— Lanny R. Berke, P.E., C.S.P.
Q: About 85% of all the equipment in our factory was designed and built by a sister company in Europe. As such, when we must modify these machines, we cannot throw the responsibility for safety back to the manufacturer. We are the manufacturer.
Regulations here in Canada dictate we operate any machinery in the factory as per the manufacturer's specifications, or when such specifications do not exist, to those of an engineer. The engineer is defined as a licensed professional engineer (P.Eng. for Canadians).
The problem is that in a manufacturing environment, eventually we have to modify almost every machine, if only a little bit. One of the things we constantly must come to grips with is how far we should go to assure the modified machine component is as safe as the original part.
As an example, our National Fire Code (NFC) says containers used to store or distribute flammable liquids such as solvents must be either ULC or FM approved. In one case we had to modify a solvent plunger-can because the manufacturer discontinued the original. As soon as we added our new top pan, the FM approval was voided.
Luckily, I have copies of the FM test documents for these containers and have compared our new top pan to their requirements. Nothing seems to conflict. I am now contacting our Fire Marshall's Office to get an "equivalency" acceptance for it.
Do you often come up against these kinds of things in the U.S.? If so, how are they handled?
A: You know the standards that the equipment you modified was originally designed to meet. Any time you modify a piece of equipment make sure the machine meets the latest version of that standard. In addition, I would strongly advise you to do a hazard analysis on each machine when it has been modified.
When you modify solvent equipment or electrical equipment, make sure it meets your CSA that is equivalent to our UL. You can submit it for listing under your CSA accelerated program when working with, I believe, 12 or fewer units. This is far cheaper and faster than a full-blown CSA study.
My former employer built a plant in California that was heavily computer controlled. There was a three-year delay before it could go online because it was not submitted to a third-party test laboratory as required by a local ordinance. The firm finally had CSA evaluate it under this accelerated program, and had it up and running within six months.
My former employer also constantly modified equipment that it purchased. We always made sure the modified equipment met the latest version of the original standards, and then made sure it would pass a hazard analysis. In addition, we ensured it met all pertinent NFPA standards and NEC standards that applied. Remember, all standards are minimum levels of safety, and meeting the standards does not necessarily mean you have a safe machine. I strongly advise that, besides meeting safety standards, you perform a hazard analysis each time a machine is modified.
I hope that this helps.
is a registered professional engineer and a Certified Safety Professional involved in forensic engineering since 1972. Got a question about safety? You can reach Lanny at email@example.com