How to avoid to become an Ex manufacturer?

In any possible hazardous environment you may find Ex certified devices, installations or even systems. The formula is kind of simple – as long as we do install, operate, maintain and repair as it should be, device is still Ex, and there shall be not any modification even in terms of legal considerations.
What is an Ex product?
– There is a manufacturer
– Product is Ex certified either by 3rd party (ATEX Notified Body, IECEx CB, etc.) or manufacturer (if IECEx, it is not an option)
o In case of ATEX Category 2 non-electrical devices there you might find the following option: retention of documentation
– There is a manual focusing on Ex integrity
o List of Ex accessories has been added
– Declaration of Conformity
– All above displayed on the label
By any chance where you do not follow anything defined in the above mentioned list of mandatory to-do-s you immediately may become the manufacturer of the one device you are looking at. In case* you have become a manufacturer of that certain device, and that means: you shall start the certification process, but before the research and development phase of your product including design & manufacturing.
* Examples:
– you replace the lighting tubes specified in Ex type certification to another type
– you replace the bearing to another type
– you modify the internal design of an Ex d control station
– you add additional functionality to your device
– …
The list is a neverending story. What is the truth behind? Functionality has just the 2nd place in the life of Hazardous Area Compliance. The very 1st has been taken long long time ago by Integrity of Explosion Protection. All relevant standards, directives and schemes communicate the importance of lifetime tracking of your Ex assets in order to be able to deliver proof of evidence of integrity of explosion protection has been maintained and still complies with original Ex certificate.
Why is that much important? Answer is simple (another question): who is the repsonsible person?

Responsible not for manufacturing, but on site! The one who shall be competent enough to realise the importance of explosion protection. Similar question for sure you will get from your insurance company, how you maintained integrity of explosion protection.
In case of hazardous industries  explosion protection works like dot on „i”. Fire-, environmental- and work safety are important, but the final acceptance comes with explosion protection. If all Ex, hazardous area site can be operated.
Being honest all sound very simple, but life may take various challenges. Ex personnel competency may help to make site Ex safe and keep it that way.
Keep up good work!
Original edition: – see page 19.

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