Although I'm not familiar with the issue, maybe OSHA should charge NRTLs
exorbitant fees for their label changes.  This might relieve their
headache, and give the NRTLs a taste of their own medicine.

Pat

On Mon, Sep 29, 2014 at 1:14 PM, Kevin Robinson <kevinrobinso...@gmail.com>
wrote:

> Brian,
>
> I am responding from my personal account which is where I monitor the
> EMC-PSTC, so this can not serve as an "Official Response" from OSHA, but if
> you would like something, more official, I have included my work e-mail
> below.  For the purpose of this discussion, I will keep my comments generic
> and not tied to a specific NRTL.  If you wish to discuss the markings of a
> specific NRTL, please contact me at one of the e-mail addresses below with
> the appropriate details.
>
> The use of what I will call "supplemental" information around an NRTL's
> certification mark became an administrative headache for OSHA late last
> year, and it was determined that OSHA would simply include on its website a
> sample of the "Core" certification mark on its website
> https://www.osha.gov/dts/otpca/nrtl/nrtlmrk.html .  We then asked NRTLs
> to create a web page that described the different variations of its mark
> and what each one means.  For example, several NRTLs use a "US" designation
> and/or an "NRTL" designation or other additional text in conjunction with
> their mark.  These clarification web pages can be found by clicking on the
> NRTL name that you are interested in at:
> https://www.osha.gov/dts/otpca/nrtl/.
>
> If you have any questions about this, or any NRTL related matter, please
> contact me directly at:  robinson.ke...@dol.gov or send an e-mail to the
> general NRTL Program mail box at: nrtlprog...@dol.gov
>
>
> Kevin Robinson
> (Unofficially in this e-mail) Acting Director
> OSHA NRTL Program
> 202-693-1911
>
>
> On Mon, Sep 29, 2014 at 3:19 PM, Brian Oconnell <oconne...@tamuracorp.com>
> wrote:
>
>> Good People,
>>
>> Per OSHA and 29CFR1910, the images for the various marks shall be
>> registered. For the third time, yet another NRTL has mandated a mark change
>> where there is no record of the image in the OSHA database for registered
>> NRTL marks. Previously, an NRTL has issued a change notice so an ECO was
>> issued to update marking labels. After questioning the NRTL about the
>> 'official' mark, they said "never mind, just use the old marks", so we had
>> to eat several rolls of useless labels.
>>
>> Am at these same cross-roads - agency demanding that I change NRTL mark
>> image on labels where there is no official image in the OSHA database.
>>
>> Sent a message to OSHA requesting clarification, but no answer. Any ideas
>> on what OSHA officials would be appropriate for escalation of this issue?
>>
>> Thanks,
>> Brian
>>
>> -
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