Re: [PSES] OSHA and UL60974-1 Engine Driven Arc Welders

2015-10-08 Thread John Allen 
Hi Kevin,


Thank you for the detailed clarification!!


Best Regards,


John



From: Kevin Robinson 
Sent: Thursday, October 8, 2015 2:27 PM
To: John Allen
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] OSHA and UL60974-1 Engine Driven Arc Welders

Hi John,

My name is Kevin Robinson, and I am the Director of the office that administers 
the NRTL Program for OSHA.  While this response is not an "official" response 
from OSHA (as I am sending it from my personal account), I would say the same 
thing if you were to contact me at work 
(robinson.ke...@dol.gov<mailto:robinson.ke...@dol.gov>).

Before I answer your question, I would like to help set the stage a bit.  The 
NRTL Program was created by OSHA and for OSHA.  OSHA NRTL Approval requirements 
while adopted by many state and local AHJs do not officially travel down to 
that level.  Whether an AHJ would accept a certification is really up to that 
AHJ.  Additionally, only certain types of equipment 
(http://www.osha.gov/dts/otpca/nrtl/prodcatg.html) are required by OSHA 
regulations to be "acceptable" (certified by an  NRTL).  You will notice that 
engine driven arc welders do not appear on the list of products requiring NRTL 
approval, therefore, NRTL approval is not required to satisfy OSHA (but your 
local AHJ may require some independent certification).

With that said, any organization recognized by OSHA as an NRTL can evaluate, 
test and certify equipment that is not on their NRTL scope and issue a 
certification, however, if the standard is not in their NRTL scope of 
recognition (http://www.osha.gov/dts/otpca/nrtl/nrtllist.html) then they may 
not represent themselves as an NRTL (either in the quotation, contracts, but 
most importantly, on the certification mark that they authorize you to apply to 
your product.  If an organization recognized by OSHA as an NRTL were to test 
and certify a product outside their NRTL scope that would be fine.  An AHJ may 
accept that certification, but the certification would NOT be acceptable to 
OSHA (assuming NRTL certification was even required).

If you have any additional questions, feel free to contact me directly.

Kevin Robinson
202-693-1911
robinson.ke...@dol.gov<mailto:robinson.ke...@dol.gov>



On Thu, Oct 8, 2015 at 2:54 PM, John Allen 
mailto:jral...@productsafetyinc.com>> wrote:

Hi guys,


Question on the subject -

UL60974-1 (Engine Driven Arc Welders) is not on the OSHA list of "Appropriate 
Test Standards".  UL551 (Transformer Arc Welders) is on the list.  No NRTLs 
have UL60974-1 coverage by OSHA.  Can we still use UL60974-1 for USA 
Certification?

Our issue is that UL551 does not cover our product - an Engine Driven Arc 
Welder.

Stated another way, if a Standard is not on the "Appropriate Test Standard" 
list, and no NRTLs have OSHA coverage for it, can we still Certify to it and 
have it be accepted by OSHA or any AHJ?

Thanks,

John
-


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-

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Re: [PSES] OSHA and UL60974-1 Engine Driven Arc Welders

2015-10-08 Thread Kevin Robinson 
Hi John,

My name is Kevin Robinson, and I am the Director of the office that
administers the NRTL Program for OSHA.  While this response is not an
"official" response from OSHA (as I am sending it from my personal
account), I would say the same thing if you were to contact me at work (
robinson.ke...@dol.gov).

Before I answer your question, I would like to help set the stage a bit.
The NRTL Program was created by OSHA and for OSHA.  OSHA NRTL Approval
requirements while adopted by many state and local AHJs do not officially
travel down to that level.  Whether an AHJ would accept a certification is
really up to that AHJ.  Additionally, only certain types of equipment (
http://www.osha.gov/dts/otpca/nrtl/prodcatg.html) are required by OSHA
regulations to be "acceptable" (certified by an  NRTL).  You will notice
that engine driven arc welders do not appear on the list of products
requiring NRTL approval, therefore, NRTL approval is not required to
satisfy OSHA (but your local AHJ may require some independent
certification).

With that said, any organization recognized by OSHA as an NRTL can
evaluate, test and certify equipment that is not on their NRTL scope and
issue a certification, however, if the standard is not in their NRTL scope
of recognition (http://www.osha.gov/dts/otpca/nrtl/nrtllist.html) then they
may not represent themselves as an NRTL (either in the quotation,
contracts, but most importantly, on the certification mark that they
authorize you to apply to your product.  If an organization recognized by
OSHA as an NRTL were to test and certify a product outside their NRTL scope
that would be fine.  An AHJ may accept that certification, but the
certification would NOT be acceptable to OSHA (assuming NRTL certification
was even required).

If you have any additional questions, feel free to contact me directly.

Kevin Robinson
202-693-1911
robinson.ke...@dol.gov



On Thu, Oct 8, 2015 at 2:54 PM, John Allen 
wrote:

> Hi guys,
>
>
> Question on the subject -
>
> UL60974-1 (Engine Driven Arc Welders) is not on the OSHA list of
> "Appropriate Test Standards".  UL551 (Transformer Arc Welders) is on the
> list.  No NRTLs have UL60974-1 coverage by OSHA.  Can we still use
> UL60974-1 for USA Certification?
>
> Our issue is that UL551 does not cover our product - an Engine Driven Arc
> Welder.
>
> Stated another way, if a Standard is not on the "Appropriate Test
> Standard" list, and no NRTLs have OSHA coverage for it, can we still
> Certify to it and have it be accepted by OSHA or any AHJ?
>
> Thanks,
>
> John
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
>
> Attachments are not permitted but the IEEE PSES Online Communities site at
> http://product-compliance.oc.ieee.org/ can be used for graphics (in
> well-used formats), large files, etc.
>
> Website: http://www.ieee-pses.org/
> Instructions: http://www.ieee-pses.org/list.html (including how to
> unsubscribe) 
> List rules: http://www.ieee-pses.org/listrules.html
>
> For help, send mail to the list administrators:
> Scott Douglas 
> Mike Cantwell 
>
> For policy questions, send mail to:
> Jim Bacher 
> David Heald 
>

-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 


All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website:  http://www.ieee-pses.org/
Instructions:  http://www.ieee-pses.org/list.html (including how to unsubscribe)
List rules: http://www.ieee-pses.org/listrules.html

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Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald:

[PSES] OSHA and UL60974-1 Engine Driven Arc Welders

2015-10-08 Thread John Allen 
Hi guys,


Question on the subject -

UL60974-1 (Engine Driven Arc Welders) is not on the OSHA list of "Appropriate 
Test Standards".  UL551 (Transformer Arc Welders) is on the list.  No NRTLs 
have UL60974-1 coverage by OSHA.  Can we still use UL60974-1 for USA 
Certification?

Our issue is that UL551 does not cover our product - an Engine Driven Arc 
Welder.

Stated another way, if a Standard is not on the "Appropriate Test Standard" 
list, and no NRTLs have OSHA coverage for it, can we still Certify to it and 
have it be accepted by OSHA or any AHJ?

Thanks,

John

-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 


All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website:  http://www.ieee-pses.org/
Instructions:  http://www.ieee-pses.org/list.html (including how to unsubscribe)
List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
Scott Douglas 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: