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Joined: Jan 2005
Posts: 5,445
Likes: 3
Cat Servant
Member
Greg, trust me on this ... dairies get LOTS of inspections laugh BTW, the USDA inspector trumps everyone else.

The OP is 'crossing a line' here. Once you take a bunch of equipment, cobble it together, and mount it on a skid ... the NEC no longer applies, as you have constructed an 'appliance.' The same principle applies to process equipment and assembly lines.

That's one of the real problems with the new NEC section about control panels .... there's absolutely no way for any NRTL to review what the controls are telling the machinery to do - all they can do is measure clearances.

The NEC almost starts off by stating that methods need to be suitable for the environment .... and those 'environmental' factors can easily include sanitation requirements, etc.

We can use the NEC, product standards, etc., for guidance .... but, when you're making an appliance, it comes down to your design requirements and professional judgment.

This is also the reason that the NEC recognizes the need for the AHJ to be able to disregard parts of the code. Industrial situations can very easily become "special" cases.

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Joined: Jul 2007
Posts: 1,335
S
Member
I may be off on this because I still am not sure what your "skid" is. My apolgies This my be cost prohibitive, but your may be able to get your "skids" listed if you mass produce (relative term) them. If the "skids" are unique from one another that you will not need to list them.

Either way they would need to be reviewed and sign off by a Electrical Engineer and the "skids" would have to assembled in an "engineer controlled environment" or by a licensed electrical contractor using listed conduits. Your local and state laws should address these matters.

If you are considering to "list" your skids, you are not limited to UL (no disrespect to UL) there are other Nationally Recognized Testing Laboratories (NRTL)

For more info to common questions on NRTL:
NRTL FAQ's

NRTL website

Underwriter Labratory listing process:
UL listing process


"Live Awesome!" - Kevin Carosa
Joined: Jul 2004
Posts: 9,931
Likes: 34
G
Member
John what you are saying is consumer equipment is not subject to the NEC if it is not hardwired into the building wiring?
By "inspection" I was talking about the NEC inspector, not the health department.




Greg Fretwell
Joined: Jan 2005
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Cat Servant
Member
Right, Greg ... but it's quite possible for a dairy to find itself in a conflict between different inspectors. If the USDA guy says "I want it welded, smooth, with no place for germs to collect," that's what will happen.

I said nothing about hard-wiring. Any appliance is, by definition, beyond the scope of the NEC. Open up nearly any appliance - UL listed included - and you'll easily find all manner of 'violations' in wire sizing, overcurrent protection, bend radius, and conduit fill. FWIW, you'll also see wires routed through all manner of raceways that are not recognized by the NEC.

Perhaps the simplest example is the ordinary table lamp. The cord certainly isn't #12 gauge, even though we plug it into a 20 amp circuit. That bored hole through the base isn't a recognized raceway. Yet, UL has no trouble listing it (to a non-NEC standard) because it's an appliance.

Further, as a general principle, there is no requirement that appliances be listed or approved by anyone. That many -especially consumer ones- are is the result of marketing, not regulation. Step away from the consumer marketplace, and listing marks, especially for complete assemblies, become pretty rare.

Or, as I like to point out .... Apollo 11 was NOT UL listed. Nor are the Abrams tank, the Boeing 747, the USS Enterprise, or even the family car. It just happens that we, as electricians, happen to work in the market that is most heavily penetrated by UL.

Now ... lest anyone think I'm being cavalier ... there have been times when I, or my employer, was forced to act contrary to the NEC's (or other codes') specific requirements. Such should not be done carelessly; in the instances that I participated in, there were specific reasons, and other documents (UL, NEMA standards, for instance) were referenced to identify important requirements. In short, we were able to reasonably state that the 'work around' would meet every requirement the listed product would, as well as some the listed product could not.

Joined: Jul 2007
Posts: 1,335
S
Member
well put Reno!


"Live Awesome!" - Kevin Carosa
Joined: Jul 2004
Posts: 9,931
Likes: 34
G
Member
Actually when you look at your table lamp and the NEC I would direct you to "fixture wires" and you will see the 18ga.

My real concern with welding is the inside of the pipe. I know they can weld, grind and polish stainless to make the outside look like it was always one piece of metal but the inside could look like a hacksaw blade.


Greg Fretwell
Joined: Jan 2005
Posts: 5,445
Likes: 3
Cat Servant
Member
I agree, that is a concern, an issue that needs to be addressed.

Joined: Aug 2008
Posts: 10
S
Member
I think that would be case to case. Our welder fitters weld for sanitary processes and if the inside of our pipes looked like you described our piping would not be considered sanitary. If it did look like that would that be worse than an improperly reamed conduit?

Joined: Oct 2006
Posts: 745
E
Member
Originally Posted by gfretwell
I know they can weld, grind and polish stainless to make the outside look like it was always one piece of metal but the inside could look like a hacksaw blade.


I love that response! Well stated for sure.

I completely missed the OP's intent here. I thought we were speaking of field-installed material where the NEC would likely be the most likely code being referenced. True, if it is a skid-mounted or portable assembly, just like a manufactured home, the rules change dramatically.


---Ed---

"But the guy at Home Depot said it would work."
Joined: Jan 2004
Posts: 1,507
G
Member
For the record- I worked for about 4 years in a dairy where they welded stainless steel piping together on a regular basis and I can assure you there were no rough edges inside the pipe. This would still not permit to be used as a raceway per the NEC. I would not have a problem if it were parted of a listed assembly as reviewed by UL. My reason for posting is to tell you SS piping as used in a dairy is absolutely smooth both inside and out due to the special welding process and the need for sanitation and ease of cleaning.


George Little
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