Relation to UL
A pre-field evaluation—similar to a preliminary acceptance inspection—allows a machine or system to be inspected prior to delivery, for example, during pre-commissioning in Germany, to verify its compliance with the standards and guidelines applicable in North America.
What does “pre-field evaluation” mean?
During a pre-field evaluation, a machine or electrical system is inspected at its production site to determine whether it complies with the relevant U.S. occupational safety regulations.
How is a pre-field evaluation conducted?
During a pre-field evaluation, the entire system is inspected to ensure it complies with the standards in effect at the installation site. To this end, all technical documentation for the system, as well as the associated schematics, are submitted to the testing laboratory. A thorough review of the documents and an inspection of the system are documented in a detailed report. This report lists all necessary modifications to the product that must be implemented to ensure the system complies with OSHA standards.
Purpose of the Pre-Field Evaluation
In the United States, strict regulations govern the operation of machinery and electrical systems to prevent electric shocks, fires, explosions, and other hazards. These regulations can vary from state to state, and in some cases even from municipality to municipality. Local authorities (Authorities Having Jurisdiction, AHJs) are responsible for inspecting systems to ensure compliance with these regulations. These authorities are ultimately responsible for approving the commissioning of a system and bear legal responsibility for it.
A pre-field evaluation gives the system manufacturer the assurance that its product complies with local regulations and laws. However, no certificate is issued following a pre-field evaluation, which means there is always a residual risk that approval in the United States by the responsible AHJ inspector could be denied. Furthermore, there are occupational safety regulations and laws that may not be covered by the UL standards under review, such as noise protection. To ensure that a system also complies with the relevant regulations in these areas, it is recommended to consult with the responsible AHJ.
Why is a pre-field evaluation useful?
During a pre-field evaluation, all issues identified by the inspector can be resolved on-site at the production facility. This significantly reduces the logistical effort required to correct defects for companies based in Germany.
Of course, this inspection can also be conducted after the system has been installed in the U.S.—in which case it is referred to as a field evaluation. However, if the inspectors identify any issues during the evaluation, the defects can only be corrected on-site, or the system must be returned. In either case, this results in a significant logistical burden.
Who conducts a pre-field evaluation?
As a rule, pre-field evaluations are conducted by the same OSHA-accredited testing laboratories (Nationally Recognized Testing Laboratories, NRTLs) that also perform the field inspections for which a corresponding field evaluation label is issued. In Germany, there are only a few providers of this service. Perhaps the best known is Underwriters Laboratories (UL), which translates OSHA’s occupational safety regulations into numerous internal UL standards. Many of the more than 1,300 safety standards developed by UL have since become official American National Standards (ANSI).
Is there a Pre-Field Evaluation certification mark?
The tests, conducted primarily by UL, are very comprehensive. In consultation with the local competent authority, it is ensured that all applicable standards and local requirements have been taken into account. However, a Pre-Field Evaluation certification mark —which verifies the machine’s or system’s compliance with applicable safety regulations—is not issued during a Pre-Field Evaluation.
This process, therefore, serves solely to inspect a product so that any issues can be resolved here in Germany, and not to verify compliance with safety regulations.
As a result, there is always a residual risk that approval in the United States could be denied by the responsible AHJ inspector. However, even with a UL mark, there is no guarantee that approval will be granted. The pre-field evaluation, however, at least provides sufficient assurance that any violations of the applicable regulations have already been identified and corrected.
What is the difference between a pre-field evaluation and a field evaluation?
The field evaluation takes place on-site at the installed and operational facility. The on-site inspection entails the disadvantages mentioned above in the event of potential complaints. However, if the field evaluation is successfully conducted by an accredited testing laboratory, a corresponding inspection label can be issued, which significantly facilitates official acceptance by the competent building authority. Conversely, the field evaluation proceeds more quickly if any existing defects have already been rectified as part of a pre-field evaluation in the system’s country of origin.
Pre-field evaluation and field evaluation are therefore not mutually exclusive alternatives, but rather complement each other. For foreign companies in particular, it is recommended to conduct both a pre-field evaluation—to address any deficiencies in a straightforward manner—and a field evaluation, which enables faster commissioning of the system at the customer’s site.
