Warning on unsafe Ex luminaires!

Ex area professionals were surprised by the FOD bulletin 1-2017 issued on January 10, 2017, by the Field Operations Directorate of HSE UK, reporting that a family of Hadar Ex luminaires (models HDL100, HDL106, HDL 206 and HDL109) was considered unsafe for use in classified areas.

The communication impact was great, considering that this type of luminaire (as example HDL 100 options: 2x18W, 2x36W and 2x58W, marking II 2 GD Ex emb II T4 / T5, Ex tD A21 IP66 / 67 T100 oC), has wide application in industrial plants and also the period of manufacture stipulated in the bulletin: from 2006 to 2016.

For application in classified areas, electrical and electronic equipment must be approved in several specific tests and the manufacturer needs to have a quality system that guarantees the reproduction of all characteristics of the specimen that has been approved by the certifying body, in all units produced . This is the basis for issuing a certificate of compliance, which aims to give to the consumer the peace of mind that he is purchasing a safe product.

The HSE bulletin

According to the bulletin, such luminaires after tests carried out on samples by a certifying body, "may present a source of ignition that could result in a fire or explosion when used in potentially flammable atmospheres identified under the Dangerous Substances and Explosive Atmospheres Regulations 2002 (DSEAR). They may also fail to operate safely or effectively when used in wet or dirty environments."

The bulletin also says that they do not meet the requirements of the impact tests, degree of protection and safety items set out in the ATEX directive for the operating temperature range announced by the manufacturer (- 30 oC to +55 oC).

The Hadar position

It was issued a letter explaining that during a routine assessment audit conducted by CSA-Sira on A-Belco Ltd’s manufacturing operation in Ashington, Northumberland UK, there were findings recorded with respect to the A-Belco production and process control. As a result of these findings, CSA-Sira began a more detailed evaluation of the product ranges identified and conducted additional testing. These tests indicated some non-conformances to industry standard regarding Ingress Protection, IP ratings. In particular, some of the test samples failed the IP tests following the impact test post thermal conditioning.

These actions resulted in the suspension of use of the A-Belco QAN (Quality Assurance Notification) and QAR (Quality Audit Reports). The letter ends announcing that "the manufacturer has worked with the notified body, CSA-Sira, to define a proper solution to the IP question."

The Sira website

Information about the certificate SIRA 06ATEX3079X (basis for the IECEx one), was accessed via the Sira's certificate database website and found with the status "current" on March 3, 2017. No comments were found on the website about the bulletin FOD 1-2017.

Considering it is a valid ATEX certificate, these luminaires can still be sold in Europe.

The IECEx website

For the HDL 100 and HDL 109 models, the IECEx SIR 06.0026X certificate of conformity (firstly issued on 10/07/2006 and currently in issue 8, dated 9/13/2016) was consulted online at IECEx website on 2/14/2017. It was not found any comments on the IECEx website, regarding the HSE FOD bulletin 1-2017.

It is understood that the FOD Bulletin 1-2017 seriously questioned the validity of the certificate of conformity as it stated that such luminaires present a risk of ignition which could result in a fire or explosion when used in classified areas and may be compromised when operating in wet environments or subject to post-combustion.

Ex-certified equipment is to be considered safe, but in this case, because the non-compliance period covered all its production (10 years) and that the latest issue of the certificate is dated on September 2016, a serious failure in the quality system of the manufacturer, of the certifying body and also, of the IECEx Scheme, was exposed.

The end-users' concerns

The FOD 1-2017 also made the recommendation that these luminaires be inspected according to IEC 60079-17 and that those identified as defective be replaced with others that meet the requirements of the installation. Besides that, another recommendation made is that even if installed in unclassified areas, it is recommended that such luminaires be inspected and evaluated for their safety in continuous use.

The FOD bulletin ends with "This alert sheet contains notes on good practice which are not compulsory but which you may find helpful in considering what you need to do."

Since the risk involved is explosion, it seems that the safest recommendation until replacement is completed (which may depend on purchase orders), luminaires considered to be inadequate are kept de-energized.

Conclusions & suggestions

Every industrial facility that processes flammable products must have a program to train professionals in the operation and maintenance of electrical equipment in classified areas, since only the correct installation and maintenance will provide the necessary safety. The effectiveness of these actions is totally dependent on that the Ex equipment has its valid Certificate of Conformity and that the entire process involving the government regulatory body, the certification body and the manufacturer is duly structured and monitored.

Disclosure of this problem to users needs to be carried out on a wide scale, involving distributors and resellers in a way to alert end users. The only information found this moment is at the HSE and manufacturer websites.

Considering that by FOD 1-2017 all luminaires manufactured since 2006 were considered unsafe, it seems that there is a design failure, which in principle, only the manufacturer can promote a solution.

The great number of legal requirements and standards on this subject, points that it is indispensable to have a specialized consultancy to implement an Ex Compliance Monitoring Plan (Ex-CMP), which provides guidelines for routine demands and also that on emergency situations - such as eventual recalls - be structured to act quickly, ensuring the safety of the industrial unit against the risk of explosion, which consequences may lead to the closure of the company's activities.

References

HSE FOD 1-2017

Hubbel's response

Sira's certificate database

IECEx certificate database