This is a multi-part message in MIME format.
Dave's question - Does this apply to in-house test equipment?
Hi Dave - Good question (Please see attached). I'm sorry about the file size but I took it from the Department of Labor web site several years ago when this topic first came up. (It repeats about every 6 months if my memory serves) Beware of defining the situation incorrectly. Between R&D - Prototyping - Manufacturing - customer site. As you change location the "to NRTL or not to NRTL" conditions may change - so ..... FIRST - THINK IT THROUGH VERY CAREFULLY - short term - long term. Document your CONDITIONS of acceptable USE However - the BEST and MOST RELEVANT people to ask are your Corporate Insurers. It would be little good meeting the local code to find that there is small print in your corporate liability insurance leaves you with personal liability for any failure - injury or death!!!!!!! NEXT - is it legal? - If 'yes' then..... - ASK WHY AM I DOING THIS? If you answer "legal requirements" then think again. If you answer "to reduce liability" then think again If the answer is "to prevent injury, etc" then consider what if things go wrong - what protection do you would have in law. "I thought it was OK" is not good. "I was only doing my job" or "I'm not paid to do that" are worst Will there be any evidence (maybe even years after you have left the company) you made any assessment? Will there be any record of any changes to 'your' design????? Even if you can avoid NRTL testing then you need to protect yourself - NOT YOUR COMPANY - (people go to jail - companies don't). You would be most wise to create a UL-Style Product Description AND UL style test Report so that you have some sort of evidence of due diligence AND A CONFIGURATION RECORD OF WHAT YOU TESTED. It have seen too many modifications that have made products d-a-n-g-e-r-o-u-s. Whereas I believe that there is may be no single one right answer to your question there will be, I am sure, plenty of wrong ones. Hopefully those will not be posted here!!! STEP OUTSIDE THE BOX Try to think of 'compliance' not as PASS or FAIL; but as a continuum from DEPLORABLE through ACCEPTABLE to the UNATTAINABLE. Whereas there is a basic legal need to reach "ACCEPTABLE" there is a commercial need (6-sigma - zero-defect - fault-free : call it what you will) that strives for better things. (Which is just as well because the standards have become stricter and will continue to do so.) My company has clients at all points along that continuum and work with them to progress their knowledge and to show them how they can reduce their personal and corporate risks. Before someone shoots "COSTS" at me - please let me add - we find that the cost (of training and implementation) is more than offset by cost saving that result from the compliance improvement exercise. There are free downloads under the eLearning section of our web site - please help yourself. Best regards Gregg Gregg Kervill DipIM, MIMgt, MIEEE VP Engineering Test4Safety.com Inc PO Box 310, Reedville, VA 22539. USA Phone ( 804) 453-3141 Fax (804) 453-9039 http://www.test4safety.com/ From: drcuthbert [mailto:drcuthb...@micron.com] Sent: Tuesday, January 14, 2003 12:53 PM To: 'Gregg Kervill'; 'Joe P Martin'; emc-p...@majordomo.ieee.org Subject: RE: NRTL in the U.S. Does this apply to in-house test equipment? That is, equipment that is built in-house and remains on site? In the past I have designed in-house equipment to meet the safety standards but did not send the equipment out for testing and certification. Dave From: Gregg Kervill [mailto:gr...@test4safety.com] Sent: Tuesday, January 14, 2003 7:50 AM To: 'Joe P Martin'; emc-p...@majordomo.ieee.org Subject: RE: NRTL in the U.S. Importance: High Joe, You are correct that NRTL LISTING is a specified requirement by some cities and states. You are incorrect in that all products used where OSHA applies are required to be NRTL LISTED. NEC Code makes that same requirement Furthermore most (I have yet to find an exception) cities and states base their code upon NEC There may be local exception but I believe that to make a 'blanket statement that ".. NRTL is not required in the US..." is I believe at best confusing and at that the worst very dangerous. The following is a statement from the US NOL: All electrical equipment, except those kinds which no NRTL accepts, certifies, lists, labels, or otherwise determines to be safe, must be "approved", as that term is defined at 29 CFR 1910.399. Except as indicated in the following this means that a NRTL must accept, certify, label, list, or otherwise determine that equipment is safe for it to be considered "approved". The requirement mandating that electrical equipment be "approved" is set forth at 29 CFR 1910.303(a). Also, OSHA Standard 29 CFR 1910.303(b)(2) requires that "approved" equipment be used in conformance with its approval. Electrical equipment which no NRTL accepts, certifies, lists, labels, or determines to be safe is acceptable to OSHA under the following if the equipment 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 NEC and found in compliance with the provisions of the NEC as applied to Subpart S of 29 CFR 1910 standards. Custom made equipment which is designed, fabricated for, and intended for use by a particular customer does not have to be approved if it is determined to be safe for its intended use by its manufacturer. The determination must be made on the basis of test data that the employer keeps and makes available to the Assistant Secretary of Labor for OSHA. In summary then if there are ten different models of a particular kind of equipment, but only one of them is accepted, certified, listed, labeled or otherwise determined to be safe by a NRTL only that one would be considered to be "approved"; unless of course it is custom made equipment. Only those entities that have applied and been approved pursuant to the requirements of 29 CFR 1910.7 are considered to be a NRTL. Recently the "Canadian Standards Association" was the first foreign laboratory approved as an NRTL. Enclosed find a copy of a directive that discusses NRTLs. Best regards Gregg Kervill Gregg Kervill DipIM, MIMgt, MIEEE VP Engineering Test4Safety.com Inc PO Box 310, Reedville, VA 22539. USA Phone ( 804) 453-3141 Fax (804) 453-9039 http://www.test4safety.com/ From: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of Joe P Martin Sent: Monday, January 13, 2003 11:22 PM To: emc-p...@majordomo.ieee.org Subject: NRTL in the U.S. Greetings, As has been discussed in previous threads, NRTL Listing is not a requirement to sell electronic products in the U.S. However, there are cities, counties, etc. within the U.S. that do require NRTL Listing. These include Los Angeles and Chicago. Does anyone have a comprehensive list of all the cities, counties or states that do require NRTL Listing. Any and all comments are appreciated. Regards Joe Martin Applied Biosystems marti...@appliedbiosystems.com 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" 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"Title: RE: NRTL in the U.S.
Dave's question - Does this apply to in-house test equipment?
Hi Dave - Good question (Please see attached). I'm sorry about the file
size but I took it from the Department of Labor web site several years ago
when this topic first came up. (It repeats about every 6 months if my memory
serves)
Beware of defining the situation incorrectly.
Between R&D - Prototyping - Manufacturing - customer site.
As you change location the "to NRTL or not to NRTL" conditions may change -
so .....
FIRST - THINK IT THROUGH VERY CAREFULLY - short term - long term. Document
your CONDITIONS of acceptable USE
However - the BEST and MOST RELEVANT people to ask are your Corporate
Insurers.
It would be little good meeting the local code to find that there is small
print in your corporate liability insurance leaves you with personal
liability for any failure - injury or death!!!!!!!
NEXT - is it legal? - If 'yes' then.....
- ASK WHY AM I DOING THIS?
If you answer "legal requirements" then think again.
If you answer "to reduce liability" then think again
If the answer is "to prevent injury, etc" then consider what if things go
wrong - what protection do you would have in law.
"I thought it was OK" is not good.
"I was only doing my job" or "I'm not paid to do that" are worst
Will there be any evidence (maybe even years after you have left the
company) you made any assessment?
Will there be any record of any changes to 'your' design?????
Even if you can avoid NRTL testing then you need to protect yourself - NOT
YOUR COMPANY - (people go to jail - companies don't).
You would be most wise to create a UL-Style Product Description AND UL style
test Report so that you have some sort of evidence of due diligence AND A
CONFIGURATION RECORD OF WHAT YOU TESTED.
It have seen too many modifications that have made products
d-a-n-g-e-r-o-u-s.
Whereas I believe that there is may be no single one right answer to your
question there will be, I am sure, plenty of wrong ones. Hopefully those
will not be posted here!!!
STEP OUTSIDE THE BOX
Try to think of 'compliance' not as PASS or FAIL; but as a continuum from
DEPLORABLE through ACCEPTABLE to the UNATTAINABLE.
Whereas there is a basic legal need to reach "ACCEPTABLE" there is a
commercial need (6-sigma - zero-defect - fault-free : call it what you will)
that strives for better things. (Which is just as well because the standards
have become stricter and will continue to do so.)
My company has clients at all points along that continuum and work with them
to progress their knowledge and to show them how they can reduce their
personal and corporate risks.
Before someone shoots "COSTS" at me - please let me add - we find that the
cost (of training and implementation) is more than offset by cost saving
that result from the compliance improvement exercise.
There are free downloads under the eLearning section of our web site -
please help yourself.
Best regards
Gregg
Gregg Kervill DipIM, MIMgt, MIEEE
VP Engineering
Test4Safety.com Inc
PO Box 310,
Reedville, VA
22539. USA
Phone ( 804) 453-3141
Fax (804) 453-9039
http://www.test4safety.com/
-----Original Message-----
From: drcuthbert [mailto:drcuthb...@micron.com]
Sent: Tuesday, January 14, 2003 12:53 PM
To: 'Gregg Kervill'; 'Joe P Martin'; emc-p...@majordomo.ieee.org
Subject: RE: NRTL in the U.S.
Does this apply to in-house test equipment? That is, equipment that is built
in-house and remains on site? In the past I have designed in-house equipment
to meet the safety standards but did not send the equipment out for testing
and certification.
Dave
-----Original Message-----
From: Gregg Kervill [mailto:gr...@test4safety.com]
Sent: Tuesday, January 14, 2003 7:50 AM
To: 'Joe P Martin'; emc-p...@majordomo.ieee.org
Subject: RE: NRTL in the U.S.
Importance: High
Joe,
You are correct that NRTL LISTING is a specified requirement by some cities
and states.
You are incorrect in that all products used where OSHA applies are required
to be NRTL LISTED.
NEC Code makes that same requirement
Furthermore most (I have yet to find an exception) cities and states base
their code upon NEC
There may be local exception but I believe that to make a 'blanket statement
that ".. NRTL is not required in the US..." is I believe at best confusing
and at that the worst very dangerous.
The following is a statement from the US NOL:
All electrical equipment, except those kinds which no NRTL accepts,
certifies,
lists, labels, or otherwise determines to be safe, must be "approved", as
that term
is defined at 29 CFR 1910.399. Except as indicated in the following this
means
that a NRTL must accept, certify, label, list, or otherwise determine that
equipment is safe for it to be considered "approved".
The requirement mandating that electrical equipment be "approved" is set
forth at
29 CFR 1910.303(a). Also, OSHA Standard 29 CFR 1910.303(b)(2) requires that
"approved" equipment be used in conformance with its approval.
Electrical equipment which no NRTL accepts, certifies, lists, labels, or
determines to be safe is acceptable to OSHA under the following if the
equipment 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 NEC and found in compliance with the provisions of the NEC
as
applied to Subpart S of 29 CFR 1910 standards.
Custom made equipment which is designed, fabricated for, and intended for
use
by a particular customer does not have to be approved if it is determined to
be
safe for its intended use by its manufacturer. The determination must be
made
on the basis of test data that the employer keeps and makes available to the
Assistant Secretary of Labor for OSHA.
In summary then if there are ten different models of a particular kind of
equipment, but only one of them is accepted, certified, listed, labeled or
otherwise determined to be safe by a NRTL only that one would be considered
to
be "approved"; unless of course it is custom made equipment.
Only those entities that have applied and been approved pursuant to the
requirements of 29 CFR 1910.7 are considered to be a NRTL. Recently the
"Canadian Standards Association" was the first foreign laboratory approved
as
an NRTL. Enclosed find a copy of a directive that discusses NRTLs.
Best regards
Gregg Kervill
Gregg Kervill DipIM, MIMgt, MIEEE
VP Engineering
Test4Safety.com Inc
PO Box 310,
Reedville, VA
22539. USA
Phone ( 804) 453-3141
Fax (804) 453-9039
http://www.test4safety.com/
-----Original Message-----
From: owner-emc-p...@majordomo.ieee.org
[mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of Joe P Martin
Sent: Monday, January 13, 2003 11:22 PM
To: emc-p...@majordomo.ieee.org
Subject: NRTL in the U.S.
Greetings,
As has been discussed in previous threads, NRTL Listing is not a
requirement to sell electronic products in the U.S. However, there are
cities, counties, etc. within the U.S. that do require NRTL Listing.
These include Los Angeles and Chicago. Does anyone have a comprehensive
list of all the cities, counties or states that do require NRTL Listing.
Any and all comments are appreciated.
Regards
Joe Martin
Applied Biosystems
marti...@appliedbiosystems.com
-------------------------------------------
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"
-------------------------------------------
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"
US DOL Requirements.pdf
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