To all us others, and primarily to George at Lexmark! Regarding your item "3. The NEC and OSHA requirements "probably" do apply to any electrical device that is operated from voltages above SELV." Take a look at the 3rd edition of UL1950 under Scope, 1.1.1: "This standard is applicable to mains-powered or battery-powered information technology equipment, including electrical business equipment and associated equipment, with a rated voltage not exceeding 600 V and......" Nowhere does it state that this standard applies only to equipment at SELV and above. In fact, if you go further into the standard and check out section 1.2.4.3, it describes Class III equipment (SELV supplied). Thus, any equipment, including that which operates at SELV voltages, falls under this standard.
Regarding the following comment- (Obviously, OSHA ignores low-voltage and battery-operated equipment such as flashlights and calculators. I haven't located the "out" for these kinds of equipments.) -- I believe that flashlights and calculators are "ignored" because the standard addresses mains-powered or (they should have said) mains battery-powered equipment..... If your equipment needs a wire to obtain power, you are covered by this standard (assuming other characteristics apply.) And yes, I do agree with your 4th item. The legalese could be more user friendly. Tania Grant, tgr...@lucent.com <tgr...@lucent.com> Lucent Technologies, Communications Applications Group ---------- From: geor...@lexmark.com [SMTP:geor...@lexmark.com] Sent: Wednesday, August 18, 1999 2:02 PM To: ri...@sdd.hp.com Cc: private_u...@lexmark.com; emc-p...@majordomo.ieee.org Subject: Re: U.S. National Product Safety "Laws" To Rich et al (fancy way of saying "and others"): I was a little reluctant to fan the embers of this discussion the other day, but do not regret doing so based on the healthy discussion that followed. In any event, I shall blame Doug's append for peaking my interest. I assume we can all agree that: 1. We do not want to market unsafe products that may cause harm. 2. No one is looking for "loopholes" in the safety standards. 3. The NEC and OSHA requirements "probably" do apply to any electrical device that is operated from voltages above SELV. 4. The NEC and OSHA requirements are worded like legal documents, and thus, far from clear in their meaning. Having said this, I have added some remarks (in brackets [ ] ) to your last note below, hoping that these do not not extend the discussion, but are my final thoughts..... Best regards, George Alspaugh __________________________________________________________________________ Hi George: > I've read these sections of the CFR many times, and always interpreted them > to apply to end user equipment, as you imply. However, I am beginning to see > that this may be somewhat like quoting the Bible out of context. The context > in this section of the CFR (before and after) overwhelmingly refers to "house" > wiring types of equipment. I don't agree that the text overwhelmingly refers to wiring (i.e., in OSHA words, "utilization system"). First, it would be derelict of OSHA to ignore the utilization equipment used by employees. One of the major construction site hazards was failure of insulation in portable electric tools. OSHA was the prime mover towards double-insulated electric tools! While our government often makes mistakes, they do NOT ignore "utilization equipment." [I believe that there are a dozen ways "utilization equipment" could be better stated to clarify the intended meaning. How about "any electrical equipment, devices, appliances, and other products that are connected to electrical power systems at voltages deemed to be hazardous." Note that in homes and offices there are products requiring 220V (e.g. air conditioners, dryers, heaters) in addition to those operated from 115V.] Second, the text refers to "equipment" and to "utilization equipment," both of which are defined terms. The definitions must be substituted EVERYWHERE the words appear in the text. When I apply the definitions, I cannot conclude as you do that the text refers "overwhelmingly" to wiring. [I suggest if one goes to the cheapest discount store in their area, and look at the table/floor lamps offered for sale, they will find some with no NRTL markings. I will also suggest that these were NOT approved by a Federal, state, or local government authority. Are these "utilization equipment"? If so, how can they be offered for sale?] > Is it only me, or do others have problems reading into this that it does apply > to end user products such as ITE or blenders? With so many pages dedicated to > describing the exact requirements for the construction of an "installation" to > provide power to "equipment", why are there no pages dedicated to describing the > requirements of the "equipment"? IEC 60950 contains 180 pages of such > requirements. The OSHA standard for electrical "equipment" is that it be "approved." "Approved" means "acceptable." "Acceptable" has three definitions, one of which is certified by an NRTL, one of which is testing to NEC provisions, and one of which is testing by the manufacturer. In this way, OSHA skirts having to publish individual product safety standards. As near as I can tell, OSHA did this overtly and after having thought it out rather extensively. OSHA realized that it could NEVER cover all electrical products with standards. > Note that covered equipment (whatever that may be) can be acceptable by virtue > of the proper labelling/lisitng, or simply inspected and found to be safe by > one of the referenced authorities. Several have pointed out that such > authorities typically require a NRTL listing/marking. If your "proof" is to be > interpreted as you (and I) have been interpreting it, then every single > electrical device sold in the U.S. would HAVE to have an NRTL marking. I know > that a few years ago we were using internal PCs that bore no such markings. > I will not mention the brand name here. I suspect that one could find many > electrical products under $10 that do not display such markings either. Yes, ALL electrical equipment used by employees in the workplace must be "approved" (which means "acceptable" by one of the three definitions). (Obviously, OSHA ignores low-voltage and battery-operated equipment such as flashlights and calculators. I haven't located the "out" for these kinds of equipments.) If an OSHA inspector should find an electrical product that is not certified by an NRTL, I'm sure the employer will be notified! You can, of course, ask OSHA if the standards apply to ITE. I have no doubt of the answer. [I would tend to agree. It is the wording used, rather than the intent of, the NEC/OSHA requirements that lead to such debates.] Best regards, Rich --------- This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: "unsubscribe emc-pstc" (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators). --------- This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to majord...@ieee.org with the single line: "unsubscribe emc-pstc" (without the quotes). For help, send mail to ed.pr...@cubic.com, jim_bac...@monarch.com, ri...@sdd.hp.com, or roger.volgst...@compaq.com (the list administrators).