Doug,

I agree entirely!

Yesterday I sent the below mail to a fellow emc-pstc groupie:


"I have struggled through the OSHA webpages before, including SubPart S:

SubPart Title: Electrical - Design Safety Standards for Electrical Systems

where it does clearly say:
"Approval. The conductors and equipment required or permitted by this subpart
shall be acceptable only if approved."

Under definitions, approved refers to acceptable which is defined as:
"(i) If it is accepted, or certified, or listed, or labeled, or otherwise
determined to be safe by a nationally recognized testing laboratory"


So it is quite clear that conductors and equipment for electrical systems must
be listed or similar.

However nowhere does it make clear what is covered under "equipment". Is a PC
covered? Probably yes. Is a palmtop with mains adaptor covered? Maybe. Is a
pocket calculator covered? Surely not."

So I too would like a definitive answer! (Well, if the answer is definitive, it
probably comes from a lawyer, so I might not like it!).

Regards,

Roger Viles
WWG




Doug McKean <dmck...@corp.auspex.com> on 17/08/99 04:48:09

Please respond to Doug McKean <dmck...@corp.auspex.com>

To:   emc-p...@majordomo.ieee.org
cc:    (bcc: Roger Viles/PLY/Global)

Subject:  Re: U.S. National Product Safety "Laws"






Dear Fellow Professionals,

Let me be the devil's advocate for the moment.
I normally do not like to pick apart standards,
but this one has been kicking around my mind
for years.

I will refer all to the following websites so we're
all on the same playing field.

 http://www.osha-slc.gov/OshStd_toc/OSHA_Std_toc.html
 http://www.osha-slc.gov/OshStd_toc/OSHA_Std_toc_1910_SUBPART_S.html

Would you please note that in 29 CFR 1910.301
"Introduction", that the "practical safeguarding
of employees in their workplaces" has four parts to it:

"...

    a) Electrical systems.
    b) Safety-realted work practices.
    c) Safety-related maintenance requirements.
    d) Safety requirements for special equipment.

 ..."

Of the four major divisions for safeguarding employees,
please note the first one - "Electrical Systems".

As stated in 29 CFR - 1910.399 "Definitions", a "system"
is defined as

"Utilization system. A utilization system is a system
 which provides electric power and light for employee
 workplaces, and includes the premises wiring system
 and utilization equipment."

Had the standard used the word "equipment", then as
such 29 CFR - 1910.399 "Definitions" would have used
the following definition

"Utilization equipment. Utilization equipment means
 equipment which utilizes electric energy for mechanical,
 chemical, heating, lighting, or similar useful purpose."

Therefore, people, I submit that since 29 CFR 1910 directs
it's attention to "systems", it is strictly concerned with
that which provides electrical power or lighting and does
NOT concern itself with "equipment", i.e. that utiliizes
said power.

Comments?

Regards,  Doug McKean

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