As other have mentioned there is another route you can go other than NRTL listing in that you can have a field evaluation of a product but that is only really financially feasible for high cost low production specialty equipment. It may work for certain laboratory equipment but again it would have to be something low volume and it is not inexpensive as I have looked into it before.
Here are some excerpts from the Survey MARYLAND Md. COMMERCIAL LAW Code Ann. § 13-308 (2007) § 13-308. Electrical consumer products (a) Symbol of testing laboratory required. -- A person may not sell or distribute an electrical consumer product which is intended ultimately for the personal use of a consumer in or around a permanent or temporary household or residence, unless the product is clearly labeled, marked, or stamped with the symbol of an electrical testing laboratory which is certified by the State Fire Marshal to test products to determine that they are safe for use. MAINE 30-A M.R.S. § 4162 (2006) All electrical equipment installed or used must be reasonably safe to persons and property and must comply with the applicable laws of the State. Conformity of electrical equipment with applicable standards of Underwriters' Laboratories, Inc. is prima facie evidence that the equipment is reasonably safe to persons and property. Delaware's law requires that a lab does follow-up inspections which is a requirement for NRTL status so while it is possible a lab could be accredited in Delaware without NRTL accreditation it is very unlikely Delaware CDR 1-700-705 (2010) 5.1.1 A person may not sell or distribute an electrical consumer product which is intended ultimately for the personal use of a consumer in or around a permanent or temporary household or residence, unless the product is clearly labeled, marked, or stamped with the symbol of an electrical testing laboratory which is certified by the State Fire Marshal to test products to determine that they are safe for use. CDR 1-700-701 (2010) " Listed " Equipment or materials included in a list published by an organization acceptable to the State Fire Marshal and concerned with product evaluation, that maintains periodic inspection of production of listed equipment or materials and whose listing states either that the equipment or material meets appropriate standards or has been tested and found suitable for use in a specified manner. CDR 1- GEORGIA Ga. Comp. R. & Regs. r. 300-5-14-.02 (2007) All electrical wire, apparatus, and equipment in temporary or permanent use shall be, where applicable, of a type approved by and bearing the Underwriters Laboratories label. Alaska offers the option of NRTL or a bright label saying the product is not listed ALASKA Alaska Stat. § 45.45.910 (2007) A person may not sell, offer to sell, or otherwise transfer in the course of the person's business a consumer electrical product that is manufactured after August 14, 1990, unless the product is clearly marked as being listed by an approved third-party certification program or with a warning label. The warning label required by this section must be a brightly colored label that contains in simple, direct language a warning that the electrical product is not listed by an approved third-party certification program. The department shall adopt regulations establishing the exact content, color, design, and use of the warning label. IDAHO IDAPA 07.01.10.011 (2006) All materials, devices, fittings, equipment, apparatus, fixtures, and appliances installed or to be used in installations that are supplied with electric energy shall be approved as provided in one (1) of the following: 1) Testing Laboratory. Be tested, examined, and certified (Listed) by an accredited electrical product testing laboratory. The Division of Building Safety, Electrical Bureau, shall maintain an up-to-date list of products and equipment approved by such testing laboratories as well as an updated list of accredited products which shall be used and installed in accordance with the certification (Listing). 2) Approval Of Electrical Inspector. Be approved by the Electrical Inspector provided such an assembly, product, or equipment is installed under an electrical permit issued by the Division of Building Safety, Electrical Bureau, and conforms to the National Electrical Code and recognized industry standards. Where in the judgment of the Electrical Bureau a field evaluation is necessary to determine the acceptability of the assembly, product, or equipment to recognized industry standards, this field evaluation shall be completed by an accredited electrical product testing laboratory. The Division of Building Safety, Electrical Bureau, shall maintain a list of accredited electrical testing laboratories approved to complete such field evaluations. Such approval shall not be required for types of products that are regularly certified (Listed) or for certified (Listed) products as determined by the list maintained by the Division of Building Safety, Electrical Bureau. Such approval shall be obtained prior to installation. If approval is denied, the particular reasons for denial shall be stated through issuance of a notice of defects pursuant to Section 54-1004, Idaho Code. IDAPA 07.01.10.000 (2006) The Idaho Electrical Board is authorized under Sections 54-1001 and 54-1006(5), Idaho Code, to adopt As other have mentioned there is another route you can go other than NRTL listing in that you can have a field evaluation of a product but that is only really financially feasible for high cost low production specialty equipment. It may work for certain laboratory equipment but again it would have to be something low volume and it is not inexpensive as I have looked into it before. From: Ron Wellman [mailto:rwell...@wellman.com] Sent: Sunday, January 08, 2012 12:58 PM To: Tyra, John; peterh...@aol.com; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: Mandatory NRTL certification I refer you to what Rich Nute posted. From: Tyra, John [mailto:john_t...@bose.com] Sent: Sunday, January 08, 2012 9:24 AM To: 'Ron Wellman'; 'peterh...@aol.com'; 'EMC-PSTC@LISTSERV.IEEE.ORG' Subject: RE: Mandatory NRTL certification As I mentioned in my previous posts the laws in 16 States do not specify any exemptions for the type of equipment so based on that I believe that test, measurement and laboratory would need to comply........... there are 4 other States which specifically specify consumer products so based on the that I believe the type of equipment you mention may be exempt From: Ron Wellman [mailto:rwell...@wellman.com]<mailto:[mailto:rwell...@wellman.com]> Sent: Friday, January 06, 2012 2:46 PM To: Tyra, John; peterh...@aol.com<mailto:peterh...@aol.com>; EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: RE: Mandatory NRTL certification For Consumer products I see your point, but what about test, measurement, and laboratory equipment? These products are usually sold business to business and it's really up to the Customer to decide if NRTL is required for the sale. Best regards, Ron Wellman From: Tyra, John [mailto:john_t...@bose.com]<mailto:[mailto:john_t...@bose.com]> Sent: Friday, January 06, 2012 8:50 AM To: 'Ron Wellman'; peterh...@aol.com<mailto:peterh...@aol.com>; EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: RE: Mandatory NRTL certification I don't see where companies really have much of a choice as this is a legal requirement in 20 States for Consumer products From: Ron Wellman [mailto:rwell...@wellman.com]<mailto:[mailto:rwell...@wellman.com]> Sent: Friday, January 06, 2012 10:27 AM To: Tyra, John; peterh...@aol.com<mailto:peterh...@aol.com>; EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: RE: Mandatory NRTL certification This question comes up about every two years and what it boils down to is a catch 22. Damned if you do, damned if you don't. In my opinion, it is better to do regardless of how unbalanced these requirements are within the United States. As long as you budget for it and your management understands the risks of not having NRTL listing, it will be easier to manage. Best regards, Ron Wellman From: Tyra, John [mailto:john_t...@bose.com]<mailto:[mailto:john_t...@bose.com]> Sent: Friday, January 06, 2012 6:34 AM To: 'Ron Wellman'; 'peterh...@aol.com'; 'EMC-PSTC@LISTSERV.IEEE.ORG' Subject: RE: Mandatory NRTL certification While there are no Federal laws requiring NRTL certification and marking of electronic products there are laws in 16 States which require an NRTL mark for mains connected electronic products...and laws in 4 other States which specify consumer products only. CEA commissioned a State survey, which was updated in 2010, which outlines the legal requirement or lack of for all 50 States........... From: emc-p...@ieee.org<mailto:emc-p...@ieee.org> [mailto:emc-p...@ieee.org]<mailto:[mailto:emc-p...@ieee.org]> On Behalf Of Ron Wellman Sent: Thursday, January 05, 2012 11:49 PM To: peterh...@aol.com<mailto:peterh...@aol.com>; EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: RE: Mandatory NRTL certification NRTL certification/listing is not mandatory for product Manufacturers. This is a Customer driven requirement so your Customers can comply with local OSHA requirements. If you don't want to list or certify your product that's really a Marketing call. Also, it is my experience that most large Companies require third party approvals as a condition of sale. Therefore, unless you want to be reactive to Customer sales I would make sure your Marketing people understand the risk of losing a sale if your product is not certified/listed by an NRTL. Best regards, Ron Wellman From: emc-p...@ieee.org<mailto:emc-p...@ieee.org> [mailto:emc-p...@ieee.org]<mailto:[mailto:emc-p...@ieee.org]> On Behalf Of peterh...@aol.com<mailto:peterh...@aol.com> Sent: Thursday, January 05, 2012 5:41 PM To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Mandatory NRTL certification Hello All, Today a colleague asked me a question as to why do we need NRTL certification such as UL or CSA on any product in the US. I thought this was a good and logical question and the way I answered it was that to the best of my knowledge, OSHA requires that any products that is used in work place to be safe and to have been certified by one of the NRTL labs. Would you say that is a correct answer? Thank you Peter - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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