EVERYTHING A PROJECT MANAGER

WANTS TO KNOW ABOUT

LOW COST SYSTEMS AND
ELECTRICAL REGULATIONS
April 28, 2006

Over the decades P&G has typically sourced our machines and process skids from fully capable suppliers in the
developed countries, generally North America and Europe. Recently Product Supply has been sourcing more and
more of our equipment from suppliers “remote” to the country where the equipment is to be installed. In the first
situation, the “developed” sources generally understood the legal requirements the machines and process skids must
meet. In the second situation, it has been my experience that our “remote” sourcing suppliers of equipment generally
do not understand the legal regulations applicable to the foreign country. This is pretty understandable, as
engineering contractors and equipment fabricators are generally familiar with the legal requirements for their own
country, but generally are not familiar with those requirements for other regions.

Building machines and process skids that do not meet the applicable legal regulations has resulted in significant
project delays and cost adders – resulting from rework of the equipment to bring it up to the legal regulations of
the country where the equipment is installed. Is this an isolated problem? I don’t think so, as this has occurred on
every “remote” project I have been involved in over the past several years.

What can we as a Product Supply organization do to insure our machines and process skids built in “remote”
countries meet the legal regulations for the country where the equipment is to be installed? Read on…

P&G and Legal Regulations

At an absolute minimum our equipment systems must meet all applicable legal requirements for the country or
countries in which the system will be installed and operated (see Figure 1 below). The statements “we operate
within the letter and spirit of the law 1 ” “obey all applicable legal requirements at all times 2 ” and “no one at any
level of the Company has the authority to require or permit you to violate the law 3 ” are statements we are all
familiar with.

Wise to consider
Value-Add Considerations

Must consider
P&G and Outside Safety-Related
Standards and Practices

P&G Policy
Must follow

Legal Regulations

Figure 1 – Hierarchy of Project Considerations

1
Our Purpose, Values and Principals.
2
Worldwide Business Conduct Manual, page 12.
3
Worldwide Business Conduct Manual, page 7.
Legal Regulations Around the World for Electrical Systems
What are the legal regulations around the world associated with the design, fabrication and installation of the
electrical power and controls portion of our machines and process skids?

First off, and unfortunately, there are no universal worldwide electrical regulations. Part of the reason for this is the
difference in electrical power systems. The U.S. and some countries use 120 VAC, 60 Hz systems, whereas other
regions use 220 VAC, 50 Hz. Building practices vary worldwide and a multitude of other differences exist. The
bottom line is each region has its own unique set of laws, and these laws extend into the world of electrical
installations. Just as there are no universal worldwide highway speed limits and driving laws, there are no universal
electrical regulations.

Is the requirement to meet these electrical regulations for our machines something new? No, these legal regulations
have been in place for decades. What is new is how and where we are procuring our systems.

In the past, we used engineering contractors with strong knowledge of the local regulations to execute our projects.
We built our machines and systems using major U.S. and European-based machine fabricators. Roll forward to
today – where we may be using an engineering contractor with little or no knowledge of the electrical regulations for
the region where the machine will be delivered. Often no engineering contractor is involved at all, with the
equipment fabricator providing the detailed engineering for the equipment. The machine fabricators we are using
today often have no knowledge of how to build a machine that meets the electrical regulations for the intended
region.

So the legal regulations are the “absolute minimum scope” that is required for our projects. What are these
regulations? Unfortunately, because laws are themselves complex, and because many of the regions have very
different regulations – there is not a straight-forward answer to this question. An overview of this can be seen in
Table 1 below.

“U.S. – Type “EU Regulations” Countries with Other Countries

Regulations” (EN/CENELEC Standards) Unique
Regulations

• U.S. – NEC (and • Austria • Ireland • China: CCC • In general, most

OSHA) • Belgium • Italy • Australia other countries
• Canada – CEC • Cyprus • Latvia • Brazil follow
• Mexico – NOM (Greek • Lithuania (BNR/NBR international
• Columbia portion) • Luxembourg standards, (IEC) standards
• Venezuela • Czech • Netherlands along with
• Panama Republic • Portugal IEC)
• Saudi Arabia • Denmark • Spain • Japan (JIS
• Puerto Rico • Estonia • Sweden Standards)
• Philippines • Finland • UK (Great
• France Britain &
• Germany Northern
• Greece Ireland)
• Hungary

Table 1 – Electrical Regulations Across the World

In the U.S. the primary regulations that apply to electrical systems are the National Electrical Code (NEC) and the
Occupational Safety and Health Act (OSHA – a Federal law).

The Canadian Electrical Code (CEC), although similar to the U.S. NEC, contains particular requirements that are
different from and in some cases exceed the requirements of the NEC.

The European Union comprises 25 member countries (see Table 1 above). CE marking of our systems is a legal
regulation in the EU. CE marking indicates compliance with the following EU Directives (laws):
• Machinery Directive
• Low Voltage Directive
• EMC (electromagnetic compatibility) Directive
• ATEX Directive (for hazardous systems)

Unfortunately there are significant differences between the electrical regulations in the U.S. and the EU. These
differences are not only in executional details (e.g. electrical insulation wire colors, conduit versus cable tray, etc.)
but are more importantly identified in differences in philosophy between the regions. The U.S. regulations tend to be
more specific and executional in nature – for example, how to fill a conduit seal for use in an explosion area.
European Union regulations tend to be more risk-based – for example, you must do a risk analysis and ensure that
all risks are removed or properly dealt with, and then carefully document this.

Some wish there were magical “international standards” that could be followed – unfortunately there is no such
thing. Others ask “can’t we just get CE marking and use that?” Unfortunately CE marking, a legal requirement for
the EU, is of absolutely no significance in any regions other that the EU – just as driving regulations in France has
no significance to driving regulations in the U.S.

So What Can You as a Project Manager do to Help?

Although certainly not a checklist, the information below can be used to help projects progress more effectively in
this area. The basic and most important concept is to select those who will do detailed engineering and machine /
process skid fabrication who are experienced with the electrical regulations in the regions where the equipment
will be installed.

1. Since the regulations are built on national or regional laws, first identify the region where the machine or
process skid will be installed and operated. Whereas it may be possible to make a machine that can work
and be legal in various regions, doing so will invariably cost more money, at least for the design and
fabrication of the first units.

2. Ensure that the inquiry and purchase specifications clearly note the countries where the equipment will be
installed, and also clearly note that all legal regulations for those countries shall be met.
In the inquiry specification, request the vendor provide information on equipment supplied for the region of
interest. That information should include:
• Description of equipment or service rendered
• Customer name
• Country delivered to
• Year
• List of engineering employees by discipline, with years of experience.
Especially note the number of degreed electrical engineers and years of
experience.

3. Ensure that those selected for the detailed electrical design engineering for the project (wiring drawings,
raceway drawings, equipment specifications and the like) are experienced with the electrical regulations
for the countries in which the equipment will be operated. Generally you can consider if an organization
has delivered many dozens of projects to a particular region they are familiar with the regulations for that
region. An organization that has done only a few projects for a given region most likely is not
knowledgeable of the electrical regulations for that region. Capable organizations generally have a number
of degreed electrical engineers with substantial years of experience on their staff.
Involving a PC&IS engineer in this selection process may be wise.
4. Ensure that those selected for fabrication of the electrical system are experienced with the electrical
regulations for the countries in which the equipment will be operated. If the fabricator has delivered many
dozens of different types of machines or process skids to a particular region, they most likely have that
experience. In regions where such expertise is lacking, consider enlisting the local services of Rockwell or
Siemens to build electrical control panels and otherwise assist in the construction of the machine.
Involving a PC&IS engineer in this selection process may be wise.

5. If for whatever reason it is impossible to use engineering contractors and machine fabricators who have
sufficient experience, the following options may be considered:
o Have the company do the work anyway, and then have it modified to meet the legal requirements
once the equipment arrives at the P&G site. Our experience to date has shown this to be a
generally unacceptable option, as the resulting added cost and schedule delays have been
untenable for most projects.
o Train the engineering contractor and the machine fabricator in the required skills. Generally this is
a months-long exercise, and P&G has neither the staffing nor the skills required to do this – so
outside help will be required. This approach only makes sense where we are sure that we want to
have a long-term relationship with that company.
o Have the machine built minus the electrical systems. Have an organization with electrical design
engineering skills and electrical construction skills (may be separate companies or a design/build
company) that is familiar with the electrical regulations in the target country do the electrical
work. Because there must be close coordination between the design of the machine and its power
and control system, this option will only work if the interface issues are dealt with early, carefully
and completely. This option is much more difficult to accomplish than it might appear on the
surface.

If any of the above options are used, the Project Manager should ensure that sufficient capital and schedule
time is allotted to execute this work.

6. Develop a method to verify the machine or process skid is built to the regulations. Think of this as similar
to how the P&G QA (Quality Assurance) organization validates our products meets their product design
and regulatory requirements. Doing such verification at the fabricator’s site – prior to shipment to our
manufacturing facility – is a method to save time and money in rework. Generally P&G people do not have
the skills to do such verification. One method of such verification is to enlist the help of a third-party
testing organization such as TUV Rheinland (www.tuv.com). TUV will inspect and test the machine or
process skid and ensure that it meets the legal requirements for the country where it will be operated. This
process is somewhat analogous to getting a household appliance listed and labeled by Underwriters
Laboratories (UL) in the U.S., or by the German testing lab VDE for use in the E.U.
It may be easiest to request the machine vendor include this in their bid and manage this interface. Such
verification would be part of the P&G vendor acceptance test.
Figure 2 below shows some of the major points of significant P&G impact on machine / process skid projects.

Inquiry
Equipment

Verify regulations met

Select
Equipment
Manufacturer

Detailed Design
Engineering
out regions
Identify and call

Equipment
Fabrication
Select vendors with
appropriate experience

Inspect
& Verify

Ship

Install

Figure 2 – Areas for Significant P&G Impact on Machines and Process Skids

Sources of Additional Information

• Your local PC&IS contact.
• AskMe, at the Power, Control and Information System community (http://askme.pg.com/askme/).
• Contact the author of this document.

Jim Reizner
Power, Controls and Information Systems
Corporate Engineering