US A.3.1 T This clause does not fully explain Add clause for how verification is to be and Tests “Verifications achieved, as some clauses of All verifications against Ex safety ISO/IEC 80079-34, Edition 1 do. parameters/aspects should be documented. Recommend adding a clause with All tests which are used to verify Testing or Verification similar to the Ex safety aspects or ISO/IEC 80079-34. parameters of the equipment should follow industry standard test Nowhere is there are requirement methods and should be to document the verifications, to documented.” define test procedures or to document tests which are deemed critical to the Ex safety. US A.3.2 T There is no distinction to explain Include the following text: As explained earlier that only those non-metallic requirements for verification only wording of CD “The materials of equipment or parts of materials should apply to those is used - not any of equipment on which the Ex aspects of non-metallic materials, new wording. safety depends is what needs to non-metallic enclosures, and be controlled. As a result, the metallic parts of enclosures on auditor is left to verify that the which the type of protection manufacturer verifies 100% of depends.” the non-metallic materials used in the equipment, regardless of the potential risk level US A.3.2 T The required information should Change this section to: As explained earlier be listed in the equipment metallic materials only wording of CD “A.3.2 Non standard ISO 80079-36 as it is Where the non metallic materials is used - not any – in EN 13463-1, clause 7.3. affect the Ex safety of the new wording. equipment, the material should be subject to verification that demonstrates conformity to clause
US A.3.1 T This clause does not fully explain how verification is to be achieved, as some clauses of ISO/IEC 80079-34, Edition 1 do. Recommend adding a clause with Testing or Verification similar to ISO/IEC 80079-34. Nowhere is there are requirement to document the verifications, to define test procedures or to document tests which are deemed critical to the Ex safety. Add clause for “Verifications and Tests All verifications against Ex safety parameters/aspects should be documented. All tests which are used to verify the Ex safety aspects or parameters of the equipment should follow industry standard test methods and should be documented.” US A.3.2 T There is no distinction to explain that only those non-metallic materials of equipment or parts of equipment on which the Ex safety depends is what needs to be controlled. As a result, the auditor is left to verify that the manufacturer verifies 100% of the non-metallic materials used in the equipment, regardless of the potential risk level Include the following text: “The requirements for verification of materials should apply to those aspects of non-metallic materials, non-metallic enclosures, and parts of enclosures on which the type of protection depends.” As explained earlier only wording of CD is used - not any new wording. US A.3.2 T The required information should be listed in the equipment standard – ISO 80079-36 as it is in EN 13463-1, clause 7.3. Change this section to: “A.3.2 Non metallic materials Where the non metallic materials affect the Ex safety of the equipment, the material should be subject to verification that demonstrates conformity to clause metallic As explained earlier only wording of CD is used - not any new wording.
ExMC_1175_R_Response_to_US_Comments_ExMC1032CD.docx