IECEx in Brazil
24 December 2013
Fortaleza, nearly on the equator on Brazil’s Atlantic Coast, proved an ideal venue for this year’s major series of IECEx Meetings during September. The meetings followed the usual format, with the ExTAG Meetings and the ExMC Meetings separated by a day devoted to the UNECE Sectoral Initiative on Conformity Assessment for the Ex Market.
In this session we received presentations from around the world, describing how the local rules on conformity assessment are (or are not) being aligned with the IECEx processes. Although the number of countries giving direct legal recognition to IECEx remains comparatively low, the areas where informal acceptance is normal are growing rapidly. Also, there are many areas where the IECEx reports are accepted technically, albeit with the need for topping up with the local documentation.
Brazil is now in that position, along with the major market of the European Economic Area.
Probably of greatest interest to users of the Product Certification Scheme, ExTAG recommended (and ExMC endorsed) two new Operational Documents (ODs) which will be issued shortly. They both recognise common commercial procedures and put the necessary checks and balances into the IECEx process to ensure that the final products fully meet the requirements.
TRADE AGENT is the term used to describe a “pseudo” manufacturer who sells equipment fully manufactured elsewhere but badged so that the trade agent appears on the market place as the manufacturer. The OD places a number of restrictions on the contractual arrangements and outlines the process for issuing a certificate in the name of the trade agent, while maintaining the integrity of the product and the process. The trade agent needs to have a Quality Assessment Report (QAR) covering all the sales and after-sales activity, including provision of instructions and the ability to institute a product recall in conjunction with the actual manufacturer.
LOCAL ASSEMBLER is used to describe a remote final assembly location, under the control of the manufacturer. The critical difference between the local assembler and a sub-contractor is that the product can be despatched direct to the customer, rather than being passed via the manufacturer for final inspection. The OD will contain a number of additional requirements to make up for the lack of final inspection by the manufacturer. The largest take-up for this designation is expected to be stockists who assemble Ex e junction boxes with the exact terminal requirements for the customer. It is expressly forbidden for the assembler to machine or create additional entries in Ex d enclosures, as that is considered to be manufacturing rather than assembling.
In the main Management Committee Meeting (ExMC) we elected a new chairman designate to replace Kerry McManama. Thorsten Arnhold from Stahl in Germany is the first manufacturer to hold this position and, by the time you read this, I expect that his appointment will have been confirmed by the IEC Conformity Assessment Board meeting in Delhi.
ExMC accepted the recommendation from ExTAG that Julien Gauthier be appointed secretary of ExTAG in succession to Michel Brenon. Tribute was paid to the work that Michel had done for the IECEx system ever since its foundation in the 1990s.
Progress was made with the OD that will provide the mechanism for IECEx Certification Bodies to work with the Special Protection standard IEC 60079-33, published some time ago. The discussions have centred on the necessary separation between the “independent” verifiers required by the standard, and who would take final liability if more than one ExCB were to be involved.
Perhaps the most contentious issue for discussion was the requirement imposed by IEC at the highest level that IECEx, in common with the other certification schemes, should work towards achieving a financial reserve equivalent to three times the annual running costs. One of the problems is that as the system sees continuous expansion, so the need for money to be put into reserves increases. A fairly strongly worded message is being sent to IEC to explain exactly the justification for this requirement. About the author:
SGS Baseefa General Manager Ron Sinclair MBE is chairman of BSI Committee EXL/31, responsible for the UK input to both European and International standards for Electrical Equipment for use in potentially explosive atmospheres. He is chairman of Cenelec TC31 and ExTAG, the Test and Assessment Group of the IECEx International Certification Scheme.