Hello Brian. As far as I know there is no OSHA regulation requiring NRTLs to accept FUS reports, and even approvals from other NRTLs, although it is implied. The whole NRTL program is such that the labs are accredited and audited by OSHA. I think a NRTL lab that did not accept testing or FUS from another NRTL because it was deemed inadequate could be in legal hot water, as both are accedited and audited by the same body, namely OSHA. The FUS procedures are defined by OSHA and as long as the lab is still listed as a NRTL, the procedures and testing should be adequate. An important thing to note is that there is no requirement for FUS on a CB scheme approval, i.e. the issuing NCB does not have a FUS agreement with the manufacturer. This is an OSHA NRTL requirement only. Check out this document:
http://www.osha-slc.gov/pls/oshaweb/owa isp.show_document?p_table=DIRECTIVES&p_id=2004#APPENDIXC A number of years back, I had an issue similar to this with a transformer approval, which was resolved by raising the issue with the upper management of both agencies. Since then I have not had an issue with informal acceptance of test data, particularly component data, between the two NRTLs that I deal with. Recently they have actually formalised that into a signed agreement on acceptance of test data. I don't want to promote or advertise here, so you can contact me off line if you want more details about who they are. Our experience using a single agency to provide both international and NRTL approvals has been very good, and saves a ton of time, effort and cost. We are an end equipment manufacturer, and in recent years I have never had a problem with the agency accepting copmponent/subsystem approvals from other NRTLs or NCBs. The two NRTLs that I deal with are also NCBs, so they do accept my CB reports issued by other NCBs as a basis for NRTL approval. As I understand it, when it comes to acceptance of CB reports, the terms of the CB scheme membership require that CB reports issued by one NCB be accepted by all other NCBs without additional testing, provided the national differences for that particular country have been evaluated. When you use a CB report as a basis for an NRTL approval, the NRTL may impose other national requirements/tests if they have not been covered in the CB report national differences, as well as manufacturing tests (dielectric, ground continuity, etc), which, for example are not specifed in any of the flavours of the 60950 standards. Manufacturing tests are usually common sense, but are somewhat arbitary, and are determined by the particular agency or the particular person within the agency. There doesn't seem to be a document or guide published at the OSHA NRTL Bi-Nat or even IEC level that would take a standard, say 60950, and define minimum requirements for manufacturing tests applicable to the equipment covered by that standard. This would be a tremendous aid to smaller manufacturers who don't have in-house expertise. Hmmm....... fodder for thought here. What we really need is a single non-partisan safety marking (like the CE marking), backed up by a NRTL or NCB, then the system guys like ourselves could put bits approved by various agencies together, without getting involved in the NRTL wars. This will never happen though, something to do with too many poor underpaid lawyers in North America. (Plug for self declaration here, we can dream can't we) Regards Doug "Brian O'Connell" <[email protected]> Sent by: [email protected] 04/09/04 07:04 PM Please respond to "Brian O'Connell" To: [email protected] cc: Subject: NRTL vs. NRTL, NCB vs. NCB Good People Currently, my employer is attempting to go with a single safety agency as both NCB and NRTL. We submitted a "test case" project, but a customer is having problems because the (different) NRTL that the end-item was submitted to will not accept components recognized by the NRTL (that provided component-level recognition) because "their follow-up service is not adequate". In the U.S., OSHA, (an agency of the federal government) confers NRTL status; so what is the basis of one NRTL not allowing the use of components that were certified by another NRTL in the end-product that is being evaluated ? The evaluating engineer required our customer to perform additional testing and enter construction data into the FUS report, on a component that the customer does not manufactur. The engineer evaluating the end-use product did not say that the test reports or construction data in component's CB report and FUS report were not adequate, or that the data was incomplete. The re-evaluation and additional test and data requirements were based on the fact that the agency that performed the evaluation does not have "adequate" FUS audits. (And I personally have not noticed any significant differences for the three agencies that audit my factories.) I still do business with both of these agencies, and want to remain on good terms with both; but I am growing weary with NRTL and NCB "wars". I understand that the IECEE requires all NCBs to use each other's CB reports. Is there and equivalent requirement by OSHA that all NRTLs use others' FUS reports ? luck, Brian
