The terms “field evaluation body” and “field labeled” were defined in Article 100 of the 2017 Edition of the National Electrical Code (NEC). These definitions were taken from two standards, NFPA 790 – Standard for Competency of Third-Party Field Evaluation Bodies and NFPA 791 – Recommended Practice and Procedures for Unlabeled Electrical Equipment Evaluation, which were established to confirm the competency of a third-party field evaluation bodies.
Per NFPA 790, a field evaluation is “the process used to determine conformance with requirements for one-of-a-kind, limited production, use, or modified products that are not listed or field labeled under a certification program.” A field evaluation body (FEB) is “an organization, or part of an organization, that performs field evaluations of electrical or other equipment.” Even with the added emphasis towards the competence of field evaluation bodies, many authorities having jurisdiction (AHJs) are unaware that the NFPA 790/791 standards exist, or, if they are aware, they do not have a program in place to enforce these requirements.
The purpose of this article is to provide background on FEBs and the challenges of confirming the competency of a FEB with the varying requirements from one AHJ to another.
Authorities Having Jurisdiction: Who Are They?
The use of the NFPA 790/791 standards is a great way to ensure that an FEB is competent. However, the AHJ is ultimately responsible for ensuring that electrical installations and equipment are safe within a certain jurisdiction. There are thousands of AHJs in the United States and sometimes the AHJ works for the state, county or even a municipality. Also, depending on the jurisdiction, the AHJ may work in a different department or have a different job title than an AHJ in another jurisdiction. For example, most AHJs work in the Building Department of their jurisdictions, but it is also common for an AHJ to work in the Inspection Services Department, or the Planning and Development Department.
The AHJ’s job title can also vary greatly depending on the jurisdiction. Most commonly, the AHJ holds the position of Building Inspector or Electrical Inspector. However, the AHJ might hold the position of Building Official or Code Compliance Inspector. With the variance in the department the AHJ works in and the job title of the AHJ per jurisdiction, the creators of the NFPA 790/791 standards are challenged in communicating information about the standards to the appropriate individuals. Once the AHJs become aware of the NFPA 790/791 requirements, they can enforce these requirements to ensure the field evaluations are being completed by competent FEBs.
Development of NFPA 790/791
The determination of conformance of electrical products to a product safety standard is through the process of certification. The formalized process of certification is spelled out in the international standard ISO/IEC 17065 – Requirements for Bodies Certifying Products, Processes, and Services. In the certification process, the original certification usually takes place at the manufacturing site and then there are ongoing surveillance activities required for the certification to remain valid.
Over time, it became evident that certain products needed to be evaluated differently than using the certification process, such as products that are unique or already in place at the site of installation. Also, products may be altered or modified, which makes the original certification of the product invalid. The alternative certification process for unique or modified products became known as a field evaluation.
In 2008, two documents were developed by the American Council for Electrical Safety (ACES), a division of American Council of Independent Laboratories (ACIL), to determine compliance for field evaluation bodies. The two documents developed were a blend of the requirements stated in ISO/IEC 17065 for product certification and ISO/IEC 17020 for inspection bodies. NFPA 790 contains most of the quality system documentation requirements, along with test and measuring equipment requirements. NFPA 791 contains more of the technical requirements related to the performing the field evaluations such as pre-site preparation, construction inspection, and electrical testing.
Accreditation to NFPA 790/791
Now, most of the organizations that provide field evaluation services are also recognized as a Nationally Recognized Testing Laboratory (NRTL). NRTL is an organization recognized by the Occupational Safety and Health Administration (OSHA) as meeting the requirements of 29 CFR 1910.7 as a product safety testing laboratory and product certification body. However, OSHA does not accredit any organization to perform field evaluations. Due to this gap, several accreditation bodies have created accreditation programs to accredit FEBs to NFPA 790 and NFPA 791.
Currently, the American Association for Laboratory Accreditation (A2LA), ANSI-ASQ National Accreditation Board (ANAB), and International Accreditation Service (IAS) are internationally-recognized accreditation bodies that can provide accreditation to NFPA 790/791. Since the requirements of NFPA 790 and 791 are a blend of ISO/IEC 17065 and ISO/IEC 17020, these accreditation bodies also have programs to obtain both the ISO/IEC accreditation and NFPA 790/791 accreditation during one on-site visit. For example, A2LA has a program that provides accreditation to ISO/IEC 17020 for inspection bodies as well as NFPA 790/791 for field evaluation bodies. The assessment process includes an on-site quality system assessment and a technical assessment for the field evaluation product types for which the FEB wishes to be accredited. The product types are established by Annex C of NFPA 790 and listed below:
- Power distribution equipment under 600 volts
- Power distribution equipment over 600 volts
- Industrial control and utilization equipment
- Commercial utilization equipment and appliances
- Luminaries (lighting fixtures) and signs
- Medical and dental equipment
- Information technology equipment
- Hazardous location equipment
If a FEB becomes accredited to NFPA 790 and 791, they can provide their scope of accreditation to the AHJ as evidence that a third party has confirmed their technical competence to perform field evaluations for the product types listed on their scope. This gives the AHJ confidence that the field evaluation will be performed by a competent field evaluation body.
Andrew Bohan is a Senior Accreditation Officer at A2LA. He supports the day-to-day operations of accreditation, by assisting clients in obtaining and maintaining ISO/IEC 17025 and ISO/IEC 17020 accreditation in the Mechanical, Chemical, and Inspection Body fields of accreditation. In addition, he is the staff contact for the GE Aviation S400 Program and NFPA Field Evaluation Body Program. He has been employed as an Accreditation Officer for A2LA since June 2012.
Andrew is a Staff Approved Lead Assessor for both ISO/IEC 17020 and ISO/IEC 17025, and conducts both quality system assessments and surveillance assessments for testing and inspection body organizations. He received his Bachelor of Science degree in Chemistry from Gettysburg College in Gettysburg, PA, and can be reached at abohan@A2LA.org.