Do You Know Who Made Your Valves?

Counterfeiting is a slippery business. Here’s how to minimize the risk and danger of fake process controls.

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Baker adds that checking wall thickness is so important because the traditional hydro test is only one of the two elements necessary to meet ASME B16.43 intent. Hydro testing involves filling a valve or component with water, and pressurizing it to 1.5 times its cold, working pressure rating. “Many people in our industry have a paradigm that hydro testing is all that’s required to ensure pressure class integrity, but buyers should ask their suppliers to certify wall thickness in addition to hydro testing.”

With increasing age and typically unknown prior application history of salvaged/refurbished/remanufactured valves, meeting both of ASME B16.34 (paragraphs 6.1.7 for additional metal thickness and 7.1 for shell testing) should be a critical requirement.

“To reduce the risk of non-compliance and better increase plant safety associated with salvaged/refurbished/remanufactured equipment, end users should implement appropriate awareness, specifications, and purchasing procedures to ensure that suppliers of such equipment are fully capable of restoring to original OEM design specifications.

“In addition, to containing process pressures, the certification of electrical/electronic devices for use in hazardous (classified) locations is another critical issue associated with salvaged/refurbished/remanufactured instrumentation.

The Electrical Side

OSHA’s 20-year-old Nationally Recognized Testing Laboratory (NRTL) program inspects the 18 labs presently authorized to test products (see Sidebar, Nationally Recognized Testing Laboratories at the end of this article), and confers non-incendive, intrinsic safety, and explosion-proof ratings on OEM-designed, new products. A subset of the 18 labs are authorized for specifically certifying process equipment for use in hazardous location. However, it’s the end users that bear the responsibility for ensuring compliance to OSHA 1910 electrical approval requirements. Any change made to an NRTL-approved device, even if inadvertent, may alter the device’s design attributes as originally tested and certified by the NRTL too appropriate consensus standards.

“When end users purchase equipment for use in hazardous locations, the NRTL certification mark on the device nameplate provides the confidence that the device continues to meet the codes and standards that the NRTL lab originally tested to,” says Baker. “For example, take the everyday, common task of removing and replacing the cover on an NRTL-approved device, such as during calibration, instrument installation, etc. When replacing the threaded cover—an explosion-proof enclosure—one must ensure the cover is screwed on with a specified number of threads engaged, or else the explosion-proof approval is not valid as originally tested by the NRTL. Further, if damage to the threads occurs due to cross threading (or a technician subsequently filing the threads to facilitate full engagement), then that instrument ‘has incurred a change,’ and is no longer considered by NRTL as equal to what it originally tested and approved. When threads are damaged on an approved, explosion-proof device, then a potential flame path is created at the location of thread damage. Depending on instrument brand and design, there are other parts of and flame paths that could inadvertently create a ‘change’ to an approved device during repair or component replacement.

“My last several years of experience indicate that few end users fully understand the issues and requirements of NRTL approvals for instrumentation used in hazardous locations. And, similar to the control valve example mentioned earlier, an instrument salvager/refurbisher/remanufacturer may sandblast, repaint, and recalibrate an NRTL-approved device, and then usually leave the old nameplate containing the original NRTL approval certification mark on it. Some remanufacturers even create new nameplates, and we’ve seen unauthorized NRTL certification marks applied to them (NRTLs have classified such as counterfeit marks). NRTL labs, such as FM Approvals, have taken the position that if a device’s ownership changes, then, until the device is re-certified by an NRTL-approved facility, the device is no longer considered approved, and its nameplate or certification mark and certification description should be removed.”

Removing these should assist end users in appropriately applying the instrument, and avoid installing it in a hazardous (classified) location, because the NRTL certification mark or certification descriptions would no longer be present on the device.  

While copying relatively big-ticket items like valves is attractive, it can be it can be even more tempting to fake smaller, more easily built items, such as circuit breakers and contactors. 

“There’s a tendency to think of counterfeiting as an outside-the- U.S. problem, but we’ve been getting a wake-up call in the past three to five years that this is a problem in the U.S. too,” says Jim Pauley, industrial and government relations VP for Schneider Electric’s North American operating division. “For example, we received a phone call from the U.S. customs office in San Francisco a couple of years ago because they found a person trying to get through from China with a suitcase full of circuit breakers with our Square D logo and UL labels on them. All of them were fakes. This has led to several ongoing litigations, and six settled lawsuits, but we think the overall state of the problem is still much worse than people realize or are willing to admit that it is.”
Pauley adds that users can learn more or report possible fake circuit breakers by visiting www.squared.com and clicking on “more information about counterfeit circuit breakers.”

“The old adage that ‘if a deal seems too good to be true, then it probably is’ was never more true than now,” says Pauley. “However, for us, counterfeits also mean that the safety capabilities that users depend on from products with our name on it may not be available. The danger is that users may not realize this until years later, when those fake devices are called on to work and fail instead. So counterfeiting doesn’t just involve stealing intellectual property, it also puts people at risk.”

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