This is indeed an interesting thread.
Hi Doug, So even though the ESA has no mandatory deadline, does the ESA still expect registrations to be made along with their respective initial and recurring payments? And, does the ESA actually intend to solidify the mandatory deadline? Inquiring minds need to know. I look forward to your reply. Best regards, Ron From: Doug Nix [mailto:d...@mac.com] Sent: Friday, March 26, 2010 12:54 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Requirement or not ? I have to contest Mr. Monsen's posting - The ESA registration MANDATORY DEADLINE was postponed, but the requirement to register still exists, and you must register if you wish your expensive certification mark to be respected by ESA. If you fail to register your approved product will be deemed unapproved. If you wish to verify my statements, please contact Mr. Mina Yousef at ESA - mina.you...@electricalsafety.on.ca. I am certain that my information on this point is correct. -- Doug Nix Office: (519) 650-4753 Mobile (519) 729-5704 d...@complianceinsight.ca On 26-Mar-10, at 13:47 , monrad.mon...@oracle.com wrote: Mark, You are correct that NRTL is a USA-only issue, but your information about the Electrical Safety Authority (ESA) registration is outdated. Ontario has postponed indefinitely the registration requirement for manufacturers. The original program was a poorly conceived program to make money for the nongovernmental agency that would have required every system manufacturer and every component manufacturer (even if the component was only distributed to Ontario by the larger system manufacturer to maintain its systems within Ontario) with a fee for each registration. ESA's own web site acknowledges that this requirement has been postponed. (http://www.esasafe.com/product_safety/index.php) Of course, ESA hopes that they can convince the Ontario government to re-instate the requirement, I doubt it will because they also want to encourage business in Ontario and the registration does nothing to make products safer for customers. Bottom line: I recommend that you don't waste your corporate money to pay for a defunct registration program through ESA. Monrad Monsen On 3/26/2010 9:33 AM, Doug Nix wrote: Mark, Don't make the mistake of thinking that an NRTL mark carries any weight in Canada. We do not follow US OSHA, and have our own, similar, requirements. Unless you request that a Canadian accredited certification body provides you with a recognized Canadian mark, your product will not have ANY approval status in Canada. In the Province of Ontario, you have an additional layer of complication, because electrical products covered bt the CEC and the OESC and sold in the province must have the manufacturer or the distributor registered with Ontario's Electrical Safety Authority. No other Canadian Province has a similar system. Sent from my iPhone Doug Nix d...@complianceinsight.com Mobile: (519) 729-5704 Office:(519) 650-4753 Fax: (519) 653-1318 On 2010-03-26, at 10:53, "Kunde, Brian" <brian_ku...@lecotc.com> wrote: I like Andrew’s post. Well written. I have some additional thoughts for your consideration. Other than the reference to NRTL approval on electrical devices in the NEC, the Legislative branch of the US government has no law requiring NRTL approval on consumer products that I am aware of. If there is, please post it. In regards to the Judicial branch of the US government, everyone and every company needs to protect their assists in the case of a lawsuit. The more you have to lose the more protection you need. This is done through setting up corporations, LLC’s, insurances, getting NRTL, etc.. Having NRTL will not protect you from lawsuits. You have to figure risk verses cost. If getting NRTL really really buys you some protection, then you should get it. But only you can make that determination. I’m not aware of any study that shows how much having NRTL will save a company in case of a lawsuit. As a clarification, if Joe Blow’s house burns down, it doesn’t matter if the device that caused the fire has NRTL or not; the responsible party, if it can be determined, will buy Joe a new house. Having NRTL does not protect you >from law suits. And a product not having NRTL does not automatically assume all blame. In the US you are innocent until proven guilty. There must be at least some proof a device caused the fire. If there is no proof other than the non NRTL device was in the room, that is not enough to cause blame. In a Civil Suit, the prosecution only has to show a higher weight of the evidence. Having NRTL may be enough to sway a jury depending on what other evidence is presented. It may reduce the award amount. If an NRTL device caused the fire, having HRTL will not help you much. As far as marketing goes, again you have to make this determination yourself. Few consumers care or even know what the NRTL marks are or mean in the US. One time NRTL will benefit you is if you are dealing with some large corporation or government agency and the sales contract gives mention to NRTL approval. We do get this from time to time. Usually you can negotiate around this requirement. Having NRTL approval makes sense for most all consumer electronics products. But your USB driven device fails into an area that is not so clear. I would be curious to know what you decide. I find this topic very interesting. I have enjoyed the many viewpoints and input from different people. The Other Brian ________________________________ From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Andrew Robbins Sent: Friday, March 26, 2010 9:41 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] Requirement or not ? IMHO OSHAs rule and the NEC are intentionally vague on this subject. There are two reasons manufacturers go to the trouble to obtain NRTL approval, and neither is documented in a nice neat standard. 1) Liability - we are a law suit happy nation and if Joe Blow purchases your product and his house burns down, he will blame it on the "unapproved" device. In court your company will be unarmed with no third party safety approval (NRTL) to back up your claims. The jury will award Joe Blow a new house on your nickel - and plenty of pain and suffering cash. ;-) 2) Market Driven - the market drives the need for NRTL approval, not the law. A pull system instead of a push system. Your buyers don't want the liability either because they know Joe Blow wont stop at suing your company, he will sue the distributor as well. Therefore the distributor (Wal-mart) doesn't want to deal with unapproved products. Continue to obtain NRTL approval on your devices. Even the low voltage, seemingly harmless ones. It will pay off in the long run. If one agency is too expensive and slow, try another. Andrew Robbins Nemko USA, East Coast US Regional Sales Manager ________________________________ From: Mark Schmidt [mailto:mschm...@xrite.com] Sent: Fri 3/26/2010 9:11 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Requirement or not ? This is a very informative discussion for me. Why is it that OEM’s and the majority of our other customers think it is a requirement and are so misinformed? Why is it when you request for quote from the NRTL’s they never tell you this falls out of the scope of the applicable standard? I have used three different NRTL’s for similar products and not one has ever mentioned this. During the quoting process I always send a copy of the preliminary operators manual so they know exactly what the device is. I agree with Mark Gander’s non official rule, it is logical but again applying logic isn’t the best way to prevail in a discussion such as this especially with OEM’s. Data referenced from an official source / standard however would probably work otherwise its hearsay. The LVD is specific and the information is easily attainable. Below stamen taken fromhttp://ec.europa.eu/enterpris /sectors/electrical/documents/lvd/guidance/chapter3/index_en.htm “The Directive applies to all electrical equipment [8] designed for use with a voltage rating of between 50 and 1 000 V for alternating current and between 75 and 1 500 V for direct current. Voltage ratings refer to the voltage of the electrical input or output, not to voltages which may appear inside the equipment. Battery operated equipment outside the voltage rating is obviously outside the scope of the LVD. Nevertheless, the accompanying battery-charger as well as equipment with integrated power supply unit within the voltage ranges of the Directive, are in the scope of the LVD. This applies also, in the case of battery-operated equipment with supply voltage rating under 50 V AC and 75 V DC, for their accompanying power supply unit (e.g. Notebooks).” Anyway – I guess I am going to assume that for this product it is not a requirement. It is however a marketing tool, maybe even a customer request and If I do not attain North American recognition/listing I can expect decreased revenue in Canada and the US due to lack of definition of rules. I will somehow be responsible for any decision I make here for either spending money to attain the mark and maintaining the mark or the lack of sales when an OEM requires it on the device and it’s not there. 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