Rich,
I must differ with you on one point below. Refer to
29 CFR 1910.399 (a)(ii). This is the section just past
the reference to NRTL acceptance cited below.
In so many words, paragraph (ii) says that if the equipment
is not approved etc. by an NRTL, then it must be inspected
etc by a Federal, state, municipal, or other local
authority responsible for enforcing occupational safety.
Again, the choice is (1) NRTL blessing, or (2) a beating
by the local authorities to get approval. OSHA does not
REQUIRE NRTL acceptance, but offers it as one alternative.
George Alspaugh
Lexmark International
---------------------- Forwarded by George Alspaugh/Lex/Lexmark on 09/16/98
03:13 PM ---------------------------
Rich Nute <richn%sdd.hp....@interlock.lexmark.com> on 09/16/98 02:27:03 PM
Please respond to Rich Nute <richn%sdd.hp....@interlock.lexmark.com>
To: ron_pickard%hypercom....@interlock.lexmark.com
cc: emc-pstc%ieee....@interlock.lexmark.com (bcc: George Alspaugh/Lex/Lexmark)
bcc: George Alspaugh/Lex/Lexmark
Subject: Re: Query: US safety required for ITE?
Hello from San Diego:
Ron Pickard asks:
... what specific requirements are there that positively
and unequivicably require NRTL Listing...
To my knowledge, there are two, independent sets of regulations
that require third-party safety certification:
1) OSHA (safety of electrical products in workplaces).
-requires NRTL certification.
2) NEC (safety of electrical products in installations).
-requires "listing" by a certification house determined
by the local code authority.
OSHA (Occupational Safety and Health Administration)
-----------------------------------------------------
Ron has properly quoted the OSHA regulations:
"Acceptable." An installation or equipment is acceptable to
the Assistant Secretary of Labor, and approved within the
meaning of this Subpart S:
(i) If it is accepted, or certified, or listed, or labeled,
or otherwise determined to be safe by a nationally recognized
testing laboratory;"
These two statements essentially and practically invoke NRTL
certification of electrical products (used in workplaces).
NEC (National Electrical Code)
-------------------------------
"90-7. Examination of Equipment for Safety.
:
:
:
"It is the intent of this code that factory-installed internal
wiring or the construction of equipment need not be inspected
at the time of installation of the equipment, except to detect
alterations or damage, if the equipment has been listed by a
qualified electrical testing laboratory that is recognized as
having the facilities described above and that requires
suitability for installation in accordance with this Code."
"110-2. Approval. The conductors and equipment required or
permitted by this Code shall be acceptable only if approved."
"Approved: Acceptable to the authority having jurisdiction."
"Listed: Equipment or materials included in a list published
by an organization acceptable to the authority having
jurisdiction and concerned with product evaluation, that
maintains periodic inspection of production of listed equipment
or matierals, and whose listing states either that the equipment
or matieral meets appropriate designated standards or has been
tested and found suitable for use in a specified manner."
"Equipment: A general term including material, fittings,
devices, appliances, fixtures, apparatus, and the like used as a
part of, or in connection with, an electrical installation.
The Code requires the city, county, or state building code authority
to identify the laboratories whose certification marks are acceptable
to them. In my experience, the various building code authorities
each have their own criteria for laboratories. The City of Los
Angeles not only accepts a number of independent laboratories, it
runs its own testing laboratory and certification program! (Nearby
municipalities accept City of Los Angeles certifications.) The
State of Oregon has its own set of criteria by which it accepts
laboratories. (It accepts labs that are not NRTLs.)
So, there is no general "rule" that an NRTL is also accepted under
the NEC in a particular jurisdiction (i.e., city, county, or state.)
(However, most of us assume that this is the case.)
Best regards,
Rich
-------------------------------------------------------------
Richard Nute Product Safety Engineer
Hewlett-Packard Company Product Regulations Group
All-In-One Division Tel : +1 619 655 3329
16399 West Bernardo Drive FAX : +1 619 655 4979
San Diego, California 92127 e-mail: ri...@sdd.hp.com
-------------------------------------------------------------
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