laboratory

**Notes:**
Good Afternoon:

I’d just like to first give you a quick look at the electrical safety division here at the A&CC.  Our personnel consists of a staff of 24, which includes the division chief, the team leader, and our office automation assistant.

The technical staff consist of 21 investigators, which includes 14 engineers and 7 technicians.

Our primary focus is product approvals.  However, some of the additional assignments may include technical assistance, Accident Investigation assistance, providing training, and we could be asked to provide litigation or regulatory support

Our facilities here include the Explosion Gallery located in Building 3 and our Intrinsic Safety laboratory on the first floor of Building 1.

## Electrical Safety DivisionApproval Programs

- Part 7: Motors and Battery Assemblies
- Testing by Applicant or Third Party
- Part 18: Machine/System Approvals
- Part 18: Explosion-Proof Enclosures
- Part 18: Intrinsic Safety Instruments & 	 Circuits (I.S.)

**Notes:**
I’m going to give an overview of the processes for approval of program areas and products regulated by Title 30 CFR that the Electrical Safety Division is responsible for:

Part 7 is testing by applicant or 3rd party.  The equipment in Part 7 that ESD is responsible for is explosion-proof motors and battery assemblies.

Part 18 is titled “Electric Motor-Driven Mine Equipment and Accessories.”   Part 18 products include continuous miners, longwall mining systems, pump systems, and explosion-proof enclosures.

Testing for intrinsically safe instruments and circuits is referenced in 18.68, but the ESD has developed a criteria for evaluating electrical apparatus whose circuits are intended to be intrinsically safe as required by Title 30 CFR.  

## Electrical Safety DivisionApproval Programs

- Part 19: Cap Lamps
- Part 20:  Electric Mine Lamps other than Standard Cap Lamps
- Flashlights
- Part 22: Portable Methane Detectors

**Notes:**
Other Electrical Safety Division responsible approval programs include Part 19 cap lamps, Part 20 “Electric Mine Lamps other than Standard Cap Lamps” such as Flashlights.  Basically Part 20 evaluation is the same as for cap lamps, except there is no performance evaluation.

Part 22 Portable Methane Detectors.

## Electrical Safety DivisionApproval Programs

- Part 23: Telephones and Signaling Devices (Communications and Tracking Devices and Systems)
- Part 27: Machine Mounted Methane Monitors
- Part 28: D.C. Fuses
- Other Programs

**Notes:**
Part 23 Telephones and Signaling Devices, and Part 27 Machine Mounted Methane Monitors, and Part 28: Fuses for use with Direct Current in Providing Short-Circuit Protection for Trailing Cable in Coal Mines

Where these products are also required to be intrinsically safe, they are subject to the intrinsic safety criteria, otherwise known as ACRI2001.

Last bullet:  I’ll also briefly talk about some other approval programs that we are responsible for in the ESD.

## Part 7 Motors and Battery Boxes

- Testing by Applicant or Third Party
- Applicants Submits Certified Statements
- Compliance with Design Specifications
- Compliance with Test Requirements
- Quality Assurance
- Third party laboratory evaluations
- Test Observations
- MSHA observes first test and any additional testing deemed necessary

**Notes:**
The purpose of 30 CFR part 7 is to provide requirements for MSHA approval for certain equipment and materials whose product testing and evaluation does not involve subjective analysis.  The drawings and documentation are still evaluated by ESD personnel for compliance with the applicable regulations and policies.  However, any required testing is performed by either the applicant or a 3rd party of the applicant’s choice.  Products are tested using applicable test procedures, and MSHA may elect to observe product testing.  Applicants are required to maintain records of test results and procedures for 3 years.

These “certified statements” are required for all applications for approval.  The applicant is certifying that the product meets the appropriate design portion of the technical requirements, that the applicant will perform the quality assurance functions specified in §7.7.  After completion of testing, the applicant certifies that the product has been tested and meets the performance portion of the technical requirements.

The regulation requires MSHA to witness the first product testing conducted by the applicant or laboratory and any subsequent testing until confidence is achieved.  One common pitfall, for example, relative to battery boxes:  Even though an applicant is using a flame-resistant insulation material, if this is their first application, they are required to do acid resistance testing and MSHA must witness it.   We are looking for their ability to apply the material.

## Machine/System Approvals

- Continuous mining machines, shuttle cars, scoops, high voltage longwalls, etc.
- Machines are evaluated for compliance with 30 CFR Part 18
- Typically consists of X/P enclosures and I.S. Circuits
- Factory/field inspection is required after completion of the drawing evaluation
- High voltage longwall regulations §18.53
- Compliance guide on _[http://www.msha.gov/](http://www.msha.gov/)_

**Notes:**
Machines and system approvals that are accepted under Title 30 CFR Part 18 include continuous miners, continuous haulage equipment, fans, pumps, roof bolters, shuttle cars, longwall mining machines, etc., and also battery powered mobile equipment such as scoops, permissible personnel carriers.

This equipment is evaluated using the regulations cited in Part 18, and also any applicable policies, criteria or test procedures.

An inspection by the MSHA A&CC investigator of the equipment is normally required; however, this may be waived if similar equipment built by the same approval holder was previously inspected and no significant changes have been made.

New regulations for high voltage longwalls were promulgated in March, 2002.  A&CC published a compliance guide and addendum to assist applicants.  This is posted on the main msha.gov page on the internet under compliance assistance, then compliance guides.

## Explosion-Proof (X/P) Enclosures

- Designs are evaluated for compliance, certified to Part 18
- Enclosures are inspected and explosion tested unless similar to a previously tested enclosure
- Simplified drawings are acceptable in lieu of production drawings
- Certification does not authorize applicant to advertise product as MSHA approved
- MSHA can accept test results for IEC 60079-1 (flameproof enclosures) provided additional requirements are met

**Notes:**
Certified using applicable regulations of Part 18, including our policies and test procedures.

First, the designs are evaluated for compliance by the investigator’s review of the drawings and verifying sufficient documentation has been submitted.  Then, once the drawings are determined to be in order and all requirements have been met, a test sample is requested. Arrangements are made to have the enclosures or connector inspected and explosion tested here at the A&CC in our Building 3 test laboratory.  If the applicant wants to ask to waive testing based on a similar enclosure’s MSHA test results, the applicant must do so in writing and reference the particular enclosure that this enclosure is similar to.  The waiver of the test is at our discretion.  A +/- 10% change in empty internal volume is a general rule of thumb, but may not be the final determining factor.

“Simplified” drawings are acceptable in lieu of manufacturing or production drawings.  The simplified drawing format allows the applicant to display only the pertinent information for MSHA certification, whereas production drawings may contain information that we don’t need to control, or may specify details that aren’t required for permissibility.  Some examples include exact location of operators in a cover, or location of mounting feet on motors.

Certification does not authorize applicant to advertise product as MSHA approved.  Approved refers to a complete machine or assembly such as a continuous miner or communication system, whereas an X/P box or connector is used on a complete machine or assembly.

Through Part 6, MSHA can (and has) accept test results for IEC flameproof enclosures provided additional requirements are met.  The deviations from IEC 60079-0 and 60079-1 standards are published in 18.6(i).  Some examples include the MSHA requirement that enclosures not exceed 10’ in length, and cable entries must be MSHA accepted gland entries of Part 18 or Part 7- not sealed “certified” entries as the IEC allows.

## Part 18 Intrinsic SafetyApprovals and Evaluations

- Products are evaluated to 30 CFR 18.68 and ACRI2001, “*Criteria for Acceptance of Intrinsically Safe Apparatus and Associated Apparatus*”
- The Electrical Safety Division’s most complex approval program, which routinely requires in- depth evaluation and multiple tests
- Evaluation requires thorough documentation of components and circuitry
- Intrinsic Safety FAQ document on website

**Notes:**
I.S. requirements are given in Part 18.68 and the criteria, known as ACRI2001 (under our numbering system of Center Document System).  The criteria is what we use to evaluate electrical apparatus, or parts of apparatus, whose circuits are intended to be I.S. as required by 30 CFR.  All other applicable requirements of 30 CFR must also be met.  For example, this criteria may be used for evaluating circuitry on a handheld methane detector, while performance requirements specified in Part 22 also have to be met.

Equipment that is successfully evaluated under Part 18 for intrinsic safety is given a Part 18 intrinsic safety evaluation or approval number.  

Later in the presentation I’d like to go over some helpful tips to avoid some common pitfalls, concerning intrinsic safety approval process.

## Cap Lamps

- Cap Lamps are approved to 30 CFR Part 19
- Evaluation includes drop and impact testing, and performance tests such as light output and battery life tests
- Recently added ACRI2001 to approval requirements
- Recent cap lamp designs incorporate new battery and light technologies
- Recent designs incorporate communication and tracking components – given “23-ISA” evaluation number

**Notes:**
Cap Lamps are approved according to the regulations in Part 19.  This evaluation includes includes drop and impact testing, and performance tests such as light output and battery life tests.

Recently, a Program Information Bulletin was issued that stated that it is necessary for cap lamps to meet ACRI2001, our I.S. criteria.  This was in response to advancements in technology and designs in cap lamps.  For many years, the only designs submitted for approval consisted of lead acid batteries powering a filament in the headpiece.  Recent designs have included newer battery chemistries such as nickel metal hydride and lithium ion, which include electronic control circuitry.   Also, cap lamps are employing alternate light sources such as light emitting diodes.  Cap lamps are now routinely designed to deliver power to accessories such as RFID tags (Radio Frequency identification) and personal messaging devices.   Also note that these communication type accessories are given a 23 ISA number, since they are not stand-alone devices, since they receive power from a separate device such as a cap lamp.

## Portable Methane Detectors

- Approved to 30 CFR Part 22
- Requirements include ACRI2001 and methane accuracy testing; must remain accurate after being subjected to drop test
- Must include calibration requirements
- Approved detectors are used for 30 CFR Part 75 compliance
- Multi-gas instruments: measure 02 deficiency
- Miner Act:  sampling behind seals

**Notes:**
A summary of the methane accuracy testing conducted is: 100% methane mixed with dry, conditioned air, applied to the sensor head, at mixtures between 0 and 5 per cent by volume , (0 , 1⁄4, 1⁄2, 1, 2, 3, 4, and 5), between 50 and 70 degrees F, two readings at each temperature and mixture.  Device must remain accurate after drop testing.

We also verify manufacturer performance specifications for oxygen deficiency, where multi-gas instruments include this feature.

Must include specifications of the calibration procedures and equipment such as part numbers and manuals, firmware version numbers, etc.

Based on the new regulations issued (located in Part 75) for sampling behind seals, we have recently started verifying the performance specifications for detectors capable of responding to 100% methane by volume.  These are typically infrared type detectors.

## Communications and Tracking

- Approved to 30 CFR Part 23, “*Telephones and Signaling Devices*”
- Currently the heaviest volume of applications within ESD
- Communication and Tracking applications are currently given priority
- MINER Act has ushered in new generation of technology
- Requires new acceptance considerations:
- Power supplies
- Battery capacity
- Larger batteries – off gassing concerns
- Lithium batteries – high density batteries
- RFI/Blasting Circuits

## Communications and Tracking

- Recently issued PPL No. P08-V-02
- 	_[http://www.msha.gov/regsinf2.htm](http://www.msha.gov/regsinf2.htm)_
- Addressed provisions of the MINER Act
- Provided guidelines for processing:
- Any component or system used to provide voice, text, or signaling data that is intended to remain operational in the event of emergency will be evaluated under Part 23
- Line powered devices must be provided with backup standby power (24 hrs recommended)

## Communications and Tracking

- All components operating under standby power must be I.S. or housed within X/P enclosures, including cables
- I.S. batteries of portable assemblies will be drop tested;  if >5kg, subjected to Part 7 battery requirements
- Standby power sources which include rechargeable batteries must address battery off-gassing
- Standby power source must have back-feed protection

## Communications and Tracking

- Potential for RFI (radio frequency interference) with blasting circuits must be addressed
- Tracking tags drop tested or impact tested
- Cap lamps powering Part 23 components must address performance requirements of §19.9(a); recommend providing sufficient operation capability of 10 + 4 hours
- Approval documentation must include lightning arrestors where necessary per §§ 57.12069 and 75.521; evaluated to ensure that it does not invalidate the Part 23 approval

## Machine Mounted Methane Monitors

- Certified to 30 CFR Part 27
- Must provide audible or visual warning between 1.0% - 1.5% CH4
- Must provide machine/system shutdown at 2.0% CH4
- Performance testing (500 cycle test)
- Resistance to vibration, dust, and moisture
- System and components designed to be X/P and/or I.S.

## Other ESD Programs

- Field Modifications per §18.81
- Experimental Permits per §18.82
- Ground Wire Monitor Program
- ST&E (Statement of Test and Evaluation)
- Diesel Electrics (§36.32)
- New Procedure ASAP2031
- Modifications to approved or accepted equipment (RAMP applications)

**Notes:**
Field modifications are allowed under 18.81; application must be made by the mine who desires to make changes.  Not allowed to substantially alter the basic functional design that was originally approved for the equipment.

Experimental Permits are allowed under 18.82; application must be made by the user of the equipment.  Typically used for prototype equipment of experimental nature.  Not to be used for commercially marketed equipment.  Permit expires in 6 months, can be extended for an additional 6 month period.

Ground Wire Monitor Program:  A program to approve or accept instruments that assure the integrity of the grounding conductor of trailing cables.
STE:  The Statement of Test and Evaluation (ST&E) program was developed to assist industry in meeting the illumination requirements of 30 CFR, Section 75.1719.  A mining machine or a longwall mining system does not have to have a ST&E evaluation, (as documented by a plate on the machine), but from a coal operator standpoint, the issuance of a ST&E alerts the CMS&H inspector that the machine lighting meets the requirements.  Otherwise, the inspector would need to verify proper illumination by using a go/no-go photometer.

30 CFR Section 36.32 requires electrical equipment on mobile diesel-powered transportation equipment to be certified or approved under parts 18, 20 or 27, whichever is applicable. We have evaluated Diesel Electrics applications for many years, but have recently changed the program.  Previously, we would evaluate the Diesel Electric application under the diesel machine approval.  Now, the manufacturer of the electrics can submit to us to receive a DE number.  This allows the applicant with a means of having their product evaluated by MSHA prior to its use on a permissible diesel machine.  This will allow the diesel machine applicant to specify an MSHA evaluation number (DE) and, therefore, not require a complete electrical investigation in conjunction with a diesel approval application. 

Modifications to approved or accepted equipment are completed under the RAMP program.  This applies to all of the previously mentioned program areas (except field modifications).  Applicant is required to pre-authorize expenditure of at least $800 to process the application.

## Part 6

- Independent Laboratory Testing
- Recognized by a laboratory accrediting organization
- Free from commercial, financial, and other pressures that may influence the testing and evaluation process
- Evaluation of third party product safety standards (e.g., IEC)
- Single source page available on MSHA.gov:
- _[http://www.msha.gov/Part6SingleSource/Part6SingleSource.asp](http://www.msha.gov/Part6SingleSource/Part6SingleSource.asp)_

**Notes:**
Part 6 permits MSHA to accept testing and evaluation by independent laboratories in lieu of MSHA performing their own testing and evaluation.   

Applicants have the option to use MSHA for testing and evaluation or an independent laboratory.  Also, MSHA can accept test and evaluations from any accredited laboratory – not just NRTLs.  

Part 6 also permits MSHA to approve mining products designed to non-MSHA product safety standards provided MSHA determines that the standard(s) provides at least the same degree of protection as MSHA requirements or can be modified to provide at least the same degree of protection.
During the evaluation of third party product safety standards, the rule allows for up-front public input to equivalency determinations

“Single Source” page is available on internet, directly at the msha.gov page.

Part 6 is a growing area of interest.  We are working hard with independent labs, such as UL, Testsafe, and Q.P.S. to help the implementation of MSHA approval testing.  Some of this includes providing courtesy visits. This should aid in continuing to improve turnaround times with these laboratories, and therefore with our approval process.

## Recent MSHA Part 6 Activities

- Completed evaluation of IEC 60079-0 and -1 and determined modification (deviation) is required to ensure equivalent protection to MSHA approval requirements
- Evaluation of IEC 60079-0 and -11 is on-going
- Participation on IEC TC31 main committee and subcommittees
- MSHA has approved several products based on independent laboratory test reports

**Notes:**
-1 flameproof enclosures
-11 intrinsic safety

Technical Committee 31 which oversees these standards

## In general, some helpful hints...

- Ensure all required documentation is included with original application
- Use the checklist provided in the applicable application procedure (MSHA investigators do!)
- Bottom line:  the more complete and accurate the documentation for the application, the more timely the application can be evaluated

**Notes:**
Ensure all required documentation is included, such as certified statements (that is easy to overlook, even for returning applicants).

All of the major program areas include checklists; these are part of the application procedures.  Shown to be very helpful in giving the product details we need for evaluation.  For example, thorough documentation is required for windows and lenses of x/p enclosures as specified in criteria ACRI2102

For example:  Part 7 motor approvals, if the applicant chooses a test facility that has not previously conducted MSHA motor testing, then a test plan including a complete listing of test instruments should be submitted for MSHA review.  This can be done with application submission (test facility normally supplies).

Regarding fee estimates and pre-authorization, pre-authorizing a typical amount in the application letter could allow MSHA to eliminate several administrative steps.

## Adequately Documented Applications

- Consultation meetings prior to submittal
- Accurate and substantive drawing lists
- Timely and complete responses to discrepancy letters; communication with investigator
- Addressing discrepancies in timely manner may reduce the time the investigator spends to re-familiarize with complex applications/systems

**Notes:**
At no charge to the potential applicant, meetings can be arranged with MSHA investigators prior to application submittal.  This can help ensure a more complete and correct submittal.  This can be very helpful for new applicants who may not have an understanding of the requirements or how to interpret them.

Drawing Lists are important, especially with complex applications with many drawings and components

The quicker and more complete the response to a discrepancy letter, the better position the investigator is in.

## Drawing Recommendations

- If the application includes changes to drawings previously filed with MSHA, it will simplify the review process if all changes to the revised drawings are clearly identified
- Duplicate drawings with explanatory notations may be submitted in addition to a "clean" copy to be placed on file

**Notes:**
Some applicants choose to submit compared drawings, this can help.  Still MSHA investigator responsibility.

## Complete Intrinsic Safety ApplicationsShould Include...

- Technical description of operation of electrical circuit(s).  Identify features critical to safety of the product.
- Adequate use and maintenance instructions
- If applying under Part 6: Test Reports
- UL1642 report (with test records) for any lithium battery
- Drawing List
- Factory Inspection Form (or Certified Statement) for Part 18 applications

**Notes:**
A complete technical description of the operation of each electrical circuit.  This should identify components or features of the product that are critical to the safety of the product.

Adequate instructions for the installation, connection and proper use and maintenance of the product.

A copy of the UL1642 report (with test record) for the lithium battery must be provided.  This report must describe the tests and evaluation of the battery per the requirements of the standard.

## Necessary Drawings for Complete I.S. Application

- Overall system / assembly drawing
- Block diagram (if required)
- Subassembly drawings
- Internal wiring diagrams (if required)
- Schematics
- Layout
- Printed circuit board artwork
- Electrical parts list / Bill of material

**Notes:**

During the initial review of the intrinsic safety application for the purpose of generated a fee estimate, an administrative review of the application is also conducted.  This is to ensure that we have a complete application, prior to it being submitted into the queue.  As part of the fee estimate, the applicant may be asked for the required documentation.  This may relieve an investigator of requesting the required documentation in his first discrepancy letter.

## Recommendations toI.S. Application Submissions

- Identify components that have no affect on intrinsic safety or required performance by a generic description rather than the specific manufacturer and manufacturer's part number
- Submit schematics without component values accompanied by a parts list specifying the ranges of values for each non-critical component

**Notes:**
To assist in simplifying the submitted documentation and future modifications, the following are recommended: 

## Assistance for ApplicationsInvolving Intrinsic Safety

- _[http://www.msha.gov/TECHSUPP/ACC/application/application.htm](http://www.msha.gov/TECHSUPP/ACC/application/application.htm)_
- Previous Intrinsic Safety Workshop
- Intrinsic Safety FAQ and Guide
- Drawing requirements
- Technical design issues
- I.S. design tips and problem solutions

**Notes:**
Previous Intrinsic Safety Workshop.  Presentations still available.  Our internal adminstrative procedures may have changed, but the technical details should be accurate and helpful.

Detailed information available on the I.S. FAQ and Guide.  Most important are the technical design issues.

## Digitized Ignition Curves

- Hard copies in ACRI2001 still the official version
- Digitized versions promote consistency and  expedience; may aid in preventing errors
- Includes resistive, capacitive and inductive curves
- _[http://](http://www.msha.gov/TECHSUPP/ACC/application/application.htm)__[www.msha.gov/TECHSUPP/ACC/application/application.htm](http://www.msha.gov/TECHSUPP/ACC/application/application.htm)_

**Notes:**
Digitized curves developed as an aid to both investigators and applicants  2.  Complaints received on the legibility of the hardcopy ignition curves  3.  Digitized curves promote consistency and expedience and aid in preventing errors  4.  Addition includes new inductive curves extrapolated from Figure 11.2 

## Contact Information

***Rob Holubeck******304.547.2088******holubeck.robert@dol.gov***

## Questions?