The United States and the IECEx System

Background

While the United States continues to move aggressively in other national and international areas relating to Zones, up until recently, it was tentative regarding involvement in the IECEx System. Due to this lack of formal U.S. involvement, U.S representatives had only been able to function in the role of an observer throughout the development of this System.

Until very recently, there had been very little open discussion about the IECEx System in the U.S. The anticipated benefits of the System , as well as the many challenges and downsides, had not had a full hearing before the manufacturers, users, inspectors and testing houses. In order to become a participating country in the IECEx System, an application from the Member Body of the IECEx (the USNC for the U.S.) is required. While the application contains a number of specifics about the country, note the following key pieces of required information:

• IEC standard(s) for which participation is sought (participation can involve anywhere from one IEC protection method to all of them)
• National standard(s) corresponding to the IEC standard(s) for which participation is being sought
• Itemization of any national differences from the IEC standard(s)
• Indication as to whether or not IECEx Certificates of Conformity are already accepted in the country
• Where national differences exist or where IECEx Certificates of Conformity are not accepted in the country, an indication of a proposed transitional period during which national standards and IEC standards would become identical and acceptance of IECEx Certificates of Conformity would be achieved.

What delayed U.S. involvement?

The basic reason for the delay in participation in the System by the U.S. focused on a few key issues:

• U.S. acceptance of non-U.S. certification marks
• Elimination of U.S. national differences
• Third-party certification involving risk of fire and electric shock requirements, in addition to risk of explosion requirements
• Continuation of the U.S. Division system

Regarding U.S. acceptance of non-U.S. certification marks, unlike the legislative activities that prescribe the standards and acceptance of certificates, such as in Europe, the U.S. federal government has no regulatory control over the thousands of local authorities having jurisdiction (AHJs). Because of this, there is a fear that gaining acceptance of the System by the thousands of fire marshals, and electrical and building inspectors would be insurmountable. Some in the United States felt that this would prevent the United States from exhibiting a good faith effort to eliminate all differences. This is the major hurdle to full U.S. participation. However, the U.S. is not the only country dealing with issues such as these. Canada also must deal with this challenge, albeit with a significantly fewer number of AHJs, and Europe must change legislatively as well.

Regarding the need to ultimately eliminate all U.S. national differences, the United States has already made a major step toward harmonizing with the IEC in the HazLoc arena. With Zones introduced in the 1996 NEC and the subsequent publication of U.S. ANSI Zone product and installation standards (such as by IEEE, ISA, NFPA and UL), the first step towards meeting this goal has been made.

Full harmonization, as previously noted, is allowed to occur over a transitional period. The United States would be in line with other countries to propose a transition period of at least 10 years (the currently submitted period for most other member countries), with 15 years being, perhaps, a more realistic period. This would allow the necessary time frame to eliminate the national differences in both the installation and product standards.

Regarding the current U.S. need for third-party certification to address fire and electric shock requirements, the perception has been that this issue could prevent U.S. participation in the IECEx System. The concern is that, even with a transition period, the United States would never be able to eliminate this "difference" and comply with the System goals of one standard, one certificate, and one mark. However, we must understand that the System only addresses the risk of explosion requirements that are associated with the use of equipment in explosive environments. These requirements are detailed in the IEC 60079 (and 61241 and 61779) series of publications and are the Standards covered by the Scheme.

It is important to note that additional National regulatory requirements may be necessary for a product to gain entrance into a country's marketplace. In the U.S., it could be due to Federal Communications Commission (FCC) requirements or, in most cases, the need to show third-party certification involving risk of fire and electric shock requirements. As another example, in Europe, there are many additional Directives (EMC, LVD, Machinery, Med. & Dental) that must also be met for a product to gain entrance and acceptance into their marketplace. The IECEx System is not intended to replace all of these other regulatory requirements. It is only a way to harmonize risk of explosion requirements.

Regarding the need for the U.S. Division system to continue, this is the one issue that seems to cause the greatest confusion. Some industry members believe that, for the U.S. to participate in the IECEx System, the United States would have to eliminate the Division classification system. Or, at least relegate it to a secondary maintenance-only mode. This is not the case. The two methods of classifying hazardous locations and their associated installation and product requirements will coexist well into the future. The marketplace may eventually eliminate one of these methods, but it will not be a result of the Scheme rules as they exist today.

The System guidelines do not include a requirement for the elimination of other national certification/installation systems, nor does the System include any of the IEC 60079 installation and maintenance Standards under its system. This is clear in reading the guidelines, and has been stated clearly in formal System discussions.