Machinery Safety 101

Why YOU need a Product Safety Certification Strategy that Works!

How compliance efforts go wrong

Cli­ents call me when they have prob­lems. They sent some product to a cer­ti­fic­a­tion body, some tests were done, and the product failed. Now what? Usu­ally, the deliv­ery date for the cer­ti­fied product is approach­ing quickly, and no time is avail­able to react. Deliv­ery is delayed, and the cus­tom­er is upset. The busi­ness may even be lost.

This pro­cess goes wrong for a num­ber of reasons:

  1. The end goal for the cer­ti­fic­a­tion and the inter­me­di­ate require­ments were not considered
  2. The cer­ti­fic­a­tion body chose the stand­ard, and the man­u­fac­turer had no idea what the stand­ard required
  3. The samples were not care­fully pre­pared for the cer­ti­fic­a­tion body
  4. Inform­a­tion was miss­ing or par­tially missing

Motivation to Certify a Product

What motiv­ates a man­u­fac­turer to cer­ti­fy a product? The decision to cer­ti­fy comes about for a vari­ety of reas­ons, including:

  1. The leg­al require­ments for the market
  2. Cus­tom­er request
  3. Liab­il­ity limitation
  4. Mar­ket­ing advant­age over competitor’s offerings

I’ve talked about the dif­fer­ences between CE Mark­ing and tra­di­tion­al Cer­ti­fic­a­tion pro­cesses in a few art­icles, includ­ing this one recently, so I won’t repeat myself here. In Canada, Fed­er­al [1, 125(m)(iii)] and Pro­vin­cial law [2, 113 (1) (c)] require any­one selling an elec­tric­al product to ensure that it bears an elec­tric­al safety mark, and this is sup­por­ted in the Cana­dian Elec­tric­al Code [3, 2 – 024]. This require­ment is often over­looked in the industrial/commercial mar­ket where post-install­a­tion equip­ment inspec­tion, called “Field Eval­u­ation”, is typical.

In the US, each State has a slightly dif­fer­ent approach, so you will need to check out the require­ments in the states where your product is sold so that you can ensure com­pli­ance with the loc­al require­ments. From a work­place per­spect­ive, the US OSHA requires that all elec­tric­al products used in the work­place bear a mark from a Nation­ally Recog­nized Test­ing Labor­at­ory (NRTL) [5].

Cer­ti­fy­ing your product provides some degree of liab­il­ity lim­it­a­tion, in that it shows that you met the min­im­um leg­al require­ments for your mar­ket­place. To lim­it your liab­il­ity effect­ively, you will need to do more than just meet the min­im­um require­ments, and you will need doc­u­ment­a­tion of everything done to meet or exceed those requirements.

If you offer cer­ti­fied products in a mar­ket where this is uncom­mon, you have a mar­ket­ing advant­age as long as your cus­tom­ers under­stand the bene­fits cer­ti­fied products bring. If cer­ti­fic­a­tion is rare in your mar­kets, you may need to under­take some edu­ca­tion­al mar­ket­ing to help cus­tom­ers “get it”.

Anoth­er key point needs to be con­sidered: Product volume. Cer­ti­fic­a­tion costs money and takes time. If you are selling less than 200 units per year of a giv­en product in your line, cer­ti­fic­a­tion for that product is unlikely to be feas­ible. For product volumes from one to 200 units per year, Field Eval­u­ation provides a much more time and cost-effect­ive way to get your product marked.

The dia­gram shows the gen­er­al pro­cess flow for this activ­ity. If you are choos­ing to use Field Eval­u­ation instead of Cer­ti­fic­a­tion, sub­sti­tute “Field Eval­u­ation” wherever you see “Cer­ti­fic­a­tion” in the diagram.

Flowchart showing a recommended process for product safety certification.
Product Safety Cer­ti­fic­a­tion Process

Selecting standards

Select­ing the “right” stand­ard for your product can be a chal­lenge, espe­cially in the indus­tri­al mar­ket where products are often highly spe­cial­ized, “one-off” products. In many of these cases, no stand­ard exists that spe­cific­ally cov­ers the product. For rel­at­ively simple products, or for products that are very com­mon, like TVs, com­puters, and audio-video equip­ment, there are “Product Fam­ily” stand­ards that spe­cific­ally cov­er these types of products.

Not every stand­ard is a cer­ti­fic­a­tion stand­ard. Most of the cer­ti­fic­a­tion stand­ards are focused on elec­tric­al and fire safety, although there are some, like IEC 62368 – 1 [8], that have intro­duced a wider view of product safety. The con­cerns are the pre­ven­tion of elec­tric­al shock, arc flash, and fire. Cer­ti­fic­a­tion stand­ards will typ­ic­ally include spe­cif­ic tests that must be passed to show com­pli­ance with the require­ments. Design stand­ards, on the oth­er hand, will provide gen­er­al per­form­ance require­ments and some­times pre­script­ive fea­ture require­ments, but no test require­ments. This is typ­ic­al in the indus­tri­al machinery sec­tor where stand­ards like CSA Z432 [6] and the ANSI B11 fam­ily [7] of stand­ards apply. In these cases, you may be able to have the product cer­ti­fied for elec­tric­al safety, but not for machinery safety. This does not elim­in­ate cor­por­ate liab­il­ity for the machinery haz­ards, requir­ing man­u­fac­tur­ers to be know­ledge­able and dili­gent in apply­ing design standards.

Developing a Certification Strategy

To devel­op a sound strategy I recom­mend a “bot­tom-up” approach, start­ing with the product you wish to cer­ti­fy. To apply this idea, start with the bill of mater­i­als for the product. Look first at the pur­chased products: How many of these items are either already cer­ti­fied by their man­u­fac­turer? What spe­cif­ic cer­ti­fic­a­tions do they carry? Make a list of all the cer­ti­fied products and their rel­ev­ant cer­ti­fic­a­tions. All of the cer­ti­fied items can be elim­in­ated from fur­ther con­sid­er­a­tion for the moment. Next, con­sider the pur­chased but un-cer­ti­fied products. Con­tact all of your sup­pli­ers to determ­ine which of these products can be pur­chased cer­ti­fied, and adjust the bill of mater­i­als to reflect the part num­bers for the cer­ti­fied versions.

Now, the harder part. All of the remain­ing items on the bill of mater­i­als need to be looked at for cer­ti­fic­a­tion. Any­thing that can­not or need not be cer­ti­fied, e.g., nuts and bolts, oth­er mech­an­ic­al parts that are not pres­sure bear­ing, etcet­era, can be excluded from con­sid­er­a­tion. You now have a short list of uncer­ti­fied com­pon­ents that require certification.

For each item on the short list, research the stand­ards avail­able. The Scope of the stand­ards will help guide you regard­ing their applic­ab­il­ity. Once you have a matched list of com­pon­ents and stand­ards, you can extend that research to include the top level product.

Now you have the begin­ning of a com­pli­ance strategy. The next piece of the puzzle involves the intern­al eval­u­ation of each com­pon­ent against the stand­ards chosen. This gives you the abil­ity to revise your think­ing, either of the stand­ards you chose or of the design and con­struc­tion of the com­pon­ent. Mak­ing good choices at this stage to either cor­rect issues found in the design or con­struc­tion of the com­pon­ent, or in the selec­tion of the stand­ard, can save you huge amounts of time and effort once the cer­ti­fic­a­tion body gets involved.

Once the com­pon­ents have suc­cess­fully passed the intern­al “pre-com­pli­ance” eval­u­ation, you can get the cer­ti­fic­a­tion body involved, and start the form­al com­pli­ance pro­cess for each com­pon­ent. As this part of the pro­cess pro­gresses, the cer­ti­fic­a­tion body may have addi­tion­al ques­tions or requests for inform­a­tion. To reduce these in-pro­cess ques­tions, make sure that each com­pon­ent is clearly iden­ti­fied, that you have unique part num­bers for each part and that you have provided inform­a­tion on the mater­i­als used in the con­struc­tion of the com­pon­ent, as well as detailed engin­eer­ing drawings.

As the com­pon­ent cer­ti­fic­a­tion work pro­gresses, you can start on the top level product cer­ti­fic­a­tion work. The top-level product needs to go through the same sort of intern­al pre-com­pli­ance pro­cess as the com­pon­ents so that you can be as cer­tain as pos­sible that the product will meet the require­ments when it gets to the cer­ti­fic­a­tion lab.

Pre­par­a­tion of the data pack­age and the sample(s) of the top-level product that will be sub­mit­ted must be done care­fully. Con­struc­tion of the samples must match the man­u­fac­tur­ing draw­ings and instruc­tions as closely as pos­sible. Once everything is ready, the samples can be sub­mit­ted for evaluation.

Working with a Certification Body

Deal­ing with a Cer­ti­fic­a­tion Body can be very chal­len­ging. Much of the exper­i­ence will be based on the pro­ject engin­eer that is respons­ible for your product’s eval­u­ation. It’s import­ant to care­fully nur­ture a good rela­tion­ship with this per­son at the begin­ning because once prob­lems start to crop up in the lab, you will need to be able to talk to this per­son frankly and openly. Mak­ing sure that you have the “right” stand­ards selec­ted for your product is essen­tial, and the pro­ject engin­eer must agree with you. They can refuse to cer­ti­fy a product if they feel that the stand­ard chosen is incor­rect, and since they have the final word, there are few ways to appeal this decision. An open dis­cus­sion at the begin­ning of the pro­ject to dis­cuss the stand­ards selec­ted is an excel­lent place to start. If your ideas and theirs devi­ate in a big way, you may have to com­prom­ise on their selec­tion, or worse, stop the pro­ject and review the prob­lems encountered.

Once the product is cer­ti­fied, the Cer­ti­fic­a­tion Body will con­duct reg­u­lar audits on the man­u­fac­tur­ing facility(ies) to make sure that the pro­duc­tion test­ing is being done, pro­duc­tion records are kept, and that the QA pro­grams are ensur­ing that only good product leaves the plant.

Managing Customer Complaints

An import­ant part of the QA pro­cess is the Cus­tom­er Com­plaints Pro­gram. Man­u­fac­tur­ers must have a pro­gram in place to record cus­tom­er com­plaints and to respond to those com­plaints. A decision tree that helps cus­tom­er ser­vice rep­res­ent­at­ives dif­fer­en­ti­ate between safety-related and non-safety related com­plaints should be developed. Safety-related com­plaints should res­ult in an engin­eer­ing review of the prob­lems and determ­in­a­tions about the cause of the prob­lems. If these are related to man­u­fac­tur­ing or design issues, and espe­cially if these are related to com­pli­ance with the require­ments of the cer­ti­fic­a­tion stand­ard, a recall of the product may be needed. If this is the case, get the Cer­ti­fi­er involved as soon as pos­sible. Fail­ure to act, and fail­ure to inform the cer­ti­fi­er can res­ult in the cer­ti­fic­a­tion being revoked.


[1]     Canada Labour Code, [online]. Avail­able:‑2/. Accessed: 2018-01-10.

[2]     Ontario Elec­tri­city Act – Mark­ing require­ments Avail­able: Accessed: 2018-01-10.

[3]     Cana­dian Elec­tric­al Code, CSA C22.1. 2012.

[4]     Nation­al Elec­tric­al Code, NFPA 70. 2014.

[5]     Occu­pa­tion­al Safety and Health Stand­ards, 1910 Sub­part S, Elec­tric­al, Install­a­tion and Use. 29 CFR 1910.303(b)(2), [online]. Avail­able: Accessed: 2014-01-27.

[6]     Safe­guard­ing of Machinery. CSA Z432. 2016.

[7]     Safety of Machines. [Online]. Avail­able: [Accessed: 2014-01-27].

[8] Audio/video, inform­a­tion and com­mu­nic­a­tion tech­no­logy equip­ment – Part 1: Safety require­ments. IEC 62368?1,, 2018. [Online]. Avail­able: [Accessed: 2019-07-02].

Leave a Reply

Your email address will not be published. Required fields are marked *

This site uses Akismet to reduce spam. Learn how your comment data is processed.