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17) Why are Inda-Gro fixtures rated for damp locations?

We construct our lights so they may be installed in DAMP LOCATION environments such as in greenhouses. The following information applies to any type of light, HID, Induction, LED, or Plasma that would be installed in a greenhouse environment.

NATIONAL ELECTRICAL CODE (NEC) defines a DAMP LOCATION as a location where equipment will be installed that is between a DRY and a WET location. Electrical equipment mounted in DAMP LOCATIONS are protected from weather and not subject to saturation with water or other liquids but ARE subject to moderate degrees of moisture which require luminaires to be rated for that environment.

NEC SECTION 110-3B is critically important code rule because it states that manufacturers MAY NOT SELF-CERTIFY their products for the installation and application. SECTION 110-3B requires third party testing, verification, limitations, certification, listing and labeling of that equipment so that the end user, the building owner and the Authority Having Jurisdiction (AHJ), such as an electrical inspector, can easily verify that the equipment meets the minimum safety standards for that application.

OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION (OSHA) requires that any luminaires that are installed in a damp location be third party certified that they meet the criteria for installation in that environment. Once passed the manufacturer must mark and label each luminaire that it is rated for damp locations. This allows the Authority Having Jurisdiction (inspectors) and the property owner to confirm the product is suitable for installation in that environment. OSHA takes listing and certification of luminaires very seriously as they see the increased risks associated with unlisted products as preventable. Accordingly OSHA empowers the electrical inspectors to reject jobs with unlisted products and can place heavy fines on building owners and employers when unlisted products are found.

ELECTRICAL INSPECTORS AND OSHA: Electrical Inspectors have an ally in enforcing their local regulations and the National Electrical Code where there are requirements for products to be Listed and Labeled in accordance with Section 90-7 of the NEC. Electrical Inspectors are required to assure that all products installed in their jurisdiction are safe and comply with the NEC. To assure this compliance many Inspectors must rely on a label that appears on the product to make their determination of compliance. When the label does not appear the Inspector is usually left with the unpopular option of turning down the product or the installation.

This requires the Electrical Inspector not only to be very observant about the installation he/she is inspecting but also the products that are being installed. Additionally, he/she must also determine that the label is acceptable in his/her jurisdiction and the product is compliant with Section 110-3b of the NEC. If an unlisted product goes undetected and it is a Hazard, the Electrical Inspector could be held accountable. This is an unreasonable burden to be place on an inspector.

OSHA Electrical Standard (Subpart S) requires that all electrical products installed in the work place be listed, labeled or otherwise determined to be safe by a Nationally Recognized Testing Laboratory (NRTL). OSHA places the responsibility of this squarely on the Employer. OSHA, defines the building owner, facility or property owner as the employer.

The Electrical Inspector can require the contractor to remove an item not labeled in accordance with Section 90-7 or prevent the facility from opening, etc. OSHA, however can impose fines on the Employer of $7,000.00 to $70,000.00 per day for each violation. Often the Employer does not even know that a violation exists. OSHA’s involvement would be more effective than the authority an inspector may exert and would also be a major benefit in assisting an inspector with his/her legal responsibilities. The best thing an inspector can do is defer to OSHA the determination that a product legally complies with the standard and Section 90-7 of the NEC. Assuring that as many cord connected or installed devices are properly listed and labeled during an inspection is deferring a lot of the inspector’s responsibility over to OSHA.

These are some of the UL and OSHA recognized third party testing agencies. AHJ and end user confirmation of the certification can be found on the third party testing agencies website with which the manufacturer has listed that equipment.

Underwriters Laboratories Inc. (UL)
Intertek Testing Services (ETL)
Canadian Standards Association (CSA)

To confirm which agency the manufacturer has listed their products it is required that the manufacturer label their lights with the identity of the listing agency and the following marking information that would correspond with the same information that would be found on the listing agencies website:

Manufacturers Company Name
Model Designation
Factory Designation or Code
Date of Manufacture
Environmental Suitability (i.e. dry, damp or wet location)
Input limitations
Input voltage
Rated current or wattage

There are some fan cooled LED panel manufacturers who assert that they do not require damp location testing and certification of their products since they use listed components in their panel construction. This is not true. As you can see by the CSA STANDARDS for LED EQUIPMENT link these LED panels must be tested and listed for damp location environments as a whole product or in its End Use form. This is described in detail in section 1.3.1 (end use testing), 9.12.1 (humidity exposure), 9.4 (dielectric voltage withstand test for LED panels marketed expressly for damp location installations, and lastly section 10 where each fixture must bear SPECIFIC MARKINGS which proves the product has been tested and verified as acceptable for the environment it is being installed in. Without DAMP LOCATION certification and labeling these products are DRY LOCATION rated only as per OSHA, NEC and third party testing and verification processes.

Click here to see CSA Standard C22.2.250-13-12EN
Click here to see UL 1598 Standards for Wet and Damp locations Luminaires
Click here to see OSHA Standards for Construction Materials Safety and Health Workplace Inspections.

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