How often in Canada perplexed distributors or wholesalers of electrical equipment provided with various trademarks or other symbols of identification hear from a visiting inspector: “This equipment is not approved. It must not be offered for sale.” Electrical contractors can also share some of their confusion, when an inspector rejects a piece of electrical equipment for installation as being “unapproved,” although the equipment bears a familiar certification monogram. So, where is the problem, and why do “innocent” wholesalers or contractors encounter such adamant actions from the Canadian electrical inspectors?
Let’s establish some facts: Every provincial/territorial Electrical Safety Act or Regulation prohibits displays, advertisement or disposal of unapproved electrical equipment.
Rule 2-024 of the Canadian Electrical Code, Part I states that “Electrical equipment used in electrical installations within the jurisdiction of the inspection department shall be approved and shall be of a kind or type and rating approved for the specific purpose for which it is to be employed.”
These two facts certainly shed some light of this subject. But what does it actually mean “approved equipment,” and why in two earlier examples did an inspector reject a piece of equipment that contains a certification monogram?
Who makes such an approval: a manufacturer, a supplier, a testing agency, an inspector?
As the electrical equipment in question is intended to be used under installation rules of the Canadian Electrical Code, definition of the CE Code could unravel this mystery. The CE Code offers the following definition: “Approved as applied to electrical equipment means, that: (a) A certification organization accredited by the Standards Council of Canada has certified such equipment in accordance with the requirements of (i) CSA standards; or (ii) Other recognized documents where such CSA standards do not exist or are not applicable; or (b) Such equipment conforms to the requirements of the regulatory authority.” Do we feel completely relieved after reading and digesting this definition? Not exactly. It looks like we need some additional work of “deciphering” this intricate terminology.
Let’s do it step by step. First of all: What do we know about such a “certification organization accredited by the Standards Council or Canada”? The answer will yield some agencies that are very well known to the industry. Certification organizations such as CSA, UL, ETL, etc., have applied to the Standards Council of Canada for accreditation to certify electrical equipment to the CSA Safety Standards for Electrical Equipment (to Part II standards that are listed in Appendix A of the Canadian Electrical Code).
The SCC grants accreditation to a certification body when all criteria and procedures for accreditation are met (scope of accreditation is defined and the acceptable certification mark is established). Thus, for example, when the electrical equipment is certified by the CSA, the SCC requires that the “CSA” monogram must apply to the equipment. When the same electrical equipment is certified by UL to a relevant CSA Part II standard, the “”cUL”” mark must be shown on that equipment. [Note: small “c” is a Canadian Identifier. In accordance with the SCC requirements it must be located at 8 o’clock to the registered trademark “UL.” This small “c” signifies that the equipment is, indeed, certified by the U.S. based Underwriters Laboratories Inc. to the CSA Safety Standards for Electrical Equipment – Part II standards].
Therefore, a certification mark appearing on an electrical product is a testimonial provided by the certification agency that the equipment has, in fact, been subjected to a satisfactory testing by that accredited Certification Organization to all applicable requirements of a specific CSA electrical safety standard for the electrical product that is intended to be installed under provisions of the CEC, Part I.
Thus, the puzzle with the CEC, Part I and Part II is now resolved: requirements that are covered in the CEC, Part I—constitute provisions for safe electrical installation, and conditions specified in an equipment standard—represent design and construction criteria under the scope of the CEC, Part II safety standard for that specific electrical equipment (that will be installed under rules of the CEC, Part I).
From a practical side this means that if, for example, a panelboard installed in a dwelling unit is marked “CSA,” it implies that such a panelboard has been tested by the CSA Certification experts for conformance with the CSA standard C22.2 No. 29 (see Appendix A of the CE Code) This panelboard will be most likely accepted by an inspector as “approved electrical equipment.” If the same panelboard bears “cUL” monogram, the inspector will also accept it for installation, as this monogram signifies the fact that UL staff certified the panelboard for conformance to the same CSA standard.
But what about paragraph (ii) of the definition “approved electrical equipment” that states that the equipment is approved if it is certified in accordance with “”other recognized documents, where such CSA standards do not exist or are not applicable?”” Where can these situations be encountered? Perhaps a few following examples might help:
If the life safety/fire alarm equipment is installed in accordance with Section 32 of the CEC, this equipment will not be certified to the CSA, Part II standards, as CSA never developed standards for a fire alarm equipment. Instead, such equipment (a smoke detector, a pull station, a fire alarm bell, etc.) would be certified to applicable ULC Standards. Appendix B Notes on Section 32 of the CEC provide explanation on this subject.
If there is no CSA Standard available for a specific type of electrical equipment (i.e., a unique control or protection device, etc.) CSA Certification Division may publish “other recognized document” (ORD). When the CSA publishes such ORD, it is called Technical Information Letter (TIL). This TIL provides interim certification requirements for such specialty equipment, until a complete standard is developed by a technical committee of experts via a CSA consensus based process.
And finally, paragraph (b) of the definition indicates that the equipment is deemed to be approved if it “conforms to the requirements of the regulatory authority.” This, latter condition could be met, when a unique electrical equipment is constructed for which no applicable CSA Part II Standard exists and no certification program has been developed (no ORD has been published). In this case, inspection authorities may consider such equipment as “approved” if it meets criteria of a special inspection, provided by the testing agencies on behalf of the regulatory authority in conformance with SPE 1000, Model Code for the Field Evaluation of Electrical Equipment, or with other documents acceptable to the regulatory authority.
So, it looks like all aspects of the CEC definition have now been clarified, and the wholesalers’ and contractors’ confusion mentioned at the outset of this article can now be explained. Let’s check out a few examples: Let’s say, that a distributor sells a reel of a cable marked “”UL.”” Is this approved equipment? The answer is “No.” Not for use in Canada under rules of the CEC, Part I. If this cable is to be allowed to be sold and installed in a Canadian market, UL must apply a Canadian Identifier (small “c” to the “UL” registered trademark). Only this “cUL” monogram will signify that UL, in fact, tested this cable to the applicable CSA cable standard listed in the Appendix A of the CE Code. This is the reason many wholesalers and distributors are ordered to remove the equipment that is not appropriately marked. It should be noted that Rule 2-100 of the CE Code, Part I lists markings that are required to be provided on each piece of electrical equipment to ensure that the equipment is suitable for the particular installation.
If, for example, an inspector checks electrical installation in a paint spray operation (Class I; Zone 1 hazardous location) and finds a motor, or a panelboard marked “CSA.” Does this equipment meet the inspector’s acceptance? The answer is “No.” Because in addition to the CSA monogram this equipment must be “approved for specific gas, vapors, etc.” and marked accordingly as required by Section 18 of the CE Code. Referenced earlier, Rule 2-024 of the CEC is very helpful in understanding this additional requirement of being “approved for the specific purpose for which it is to be employed.”
There are numerous situations where inspectors reject electrical equipment, although this equipment has been impeccably tested and bears an acceptable certification monogram. These situations are well described by Rule 2-026 of the CE Code, which grants an inspection authority power of rejection under the following conditions: (1) if the equipment is substandard with respect to the sample on which approval was granted; or (2) if the conditions of use indicate that the equipment is not suitable; or (3) if the terms of the approval agreement are not being carried out.
It is unfortunate, but lately inspectors encounter these situations more and more often. With a huge supply of offshore equipment ranging from heavy industrial circuit breakers to basic consumer oriented power bars and extension cords many substandard or outright counterfeit pieces of electrical equipment find their ways to wholesalers, distributors, contractors and, ultimately, to consumers. Therefore, today like never before electrical inspectors must exercise their vigilance in auditing electrical equipment that is intended for use in Canada. Thus, a mutual commitment and diligence by all stakeholders of the electrical industry in understanding of the facts and confusion about “approved” equipment, and acting upon this subject effectively is paramount in our successful efforts to uphold electrical safety in Canada.