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Jim Munro Director TestSafe Australia
Practical issues concerning the receipt of ExTRs by ExCBs when issuing national certification/approval Jim Munro Director TestSafe Australia
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Some Statistics On database – 40 ExTRs by 8 ExCBs On certificates – additional 2 ExTRs not on database
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What do you take on as ExCB?
For the certificate or approval that you issue: Responsibility; and Liability
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What do you have to base your decision on?
No original test data Often no calculations No original assessment notes No marked up drawings Option – not even a sample
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What do you have to base your decision on?
Just the ExTR: and Additional information such as drawings
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Ask yourself this question
Do I have enough evidence to issue the certificate? A properly completed ExTR and accompanying information should give you this
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The next question Does that ExTR provide me with enough evidence to be confident the equipment complies with the standards?
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What should you do? Start by reading OD010 Operational Decision “Guidance for the Preparation of IECEx Test Reports (ExTRs) by IECEx Certification Bodies (ExTRs) and the Processing of ExTRs by Receiving ExCBs”.
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Steps for acceptance Review – can be administrative or technical
Whether ExTR registered Ensure ExTR has been issued – get a signed copy
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Does ExTR need to be issued for review?
Can work with a draft initially Ensure issued before you issue certificate
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What about where tests have been omitted?
Where the issuing body elected not to do some tests, this needs to be backed up by sound engineering rationale
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What about if you find problems?
Go back to issuing ExCB If not resolved – go to ExTAG Secretary
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Typical issues Most involve: Incomplete ExTRs; Errors in the ExTRs; or
Scheme rules not followed
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Issues ExTR not listed on website Wrong descriptions Lack of test data
Incorrect or incomplete test data Bits missed
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Issues Tests done or referenced that aren’t the ones in the standard
Inadequate reference to marking requirements
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Issues Difference in opinion of interpretation of standards
Use of European interpretations or draft standards changes to establish compliance
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Issues No cover page Lack of justification in comments column of Section 1 ACB Review not completed No statement of compliance
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Issues Signing of cover page/Section 1 and Section 2 (evaluation record) by same person Reference to certificates, such as ATEX in the ExTR for components
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Issues Reference to ‘vast experience’ as basis for compliance
Mismatch between the checklist in Section 1 and the information in Section 2 (evaluation record)
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Issues Use of manufacturer’s testing without any evidence that it was witnessed Numerous errors
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Issues ExTRs not signed at all or not in all correct places Page numbers, issuing body information etc ignored within report
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Any more???
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