Separating seismic certification fact from fiction
A legitimate certification process would require manufacturers to play by the same rules, providing risk protection to registered design professionals and peace of mind to building owners and authorities having jurisdiction.
Earthquakes are a real problem and not just in California. “Chapter 17” of the International Building Code (IBC) requires manufacturers of designated equipment to provide a certificate of compliance. Although the IBC document was introduced a decade ago, questions and concerns still surround the IBC-2012 requirements for emergency gensets, sub-base fuel tanks, and custom enclosures.
Even though the IBC is updated every three years and is currently in its fifth revision (IBC-2012), there is still ambiguity within the code in terms of compliance for genset sub-base fuel tanks, enclosures, and similar equipment. In the wake of this requirement, registered design professionals (RDPs), authorities having jurisdiction (AHJ), manufacturers, and building owners have grasped for concrete direction in obtaining credible certification.
All major generator set manufacturers have been aggressively pursuing IBC qualification for their standard product lines. However, this does not include custom sub-base fuel tanks and/or custom enclosures. Most emergency power applications do not use standard factory-enclosed products offered by a genset OEM. New emergency power installations above 500 kW usually require a custom sub-base fuel tank and a custom enclosure with ancillary items unique to the project design and its application (see Figure 1, right).
Figure 1: Custom sub-base fuel tanks and enclosures are usually required for new emergency power installations above 500 kW. Courtesy: Chillicothe Metal Co. Inc.
This could be a hospital, wastewater treatment plant, data center, police building, or any other important facility. Custom enclosure specifications are written by the RDP to meet project needs. If a standby power system is required to operate after an earthquake to supply life-safety systems, if the structure contains hazardous materials, or if it is located in an Occupancy Category IV structure and its failure would prevent continued operation of the facility, then the project specification should be written in a manner that demands accountability by the custom sub-base assembly and enclosure manufacturers.
Although there is great effort underway by manufacturers to seismically qualify gensets by shake-table testing for IBC compliance, progress has been slow for manufacturers to seismically qualify custom sub-base fuel tanks and enclosures. Qualification of these products usually requires engineering analysis to supplement testing. IBC-qualified gensets are often installed inside custom-designed enclosures that are not seismically qualified. Genset manufacturers must make exceptions to specifications for these types of configurations and clarify that custom enclosures are outside of the scope of their certification. Figure 2 (right) is an example of a product seismic qualification label for an MTU On-Site Energy genset. The label clearly separates the genset product seismic qualification information from any sub-base and enclosure that it may be attached to or housed within.
Figure 2: The highlighted area of this genset seismic qualification label separates the genset product seismic qualification from an associated sub-base or enclosure. Courtesy: MTU On-Site Energy, used with permission.
What is the problem?
Over the years, third-party certification has been marginalized to the point that engineers, manufacturers, and building officials have lost the true meaning of certification. There is no code or standard written to provide—once and for all, and for everyone to agree—a definition of certification. The situation is clouded by language within the IBC that requires certification by “approved agencies.” Considering the code does not well define an “approved agency,” this leaves the door wide open. In the least credible path to product qualification, a manufacturer could designate itself as an “approved agency.” This would be very cost effective for the manufacturer, but certainly not credible in the eyes of an RDP, AHJ, or building owner.
Many manufacturers have incorrectly claimed to be certified or have the ability to certify products through “self certification.” Certification is not when one sample piece of their equipment meets the requirements of an industry adopted standard/criteria or complies with a building code section. “Approval” of an agency does not give the agency the right to certify products. An AHJ giving approval is not the same as certification. And, there is no consistency in the AHJ requirements. Furthermore, there is a difference between qualification and certification. These situations have confused the entire manufacturing industry.
If the above is not certification, then what is? Defining “qualification” first will set the stage for properly defining “certification.”
Understanding the difference between qualification and certification
Qualification is intended to ensure that a product design correctly and completely implements a specification and will meet the proper standards and requirements. Qualification may involve passing or successfully satisfying a test or analysis requirement. Qualification records include appropriate documentation and deem a product design officially “on record” as qualified to perform a special function.
Qualification involves a one-time sample product performance evaluation by test or analysis. However, this is just the first step toward certification. Certification includes third-party review of qualification for compliance to industry standards. Certification also ensures that the product manufacturer has a quality control program so that all future products manufactured will meet the original qualification or product performance. Table 1 describes the different qualification and certification processes and provides a relative level of credibility associated with each process. For example, a standard product that is “qualified” by shake-table test or engineering analysis is “Level 4 Qualification.”
Certification is a confirmation of certain characteristics of an object, person, or organization. This confirmation shall be provided by an external review (third party) and includes an assessment. One of the most common types of certification is product certification. This refers to processes intended to determine if a product meets minimum standards and quality assurance. Organizational certification is provided by an accredited (not approved) agency, and the accreditation is given by a body that accredits certifying organizations. Product qualification determines if one sample product supplied by a manufacturer meets seismic and/or wind load requirements. In terms of credibility, refer to “Level 4” in Table 1.
Third-party product certification by an accredited listing agency reviews the product qualification records and inspects quality assurance procedures, which provide a higher level of confidence that the qualified product will consistently meet seismic and/or wind load requirements. This review is simplified if the manufacturer has an ISO registered quality plan. Third-party certification is critical for custom products, such as power system sub-base fuel tanks and enclosures, because they are just that—custom. Qualifying one standard product does not apply to custom manufacturing. Inspection by an accredited listing agency substantiates the credibility of the manufacturer’s ability to reproduce the qualified product. In terms of credibility, certification backed by an accredited third-party listing agency would result in “Level 6” in Table 1.
Table 1: Qualification and certification levels
Qualification certification level
Basis of evaluation
Explanation of basis
Qualified by test or analysis
Manufacturer provides certificate of compliance without any evidence, testing, or evaluations.
Testing or analysis
Manufacturer qualifies products by nonaccredited agency or by some other means such as analysis.
Testing at accredited laboratory
Testing is performed per a test program that meets ISO 17025 and is accredited.
(Certified) qualification agency document preparation
Provides assurance that equipment testing and qualification meet adopted industry standards and has a quality program that meets ISO 9001.
Certified by accredited inspection body
QA record verification (ICC-ES)
Material certification agency requires accredited testing and factory inspection by an accredited inspection body to criteria less than ISO 9001.
Factory inspection by accredited inspection body
Listing service verifies qualification documentation to industry-adopted standards and performs accredited inspection body factory inspection to ensure QA manual and records meet ISO 9001.
Product certification agency (PCA)
Performs all of the above per ISO Guide 65.
Seismic Source International, LLC, used with permission
What is the certificate of compliance worth?
Now that we know what is required to qualify equipment and certify a manufacturer, how can the RDP, AHJ, and building owner know that product qualification and manufacturer certification are legitimate? If manufacturer A is doing everything correctly and in the most credible manner and manufacturer B is getting his cousin Vinnie to rubber-stamp a useless certificate or submittal drawing with no verification of quality assurance, and the AHJ signs off and accepts the useless certificate, which do you think will be cheaper? And, which will a contractor purchase? Even NASA goes with the lowest bid. So, a certificate is only as good as the quality assurance behind it. Table 1 shows how credibility increases with increased quality assurance requirements. It is essential then, that the construction community pushes forward for qualification and verification by accredited third parties, or certification. The IBC does provide some clarification in the definition of labeling to be performed by knowledgeable individuals, but it delegates the final responsibility to the RDP and AHJ.
To reduce project risk and potential legal liability, and deliver what building owners want and expect, RDPs should require products and product manufactures to be listed by an accredited listing agency to provide the highest level of product certification available for seismic and wind certification. This ensures the product meets minimum standards and quality assurance. An accredited listing service will review the qualification agency activities combined with testing (if required) in a qualification document and will also perform inspection body services to evaluate the manufacturer’s QA program. This is the most comprehensive, cost-effective, and timely measure in which to ensure IBC compliance.
If the manufacturer/supplier for custom sub-base fuel tanks and power system enclosures does not have a listing with an accredited listing agency, the RDP and AHJ at minimum should demand complete engineering analysis for review to verify compliance. The AHJ should at minimum verify that the custom sub-base fuel tank and enclosure are built to the approved design. This is often costly and time consuming. It is not as credible as third-party certification, but actual engineering analysis that can be reviewed for compliance is much more credible than a stamp on a drawing or useless certificate.
Seismic Source International, LLC is a listing service that provides the highest level of product certification available for seismic and/or wind certification. This accredited certification agency will provide a public document that can be used by the AHJ and RDP to ensure all options provided with the equipment meet the design criteria. Special inspectors on the job site can also review the equipment delivered and installed with the public documents to ensure that any limitations (such as maximum dimensions) defined in the certification are met. Without QA oversight at the factory or field verification, self-certification manufacturers can build and deliver anything they want and put any label on their products that may be outside the umbrella of certification of compliance.
Who is responsible?
The RDP is legally responsible to follow the code as a minimum set of requirements unless the AHJ or owner has more stringent requirements. These requirements should:
- Include seismic criteria on construction documents
- State the importance factor for equipment and designated seismic systems
- Include statement of special inspection requirements
- Review and approve certificate of compliance (including shake-table test reports and/or engineering analysis).
How does the IBC apply?
The IBC and reference standards have been edited to clearly establish the adopted industry practice where the certification is reviewed by the RDP and approved by the AHJ. As stated previously, approval is not certification. AHJs are not accredited inspection bodies and do not have the oversight by an accreditation body to give certification.
For seismic applications, the IBC requires a certification for special seismic equipment. AHJs can have more stringent requirements. For example, an AHJ can require equipment certification for high wind applications. But in all cases, the certification must come from a third party and be provided for the AHJ to approve.
The IBC further confuses the certification issue with a requirement that certification is required by approved agencies. The intent is to give the AHJ authority to approve certification agencies. This amounts to giving the AHJ authority it already possesses. Logically, this is impossible. Most AHJs will not approve agencies from advice through legal counsel such that this approval is an endorsement of the agency. There are thousands of AHJs between California and New York. To get approval from every AHJ is not practical. This is why accredited listing agencies exist.
How does this affect the RDP?
The IBC requires the RDP to review the certification and the AHJ to approve the certification. This means that product manufacturers must have a credible certification as previously defined. The RDP is obligated to review the certificate and public reports (actual test or analysis) to verify the qualification is substantive and there is a quality program at the factory. Without a credible certification, the RDP is at risk.
Seismic certification is here to stay. The IBC requires a certificate of compliance from equipment manufacturers verifying that the product they supply will withstand the design seismic load for that project. It is the manufacturer’s responsibility to provide the proper testing, analysis, and QA program to earn a certificate. It is the responsibility of the RDP and AHJ to review and approve the equipment certificate of compliance. However, the RDP and AHJ are not equipped to evaluate the QA of a manufacturer, and they are not seismic experts.
Therefore, an industry requirement for third-party accredited listing of seismic certificates is essential in establishing a legitimate certification process that will require all manufacturers to play by the same rules, providing risk protection to the RDP and peace of mind to the building owner and AHJ.
Stoyanac is the national sales and marketing manager for Chillicothe Metal Co. Inc., a manufacturer of custom, on-site emergency power generation equipment. He has held this position since he started with the company in 2009 and has worked in the on-site power generation industry for 25 years. Stoyanac is a member of EGSA, was EGSA president in 2004, and is the chair of the EGSA “On-Site Power” technical reference manual committee.