UKCA Mark Webinar : Q&A With Thorne & Derrick & Raytec
Published 04 May 2021
Hazardous Area Lighting
Last week Thorne & Derrick alongside UK manufacturer of hazardous area lighting Raytec presented a webinar regarding the impact the UKCA mark would have on owners, operators, end users, specifiers and contractors working within the explosive atmosphere industry.
The aim was to give the participants a better understanding of the effect the UKCA scheme will have on them and how they can prepare for the changes ahead of the full implementation 1st January 2022.
Special thanks to Jonathan Sommersett Product Manager of Hazardous Area Division at Raytec for delivering the webinar and sharing his knowledge about the latest criteria changes. He explains how Raytec are approaching the situation by ensuring all their products are tri-rated by the 1st June 2021.
Below is a transcript of the Q&A section that took place at the end of the webinar.
Q1 – How will I know if my luminaire is UKCA approved?
A1 – Jonathan Sommersett – To obtain UKCA approval your product must be certified to the latest version of the standards and any approved body will issue an UK Ex certificate. Currently there’s an IECEx certificate & ATEX certificate there will now be UK Ex certificate to go alongside them.
Products will now have 3 certificates and any labelling on the product will carry the UKCA mark (for example packaging label or any labels attached to the product).
Q2 – Does the end date of December 31st 2021 apply to purchase or installation if you are located in the UK mainland?
A2 – Jonathan Sommersett – The advice Raytec have been given is that after 31st December 2021 a UKCA mark has to be on any product put onto the market in Great Britain. To clarify that is the first transaction between the manufacturer and distributor (or customer) after 31st December 2021.
If your product has been placed on the market before the 31st December 2021 then it can continue to circulate on the market until it reaches its end user. If you are installing a product after the 31st December 2021 you need to make sure it was placed on the market before that date. That is any transaction between a manufacturer, distributor and end user.
Q3 – We are a UK company and will be selling to another UK company who will be selling to end users who are outside the UK. Am I right to assume UKCA is not required in this insistence?
A3 – Jonathan Sommersett – In that case no UKCA would not be required it is only if the product is going to be installed in the UK. Same certification would apply for any good leaving the UK eg CE mark & ATEX mark would be required for any EU countries & IECEx for any Non-EU countries.
Q4 – Who would you advise to use to obtain UKCA?
A4 – Jonathan Sommersett – There are a list of UKCA Approved Bodies. A lot of the Notified Bodies based in the UK prior to Jan 2020 were previously ATEX Notified Bodies and they have now automatically become UKCA Approved Bodies only change is the slight difference in name. You can go to any to obtain your UKCA certification.
Terry McDonald – There is a list on the UK gov website listing all Approved Bodies
Q5 – When you say placed on the market, what do you mean by that?
A5 – Jonathan Sommersett – I can try and clarify it is a bit of a legal statement ‘placed on the market’. The advice from government is any product that has been ‘placed on the market’ as far as Raytec can tell is when any transaction between a UK manufacturer and any other user as long as money has change hands for that particular product would be classed as on the market. For example any product sitting on the shelf of a distributor owned solely by the manufacturer not would not be classed as placed on the market. If any product is on the shelf that has been paid for by the distributor then that is on the market.
Terry McDonald – This is a question that I am asked a lot and even asked ourselves for clarity around the terminology. In leaving the manufacturer a transaction has taken place so the goods moving from Raytec (manufacturer) to Thorne & Derrick (distributor) and Thorne & Derrick pay for the goods those goods would then by on the UK market. So essentially Thorne & Derrick could buy in a huge amount of stock on the 31st December 2021 with ATEX approval and continue to sell that throughout 2022 without any issues. Not our intention to do but this led on to a question about spares and whether you could sell them for non UKCA certified products post 31st December 2021. Over to you Jonathan.
Jonathan Sommersett – In terms of spares Raytec have committed for all of our products to be able to support and supply them going forward beyond 31st December 2021. Not an issue.
Q6 – So ATEX will continue to be recognised in the Europe but not in the the UK from January 2022?
A6 – Jonathan Sommersett – Yes that is correct. The UK has been split a bit by Brexit. The UKCA scheme applies to England, Scotland, Wales and the CE mark still applies to Northern Ireland because of the Northern Ireland protocol and the Brexit trade deal. So ATEX is still required in Northern Ireland or in certain circumstances UK Ni which is a completely separate mark to UKCA & CE.
Q7 – Will we need all 3 certifications (ATEX, IECEx & UKCA) for operation in the UK?
A7 – Jonathan Sommersett – You don’t need all three certs no but from the 31st December 2021 the key date we keep referring to only the UKCA mark will apply in England, Scotland & Wales so you don’t need ATEX beyond that date. One of the reasons Raytec are tri rating our products is so the same variant can be sold anywhere in the world.
Terry McDonald – I think it is worth pointing out that Raytec are a UK manufacturer have an invested interest in the UK market, the rest of Europe and the rest of the world. The message I have been trying to get across to end users is that there are manufacturers outside of the UK who may deem it not financially viable to obtain UKCA certification so therefore their products will no longer be available on the UK market. So you could be specifying products on site this year that you will no longer be able to purchase next year. So moving forward on your plant and operations to keep equipment the same for spares, repairs and operational costs it is worth obtaining UKCA approval. There is a potential that you could find yourself with some equipment on site that you can no longer purchase because it does not have a UKCA certificate.
Q8 – Will the UK hazardous area equipment certificates be referenced as UKCA Ex, UKCE or UKCA certificate? Just for purchasing references.
A8 – Jonathan Sommersett – I can try CE mark is a mark that declares that your product conforms to all the necessary legislation and ATEX is within CE as a conformity to any potentially explosives atmospheres. So the equivalent applies to UKCA which can be found on any number of different products eg lighting & radio equipment however UK Ex is specific to products for potentially explosive atmospheres so any certificate that is being issued for UKCA approval will have UK Ex within that certificate number just as ATEX currently has ATEX within the certificate number.
Q9 – What are the main requirements for getting UKCA approval?
A9 – Jonathan Sommersett – At the moment as mentioned in the slides the current standards UKCA & ATEX are currently the same so as long as your products are certified to the very latest version of EN 60079 series of standards then you should be able to apply for UKCA. The only issue is the conformity assessment which is a third party mandatory conformity assessment has to be done by a UK approved body which is separate to any EU 27 Notified Body. So you would need to separate bodies and two separate certificates – one for UKCA & one for ATEX. A critical point is that it must be up to the very latest versions of the standards so there is potentially a cost and design implication for the product to bring it up to speed.
Q10 – Any changes in Temperature Ratings for UKCA certified products?
A10 – Jonathan Sommersett – As all standards are currently the same the likelihood is that the ambient temperatures & certifications will pretty much remain the same between ATEX & UKCA because those standards are the same. There may be changes in the future but not at the moment.
Q11 – In your experience with compliance to EN 60079 was the issuing of UKCA Ex approval simply a ‘paperwork’ exercise by the UK approved body?
A11 – Jonathan Sommersett – As long as your ATEX certificates are up to date then they can be used as a reference by a UK Approved Body. It depends on the relationship between the ATEX Notified Body that did the third party assessment and the UK Approved Body that you chose to do your UKCA third party assessment so it is entirely down to the Approved Body.
Q12 – Just to clarify in terms of ‘placing on the market’. We have discussed the ‘first’ transaction between the manufacturer and customer (money changing hands) marking a product being placed on the market. Considering larger value equipment with milestone payments, would the first transaction mark the product being placed on the market, or payment in full for the item?
A12 – Jonathan Sommersett – For me it is not something that I had considered partial payment for goods it is a difficult legal question so we would have to take advice and get back to you if that is possible?
Q13 – It sounds like the solution would be to tri-rate all equipment but moving forward how will this effect periodic inspections without having an installed date of equipment without the UKCA marking?
A13 – Jonathan Sommersett – As you say tri-rating is what Raytec plan to do for any goods that why we are implementing UKCA from the 1st June 2021 so we aren’t waiting until the end of the grace period to start putting UKCA on our products giving plenty of time for these products to circulate on the market not waiting until the very last day of 2021. Ongoing in terms of maintenance schedule as long as you have the key dates when those goods were installed it will be no different to any ATEX or IECEx equipment maintenance schedule.
Q14 – Will UK approved bodies also be able to issue ATEX certificates?
A14 – Jonathan Sommersett – No. It is one of the requirements of the grace period that we are currently in if your product is currently CE marked with an ATEX certificate then that third party approval has to be done by an EU 27 Notified Body to still be compliant on the market right now. Going forward next year UKCA must be assessed by a third party UK Body and ATEX has to be approved by an EU Notified Body. So to clarify they can’t issue each other’s certificates.
Q15 – Do UKCA require LM 80 Reports for approval?
A15 – Jonathan Sommersett – In terms of UK Ex that is not a requirement at the moment. In terms of UKCA for an industrial product LM 79 and LM 80 are nice to have but they are currently UL standards so not a required for UKCA.
The full webinar can be viewed by clicking the video below:
Thorne & Derrick International, based in the UK, are Preferred Distributors and Stockists for the Raytec SPARTAN range of ATEX lighting using LED technology for the illumination of hazardous area locations and potentially explosive atmospheres.
The full webinar can be viewed by clicking the video below:
See how Raytec have been working closely with UK notified body, Eurofins CML to ensure certificates are constantly updated to the latest edition of the standards for all hazardous area lighting in their range in the following Blog.
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➡ Further Reading: UKCA ATEX & Hazardous Area Equipment Certification
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