INTERNATIONAL ELECTROTECHNICAL COMMISSION SCHEME FOR CERTIFICATION TO STANDARDS RELATING TO EQUIPMENT FOR USE IN EXPLOSIVE ATMOSPHERES (IECEx SCHEME) To: Members of the IECEx ExMC Title: Report on ExMC WG15 responses to comments from the US concerning ExMC/1032/CD - Draft OD 005-3 “Quality System requirements for manufacturers – Part 3: Supplementary requirements for non-electrical equipment to ISO/IEC 80079-34” INTRODUCTION This document contains the comments received from the US and the ExMC Working Group WG15 agreed responses to draft document ExMC/1032/CD Quality System requirements for manufacturers – Part 3: Supplementary requirements for equipment to ISO/IEC 80079-34” and is submitted for information and consideration at the 2016 ExMC Umhlanga meeting. Chris Agius IECEx Secretariat Address: Level 33, Australia Square 264 George Street Sydney NSW 2000 Australia Contact Details: Tel: +61 2 46 28 4690 Fax: +61 2 46 27 5285 e-mail: info@iecex.com electrical
Member Body/ Country Clause/ Paragraph Figure/ Table Type of comment General/ technical/ editorial COMMENTS Proposed change Comments from the IECEx Secretariat and J Munro US Overall The contents of this CD are not mature enough to progress to DV yet. Member body comments received should be addressed as part of a subsequent CD for subsequent Member Body comment. The document as presented included all the relevant requirements of the draft CD. It has now been updated to reflect the issued CD and so is as mature and complete as it can be at this stage. US 1 G This document is clearly stated to only apply as a supplement to ISO/IEC 80079-34, Ed 1.0 as it relates to non-electrical equipment, yet this document does not utilize the text and wording from ISO/IEC 80079-34, and thus, does not provide the guidance as it says it does. Provide a more definitive reference to ISO/IEC 80079-34, Edition 1 throughout the document. Where a direct reference to ISO/IEC 80079-34, Edition 1 is not sufficient, then include only that information which actually supplements the document. In some cases, it is likely better to directly copy the wording from ISO/IEC 80079-34, Edition 1 (as shown in some comments below) This document as stated only supplements ISO/IEC 80079-34 Edition 1 for Annex A. Hence there is not need to include any additional text or reference to that document. clause
US A.3.1 T This clause does not fully explain how verification is to be achieved, as some clauses of ISO/IEC 80079-34, Edition 1 do. Recommend adding a clause with Testing or Verification similar to ISO/IEC 80079-34. Nowhere is there are requirement to document the verifications, to define test procedures or to document tests which are deemed critical to the Ex safety. Add clause for “Verifications and Tests All verifications against Ex safety parameters/aspects should be documented. All tests which are used to verify the Ex safety aspects or parameters of the equipment should follow industry standard test methods and should be documented.” US A.3.2 T There is no distinction to explain that only those non-metallic materials of equipment or parts of equipment on which the Ex safety depends is what needs to be controlled. As a result, the auditor is left to verify that the manufacturer verifies 100% of the non-metallic materials used in the equipment, regardless of the potential risk level Include the following text: “The requirements for verification of materials should apply to those aspects of non-metallic materials, non-metallic enclosures, and parts of enclosures on which the type of protection depends.” As explained earlier only wording of CD is used - not any new wording. US A.3.2 T The required information should be listed in the equipment standard – ISO 80079-36 as it is in EN 13463-1, clause 7.3. Change this section to: “A.3.2 Non metallic materials Where the non metallic materials affect the Ex safety of the equipment, the material should be subject to verification that demonstrates conformity to clause metallic As explained earlier only wording of CD is used - not any new wording.
Conductor sizes (minimum and maximum cable, lug or ferrule size, maximum current capability needed for bonding conductors, etc)” US A.3.5 T This is an unnecessary clause as non-metallic materials are addressed in A.3.2 Delete clause As explained earlier only wording of CD is used. US A.3.6 T This clause does not provide supplemental information and should either reference ISO/IEC 80079-34, Edition 1 (as shown in comment relating to A.2) or should reference the applicable clause(s) in ISO/IEC 80079-34, Edition 1 which are: A.5.1, A.6.1, A.9.3 and A.10.6. Delete clause or reference ISO/IEC 80079-34, Edition 1 directly As explained earlier only wording of CD is used - not any new wording. US A.4.1 G The statement is quite binding in that it claims A.3 identified safety aspects (which it did not). Clause A.3 is identifying aspects which should be verified IF the safety of the equipment may be impacted by the aspects. It would be better to make a general statement about verification means (as ISO/IEC 80079-34, Edition 1 does in each of the sections relating to a specific method of protection). Change the wording to the following: “Those parts or sections of the equipment which are identified as using the constructional safety method of protection may include additional requirements for verifications. The following are examples of aspects or parameters which should be verified and documented, based on the type of component, part or equipment. As explained earlier only wording of CD is used - not any new wording.
Cemented and Cast Enclosure Parts, Ingress Protection and Examinations. Of these topics listed in A.10 of ISO/IEC 80079-34 Edition 1, none seem to apply to equipment used as part of Control of Ignition Sources. If earlier suggestions are accepted, regarding general requirements for all non-electrical equipment, then this clause and statement are completely unnecessary. US A.5.2 G The use of the word “parts” implies equipment and does not match the topic of the list below. Change the wording to: “Documented procedures should ensure that the following aspects are verified:” As explained earlier only wording of CD is used - not any new wording. US A.5.3 T The use of the word “parts” implies equipment and does not match the topic of the list below. Change the wording to: “Documented procedures should ensure that the following aspects are verified:” As explained earlier only wording of CD is used - not any new wording. US A.5.4 T Nowhere is the reader reminded to document the tests and examinations completed. Add the following (unless it is incorporated in a general location): “Any tests specified in Ex certificate should be controlled by documented procedures and conducted on a 100% basis, unless otherwise permitted.” As explained earlier only wording of CD is used - not any new wording.