Reposting without attachment. Sorry group I'll get the hang of it. For those who have provided response to date, thanks much
I wrote - We are working some responses to OSHA and would like to ask for some industry response from the Product Safety group (EMC welcome to respond too). Just looking for a quick statement on the Value of using a Non-NRTL firm for testing and/or certification (Listing). Statement: Non-NRTL laboratories can provide "Listings" and publish the customers (thus "Listing"). However, based on OSHA law, NEC requirements, Retailer specification, and other MOU/MRA with Canada/EU, it would not seem to be a significant accomplishment to be "Listed" or "Labeled" by a non-NRTL. In a quick paragraph, would you provide your opinion on the value of a Non-NRTL Listing Certification. Thanks Much Chris The following is from Richard Fairfax (reply to one of 4 questions) - OSHA's Director Directorate of Compliance Programs which states that Electrical products in the workplace must be Listed or Labeled by an NRTL to meet OSHA Law. Question 4: Do items identified in 1 through 3 above make the machine non-compliant with OSHA, NEC or both? As defined at 29 CFR 1910.399(a)(1) an installation or equipment is acceptable to the Assistant Secretary of Labor, and approved within the meaning of 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 (NRTL); or (ii) With respect to an installation or equipment of a kind which no nationally recognized testing laboratory accepts, certifies, lists, labels, or determines to be safe, if it is inspected or tested by another Federal agency, or by a State, municipal, or other local authority responsible for enforcing occupational safety provisions of the National Electrical Code (NEC) and found in compliance with the provisions of National Electrical Code as applied in this subpart. Therefore equipment must be listed, labeled, or certified by a NRTL. As we understand the conversation of my staff and you, the equipment was not certified by NRTL, it is a violation of OSHA standard 1910.399 (a)(1). To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov. If you have any further questions, please feel free to contact the Office of General Industry Compliance Assistance at (202) 693-1850. Sincerely, Richard E. Fairfax, Director Directorate of Compliance Programs cc: Regional Administrator, Region II ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on "browse" and then "emc-pstc mailing list"
