Members of the National Fire Protection Association (NFPA) have now completed the annual NFPA Conference and Expo, where a considerable amount of debate occurred around the topic of reconditioned equipment. Until now, this issue was not a focus of the National Electrical Code (NEC). The new updated code brings clarity and transparency to the table by educating customers around the equipment they're buying and installing. In my opinion, the electrical industry must work together to take this foundation to the next level. We now have a platform from which clarity and transparency pertaining to reconditioned equipment can be expanded upon to help buyers and sellers of refurbished electrical safety devices develop and adhere to best practices for safety's sake.
The use of reconditioned equipment and its safety implications
It's common for electrical professionals to source reconditioned equipment, especially contractors on large jobs or on those projects where a quick turn-around on older equipment is needed. The practice can be cost effective and, in instances where older legacy systems require devices that are no longer manufactured, often necessary to solve an immediate requirement. But with many counterfeit devices in the supply chain and devices and equipment that may have experienced flooding or other abnormal damage, the NEC has made it clear that safety must take a higher priority.
With that, NEC 2020 will end its silence on this topic and seek to assure proper reconditioning of electrical equipment. New requirements for are found across 20 sections of the document, with changes making it clear what equipment can and cannot be refurbished for safety reasons.
"A basic understanding of the term "reconditioned" is critical to success."
Thomas Domitrovich, Eaton vice president, technical sales
The one critical rule
Though 20 new requirements are under consideration, one is most important in my opinion: 110.21(A)(2). It states equipment must be identified as reconditioned and the original listing mark removed (though the original nameplate may remain in place). This means third-party testing marks (such as the UL listing mark) must be removed and the device identified as reconditioned.
This addition is tremendously important for the Authority Having Jurisdiction (AHJ) to help them identify equipment that has been refurbished or reconditioned and ensure these NEC requirements are enforced. These changes raise the bar of safety for refurbished equipment and those that provided refurbished equipment. Refurbished products brought to market will carry the transparency needed for the specifier, installer, and ultimately the owner. A basic understanding of the term "reconditioned" is critical to success.
What does "reconditioned" mean?
As with many changes in the NEC, good definitions are necessary for proper enforcement of requirements. Discussions will occur across the industry to understand this new term. Three different Code-making Panels assembled what we have today as a definition for "reconditioned." These technical committees have done their part to create, what I believe is, a solid definition:
"Reconditioned equipment is electromechanical systems, equipment, apparatus, or components that are restored to operating conditions. This process differs from normal servicing of equipment that remains within a facility, or replacement of listed equipment on a one-to-one basis."
As with most new changes, especially those as significant as these, NEC 2020 will benefit from public review as it rolls out across the country. Many electrical professionals will learn of what NEC 2020 now requires and develop educational materials that support it. As more people review the updated code, the more we'll see ideas arise on how to improve this text. This process is one of the best in the industry – as the code evolves over time, it improves. My colleague, Jim Dollard, IBEW Local 98 in Philadelphia, said it best: "It's a solid definition, it is comprehensive. The first sentence clarifies that reconditioned means "restored to operating conditions." That means the equipment was not useable. This also clarifies that "used equipment" that is in operating condition is not considered to be "reconditioned equipment." The second sentence is extremely important. This text provides clarification with respect to "normal servicing of equipment that remains within a facility or replacement of listed equipment on a one-to-one basis." Any "normal servicing of equipment that remains within a facility" is not reconditioned. Keep in mind that a facility is a single building, a campus or a network of cell towers for example. Replacement of "listed equipment on a one-to-one basis" clarifies that piece of equipment that is not in operating condition can be restored to operating condition through the replacement of "listed equipment on a one-to-one basis" and is not considered to be "reconditioned equipment."
Here is my opinion on a breakdown of each aspect of the definition. Keep in mind that your Authority Having Jurisdiction (AHJ) is the final say on all of these requirements including the interpretation of the definition.
"Electromechanical systems, equipment, apparatus, or components that are restored to operating conditions." This first sentence is very broad. No matter the system, equipment, apparatus, or component, the key portion of this sentence lies in these four words; "restored to operating conditions." This means the equipment was not operable and something had to be done to return it to a functioning state.
In my opinion: If an electrical contractor removes a fully operational panelboard from a facility to either upgrade or install a larger panelboard, the contractor may reinstall that panelboard elsewhere in the facility. The panelboard is clearly used equipment and not reconditioned because no steps were taken to repair or modify it and return it to an operating condition.
Continuing from the definition, "This process differs from normal servicing of equipment." There are numerous events that can affect devices including flooding, fires and other extremes. Servicing this equipment after these events will beg the question of whether or not this is "normal servicing." We won't find a definition in the NEC for "normal servicing" as commonly used, well-understood terms aren't defined. The question will remain for many though as to what exactly is meant by the use of the term "normal" in this context.
In my opinion: We have to apply common sense here. Equipment that's been underwater, in a fire, or other similar event is not normal in my opinion. Servicing equipment per manufacturer instructions for updates or maintenance reasons are normal activities. Equipment manufacturers help to define "normal" by working with service departments to identify common repairs performed on a regular basis.
"That remains within a facility." Knowing the history of equipment is the next step of this definition. It's easier to understand the history of equipment that was purchased for and remained in a single facility during its entire life. This history is important for safety. Repairing and maintaining this equipment is not considered, "reconditioning." We can't forget too that we're talking about equipment that is ". . . restored to operating conditions."
In my opinion: This asserts that the owner of equipment has a better understanding of its history. If a technician removes a device from a facility and that device is in working order when reused within that same facility, that's use of used equipment. This equipment was not in a state of condition that requires someone to return it to operating conditions. If the condition of the device is not known, steps may have to be taken to modify the equipment to replace components to raise the level of confidence that this equipment is in operating conditions addressing areas of concern. This would then meet the definition of reconditioned equipment.
"Replacement of existing equipment on a one-to-one basis." The code making panels took time to ensure that the act of replacing components within equipment per manufacturer instructions does not fall under the reconditioned equipment umbrella. Contractors and IT managers often replace existing devices for many reasons, such as equipment end-of-life or for assembly capacity increases.
In my opinion: If equipment is listed for the same purpose as the original device being replaced, it's done on a one-to-one basis and, therefore, is not reconditioned. Let's take the example of an electrician replacing a circuit breaker in a panelboard with another per manufacturer instructions. The replacement is a one-to-one example and the application was not reconditioned. On the other hand, should this replacement occur in conjunction with cleaning the internal bus and other components within the enclosure after an event such as a flood, fire or similar, we're looking at refurbished equipment.
What clarity means for the industry
These code changes were upheld at the annual meeting amidst extensive debate. Our electrical industry understands the challenges and safety concerns around reconditioned equipment. The requirements for reconditioned equipment were overwhelmingly supported on the floor of the annual meeting.
Proper governance starts with ensuring education for those focused on electrical safety. Organizations like the International Brotherhood of Electrical Workers (IBEW), the National Electrical Contractors Association (NECA), Independent Electrical Contractors (IEC), the International Association of Electrical Inspectors (IAEI) and others will be working to update and create their curricula based on these new changes. Consistency in what we all teach is important to success
As with any NEC safety change, this will be a journey with many growing pains along the way. Future efforts will seek to clarify, expand and correct requirements for used and reconditioned equipment. This journey will continue over many review cycles.
So, what can you do to protect yourself? I believe buyers and suppliers of reconditioned devices can do more to assure safety today:
Suppliers – differentiate yourself from others
- Pay close attention to product standards and perform tests that establish performance, even if standards do not exist, and document it all. Share this with your customers as a differentiator. This helps bolster the supplier's brand image and create safer products that customers ask for by name.
- Engage with the industry and join NEC and other requirement-making institution discussions. It helps to listen in on industry concerns, get first-hand feedback and refute claims you know are incorrectly positioned. It's also a great opportunity to highlight your safety processes, which may also influence future amendments.
Buyers – know where products are sourced
- Buy only from reputable resellers. Devices purchased from unauthorized distributors who lack important safety certifications carry tremendous risk. Remember, the solutions you install in a facility reflect on you. Do your due diligence.
- Note the products the NEC states cannot be refurbished. Less reputable resellers do attempt to sell molded case circuit breakers and other safety devices that can't be reconditioned. It's up to you to know the facts and act accordingly.
- If a project bid includes reconditioned devices, make sure your customer is aware. Remember that reconditioned devices are now labeled as such with third-party listing marks removed, so they're easily noticed. Some clients may not take kindly to reconditioned devices after the fact.
While creating requirements for reconditioned equipment is in its infancy, understanding the differences between used and reconditioned equipment is a great first step toward helping educators, buyers and sellers ensure the safety of people and equipment.
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