MEETING MINUTES

AMERICAN COUNCIL FOR ELECTRICAL SAFETY

(ACES)http://www.7acil.org/?page=746

NEMA Headquarters

1300 17th Street North, Suite 900

Rosslyn, VA

Conference Room (1st Floor)

Thursday

October 18, 2018

At 9:33 The ACES Chairman started us with self-introductions.

He then introduced the meeting’s context, commending attendees for coming given that it’s world standards week and cyber week, plus logistics are not easy for many. Chairman talked of ACES’s goals.

The Chairman Charles Meeker noted that he is retiring from Electrical Reliability Services (VERTIV), and while he may be able to attend future meetings, his role will not be as Chairman. He then reintroduced Don Tottingham of NSF as the proposed candidate for ACES Chairman. He commented that we all should have received Don Tottingham’s biographical material. Don was briefly introduced by Steve Fabian, and we proceeded to the program.

NOTE: Presentation slides and an attendee list are embedded at the end of these minutes.

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NEMA’s Joel Solis talked about e-labeling. With technological developments, labels are adding auditory, visual or tactile aspects; social media adding options

The problems these addresses include limited physical space on a product for all the information that needs to accompany it, plus rapid changes of technical data.

Joel mentioned that Dell & Intel are consulting on adding electronic labeling. A plebian example is electrical tape, which already bears U.S. and Canadian markings. Perhaps NAFTA 2.0 will add Mexican marks to it.

One problem is that more complex information needs to be communicated to users. There are diverse options for e-labels: they can use a device’s own screen; they can provide a net link; or a QR code.

The Grocery Manufacturers Association (GMA) is in the forefront of labeling, e.g. for nutrition, especially with e-shopping. Without a brick-and-mortar store, customers can’t examine the products for various markings.

The GMA program is available online. Consumers can go to http://smartlabel.org/ to find information on ingredients, nutrition facts, and other information, giving a consistent way to get information that manufacturers agree to offer.

Question: what happens if a product is changed?

There is a unique template per product, sold to manufacturers for a nominal fee, which is enough to support the program. Therefore, if a new product is provided or a product changes, consumers can choose information that the manufacturer supplies regarding the new product or version.

Question: who is going to maintain this database? When for example Saudi Arabia decides everyone should go to a government website with a central repository of product information, this leads to concern about budgeting for website maintenance and updating of the information.

Joel showed a self-explanatory “Benefits of e-labeling” slide.Consider an installer who sets a ballast in a ceiling, he said, and 15 years later it needs to be replaced. An e-label is available for servicing information, under this model.

Questions: When products change and their QR code doesn’t, how does a user know which version they have? When an early product is not compliant with a standard, but later ones are, how are you to know which you have? Where in the production range did it come, if the QR code is the same?

Question: what is the size of the QR code? Could this convey information on parts that are too small for adequate labeling? Joel: That’s in the standard. The ISO/IEC Tag is JTC1/SC31 and the draft standard is ISO/IEC 22603.

Question from the CPSC’s Doug Lee: how easy will it be to counterfeit e-labeling? Joel: This is a topic they are thinking about.

Question from UL’s Bob Pollock: How will QR codes impact the work of OSHA?

OSHA’s Kevin Robinson: In some places the OSHA field inspector may not have a connection to download the information the QR code points to. The QR can be useful but can’t yet stand alone.

Comment from UL’s Bob Pollock: There can be quite a difference between products that are simply bought or installed, versus products that are installed and inspected.

Comment from OSHA’s Kevin Robinson: what’s the anticipated longevity of QR codes? Remember the Digital Convergence Corporation’s: CueCat barcode reader from 15 years ago? It’s useless now. (Joel also has one.)

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Next, we heard from the ICC’s Gabe Maser, gmaser@icc.org, 202-730-3953

Among other projects, he mentioned the ICC effort to develop a benchmark for community resilience.

A good part of his talk described their Code development cycle. Their conference takes place next week in Richmond, VA. Virginia is a very active state with regard to jurisdictional authorities’ involvement in ICC.

One of their projects is harmonizing their energy code with LEED certification. They’ve planned a rollout for November 2018. Among other developments in their energy efficiency code, they’re adding a requirement for Electric Vehicle charging means and for real-time energy reporting. They are harmonizing with ASHRAE.

One issue Gabe raised is the variation in adoption of up-to-date codes and, even then, in code enforcement.

He showed us where their various codes are adopted; many are far from up-to-date, which may mean buildings do not match the expectations of purchasers.

State-level disaster-mitigation grants depend in part on modern code adoption. Draft bipartisan legislation is moving forward later this year regarding disaster recovery funding. It includes 10% for mitigation.

After a disaster, FEMA provides individual assistance too, and sometimes runs multifamily rebuilds themselves.

Meanwhile, the same problem worries the ICC that concerns the entire construction industry: 55% of bldg officials are over 55 years old.

There were no questions.

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Next, we heard from NIST’s Amy Phelps.

Conformity Assessment SP2000-01, and -02 for Fed agencies. They are avail at standards.gov

While agencies are expected to consider their contents, we’re talking about considerations documents, not at all regulatory/prescriptive. The amount of stakeholder input was very gratifying, and she and Ms. Carnahan enjoyed the process.

There were no questions.

Amy made some statements on behalf of the FDA:

The Accreditation Scheme for Conformity Assessment (ASCA) is owned by FDA, which plans enhanced use of consensus standards that the FDA accepts.

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OSHA’s Kevin Robinson was up next. He said there are no significant updates on the NRTL directive; it is being reviewed by OMB. The OMB seems to run slower than the ideal.

He added that there are no surprises expected.For many years, the NRTL program was high priority in EU negotiations. It may again, but it’s unclear what role OSHA will have.

There are Federal Register notices going through, having to do with procedural cleanup.

Question: there was an expectation of a streamlined process and a new fee schedule–is this in the notice that goes back to 2014? Kevin: there will be new forms and fees, all released at the same time as the directive.

Question: Applications for expanding standards covered had been on the order of 18 months; is this still the case? A: yes, still.

Question: are evaluation criteria at OMB? A: Sort of, but the directive they are reviewing is about OSHA’s internal process.

OSHA is looking to increase the initial fee for each expansion application, so if the application fails, technical work entailed in evaluating it is paid for. A correspondingly lower fee will be charged at the end for successful applications, at publication in Federal Register. Unsuccessful ones will cost more; successful ones, less.

Question: We are right in the middle of an application; what should we reference?A: Better an older version of ISO 17025 for now.

Some years ago, there were 15 NRTLs, and on examination, OSHA found that14 of them had significant conflicts of interest that would not comply with program as defined in the directive. Presently, none would. For now, they are using impartiality requirements in ISO standards. If a NRTL’s International Board of Directors includes manufacturers’ representatives, right there’s a potential conflict of interest.

At present, OSHA is going through 13 of 17 NRTLs with renewal applications, looking at factors including ownership, impartiality, and other aspects.

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CPSC’s Patty Adair was the next speaker, talking about the Internet of Things.

The CPSC has jurisdiction over around 14 000 categories of consumer products. Traditionally the CPSC has dealt with physical products, not software components. The IoT offers new challenges.

In January 2017 the CPSC produced the “Hazards of emerging technologies” report. Patty mentioned that it is available on the CPSC web site but offered to send it to anyone who gave her a business card.

She pointed out the risk of changing software leading to “hazardization,” by which she means modification that causes a hazard which did not exist when product was bought.Software update or hacking could affect a safety device, e.g. a smoke or carbon monoxide alarm.

UL is already in this world, we were told, with their 5500 standard for remote software updates.UL’s Bob Pollock mentioned that the UL 2900 family is Software Cybersecuity for Network Connectable Products.

Patty emphasized that the CPSC is mandated to start regulatory efforts with relying on voluntary standards.

The ASTM consumer products committee started a connected products subcommittee. The CPSC is working with international groups.

In May 2018 they had a hearing on IoT, from a safety perspective; privacy and data security are not covered by the CPSC’s mandate. They’ve gone through the feedback, which included many industry partners, albeit mostly after the hearing itself.

Comments generally supported collaboration on this and supported increasing CPSC resources to participate in voluntary standards development.

They plan to engage with the NIST framework on IoT Some commenters were pro, some con, third party certification of connected products

UL’s Ken mentioned that UL 5500 was developed proactively. UL saw this as increasingly important. Some remote updates may have safety implications.

There are various options. A user might say the user decides to update firmware; a manufacturer may push software out for this; both seem relevant. It’s a template that’s adaptable to various products.

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Ken Boyce <kenneth.p.boyce@ul.com> was next, joining us remotely to talk about UL 1974, which addresses repurposing batteries. It is primarily focused on the methods used. One important point is that the end product must meet end product standards just as it would with new batteries.

One new or newly-renamed test is the “single cell failure tolerance test.” It tests whether there is propagation, meaning explosion or propagation out of the enclosure, if one cell fails.

Increasingly the repurposed batteries are used for energy storage systems, covered by UL/CAN Standard 9540.

College campuses with Energy Storage Systems showed the few lights after hurricanes took out the grid.

UL’s working with New York City on how to safely integrate energy storage into buildings.

Question: What is the available energy density of these Energy Storage Systems compared to fossil fuel stores and generators, e.g. diesel?Ken: There are different energy densities, Li-ion batteries definitely offer the highest among battery systems.There are also issues of safety in either case. Ken hazarded that they are probably equivalent to fossil fuels in terms of danger, with the concomitant need for mitigation efforts.

Question: are there environmental aspects to repurposing?Ken: It means less mining and refining. In addition, this lets us put off building more batteries to today’s design, rather than future, more efficient ones.

Still, these chemistries are pretty dangerous. Storing the used ones at the facility where they are being evaluated and repurposed is another big danger. The risk of thermal runaway if one goes in a facility where many are stored is considerable.

Between Electric Vehicle batteries and stationary batteries, the regulatory schemes, tolerance to faults, consideration of grid disturbances and means of integration is very different. Simply taking an Electric Vehicle battery and using it for backup storage is almost certainly going to end in a fire. UL intends sharing this information worldwide--with the International Electrotechnical Commission, and maybe the International Organization for Standards; they are ready to do so.

Question: Are people in Third World countries repurposing batteries incompetently and dangerously now?Ken: In South Africa and Kenya, they are very concerned with substandard products, based on Asian manufacturers’ dumping. China has places that are investing very heavily in Electric Vehicles.

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Mike Johnston was next, giving us a very quick overview of significant changes in the 2018 edition of NFPA 70E, one of the standards for which the NEC correlating committee is responsible. After describing his extensive background and some of his credentials, Mike offered the disclaimer that whatever he would say represented only NECA’s position.

Mike did note that the first draft of the 2021 of 70E edition was published this summer.

Human error (Annex Q) now must be considered as a possible factor in an incident.

The hierarchy of risk control now is moved from an Informational Note into mandatory text.

The first choice remains eliminating the hazard–which can mean exposure to the hazard while eliminating it.

70E is now extracting language from other standards or referencing them in Informational Notes. The Style Manual does not allow mandatory language in Informational Notes and incorporating another standard by reference could be taken legally as implying that everything in that other standard is required.

“Working distance” below 600 V is defined as 18 inches to face & chest. More than 600V, 36 inches.

Along with the NEC, 70E is defining fault current and available fault current for consistent use.

ANSI z10, Management Systems for Occupational Safety and Health, doesn’t include awareness in its hierarchy of controls, but 70E now does.

They emphasize the difference between an “Incident” and an “Accident,” the latter being a case where the hazard was unforeseen.

Annual recertification for CPR and AED application is no longer required. Certifiers such as the American Medical Association and the American Red Cross decide about training intervals.

In the model of “Test on an energized source, test for voltage, retest on an energized source,” many instructors thought you need to check your instrument on the same voltage you’re confirming is shut down. This is not so– you can use any voltage source that will register.

Labels don’t have to be field-marked.

Globally, “Accidental” has been replaced with “unintentional.”

Annex F talks about Risk Assessment and risk control.

Annex K incorporates the latest Bureau of Labor Statistics electrical (injury?) (death?) numbers, which sounded like about 300 per year, 40% of them at voltages lower than 240V.

Mike emphasize the need for a cultural change among electricians. Considering risk of human error is not something a contractor or foreman is trained to do. Offering incentives for zero reportable incidents can lead to under-reporting.

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Charles expressed his appreciation for the ACIL/ACES member support of him as Chairman over the years. One of his focused goals was to get a broader balanced representation in ACES than there was when he started. He is looking forward to focusing on his grandchildren in retirement, whose picture he shared.

Don Tottingham was confirmed as the next Chairman by consensus / acclimation and the meeting was adjourned.

After consultation with Joel, we set our next meeting for April 25, 2019, with Don Tottingham as Chair.

-end-

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