Hi Tania: Thanks, this is very interesting (and well stated as your comments usually are). Particularly section 90-4 and the summary document you refer to.
Let me take this opportunity to present another point for anyone who cares to give it some thought. The NEC and/or local electrical requirements come into play because the product connects to the local electrical supply. What about battery operated products ? Is there then nothing that says that a battery operated product needs any third-party safety approvals ? Richard Payne Tektronix, Inc. > -----Original Message----- > From: Grant, Tania (Tania) [SMTP:[email protected]] > Sent: Thursday, September 17, 1998 11:37 AM > To: [email protected]; Payne, Richard > Subject: RE: US NRTL required ? > > Richard, > > The sections in the NEC you are looking for might be the following, > including the definition section. (References are to the 1996 NEC.) > > Labeled: Equipment or materials to which has been attached a label, > symbol, or other identifying mark of an organization that is acceptable > to the authority having jurisdiction and concerned with product > evaluation that maintains periodic inspection of production of labeled > equipment or materials and by whose labeling the manufacturer indicates > compliance with appropriate standards or performance in a specified > manner. > > 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 materials, and whose listing states > either that the equipment or material meets appropriate designated > standards or has been tested and found suitable for use in a specified > manner. > > (FPN): The means for identifying listed equipment may vary for each > organization with product evaluation, some of which do not recognize > equipment as listed unless it is also labeled. The authority having > jurisdiction should utilize the system employed by the listing > organization to identify a listed product. [FPN, per NEC, means "Fine > Print Note" and provides explanatory material.] > > 90-4. Enforcement: > This Code is intended to be suitable for mandatory application by > governmental bodies exercising legal jurisdiction over electrical > installations and for use by insurance inspectors. The authority having > jurisdiction for enforcement of the Code will have the responsibility > for making interpretations of the rules, for deciding upon the approval > of equipment and materials, and for granting the special permission > contemplated in a number of the rules. > > The authority having jurisdiction may waive specific requirements in > this Code or permit alternate methods where it is assured that > equivalent objectives can be achieved by establishing and maintaining > effective safety. > > 90-6. Formal Interpretations. > To promote uniformity of interpretation and application of the > provisions of this Code, Formal Interpretation procedures have been > established. > > (FPN): These procedures may be found in the "NFPA Regulations Governing > Committee Projects." [NFPA stands for National Fire Protection > Association.] > > 90-7. Examination of Equipment for Safety. > For specific items and materials referred to in this Code, examinations > for safety made under standard conditions will provide a basis for > approval where the record is made generally available through > promulgation by organizations properly equipped and qualified for > experimental testing, inspections of the run of goods at factories, and > service-value determination through field inspection. This avoids the > necessity for repetition of examinations by different examiners, > frequently with inadequate facilities for such work, and the confusion > that would result from conflicting reports as to the suitability of > devices and materials examined for a given purpose. > > 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. > -------------------------- > There is a publication that may be of interest that provides information > on electrical testing laboratory recognition and accreditation programs > and a list of those laboratories from which certain product > certifications are accepted: > > Summary of Electrical and Building Code Requirements, Licensing > Provisions and Laboratory Recognition at State and Local Levels. This > is available from > > International Association of Electrical > Inspectors > 901 Waterfall Way, Suite 602 > Richardson, Texas 75080-7702;. > > Tania Grant, Lucent Technologies, Octel Messaging Division > [email protected] > > > ---------- > From: > [email protected][SMTP:[email protected]] > Sent: Thursday, September 17, 1998 6:38 AM > To: [email protected] > Subject: US NRTL required ? > > > Well I think this has been a good discussion. I must confess > first that > there have been so many contributions that I have not been able > to read them > all completely. But it seems that there is still a connection > missing > (please correct me if I have missed something here), one which I > Iooked into > a bit a couple of years ago. > > The US National Electrical Code (NEC) requirements have been > well and > accurately stated (Thanks, Rich N. et al). But from what I have > seen, it > seems to me that the NEC never goes that final step and > proclaims "YOU MUST > LIST YOUR PRODUCT" in clear and absolute terms (LISTED being > equivalent to > CERTIFIED for those not familiar with US terms). Actually, that > is not the > role of the NEC itself. It is the responsibility of the > Authorities Having > Jurisdiction (AHJ) to mandate that, or not. The NEC in fact > acknowledges > that specoifically, though I can't seem to put my fnger on the > exact > paragraph right now (maybe someone could help me with that). > These > authorities must adopt the NEC for it to become a legal > requirement in their > jurisdiction. > > What this really means is that laws requiring approved products > can be > passed at the federal level, or at the state level, or by any > city, county, > parish, township, village, commonwealth, or whatever, as long as > they have > legal authority to make law within specified geographical > boundaries. > > I called several local electrical building inspectors around the > country > (about 2 years ago now). I asked them directly if they believed > that it was > necessary for a product to have a safety approval to be sold in > their > jurisdiction. I spoke with a couple in Florida, a couple in > Illinois, one > guy in Chicago, another at the State of Oregon, and the manager > of the > building inspector's office at the City of Los Angeles. Chicago, > Oregon and > LA each have their own specific requirements that products be > approved. > These are requiremetns beyond what the NEC has. > > For those inspectors who basically relied on the NEC and local > adoption of > it or some variant, I asked them for their specific reference in > the NEC. > They referred me to the same paragraphs that have already been > covered > previously in this discussion. > > In every case, the inspectors believed that those paragraphs DID > IN FACT > require approval of products, and that the NEC requirements did > apply within > their jurisdiction (I understood because the NEC had been at > some point > officially adopted by that jurisdiction). > > In every case, they agreed that an NRTL Listing (to the > appropriate product > category) would almost always be acceptable. They never wanted > to commit > absolutely, just to not rule out that one odd-ball situation. > > In some cases, they would also do their own evaluation to > determine if a > product is acceptable as an alternative to an NRTL Listing (for > a fee). > Others did not even want to attempt such a thing. They do not > have the > resources to do it. They would refer me to an NRTL (usually UL > was the main > one they were familair with). > > When CSA applied to be accepted as an NRTL (at least this is the > story they > have told me) they not only went to OSHA for accreditation, they > also went > almost every legal jurisdiction in the US. The number I have > heard quoted is > 40,000 jurisdictions. > > It seems to me that the practical answer for a business that > wants to market > its product across the US and feel reasonably confident that it > meets the > legal requirements of all these local jurisdictions is to get an > NRTL > approval. > > > Just my 2 cents worth, > > Richard Payne > Tektronix, Inc. > > > > > > > > > > > --------- > This message is coming from the emc-pstc discussion list. > To cancel your subscription, send mail to [email protected] > with the single line: "unsubscribe emc-pstc" (without the > quotes). For help, send mail to [email protected], > [email protected], [email protected], or > [email protected] (the list administrators). > > --------- This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to [email protected] with the single line: "unsubscribe emc-pstc" (without the quotes). 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