Hi Charlie, Thank you very much for that.
Best regards, Ron Pickard rpick...@hypercom.com From: Charles Blackham [mailto:charles.black...@sulisconsultants.com] Sent: Friday, June 23, 2006 10:40 AM To: Ron Pickard Cc: emc-p...@ieee.org Subject: RE: NRTL mark required for goods shipped into USA? Ron As I understand it, based on replies to the OP and some further investigation. The "requirement" (or strong recommendation at least) to be NRTL listed comes from: 1910.303(a) Approval. The conductors and equipment required or permitted by this subpart shall be acceptable only if approved. 1910.399 contains a number of definitions, including: Approved. Acceptable to the authority enforcing this subpart. The authority enforcing this subpart is the Assistant Secretary of Labor for Occupational Safety and Health. The definition of "acceptable" indicates what is acceptable to the Assistant Secretary of Labor, and therefore approved within the meaning of this Subpart. Acceptable. An installation or equipment is acceptable to the Assistant Secretary of Labor, and approved within the meaning of this 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; or ...other options However the exemption is in section(iv) below: 1910.302(a)(2) Not covered. The provisions of 1910.302 through 1910.308 of this subpart do not cover: (i)Installations in ships, watercraft, railway rolling stock, aircraft, or automotive vehicles other than mobile homes and recreational vehicles. (ii)Installations underground in mines. (iii)Installations of railways for generation, transformation, transmission, or distribution of power used exclusively for operation of rolling stock or installations used exclusively for signaling and communication purposes. (iv)Installations of communication equipment under the exclusive control of communication utilities, located outdoors or in building spaces used exclusively for such installations. (v)Installations under the exclusive control of electric utilities for the purpose of communication or metering; or for the generation, control, transformation, transmission, and distribution of electric energy located in buildings used exclusively by utilities for such purposes or located outdoors on property owned or leased by the utility or on public highways, streets, roads, etc., or outdoors by established rights on private property. Extracts all from http://www.osha.gov/pls/oshaweb/owastand.display_standard_group?p_toc_le vel=1&p_part_number=1910 regards Charlie > Hi Charles et al, > > Sorry for coming into this a bit late, but where does it (what federal > regulation) state that "communication equipment under the exclusive > control of communication utilities, located outdoors or in building > spaces used exclusively for such installations" do not apply to 29CFR > Part 1910? I was under the understanding that adherence to 29CFR Part > 1910 was federally mandated by the US Dept of Labor (OSHA) for all > workplaces in general without exceptions. If this exemption is indeed > the case, then what other bonafide exemptions exist? Please advise. > > Best regards, > > Ron Pickard > rpick...@hypercom.com > > -----Original Message----- > From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Charles > Blackham > Sent: Friday, June 23, 2006 3:34 AM > To: Charles Blackham > Cc: emc-p...@ieee.org > Subject: Re: NRTL mark required for goods shipped into USA? > > Thank you to all who responded on this topic > > 29CFRpart 1910, the requirment for equipment to be "Approved" ( by > various > means including being listed) do not apply to "communication equipment > under the exclusive control of communication utilities, located outdoors > or in building spaces used exclusively for such installations". Though > there is no definition of "Communications Utilities"! > > Is it stated somewhere exactly what the requirments are for > Communications > Utilities - or is that down to the rules of the operators and individual > building managers? > > regards > Charlie > >> Group >> >> Client wishes to ship wirelss Telecom equipment to US customer for use > at >> RBOC central office or commercial sites. The unit meets IEC60950-1, > but >> does not yet have an NRTL mark. >> >> As I understand it OSHA requires electrical equipment in a place of > work >> to be NRTL listed / field marked or similar, through this does not > apply >> to RBOCs as they operate their own (NEBS) rules. >> >> Also, AIUI, the right to install and operate of a piece of equipment > at an >> RBOC premise is given by the person responsible for that building - > its >> not a "given right" based on any particular level of NEBS compliance > or >> non-compliance. >> >> Please could someone confirm that I'm right, or correct any >> mis-understanding. >> >> Also - do US customs take any interest in electrical equipment > arriving in >> the US without an NRTL mark? >> >> regards >> Charlie >> >> Charles Blackham >> Sulis Consultants Ltd >> >> > > - > ---------------------------------------------------------------- > This message is from the IEEE Product Safety Engineering Society > emc-pstc discussion list. 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