Re: [PSES] Mandatory certification

[Kevin Robinson]

>From OSHA's perspective, the employer where the equipment is installed is
responsible for ensuring the equipment is "acceptable" as defined in 29 CFR
1910.399
https://www.govinfo.gov/content/pkg/CFR-2019-title29-vol5/pdf/CFR-2019-title29-vol5-sec1910-399.pdf
.

In reality, most manufacturers assume the burden of certification as it
helps with the sale of the product and certification requires intimate
knowledge of the product components and specifications.

That said, if the product is sold in retail stores, most major retailers
require product certification before the product can be sold on their
shelves.



On Fri, Feb 21, 2020 at 3:57 PM Stultz, Mark 
wrote:

> Hello Kevin,
>
>
>
> Thanks for the great explanation.  Who is ultimately responsible for
> ensuring that equipment is certified by a NRTL?  Does the final
> responsibility fall on the purchaser/end-user or on the manufacturer?
>
>
>
> Best regards,
>
>
>
> *Mark Stultz* | CMSE® | Sealed Air | Automated Packaging Systems |
> Streetsboro, OH | 330-342-2402
>
>
>
> *From:* Kevin Robinson 
> *Sent:* Friday, February 21, 2020 11:49 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] Mandatory certification
>
>
>
>
>
>  *CAUTION:* This email originated from outside of the organization. Do
> not click links or open attachments unless you recognize the sender and
> know the content is safe.
>
>
>
> Brian,
>
>
>
> I manage the NRTL Program for OSHA.  As I am responding from my personal
> address, nothing I say here can be considered as a response from OSHA (but
> if you contact me at robinson.ke...@dol.gov, I will state the same thing
> I say here.)
>
>
>
> As for low production units, you might be able to save costs by utilizing
> families.  If you can determine the worst case condition(s) you might be
> able to simply test a few products and have that representative of all of
> the units you manufacture.  As for costs, when I worked for a NRTL (granted
> this was 12 years ago), three field evaluations were about the same cost as
> a full certification.  Yes, you might have factory surveillance costs and
> certification mark costs, but compared to the actual testing and
> certification, those costs are minimal.
>
>
>
> With regard to your interpretation of 29 CFR 1910.399:
>
>
>
> 1) This clause only covers NRTL Certification.  Field evaluations are NOT
> part of the NRTL program.  NRTLs who are issuing Field certificates and
> labels are doing so under their own name and not as a NRTL.
>
>
>
> 2) There are some products for which no NRTL has been able to demonstrate
> they have the necessary test equipment and procedures for.  For example,
> several years ago, OSHA  required crane insulating links to be tested and
> certified by a NRTL.  Until last year, there was no test standard for
> insulating links and the equipment required is very specialized.  OSHA has
> not yer recognized a NRTL to test and certify these insulating links.
> There are other examples where there are no standards for certain products,
> or where no NRTL has the capability to test to the standard.  In such an
> instance, the local AHJ may approve of the installation, or if another
> Federal Agency has jurisdiction, they may approve of the installation.  In
> my experience, this is very rare, but it is an option.
>
>
>
> 3) This option only applies to unique custom made equipment that is made
> specifically for an employer.  The example I always give is the requirement
> would apply if a potato farmer contracted with a company to make a custom
> machine that he designed to separate rocks from his potato crop.  This was
> a machine made to his exact and custom specifications, and there is nothing
> else like it.  The manufacturer could conduct some basic safety testing and
> prepare a report to give to the employer to present to OSHA if they ever
> asked for it. Either the manufacturer could do the testing themselves, or
> they could hire someone to conduct the testing for them.  The requirement
> however would NOT apply if you created a "Custom" computer purchased from a
> major manufacturer (ex Dell, Apple, Lenovo etc.) .  While you can go to
> their website and build a custom machine to your exact specifications, the
> big manufacturers aren't really making custom machines.
>
>
>
> *Everything below this represents my own personal opinion and is something
> I would not say in any official capacity (mostly because manufacturer self
> declaration has so many implications in a broad spectrum of areas).*
>
>
>
> As for allowing manufacturer self declaration, I would encourage you to
> look at a Request for Information (RFI) th

Re: [PSES] Mandatory certification

[Kevin Robinson]

Lauren,


1.   No NRTL per se offers field labeling because field labeling is not
in scope of NRTL ‘responsibilities’. An NRTL company might offer it, but it
is not an NRTL function.

<<>> Correct.  As Field inspections/certifications are not a
function of OSHA's NRTL Program, if an NRTL is offering such an evaluation
(and most do), they are issuing it based on the reputation of their brand,
or possibly as accredited by an accreditation body to NFPA 790 & 791.  They
are however not operating as an NRTL.


2.   {Quite to my surprise!} the implication of 29 CFR 1910.399(2) is
that a company essentially has to try each NRTL to see if it “accepts,
certifies, lists, labels, or determines to be safe” an equipment as part of
their NRTL scope. Only if all NRTLs are reasonably investigated could one
‘advance’ in the clause to e.g., turning to a local authority (to the
location of installation) for enforcing occupational safety provisions of
the National Electrical Code etc… at which point field labeling could be
acceptable if such authority found it so.

<<>> OSHA has not said officially (in the form of an official
interpretation)
https://www.osha.gov/laws-regs/standardinterpretations/standardnumber/1910 to
what end a manufacturer must go to prove that no NRTL can certify a piece
of equipment, but yes, that is generally correct that you should reach out
to all of the NRTLs before invoking this clause.


3.   29 CFR 1910.399(3) is not really applicable to a case of equipment
customization such as adding customer specific bells or whistles to a
product that is otherwise common to units sold to other customers. It is
focused on ‘extremely’ bespoke equipment essentially designed by the
workplace owner.

<<>> Correct.

On Fri, Feb 21, 2020 at 3:52 PM  wrote:

> Kevin,
>
>
>
> Thanks for this detailed assessment.  I would like to make sure I
> understand your guidance.
>
>
>
> 1.   No NRTL per se offers field labeling because field labeling is
> not in scope of NRTL ‘responsibilities’. An NRTL company might offer it,
> but it is not an NRTL function.
>
> 2.   {Quite to my surprise!} the implication of 29 CFR 1910.399(2) is
> that a company essentially has to try each NRTL to see if it “accepts,
> certifies, lists, labels, or determines to be safe” an equipment as part of
> their NRTL scope. Only if all NRTLs are reasonably investigated could one
> ‘advance’ in the clause to e.g., turning to a local authority (to the
> location of installation) for enforcing occupational safety provisions of
> the National Electrical Code etc… at which point field labeling could be
> acceptable if such authority found it so.
>
> 3.   29 CFR 1910.399(3) is not really applicable to a case of
> equipment customization such as adding customer specific bells or whistles
> to a product that is otherwise common to units sold to other customers. It
> is focused on ‘extremely’ bespoke equipment essentially designed by the
> workplace owner.
>
>
>
> Are those roughly correct? (any further clarifications welcome).
>
>
>
> Regards,
>
> -Lauren Crane
>
>
>
> *From:* Kevin Robinson 
> *Sent:* Friday, February 21, 2020 10:49 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] Mandatory certification
>
>
>
> Brian,
>
>
>
> I manage the NRTL Program for OSHA.  As I am responding from my personal
> address, nothing I say here can be considered as a response from OSHA (but
> if you contact me at robinson.ke...@dol.gov, I will state the same thing
> I say here.)
>
>
>
> As for low production units, you might be able to save costs by utilizing
> families.  If you can determine the worst case condition(s) you might be
> able to simply test a few products and have that representative of all of
> the units you manufacture.  As for costs, when I worked for a NRTL (granted
> this was 12 years ago), three field evaluations were about the same cost as
> a full certification.  Yes, you might have factory surveillance costs and
> certification mark costs, but compared to the actual testing and
> certification, those costs are minimal.
>
>
>
> With regard to your interpretation of 29 CFR 1910.399:
>
>
>
> 1) This clause only covers NRTL Certification.  Field evaluations are NOT
> part of the NRTL program.  NRTLs who are issuing Field certificates and
> labels are doing so under their own name and not as a NRTL.
>
>
>
> 2) There are some products for which no NRTL has been able to demonstrate
> they have the necessary test equipment and procedures for.  For example,
> several years ago, OSHA  required crane insulating links to be tested and
> certified by a NRTL.  Until last year, there was no test standard for
> insulating links and the equ

Re: [PSES] Mandatory certification

[Stultz, Mark]

Hello Kevin,

Thanks for the great explanation.  Who is ultimately responsible for ensuring 
that equipment is certified by a NRTL?  Does the final responsibility fall on 
the purchaser/end-user or on the manufacturer?

Best regards,

Mark Stultz | CMSE® | Sealed Air | Automated Packaging Systems | Streetsboro, 
OH | 330-342-2402

From: Kevin Robinson 
Sent: Friday, February 21, 2020 11:49 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Mandatory certification


 CAUTION: This email originated from outside of the organization. Do not click 
links or open attachments unless you recognize the sender and know the content 
is safe.

Brian,

I manage the NRTL Program for OSHA.  As I am responding from my personal 
address, nothing I say here can be considered as a response from OSHA (but if 
you contact me at robinson.ke...@dol.gov<mailto:robinson.ke...@dol.gov>, I will 
state the same thing I say here.)

As for low production units, you might be able to save costs by utilizing 
families.  If you can determine the worst case condition(s) you might be able 
to simply test a few products and have that representative of all of the units 
you manufacture.  As for costs, when I worked for a NRTL (granted this was 12 
years ago), three field evaluations were about the same cost as a full 
certification.  Yes, you might have factory surveillance costs and 
certification mark costs, but compared to the actual testing and certification, 
those costs are minimal.

With regard to your interpretation of 29 CFR 1910.399:

1) This clause only covers NRTL Certification.  Field evaluations are NOT part 
of the NRTL program.  NRTLs who are issuing Field certificates and labels are 
doing so under their own name and not as a NRTL.

2) There are some products for which no NRTL has been able to demonstrate they 
have the necessary test equipment and procedures for.  For example, several 
years ago, OSHA  required crane insulating links to be tested and certified by 
a NRTL.  Until last year, there was no test standard for insulating links and 
the equipment required is very specialized.  OSHA has not yer recognized a NRTL 
to test and certify these insulating links.  There are other examples where 
there are no standards for certain products, or where no NRTL has the 
capability to test to the standard.  In such an instance, the local AHJ may 
approve of the installation, or if another Federal Agency has jurisdiction, 
they may approve of the installation.  In my experience, this is very rare, but 
it is an option.

3) This option only applies to unique custom made equipment that is made 
specifically for an employer.  The example I always give is the requirement 
would apply if a potato farmer contracted with a company to make a custom 
machine that he designed to separate rocks from his potato crop.  This was a 
machine made to his exact and custom specifications, and there is nothing else 
like it.  The manufacturer could conduct some basic safety testing and prepare 
a report to give to the employer to present to OSHA if they ever asked for it. 
Either the manufacturer could do the testing themselves, or they could hire 
someone to conduct the testing for them.  The requirement however would NOT 
apply if you created a "Custom" computer purchased from a major manufacturer 
(ex Dell, Apple, Lenovo etc.) .  While you can go to their website and build a 
custom machine to your exact specifications, the big manufacturers aren't 
really making custom machines.

Everything below this represents my own personal opinion and is something I 
would not say in any official capacity (mostly because manufacturer self 
declaration has so many implications in a broad spectrum of areas).

As for allowing manufacturer self declaration, I would encourage you to look at 
a Request for Information (RFI) that OSHA published almost 10 years ago 
https://www.regulations.gov/document?D=OSHA-2008-0032-0099<https://nam01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.regulations.gov%2Fdocument%3FD%3DOSHA-2008-0032-0099&data=02%7C01%7Cmark.stultz%40sealedair.com%7Cce13668c89fb4282a84708d7b6ee156b%7C2691a2514c384643af0b0c0982f197bd%7C0%7C0%7C637179005995704320&sdata=JE6wAtGyy4073R5PSnU%2FDNNI0xz1HXQTnArCuru5%2F%2FQ%3D&reserved=0>
  You can review all of the questions OSHA asked and the public responses here 
https://www.regulations.gov/docket?D=OSHA-2008-0032<https://nam01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.regulations.gov%2Fdocket%3FD%3DOSHA-2008-0032&data=02%7C01%7Cmark.stultz%40sealedair.com%7Cce13668c89fb4282a84708d7b6ee156b%7C2691a2514c384643af0b0c0982f197bd%7C0%7C0%7C637179005995714313&sdata=dgzH2QO6NkBKq%2FT8WcCE8qAfcyowFX157E1v%2F34al8M%3D&reserved=0>.
  The United States has a very robust product safety system and as a result, 
there are very few injuries as a direct result of products that are NRTL 
certified.  While you may feel that $6000 - 8000 is 

Re: [PSES] Mandatory certification

[lauren . crane]

Kevin,

Thanks for this detailed assessment.  I would like to make sure I understand 
your guidance.


1.   No NRTL per se offers field labeling because field labeling is not in 
scope of NRTL ‘responsibilities’. An NRTL company might offer it, but it is not 
an NRTL function.

2.   {Quite to my surprise!} the implication of 29 CFR 1910.399(2) is that 
a company essentially has to try each NRTL to see if it “accepts, certifies, 
lists, labels, or determines to be safe” an equipment as part of their NRTL 
scope. Only if all NRTLs are reasonably investigated could one ‘advance’ in the 
clause to e.g., turning to a local authority (to the location of installation) 
for enforcing occupational safety provisions of the National Electrical Code 
etc… at which point field labeling could be acceptable if such authority found 
it so.

3.   29 CFR 1910.399(3) is not really applicable to a case of equipment 
customization such as adding customer specific bells or whistles to a product 
that is otherwise common to units sold to other customers. It is focused on 
‘extremely’ bespoke equipment essentially designed by the workplace owner.

Are those roughly correct? (any further clarifications welcome).

Regards,
-Lauren Crane

From: Kevin Robinson 
Sent: Friday, February 21, 2020 10:49 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Mandatory certification

Brian,

I manage the NRTL Program for OSHA.  As I am responding from my personal 
address, nothing I say here can be considered as a response from OSHA (but if 
you contact me at robinson.ke...@dol.gov<mailto:robinson.ke...@dol.gov>, I will 
state the same thing I say here.)

As for low production units, you might be able to save costs by utilizing 
families.  If you can determine the worst case condition(s) you might be able 
to simply test a few products and have that representative of all of the units 
you manufacture.  As for costs, when I worked for a NRTL (granted this was 12 
years ago), three field evaluations were about the same cost as a full 
certification.  Yes, you might have factory surveillance costs and 
certification mark costs, but compared to the actual testing and certification, 
those costs are minimal.

With regard to your interpretation of 29 CFR 1910.399:

1) This clause only covers NRTL Certification.  Field evaluations are NOT part 
of the NRTL program.  NRTLs who are issuing Field certificates and labels are 
doing so under their own name and not as a NRTL.

2) There are some products for which no NRTL has been able to demonstrate they 
have the necessary test equipment and procedures for.  For example, several 
years ago, OSHA  required crane insulating links to be tested and certified by 
a NRTL.  Until last year, there was no test standard for insulating links and 
the equipment required is very specialized.  OSHA has not yer recognized a NRTL 
to test and certify these insulating links.  There are other examples where 
there are no standards for certain products, or where no NRTL has the 
capability to test to the standard.  In such an instance, the local AHJ may 
approve of the installation, or if another Federal Agency has jurisdiction, 
they may approve of the installation.  In my experience, this is very rare, but 
it is an option.

3) This option only applies to unique custom made equipment that is made 
specifically for an employer.  The example I always give is the requirement 
would apply if a potato farmer contracted with a company to make a custom 
machine that he designed to separate rocks from his potato crop.  This was a 
machine made to his exact and custom specifications, and there is nothing else 
like it.  The manufacturer could conduct some basic safety testing and prepare 
a report to give to the employer to present to OSHA if they ever asked for it. 
Either the manufacturer could do the testing themselves, or they could hire 
someone to conduct the testing for them.  The requirement however would NOT 
apply if you created a "Custom" computer purchased from a major manufacturer 
(ex Dell, Apple, Lenovo etc.) .  While you can go to their website and build a 
custom machine to your exact specifications, the big manufacturers aren't 
really making custom machines.

Everything below this represents my own personal opinion and is something I 
would not say in any official capacity (mostly because manufacturer self 
declaration has so many implications in a broad spectrum of areas).

As for allowing manufacturer self declaration, I would encourage you to look at 
a Request for Information (RFI) that OSHA published almost 10 years ago 
https://www.regulations.gov/document?D=OSHA-2008-0032-0099  You can review all 
of the questions OSHA asked and the public responses here 
https://www.regulations.gov/docket?D=OSHA-2008-0032.  The United States has a 
very robust product safety system and as a result, there are very few injuries 
as a direct result of products that are NRTL certified

Re: [PSES] Mandatory certification

[Kevin Robinson]

pment, so they will require the
>> owner/employer to get a field evaluation.
>>
>> OSHA has not made an OFFICIAL interpretation of the regulations to say
>> that a field evaluation could be used to meet the definition of
>> “acceptable”.
>> https://www.osha.gov/laws-regs/standardinterpretations/publicationdate/currentyear
>>
>> Disclaimer: My positions posted here are my own and do not represent the
>> official positions of my employer the US Department of Labor or OSHA.
>>
>> Kevin Robinson
>>
>> Get Outlook for iOS <https://aka.ms/o0ukef>
>> ------
>> *From:* Richard Nute 
>> *Sent:* Thursday, February 20, 2020 8:15:36 PM
>> *To:* EMC-PSTC@LISTSERV.IEEE.ORG 
>> *Subject:* Re: [PSES] Mandatory certification
>>
>>
>>
>>
>> Hi Regan:
>>
>>
>>
>> Yes, if that piece of equipment is not within *any* NRTL purview.
>>
>>
>>
>> Best regards,
>>
>> Rich
>>
>>
>>
>>
>>
>> *From:* Regan Arndt 
>> *Sent:* Thursday, February 20, 2020 1:22 PM
>> *To:* Richard Nute 
>> *Cc:* EMC-PSTC@listserv.ieee.org
>> *Subject:* Re: [PSES] Mandatory certification
>>
>>
>>
>> Hi Rich.
>>
>>
>>
>> If you are referring to clause (2):
>>
>>
>>
>> *(2) With respect to an installation or equipment of a kind that no
>> nationally recognized testing laboratory accepts, certifies, lists, labels,
>> or determines to be safe, if it is inspected or tested by another Federal
>> agency, or by a State, municipal, or other local authority responsible for
>> enforcing occupational safety provisions of the National Electrical Code,
>> and found in compliance with the provisions of the National Electrical Code
>> as applied in this subpart; o*r
>>
>>
>>
>> Correct me if I am wrong, "BUT ONLY" if that piece of equipment *cannot
>> be certified by the NRTL's*, which is almost rare nowadays when you look
>> at the extensive scope of accreditation of the NRTL's.
>>
>>
>>
>> Regan
>>
>>
>> -
>> 
>>
>> 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) <http://www.ieee-pses.org/list.html>
>> 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 <
>> 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) <http://www.ieee-pses.org/list.html>
>> List rules: http://www.ieee-pses.org/listrules.html
>>
>> For help, send mail to the list administrators:
>> Scott Douglas <sdoug...@ieee.org>
>> Mike Cantwell <mcantw...@ieee.org>
>>
>> For policy questions, send mail to:
>> Jim Bacher <j.bac...@ieee.org>
>> David Heald <dhe...@gmail.com>
>>
>

-

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: 

Re: [PSES] Mandatory certification

[Brian Kunde]

d be
> acceptable to OSHA if a state/federal agency determined it was safe.  The
> reality is however that most local jurisdictions don’t want to take on the
> liability of approving non certified equipment, so they will require the
> owner/employer to get a field evaluation.
>
> OSHA has not made an OFFICIAL interpretation of the regulations to say
> that a field evaluation could be used to meet the definition of
> “acceptable”.
> https://www.osha.gov/laws-regs/standardinterpretations/publicationdate/currentyear
>
> Disclaimer: My positions posted here are my own and do not represent the
> official positions of my employer the US Department of Labor or OSHA.
>
> Kevin Robinson
>
> Get Outlook for iOS <https://aka.ms/o0ukef>
> ----------
> *From:* Richard Nute 
> *Sent:* Thursday, February 20, 2020 8:15:36 PM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG 
> *Subject:* Re: [PSES] Mandatory certification
>
>
>
>
> Hi Regan:
>
>
>
> Yes, if that piece of equipment is not within *any* NRTL purview.
>
>
>
> Best regards,
>
> Rich
>
>
>
>
>
> *From:* Regan Arndt 
> *Sent:* Thursday, February 20, 2020 1:22 PM
> *To:* Richard Nute 
> *Cc:* EMC-PSTC@listserv.ieee.org
> *Subject:* Re: [PSES] Mandatory certification
>
>
>
> Hi Rich.
>
>
>
> If you are referring to clause (2):
>
>
>
> *(2) With respect to an installation or equipment of a kind that no
> nationally recognized testing laboratory accepts, certifies, lists, labels,
> or determines to be safe, if it is inspected or tested by another Federal
> agency, or by a State, municipal, or other local authority responsible for
> enforcing occupational safety provisions of the National Electrical Code,
> and found in compliance with the provisions of the National Electrical Code
> as applied in this subpart; o*r
>
>
>
> Correct me if I am wrong, "BUT ONLY" if that piece of equipment *cannot
> be certified by the NRTL's*, which is almost rare nowadays when you look
> at the extensive scope of accreditation of the NRTL's.
>
>
>
> Regan
>
>
> -
> 
>
> 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) <http://www.ieee-pses.org/list.html>
> 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 <
> 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) <http://www.ieee-pses.org/list.html>
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>
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>
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>

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Re: [PSES] Mandatory certification

[Kevin Robinson]

Clause 2 under the definition for “acceptable” can only be used under specific 
conditions, specifically if no NRTL has the capability to test and certify the 
equipment.  In such cases, the equipment/installation would be acceptable to 
OSHA if a state/federal agency determined it was safe.  The reality is however 
that most local jurisdictions don’t want to take on the liability of approving 
non certified equipment, so they will require the owner/employer to get a field 
evaluation.

OSHA has not made an OFFICIAL interpretation of the regulations to say that a 
field evaluation could be used to meet the definition of “acceptable”.  
https://www.osha.gov/laws-regs/standardinterpretations/publicationdate/currentyear

Disclaimer: My positions posted here are my own and do not represent the 
official positions of my employer the US Department of Labor or OSHA.

Kevin Robinson

Get Outlook for iOS<https://aka.ms/o0ukef>

From: Richard Nute 
Sent: Thursday, February 20, 2020 8:15:36 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: Re: [PSES] Mandatory certification




Hi Regan:



Yes, if that piece of equipment is not within any NRTL purview.



Best regards,

Rich





From: Regan Arndt 
Sent: Thursday, February 20, 2020 1:22 PM
To: Richard Nute 
Cc: EMC-PSTC@listserv.ieee.org
Subject: Re: [PSES] Mandatory certification



Hi Rich.



If you are referring to clause (2):



(2) With respect to an installation or equipment of a kind that no nationally 
recognized testing laboratory accepts, certifies, lists, labels, or determines 
to be safe, if it is inspected or tested by another Federal agency, or by a 
State, municipal, or other local authority responsible for enforcing 
occupational safety provisions of the National Electrical Code, and found in 
compliance with the provisions of the National Electrical Code as applied in 
this subpart; or



Correct me if I am wrong, "BUT ONLY" if that piece of equipment cannot be 
certified by the NRTL's, which is almost rare nowadays when you look at the 
extensive scope of accreditation of the NRTL's.



Regan



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Re: [PSES] Mandatory certification

[Richard Nute]

 

Hi Regan:  

 

Yes, if that piece of equipment is not within any NRTL purview.   

 

Best regards,

Rich

 

 

From: Regan Arndt  
Sent: Thursday, February 20, 2020 1:22 PM
To: Richard Nute 
Cc: EMC-PSTC@listserv.ieee.org
Subject: Re: [PSES] Mandatory certification

 

Hi Rich.

 

If you are referring to clause (2):

 

(2) With respect to an installation or equipment of a kind that no nationally 
recognized testing laboratory accepts, certifies, lists, labels, or determines 
to be safe, if it is inspected or tested by another Federal agency, or by a 
State, municipal, or other local authority responsible for enforcing 
occupational safety provisions of the National Electrical Code, and found in 
compliance with the provisions of the National Electrical Code as applied in 
this subpart; or  

 

Correct me if I am wrong, "BUT ONLY" if that piece of equipment cannot be 
certified by the NRTL's, which is almost rare nowadays when you look at the 
extensive scope of accreditation of the NRTL's. 

 

Regan

 


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Re: [PSES] Mandatory certification

[Regan Arndt]

Hi Rich.

If you are referring to clause (2):

*(2) With respect to an installation or equipment of a kind that no
nationally recognized testing laboratory accepts, certifies, lists, labels,
or determines to be safe, if it is inspected or tested by another Federal
agency, or by a State, municipal, or other local authority responsible for
enforcing occupational safety provisions of the National Electrical Code,
and found in compliance with the provisions of the National Electrical Code
as applied in this subpart; o*r

Correct me if I am wrong, "BUT ONLY" if that piece of equipment *cannot be
certified by the NRTL's*, which is almost rare nowadays when you look at
the extensive scope of accreditation of the NRTL's.

Regan

On Thu, Feb 20, 2020 at 10:58 AM Richard Nute  wrote:

>
>
> Hi Regan:
>
>
>
> While field inspection is not part of OSHA's NRTL program, OSHA rules
> allow another government (federal, state, local) organization to determine
> compliance with the NEC.  See:
>
>
>
> https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.399
>
>
>
> I would guess that such a government organization (not the manufacturer)
> would hire a NRTL to do a field inspection.
>
>
>
> Best regards,
>
> Rich
>
>
>
>
>
> *From:* Regan Arndt 
> *Sent:* Wednesday, February 19, 2020 10:46 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification
>
>
>
> Hello Dave/Bernd.
>
>
>
> Just a comment/clarification. The field inspection/label program is not
> part of OSHA's NRTL program despite some NRTL's that conducted this
> service. I know it can seem confusing but there are also some non-NRTL's
> that conduct these field evaluations, all of which are under state
> jurisdiction.
>
>
>
> Some may think they are abiding by OSHA rules with obtaining a field
> evaluation by an NRTL. That is not the case.
>
>
>
> Regan
>
>
>

-

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Re: [PSES] Mandatory certification

[Wiseman, Joshua]

Having worked for an NRTL in the past and with a few manufacturers, I can 
attest to Dave’s comment.  Generally, the manufacturer is responsible for the 
field inspection of the equipment.  Several of the major NRTL’s in the US have 
a program in place for this process.

Josh

Joshua Wiseman
Systems Engineering
Staff Engineer, Product Safety/EMC
Ortho Clinical Diagnostics

[cid:image001.png@01D5E800.7268C310]

From: David Nyffenegger 
Sent: Thursday, February 20, 2020 2:46 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Mandatory certification

EXTERNAL SENDER: Verify links, attachments and sender before taking action


Or typically the government organization, the AHJ, simply accepts the field 
inspection label applied by NRTL or other recognized entity.  The 
owner/operator of the product is ultimately responsible for the inspection.  
I’ve never known a government organization to hire a NRTL for field inspection, 
unless of course the product in question is owned/operated by said government 
organization (which is not unusual.)   In my experience as a manufacturer we 
will often provide for a field inspection/label of un-listed product as part of 
the sales agreement to the customer.

-Dave

On Thu, Feb 20, 2020 at 1:59 PM Richard Nute 
mailto:ri...@ieee.org>> wrote:

Hi Regan:

While field inspection is not part of OSHA's NRTL program, OSHA rules allow 
another government (federal, state, local) organization to determine compliance 
with the NEC.  See:

https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.399<https://nam03.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.osha.gov%2Flaws-regs%2Fregulations%2Fstandardnumber%2F1910%2F1910.399&data=02%7C01%7Cjoshua.wiseman%40orthoclinicaldiagnostics.com%7C8668e0b13c4f42da736508d7b63d9a82%7C6e63ffc0c2fc4cc4b6c4666b2ce89d92%7C0%7C0%7C637178248016629385&sdata=kuLUWTjisKkboRzoqx0iZoHihhn8rabSIStZbu8CwgA%3D&reserved=0>

I would guess that such a government organization (not the manufacturer) would 
hire a NRTL to do a field inspection.

Best regards,
Rich


From: Regan Arndt mailto:reganar...@gmail.com>>
Sent: Wednesday, February 19, 2020 10:46 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

Hello Dave/Bernd.

Just a comment/clarification. The field inspection/label program is not part of 
OSHA's NRTL program despite some NRTL's that conducted this service. I know it 
can seem confusing but there are also some non-NRTL's that conduct these field 
evaluations, all of which are under state jurisdiction.

Some may think they are abiding by OSHA rules with obtaining a field evaluation 
by an NRTL. That is not the case.

Regan

-


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<emc-p...@ieee.org<mailto:emc-p...@ieee.org>>

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Re: [PSES] Mandatory certification

[David Nyffenegger]

Or typically the government organization, the AHJ, simply accepts the field
inspection label applied by NRTL or other recognized entity.  The
owner/operator of the product is ultimately responsible for the
inspection.  I’ve never known a government organization to hire a NRTL for
field inspection, unless of course the product in question is
owned/operated by said government organization (which is not unusual.)   In
my experience as a manufacturer we will often provide for a field
inspection/label of un-listed product as part of the sales agreement to the
customer.



-Dave

On Thu, Feb 20, 2020 at 1:59 PM Richard Nute  wrote:

>
>
> Hi Regan:
>
>
>
> While field inspection is not part of OSHA's NRTL program, OSHA rules
> allow another government (federal, state, local) organization to determine
> compliance with the NEC.  See:
>
>
>
> https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.399
>
>
>
> I would guess that such a government organization (not the manufacturer)
> would hire a NRTL to do a field inspection.
>
>
>
> Best regards,
>
> Rich
>
>
>
>
>
> *From:* Regan Arndt 
> *Sent:* Wednesday, February 19, 2020 10:46 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification
>
>
>
> Hello Dave/Bernd.
>
>
>
> Just a comment/clarification. The field inspection/label program is not
> part of OSHA's NRTL program despite some NRTL's that conducted this
> service. I know it can seem confusing but there are also some non-NRTL's
> that conduct these field evaluations, all of which are under state
> jurisdiction.
>
>
>
> Some may think they are abiding by OSHA rules with obtaining a field
> evaluation by an NRTL. That is not the case.
>
>
>
> Regan
>
>
> -
> 
>
> 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) <http://www.ieee-pses.org/list.html>
> List rules: http://www.ieee-pses.org/listrules.html
>
> For help, send mail to the list administrators:
> Scott Douglas <sdoug...@ieee.org>
> Mike Cantwell <mcantw...@ieee.org>
>
> For policy questions, send mail to:
> Jim Bacher <j.bac...@ieee.org>
> David Heald <dhe...@gmail.com>
>

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Re: [PSES] Mandatory certification

[Richard Nute]

 

Hi Regan:

 

While field inspection is not part of OSHA's NRTL program, OSHA rules allow 
another government (federal, state, local) organization to determine compliance 
with the NEC.  See:

 

https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.399

 

I would guess that such a government organization (not the manufacturer) would 
hire a NRTL to do a field inspection. 

 

Best regards,

Rich

 

 

From: Regan Arndt  
Sent: Wednesday, February 19, 2020 10:46 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

 

Hello Dave/Bernd.

 

Just a comment/clarification. The field inspection/label program is not part of 
OSHA's NRTL program despite some NRTL's that conducted this service. I know it 
can seem confusing but there are also some non-NRTL's that conduct these field 
evaluations, all of which are under state jurisdiction.

 

Some may think they are abiding by OSHA rules with obtaining a field evaluation 
by an NRTL. That is not the case.

 

Regan

 


-

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discussion list. To post a message to the list, send your e-mail to 


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Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

[Pete Perkins]

The US product certification system seems confusing to those who have not grown 
up with it and used it.  It is divided, as has been discussed, between 
commercial/industrial (OHSA regulated) and retail/consumer (local AHJ 
controlled).  

OSHA has pretty clear requirements but enforcement is primarily done by 
investigating incidents.  

Consumer requirements are generally covered by the NEC (which requires NRTL 
listing) which is adopted in more than 10,000 jurisdictions in the US and 
enforced by AHJ inspectors.   This is also enforced at the retail level in that 
sellers won’t offer anything for sale which is not NRTL Listed as a contractual 
condition to the supplier.  AHJ facilities inspection is usually completed 
before most equipment is installed but anything installed earlier – including 
lighting, heating and air conditioning and other basic electrical appliances 
are fair game and can be ‘red tagged’ as not acceptable by the AHJ inspector.  

This has all been further confused by the enormous expansion of LV components 
used ubiquitously in both the work environment and the residential environment. 
 These LV devices used to be simple and could easily be evaluated during the 
inspection as being acceptable.  Today, however, the devices are much more 
complex and can give rise to hazards which are not obvious to a casual 
inspection (There have been numerous electric shock and/or fire issues 
developed from ‘walwarts’ which are always installed to operate connected 
equipment).  

Finally, in the American tradition the final enforcement is thru the legal 
system when there are incidents.  Any product involved which is not NRTL 
certified is condemned before the party starts.  

The manufacturer should beware and provide NRTL certification in more cases 
than not.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 1067

Albany, ORe  97321-0413

 

503/452-1201

 

IEEE Life Fellow

IEEE PSES 2020 Distinguished Lecturer

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

From: Ted Eckert <07cf6ebeab9d-dmarc-requ...@ieee.org> 
Sent: Wednesday, February 19, 2020 7:13 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

 

Hello Bernd,

 

The requirement from the National Electrical Code is either an NRTL Listing or 
approval by the local Authority Having Jurisdiction (AHJ). The latter option 
means that a local electrical inspector or building inspector will look at the 
equipment to determine whether they think it is safe and appropriate. In my 
opinion, this is a far more challenging option as opposed to getting an NRTL 
Listing. If the equipment does not meet the AHJ’s approval, it will get a “red 
tag” and will not be allowed to be operated until any corrections are made. 
Many customers will only accept NRTL Listed products.

 

Manufacturers of custom equipment will often seek “field certification”. For 
this option, the manufacturer hires an NRTL to come to the installation site to 
perform certification at that location. The NRTL can do field marking of the 
equipment if it meets approval. It then would meet the requirements of the NEC.

 

The NEC has no option for self-declaration. You either need an NRTL Listing or 
you need the approval of the AHJ. 

 

Ted Eckert

Microsoft Corporation

 

The opinions experessed are my own and do not necessarily reflect those of my 
employer.

 

 

From: Dürrer Bernd mailto:bernd.duer...@wilo.com> > 
Sent: Wednesday, February 19, 2020 7:02 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: [PSES] AW: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

 

Hello Ted, hello Regan,

 

Thank you for your clear statements on NRTL certification. Can you please 
provide some guidance on the interpretation of the National Electrical Code 
NFPA 70 (2020 edition), article 110.3, on the suitability of installation and 
use in conformity with the NEC? Informational note no. 2 explains, that this 
suitability “may” be evidenced by listing or labelling. Informative Annex A 
“provides a list of product safety standards used for product listing where 
that listing is required by the NEC.” This lists includes many product safety 
standards for consumer products like appliances that are typically plug 
connected. In the case that the NEC has been adopted by local jurisdiction and 
that the equipment is in the scope of a product safety standard listed in Annex 
A, is NRTL certification and listing then a mandatory requirement, or is there 
another option (e.g. self-declaration of the manufacturer that the product is 
suitable for installation and use in conformity with the NEC) that is accepted 
both by jurisdiction and the market?

 

Thank you and kind regards,

 

Bernd

 

Von: Regan Arndt mailto:reganar...@gmail.com> > 
Gesendet: Dienstag, 18. Februar 2020 18:01
An: EMC-PS

Re: [PSES] Mandatory certification

[Richard Nute]

 

Hi Dürrer:

 

1.  Self-declaration is not accepted by any jurisdiction (or by OSHA) in 
the USA.  However, safety certification is not mandatory (or enforced) in some 
local jurisdictions.
2.  Where the NEC is adopted by the local jurisdiction, the adoption may 
have exceptions and additions.  Note that some jurisdictions e.g., Chicago, Los 
Angeles, do not adopt the NEC, but have their own electrical code and rules for 
safety certification.
3.  Regarding the “market,” some retailers, e.g., Walmart, will not sell 
non-safety-certified products.

 

As a general rule (with exceptions), voluntary (mandatory for a workplace) 
safety certification by a NRTL is accepted everywhere in the USA.  Some 
certification houses offer individual product safety certification in situ.  

 

Best regards,

Rich

 

 

From: Dürrer Bernd  
Sent: Wednesday, February 19, 2020 7:02 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] AW: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

 

Hello Ted, hello Regan,

 

Thank you for your clear statements on NRTL certification. Can you please 
provide some guidance on the interpretation of the National Electrical Code 
NFPA 70 (2020 edition), article 110.3, on the suitability of installation and 
use in conformity with the NEC? Informational note no. 2 explains, that this 
suitability “may” be evidenced by listing or labelling. Informative Annex A 
“provides a list of product safety standards used for product listing where 
that listing is required by the NEC.” This lists includes many product safety 
standards for consumer products like appliances that are typically plug 
connected. In the case that the NEC has been adopted by local jurisdiction and 
that the equipment is in the scope of a product safety standard listed in Annex 
A, is NRTL certification and listing then a mandatory requirement, or is there 
another option (e.g. self-declaration of the manufacturer that the product is 
suitable for installation and use in conformity with the NEC) that is accepted 
both by jurisdiction and the market?

 

Thank you and kind regards,

 

Bernd

 


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Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

[Chuck August-McDowell]

I think an example of the field inspection/label program not part of OSHA's 
NRTL program would be the City of Los Angles Department of Building and Safety.
http://www.ladbs.org/services/core-services/plan-check-permit/product-approval/electrical-test-lab

Note, I did not confirm they are not also an NRTL.

Respectfully,

Charles August-McDowell
Compliance Specialist

From: Regan Arndt 
Sent: Wednesday, February 19, 2020 10:46 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification


[EXTERNAL EMAIL]
Hello Dave/Bernd.

Just a comment/clarification. The field inspection/label program is not part of 
OSHA's NRTL program despite some NRTL's that conducted this service. I know it 
can seem confusing but there are also some non-NRTL's that conduct these field 
evaluations, all of which are under state jurisdiction.

Some may think they are abiding by OSHA rules with obtaining a field evaluation 
by an NRTL. That is not the case.

Regan

On Wed, Feb 19, 2020 at 7:11 AM Nyffenegger, Dave 
mailto:dave.nyffeneg...@bhemail.com>> wrote:
Bernd,

I don’t know any jurisdiction that would accept a manufacturer self-declaration 
if the jurisdiction is requiring a safety certification.  An alternative to an 
NRTL listing is an NRTL field inspection/label which is unique to each product 
at each  installation.

-Dave

From: Dürrer Bernd 
[mailto:bernd.duer...@wilo.com<mailto:bernd.duer...@wilo.com>]
Sent: Wednesday, February 19, 2020 10:02 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] AW: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

Hello Ted, hello Regan,

Thank you for your clear statements on NRTL certification. Can you please 
provide some guidance on the interpretation of the National Electrical Code 
NFPA 70 (2020 edition), article 110.3, on the suitability of installation and 
use in conformity with the NEC? Informational note no. 2 explains, that this 
suitability “may” be evidenced by listing or labelling. Informative Annex A 
“provides a list of product safety standards used for product listing where 
that listing is required by the NEC.” This lists includes many product safety 
standards for consumer products like appliances that are typically plug 
connected. In the case that the NEC has been adopted by local jurisdiction and 
that the equipment is in the scope of a product safety standard listed in Annex 
A, is NRTL certification and listing then a mandatory requirement, or is there 
another option (e.g. self-declaration of the manufacturer that the product is 
suitable for installation and use in conformity with the NEC) that is accepted 
both by jurisdiction and the market?

Thank you and kind regards,

Bernd

Von: Regan Arndt mailto:reganar...@gmail.com>>
Gesendet: Dienstag, 18. Februar 2020 18:01
An: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Betreff: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

OSHA & the related NRTL mandatory certification is only for the 
commercial/office/industrial workplace. OSHA has no jurisdiction in the 
consumer environment.
The FCC is for both environments.

Regan

On Mon, Feb 17, 2020, 8:29 PM 
<06cee064502d-dmarc-requ...@ieee.org<mailto:06cee064502d-dmarc-requ...@ieee.org>>
 wrote:
Thank you Ted, Rich and Regan,

The product is classified as IT and is sold to pro market. i.e it is used by 
professional and not consumer market. There two types of products. Class I as 
well as Class III. They are mainly used in corporation conference rooms.

With that in mind, what are your thoughts about mandatory NRTL certification as 
well as FCC?

Thanks
Peter
-Original Message-
From: Ted Eckert 
<07cf6ebeab9d-dmarc-requ...@ieee.org<mailto:07cf6ebeab9d-dmarc-requ...@ieee.org>>
To: EMC-PSTC mailto:EMC-PSTC@LISTSERV.IEEE.ORG>>
Sent: Mon, Feb 17, 2020 6:16 pm
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification
Hello Peter,

Let me add to Rich and Regan’s comments.

The question for residential installations isn’t as clear as for the workplace. 
Most jurisdictions in the United States have adopted the National Electrical 
Code which requires many electrical and electronic products to either be Listed 
or to be investigated and approved by the local Authority Having Jurisdiction. 
In practice, this typically will apply to hard-wired products or products 
attached to building structure. The enforcement is typically through an 
electrical inspection which will often not cover plug-connected devices.

In the workplace, any product that has a direct connection to the mains will 
need NRTL approval. At the other end of the spectrum, a product like a USB 
mouse or remote control using alkaline batteries likely won’t need NRTL 
approval. In theory, I believe an OSHA inspector could enforce the NRTL 
requirement on any electrical product, but that won’t necess

Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

[Regan Arndt]

Hello Dave/Bernd.

Just a comment/clarification. The field inspection/label program is not
part of OSHA's NRTL program despite some NRTL's that conducted this
service. I know it can seem confusing but there are also some non-NRTL's
that conduct these field evaluations, all of which are under state
jurisdiction.

Some may think they are abiding by OSHA rules with obtaining a field
evaluation by an NRTL. That is not the case.

Regan

On Wed, Feb 19, 2020 at 7:11 AM Nyffenegger, Dave <
dave.nyffeneg...@bhemail.com> wrote:

> Bernd,
>
>
>
> I don’t know any jurisdiction that would accept a manufacturer
> self-declaration if the jurisdiction is requiring a safety certification.
> An alternative to an NRTL listing is an NRTL field inspection/label which
> is unique to each product at each  installation.
>
>
>
> -Dave
>
>
>
> *From:* Dürrer Bernd [mailto:bernd.duer...@wilo.com]
> *Sent:* Wednesday, February 19, 2020 10:02 AM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] AW: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification
>
>
>
> Hello Ted, hello Regan,
>
>
>
> Thank you for your clear statements on NRTL certification. Can you please
> provide some guidance on the interpretation of the National Electrical Code
> NFPA 70 (2020 edition), article 110.3, on the suitability of installation
> and use in conformity with the NEC? Informational note no. 2 explains, that
> this suitability “may” be evidenced by listing or labelling. Informative
> Annex A “provides a list of product safety standards used for product
> listing where that listing is required by the NEC.” This lists includes
> many product safety standards for consumer products like appliances that
> are typically plug connected. In the case that the NEC has been adopted by
> local jurisdiction and that the equipment is in the scope of a product
> safety standard listed in Annex A, is NRTL certification and listing then a
> mandatory requirement, or is there another option (e.g. self-declaration of
> the manufacturer that the product is suitable for installation and use in
> conformity with the NEC) that is accepted both by jurisdiction and the
> market?
>
>
>
> Thank you and kind regards,
>
>
>
> Bernd
>
>
>
> *Von:* Regan Arndt 
> *Gesendet:* Dienstag, 18. Februar 2020 18:01
> *An:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Betreff:* Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification
>
>
>
> OSHA & the related NRTL mandatory certification is only for the
> commercial/office/industrial workplace. OSHA has no jurisdiction in the
> consumer environment.
>
> The FCC is for both environments.
>
>
>
> Regan
>
>
>
> On Mon, Feb 17, 2020, 8:29 PM <06cee064502d-dmarc-requ...@ieee.org>
> wrote:
>
> Thank you Ted, Rich and Regan,
>
> The product is classified as IT and is sold to pro market. i.e it is used
> by professional and not consumer market. There two types of products. Class
> I as well as Class III. They are mainly used in corporation conference
> rooms.
>
>
>
> With that in mind, what are your thoughts about mandatory NRTL
> certification as well as FCC?
>
>
>
> Thanks
>
> Peter
>
> -Original Message-
> From: Ted Eckert <07cf6ebeab9d-dmarc-requ...@ieee.org>
> To: EMC-PSTC 
> Sent: Mon, Feb 17, 2020 6:16 pm
> Subject: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification
>
> Hello Peter,
>
>
>
> Let me add to Rich and Regan’s comments.
>
>
>
> The question for residential installations isn’t as clear as for the
> workplace. Most jurisdictions in the United States have adopted the
> National Electrical Code which requires many electrical and electronic
> products to either be Listed or to be investigated and approved by the
> local Authority Having Jurisdiction. In practice, this typically will apply
> to hard-wired products or products attached to building structure. The
> enforcement is typically through an electrical inspection which will often
> not cover plug-connected devices.
>
>
>
> In the workplace, any product that has a direct connection to the mains
> will need NRTL approval. At the other end of the spectrum, a product like a
> USB mouse or remote control using alkaline batteries likely won’t need NRTL
> approval. In theory, I believe an OSHA inspector could enforce the NRTL
> requirement on any electrical product, but that won’t necessarily be what
> happens in practice.
>
>
>
> That being said, you can choose not to get NRTL approval for your product.
> However, you need to understand the risks your product may pose. If you
> sell products to commercial customers, are you meeting their needs? Will
>

Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

[Ted Eckert]

Hello Bernd,

The requirement from the National Electrical Code is either an NRTL Listing or 
approval by the local Authority Having Jurisdiction (AHJ). The latter option 
means that a local electrical inspector or building inspector will look at the 
equipment to determine whether they think it is safe and appropriate. In my 
opinion, this is a far more challenging option as opposed to getting an NRTL 
Listing. If the equipment does not meet the AHJ’s approval, it will get a “red 
tag” and will not be allowed to be operated until any corrections are made. 
Many customers will only accept NRTL Listed products.

Manufacturers of custom equipment will often seek “field certification”. For 
this option, the manufacturer hires an NRTL to come to the installation site to 
perform certification at that location. The NRTL can do field marking of the 
equipment if it meets approval. It then would meet the requirements of the NEC.

The NEC has no option for self-declaration. You either need an NRTL Listing or 
you need the approval of the AHJ.

Ted Eckert
Microsoft Corporation

The opinions experessed are my own and do not necessarily reflect those of my 
employer.


From: Dürrer Bernd 
Sent: Wednesday, February 19, 2020 7:02 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] AW: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

Hello Ted, hello Regan,

Thank you for your clear statements on NRTL certification. Can you please 
provide some guidance on the interpretation of the National Electrical Code 
NFPA 70 (2020 edition), article 110.3, on the suitability of installation and 
use in conformity with the NEC? Informational note no. 2 explains, that this 
suitability “may” be evidenced by listing or labelling. Informative Annex A 
“provides a list of product safety standards used for product listing where 
that listing is required by the NEC.” This lists includes many product safety 
standards for consumer products like appliances that are typically plug 
connected. In the case that the NEC has been adopted by local jurisdiction and 
that the equipment is in the scope of a product safety standard listed in Annex 
A, is NRTL certification and listing then a mandatory requirement, or is there 
another option (e.g. self-declaration of the manufacturer that the product is 
suitable for installation and use in conformity with the NEC) that is accepted 
both by jurisdiction and the market?

Thank you and kind regards,

Bernd

Von: Regan Arndt mailto:reganar...@gmail.com>>
Gesendet: Dienstag, 18. Februar 2020 18:01
An: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Betreff: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

OSHA & the related NRTL mandatory certification is only for the 
commercial/office/industrial workplace. OSHA has no jurisdiction in the 
consumer environment.
The FCC is for both environments.

Regan

On Mon, Feb 17, 2020, 8:29 PM 
<06cee064502d-dmarc-requ...@ieee.org<mailto:06cee064502d-dmarc-requ...@ieee.org>>
 wrote:
Thank you Ted, Rich and Regan,

The product is classified as IT and is sold to pro market. i.e it is used by 
professional and not consumer market. There two types of products. Class I as 
well as Class III. They are mainly used in corporation conference rooms.

With that in mind, what are your thoughts about mandatory NRTL certification as 
well as FCC?

Thanks
Peter
-Original Message-
From: Ted Eckert 
<07cf6ebeab9d-dmarc-requ...@ieee.org<mailto:07cf6ebeab9d-dmarc-requ...@ieee.org>>
To: EMC-PSTC mailto:EMC-PSTC@LISTSERV.IEEE.ORG>>
Sent: Mon, Feb 17, 2020 6:16 pm
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification
Hello Peter,

Let me add to Rich and Regan’s comments.

The question for residential installations isn’t as clear as for the workplace. 
Most jurisdictions in the United States have adopted the National Electrical 
Code which requires many electrical and electronic products to either be Listed 
or to be investigated and approved by the local Authority Having Jurisdiction. 
In practice, this typically will apply to hard-wired products or products 
attached to building structure. The enforcement is typically through an 
electrical inspection which will often not cover plug-connected devices.

In the workplace, any product that has a direct connection to the mains will 
need NRTL approval. At the other end of the spectrum, a product like a USB 
mouse or remote control using alkaline batteries likely won’t need NRTL 
approval. In theory, I believe an OSHA inspector could enforce the NRTL 
requirement on any electrical product, but that won’t necessarily be what 
happens in practice.

That being said, you can choose not to get NRTL approval for your product. 
However, you need to understand the risks your product may pose. If you sell 
products to commercial customers, are you meeting their needs? Will your 
products be acceptable to them? If you have a low-voltage dev

Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

[Nyffenegger, Dave]

Bernd,

I don’t know any jurisdiction that would accept a manufacturer self-declaration 
if the jurisdiction is requiring a safety certification.  An alternative to an 
NRTL listing is an NRTL field inspection/label which is unique to each product 
at each  installation.

-Dave

From: Dürrer Bernd [mailto:bernd.duer...@wilo.com]
Sent: Wednesday, February 19, 2020 10:02 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] AW: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

Hello Ted, hello Regan,

Thank you for your clear statements on NRTL certification. Can you please 
provide some guidance on the interpretation of the National Electrical Code 
NFPA 70 (2020 edition), article 110.3, on the suitability of installation and 
use in conformity with the NEC? Informational note no. 2 explains, that this 
suitability “may” be evidenced by listing or labelling. Informative Annex A 
“provides a list of product safety standards used for product listing where 
that listing is required by the NEC.” This lists includes many product safety 
standards for consumer products like appliances that are typically plug 
connected. In the case that the NEC has been adopted by local jurisdiction and 
that the equipment is in the scope of a product safety standard listed in Annex 
A, is NRTL certification and listing then a mandatory requirement, or is there 
another option (e.g. self-declaration of the manufacturer that the product is 
suitable for installation and use in conformity with the NEC) that is accepted 
both by jurisdiction and the market?

Thank you and kind regards,

Bernd

Von: Regan Arndt 
Gesendet: Dienstag, 18. Februar 2020 18:01
An: EMC-PSTC@LISTSERV.IEEE.ORG
Betreff: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

OSHA & the related NRTL mandatory certification is only for the 
commercial/office/industrial workplace. OSHA has no jurisdiction in the 
consumer environment.
The FCC is for both environments.

Regan

On Mon, Feb 17, 2020, 8:29 PM 
<06cee064502d-dmarc-requ...@ieee.org<mailto:06cee064502d-dmarc-requ...@ieee.org>>
 wrote:
Thank you Ted, Rich and Regan,

The product is classified as IT and is sold to pro market. i.e it is used by 
professional and not consumer market. There two types of products. Class I as 
well as Class III. They are mainly used in corporation conference rooms.

With that in mind, what are your thoughts about mandatory NRTL certification as 
well as FCC?

Thanks
Peter
-Original Message-
From: Ted Eckert 
<07cf6ebeab9d-dmarc-requ...@ieee.org<mailto:07cf6ebeab9d-dmarc-requ...@ieee.org>>
To: EMC-PSTC mailto:EMC-PSTC@LISTSERV.IEEE.ORG>>
Sent: Mon, Feb 17, 2020 6:16 pm
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification
Hello Peter,

Let me add to Rich and Regan’s comments.

The question for residential installations isn’t as clear as for the workplace. 
Most jurisdictions in the United States have adopted the National Electrical 
Code which requires many electrical and electronic products to either be Listed 
or to be investigated and approved by the local Authority Having Jurisdiction. 
In practice, this typically will apply to hard-wired products or products 
attached to building structure. The enforcement is typically through an 
electrical inspection which will often not cover plug-connected devices.

In the workplace, any product that has a direct connection to the mains will 
need NRTL approval. At the other end of the spectrum, a product like a USB 
mouse or remote control using alkaline batteries likely won’t need NRTL 
approval. In theory, I believe an OSHA inspector could enforce the NRTL 
requirement on any electrical product, but that won’t necessarily be what 
happens in practice.

That being said, you can choose not to get NRTL approval for your product. 
However, you need to understand the risks your product may pose. If you sell 
products to commercial customers, are you meeting their needs? Will your 
products be acceptable to them? If you have a low-voltage device that isn’t 
mains connected, you will need to understand your customer’s needs before you 
make any determination about skipping NRTL approval.

Let’s use the USB mouse example. If you sell a USB mouse that has no NRTL 
approval, you can state that you are selling a product to the general public 
for home use where NRTL approval for a mouse is clearly not required. You can 
then argue that any business that purchases it is making their own decision on 
whether to accept a non-NRTL product. However, it is up to you, your employer 
and your employer’s legal department on whether you should take this approach.

Ted Eckert
The opinions expressed do not necessarily reflect those of my employer, OSHA or 
the U.S. Department of Labor.

From: Richard Nute mailto:ri...@ieee.org>>
Sent: Monday, February 17, 2020 3:52 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [EXTERNAL] Re: [PSES] Mandato

[PSES] AW: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

[Dürrer Bernd]

Hello Ted, hello Regan,

Thank you for your clear statements on NRTL certification. Can you please 
provide some guidance on the interpretation of the National Electrical Code 
NFPA 70 (2020 edition), article 110.3, on the suitability of installation and 
use in conformity with the NEC? Informational note no. 2 explains, that this 
suitability “may” be evidenced by listing or labelling. Informative Annex A 
“provides a list of product safety standards used for product listing where 
that listing is required by the NEC.” This lists includes many product safety 
standards for consumer products like appliances that are typically plug 
connected. In the case that the NEC has been adopted by local jurisdiction and 
that the equipment is in the scope of a product safety standard listed in Annex 
A, is NRTL certification and listing then a mandatory requirement, or is there 
another option (e.g. self-declaration of the manufacturer that the product is 
suitable for installation and use in conformity with the NEC) that is accepted 
both by jurisdiction and the market?

Thank you and kind regards,

Bernd

Von: Regan Arndt 
Gesendet: Dienstag, 18. Februar 2020 18:01
An: EMC-PSTC@LISTSERV.IEEE.ORG
Betreff: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

OSHA & the related NRTL mandatory certification is only for the 
commercial/office/industrial workplace. OSHA has no jurisdiction in the 
consumer environment.
The FCC is for both environments.

Regan

On Mon, Feb 17, 2020, 8:29 PM 
<06cee064502d-dmarc-requ...@ieee.org<mailto:06cee064502d-dmarc-requ...@ieee.org>>
 wrote:
Thank you Ted, Rich and Regan,

The product is classified as IT and is sold to pro market. i.e it is used by 
professional and not consumer market. There two types of products. Class I as 
well as Class III. They are mainly used in corporation conference rooms.

With that in mind, what are your thoughts about mandatory NRTL certification as 
well as FCC?

Thanks
Peter
-Original Message-
From: Ted Eckert 
<07cf6ebeab9d-dmarc-requ...@ieee.org<mailto:07cf6ebeab9d-dmarc-requ...@ieee.org>>
To: EMC-PSTC mailto:EMC-PSTC@LISTSERV.IEEE.ORG>>
Sent: Mon, Feb 17, 2020 6:16 pm
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification
Hello Peter,

Let me add to Rich and Regan’s comments.

The question for residential installations isn’t as clear as for the workplace. 
Most jurisdictions in the United States have adopted the National Electrical 
Code which requires many electrical and electronic products to either be Listed 
or to be investigated and approved by the local Authority Having Jurisdiction. 
In practice, this typically will apply to hard-wired products or products 
attached to building structure. The enforcement is typically through an 
electrical inspection which will often not cover plug-connected devices.

In the workplace, any product that has a direct connection to the mains will 
need NRTL approval. At the other end of the spectrum, a product like a USB 
mouse or remote control using alkaline batteries likely won’t need NRTL 
approval. In theory, I believe an OSHA inspector could enforce the NRTL 
requirement on any electrical product, but that won’t necessarily be what 
happens in practice.

That being said, you can choose not to get NRTL approval for your product. 
However, you need to understand the risks your product may pose. If you sell 
products to commercial customers, are you meeting their needs? Will your 
products be acceptable to them? If you have a low-voltage device that isn’t 
mains connected, you will need to understand your customer’s needs before you 
make any determination about skipping NRTL approval.

Let’s use the USB mouse example. If you sell a USB mouse that has no NRTL 
approval, you can state that you are selling a product to the general public 
for home use where NRTL approval for a mouse is clearly not required. You can 
then argue that any business that purchases it is making their own decision on 
whether to accept a non-NRTL product. However, it is up to you, your employer 
and your employer’s legal department on whether you should take this approach.

Ted Eckert
The opinions expressed do not necessarily reflect those of my employer, OSHA or 
the U.S. Department of Labor.

From: Richard Nute mailto:ri...@ieee.org>>
Sent: Monday, February 17, 2020 3:52 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [EXTERNAL] Re: [PSES] Mandatory certification


Hi Peter:

I can only speak to NRTL certification.

If your product can be used in a workplace, then NRTL certification is 
mandatory.

In most non-workplace locations, safety certification is mandatory.  A local 
authority specifies the acceptable certification houses.  Most local 
authorities specify the NRTL certification houses.

Certification by a NRTL certification house is accepted almos

Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

[Regan Arndt]

OSHA & the related NRTL mandatory certification is only for the
commercial/office/industrial workplace. OSHA has no jurisdiction in the
consumer environment.
The FCC is for both environments.

Regan


On Mon, Feb 17, 2020, 8:29 PM <06cee064502d-dmarc-requ...@ieee.org>
wrote:

> Thank you Ted, Rich and Regan,
>
> The product is classified as IT and is sold to pro market. i.e it is used
> by professional and not consumer market. There two types of products. Class
> I as well as Class III. They are mainly used in corporation conference
> rooms.
>
> With that in mind, what are your thoughts about mandatory NRTL
> certification as well as FCC?
>
> Thanks
> Peter
>
> -Original Message-
> From: Ted Eckert <07cf6ebeab9d-dmarc-requ...@ieee.org>
> To: EMC-PSTC 
> Sent: Mon, Feb 17, 2020 6:16 pm
> Subject: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification
>
> Hello Peter,
>
> Let me add to Rich and Regan’s comments.
>
> The question for residential installations isn’t as clear as for the
> workplace. Most jurisdictions in the United States have adopted the
> National Electrical Code which requires many electrical and electronic
> products to either be Listed or to be investigated and approved by the
> local Authority Having Jurisdiction. In practice, this typically will apply
> to hard-wired products or products attached to building structure. The
> enforcement is typically through an electrical inspection which will often
> not cover plug-connected devices.
>
> In the workplace, any product that has a direct connection to the mains
> will need NRTL approval. At the other end of the spectrum, a product like a
> USB mouse or remote control using alkaline batteries likely won’t need NRTL
> approval. In theory, I believe an OSHA inspector could enforce the NRTL
> requirement on any electrical product, but that won’t necessarily be what
> happens in practice.
>
> That being said, you can choose not to get NRTL approval for your product.
> However, you need to understand the risks your product may pose. If you
> sell products to commercial customers, are you meeting their needs? Will
> your products be acceptable to them? If you have a low-voltage device that
> isn’t mains connected, you will need to understand your customer’s needs
> before you make any determination about skipping NRTL approval.
>
> Let’s use the USB mouse example. If you sell a USB mouse that has no NRTL
> approval, you can state that you are selling a product to the general
> public for home use where NRTL approval for a mouse is clearly not
> required. You can then argue that any business that purchases it is making
> their own decision on whether to accept a non-NRTL product. However, it is
> up to you, your employer and your employer’s legal department on whether
> you should take this approach.
>
> Ted Eckert
> The opinions expressed do not necessarily reflect those of my employer,
> OSHA or the U.S. Department of Labor.
>
> *From:* Richard Nute 
> *Sent:* Monday, February 17, 2020 3:52 PM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [EXTERNAL] Re: [PSES] Mandatory certification
>
>
> Hi Peter:
>
> I can only speak to NRTL certification.
>
> If your product can be used in a workplace, then NRTL certification is
> mandatory.
>
> In most non-workplace locations, safety certification is mandatory.  A
> local authority specifies the acceptable certification houses.  Most local
> authorities specify the NRTL certification houses.
>
> Certification by a NRTL certification house is accepted almost universally
> in the USA.
>
> Best regards,
> Rich
>
>
> -
> 
> 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
> <https://nam06.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.ieee-pses.org%2Femc-pstc.html&data=02%7C01%7Cted.eckert%40microsoft.com%7C4ef9f645b43f44adca4a08d7b4046977%7C72f988bf86f141af91ab2d7cd011db47%7C0%7C0%7C637175803349145764&sdata=EdBJ6k%2FPdQeu60PsalDmtIEqa5PMzhzdo%2BkAhKJrtQE%3D&reserved=0>
> Attachments are not permitted but the IEEE PSES Online Communities site at
> http://product-compliance.oc.ieee.org/
> <https://nam06.safelinks.protection.outlook.com/?url=http%3A%2F%2Fproduct-compliance.oc.ieee.org%2F&data=02%7C01%7Cted.eckert%40microsoft.com%7C4ef9f645b43f44adca4a08d7b4046977%7C72f988bf86f141af91ab2d7cd011db47%7C0%7C0%7C637175803349155760&sdata=dwSfp%2BU9BFjw5pnaQjhpPd8v8miHM0uP91TewlVEu08

Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

[Jim Hulbert]

Compliance with FCC Rules Part 15 is required for any IT product sold to either 
consumers or professional users.  If your product contains a wireless 
communication function it will require FCC certification as an intentional 
radiator.  If it is not wireless, only verification is required.

Class I is powered by the AC mains, so NRTL is required because the device will 
be used in the workplace.   Class III products should technically be NRTL as 
well as Ted stated below, but it is up to you (business decision) as this would 
likely not be a focus of OSHA enforcement.

Jim Hulbert

From: 06cee064502d-dmarc-requ...@ieee.org 
[mailto:06cee064502d-dmarc-requ...@ieee.org]
Sent: Monday, February 17, 2020 11:29 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

Thank you Ted, Rich and Regan,

The product is classified as IT and is sold to pro market. i.e it is used by 
professional and not consumer market. There two types of products. Class I as 
well as Class III. They are mainly used in corporation conference rooms.

With that in mind, what are your thoughts about mandatory NRTL certification as 
well as FCC?

Thanks
Peter
-Original Message-
From: Ted Eckert 
<07cf6ebeab9d-dmarc-requ...@ieee.org<mailto:07cf6ebeab9d-dmarc-requ...@ieee.org>>
To: EMC-PSTC mailto:EMC-PSTC@LISTSERV.IEEE.ORG>>
Sent: Mon, Feb 17, 2020 6:16 pm
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification
Hello Peter,

Let me add to Rich and Regan’s comments.

The question for residential installations isn’t as clear as for the workplace. 
Most jurisdictions in the United States have adopted the National Electrical 
Code which requires many electrical and electronic products to either be Listed 
or to be investigated and approved by the local Authority Having Jurisdiction. 
In practice, this typically will apply to hard-wired products or products 
attached to building structure. The enforcement is typically through an 
electrical inspection which will often not cover plug-connected devices.

In the workplace, any product that has a direct connection to the mains will 
need NRTL approval. At the other end of the spectrum, a product like a USB 
mouse or remote control using alkaline batteries likely won’t need NRTL 
approval. In theory, I believe an OSHA inspector could enforce the NRTL 
requirement on any electrical product, but that won’t necessarily be what 
happens in practice.

That being said, you can choose not to get NRTL approval for your product. 
However, you need to understand the risks your product may pose. If you sell 
products to commercial customers, are you meeting their needs? Will your 
products be acceptable to them? If you have a low-voltage device that isn’t 
mains connected, you will need to understand your customer’s needs before you 
make any determination about skipping NRTL approval.

Let’s use the USB mouse example. If you sell a USB mouse that has no NRTL 
approval, you can state that you are selling a product to the general public 
for home use where NRTL approval for a mouse is clearly not required. You can 
then argue that any business that purchases it is making their own decision on 
whether to accept a non-NRTL product. However, it is up to you, your employer 
and your employer’s legal department on whether you should take this approach.

Ted Eckert
The opinions expressed do not necessarily reflect those of my employer, OSHA or 
the U.S. Department of Labor.

From: Richard Nute mailto:ri...@ieee.org>>
Sent: Monday, February 17, 2020 3:52 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [EXTERNAL] Re: [PSES] Mandatory certification


Hi Peter:

I can only speak to NRTL certification.

If your product can be used in a workplace, then NRTL certification is 
mandatory.

In most non-workplace locations, safety certification is mandatory.  A local 
authority specifies the acceptable certification houses.  Most local 
authorities specify the NRTL certification houses.

Certification by a NRTL certification house is accepted almost universally in 
the USA.

Best regards,
Rich


-

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 
mailto:emc-p...@ieee.org>>
All emc-pstc postings are archived and searchable on the web at: 
http://www.ieee-pses.org/emc-pstc.html<https://nam03.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.ieee-pses.org%2Femc-pstc.html&data=02%7C01%7CJim.Hulbert%40bluecrestinc.com%7Cc157be7982ea46e8bf5808d7b42b2104%7C8310f036fe8d4702a1e0177e9320227c%7C0%7C0%7C637175969656235377&sdata=9wXMjQPYKAQ4iZpm4D0aGi3H1BcQqSKv%2FxTv0iGqk0A%3D&reserved=0>
Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/<https

Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

[James Pawson (U3C)]

Hello Peter,

 

For the EMC/EMI side of things, I believe the table in CFR 47 15.101 
<https://www.ecfr.gov/cgi-bin/text-idx?SID=49e72efdc6ea3312ab830e537ec099c5&mc=true&node=se47.1.15_1101&rgn=div8>
  is the key. The Suppliers Declaration of Conformity (SDoC) path means no 
formal certification is required. You don’t even have to use an accredited test 
laboratory (you do for Certification).

 

The definition for SDoC is in 2.906 
<https://www.ecfr.gov/cgi-bin/text-idx?SID=ab2ffb5d72e50fb05cbcaf9fc5175e51&mc=true&node=se47.1.2_1906&rgn=div8>
  (more explanation in 2.1071 
<https://www.ecfr.gov/cgi-bin/retrieveECFR?gp=&SID=a0493712516ac8c884a822d7cc8b64a6&mc=true&n=sp47.1.2.j&r=SUBPART&ty=HTML#sg47.1.2_11060.sg5>
  onwards) and Certification in 2.907 
<https://www.ecfr.gov/cgi-bin/text-idx?SID=ab2ffb5d72e50fb05cbcaf9fc5175e51&mc=true&node=se47.1.2_1907&rgn=div8>
  (more explanation in 2.1031 
<https://www.ecfr.gov/cgi-bin/retrieveECFR?gp=&SID=a0493712516ac8c884a822d7cc8b64a6&mc=true&n=sp47.1.2.j&r=SUBPART&ty=HTML#sg47.1.2_11060.sg5>
  onwards).

 

Hope this is useful

All the best

James

 

 

 

James Pawson

EMC Problem Solver

 

Unit 3 Compliance

Design for EMC / Pre Compliance / Problem Solving / EMC Testing / Consultancy / 
Environmental & Vibration

 <http://www.unit3compliance.co.uk/> www.unit3compliance.co.uk -- 07811 139957

Opening Hours: Tuesday to Friday, 0830 to 1800. Closed Monday.

 

From: 06cee064502d-dmarc-requ...@ieee.org 
<06cee064502d-dmarc-requ...@ieee.org> 
Sent: 18 February 2020 04:29
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

 

Thank you Ted, Rich and Regan,

The product is classified as IT and is sold to pro market. i.e it is used by 
professional and not consumer market. There two types of products. Class I as 
well as Class III. They are mainly used in corporation conference rooms. 

 

With that in mind, what are your thoughts about mandatory NRTL certification as 
well as FCC?

 

Thanks

Peter

-Original Message-
From: Ted Eckert <07cf6ebeab9d-dmarc-requ...@ieee.org 
<mailto:07cf6ebeab9d-dmarc-requ...@ieee.org> >
To: EMC-PSTC mailto:EMC-PSTC@LISTSERV.IEEE.ORG> >
Sent: Mon, Feb 17, 2020 6:16 pm
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

Hello Peter,

 

Let me add to Rich and Regan’s comments.

 

The question for residential installations isn’t as clear as for the workplace. 
Most jurisdictions in the United States have adopted the National Electrical 
Code which requires many electrical and electronic products to either be Listed 
or to be investigated and approved by the local Authority Having Jurisdiction. 
In practice, this typically will apply to hard-wired products or products 
attached to building structure. The enforcement is typically through an 
electrical inspection which will often not cover plug-connected devices. 

 

In the workplace, any product that has a direct connection to the mains will 
need NRTL approval. At the other end of the spectrum, a product like a USB 
mouse or remote control using alkaline batteries likely won’t need NRTL 
approval. In theory, I believe an OSHA inspector could enforce the NRTL 
requirement on any electrical product, but that won’t necessarily be what 
happens in practice. 

 

That being said, you can choose not to get NRTL approval for your product. 
However, you need to understand the risks your product may pose. If you sell 
products to commercial customers, are you meeting their needs? Will your 
products be acceptable to them? If you have a low-voltage device that isn’t 
mains connected, you will need to understand your customer’s needs before you 
make any determination about skipping NRTL approval.

 

Let’s use the USB mouse example. If you sell a USB mouse that has no NRTL 
approval, you can state that you are selling a product to the general public 
for home use where NRTL approval for a mouse is clearly not required. You can 
then argue that any business that purchases it is making their own decision on 
whether to accept a non-NRTL product. However, it is up to you, your employer 
and your employer’s legal department on whether you should take this approach.

 

Ted Eckert

The opinions expressed do not necessarily reflect those of my employer, OSHA or 
the U.S. Department of Labor.

 

From: Richard Nute mailto:ri...@ieee.org> > 
Sent: Monday, February 17, 2020 3:52 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: [EXTERNAL] Re: [PSES] Mandatory certification

 

 

Hi Peter:

 

I can only speak to NRTL certification. 

 

If your product can be used in a workplace, then NRTL certification is 
mandatory.  

 

In most non-workplace locations, safety certification is mandatory.  A local 
authority specifies the acceptable ce

Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

[000006cee064502d-dmarc-request]

Thank you Ted, Rich and Regan,

The product is classified as IT and is sold to pro market. i.e it is used by 
professional and not consumer market. There two types of products. Class I as 
well as Class III. They are mainly used in corporation conference rooms.
With that in mind, what are your thoughts about mandatory NRTL certification as 
well as FCC?
ThanksPeter

-Original Message-
From: Ted Eckert <07cf6ebeab9d-dmarc-requ...@ieee.org>
To: EMC-PSTC 
Sent: Mon, Feb 17, 2020 6:16 pm
Subject: Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

#yiv5277480094 #yiv5277480094 -- _filtered {} _filtered {} #yiv5277480094 
#yiv5277480094 p.yiv5277480094MsoNormal, #yiv5277480094 
li.yiv5277480094MsoNormal, #yiv5277480094 div.yiv5277480094MsoNormal 
{margin:0in;margin-bottom:.0001pt;font-size:11.0pt;font-family:sans-serif;} 
#yiv5277480094 a:link, #yiv5277480094 span.yiv5277480094MsoHyperlink 
{color:blue;text-decoration:underline;} #yiv5277480094 
span.yiv5277480094EmailStyle20 {font-family:sans-serif;color:windowtext;} 
#yiv5277480094 .yiv5277480094MsoChpDefault {font-size:10.0pt;} _filtered {} 
#yiv5277480094 div.yiv5277480094WordSection1 {} #yiv5277480094 Hello Peter,    
Let me add to Rich and Regan’s comments.    The question for residential 
installations isn’t as clear as for the workplace. Most jurisdictions in the 
United States have adopted the National Electrical Code which requires many 
electrical and electronic products to either be Listed or to be investigated 
and approved by the local Authority Having Jurisdiction. In practice, this 
typically will apply to hard-wired products or products attached to building 
structure. The enforcement is typically through an electrical inspection which 
will often not cover plug-connected devices.     In the workplace, any product 
that has a direct connection to the mains will need NRTL approval. At the other 
end of the spectrum, a product like a USB mouse or remote control using 
alkaline batteries likely won’t need NRTL approval. In theory, I believe an 
OSHA inspector could enforce the NRTL requirement on any electrical product, 
but that won’t necessarily be what happens in practice.    That being said, you 
can choose not to get NRTL approval for your product. However, you need to 
understand the risks your product may pose. If you sell products to commercial 
customers, are you meeting their needs? Will your products be acceptable to 
them? If you have a low-voltage device that isn’t mains connected, you will 
need to understand your customer’s needs before you make any determination 
about skipping NRTL approval.    Let’s use the USB mouse example. If you sell a 
USB mouse that has no NRTL approval, you can state that you are selling a 
product to the general public for home use where NRTL approval for a mouse is 
clearly not required. You can then argue that any business that purchases it is 
making their own decision on whether to accept a non-NRTL product. However, it 
is up to you, your employer and your employer’s legal department on whether you 
should take this approach.    Ted Eckert The opinions expressed do not 
necessarily reflect those of my employer, OSHA or the U.S. Department of Labor. 
   From: Richard Nute  
Sent: Monday, February 17, 2020 3:52 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] Re: [PSES] Mandatory certification       Hi Peter:    I can 
only speak to NRTL certification.    If your product can be used in a 
workplace, then NRTL certification is mandatory.     In most non-workplace 
locations, safety certification is mandatory.  A local authority specifies the 
acceptable certification houses.  Most local authorities specify the NRTL 
certification houses.      Certification by a NRTL certification house is 
accepted almost universally in the USA.     Best regards, Rich       -
 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:
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Mike Cantwell   For policy questions, send mail to:
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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.htmlAttachmen

Re: [PSES] [EXTERNAL] Re: [PSES] Mandatory certification

[Ted Eckert]

Hello Peter,

Let me add to Rich and Regan’s comments.

The question for residential installations isn’t as clear as for the workplace. 
Most jurisdictions in the United States have adopted the National Electrical 
Code which requires many electrical and electronic products to either be Listed 
or to be investigated and approved by the local Authority Having Jurisdiction. 
In practice, this typically will apply to hard-wired products or products 
attached to building structure. The enforcement is typically through an 
electrical inspection which will often not cover plug-connected devices.

In the workplace, any product that has a direct connection to the mains will 
need NRTL approval. At the other end of the spectrum, a product like a USB 
mouse or remote control using alkaline batteries likely won’t need NRTL 
approval. In theory, I believe an OSHA inspector could enforce the NRTL 
requirement on any electrical product, but that won’t necessarily be what 
happens in practice.

That being said, you can choose not to get NRTL approval for your product. 
However, you need to understand the risks your product may pose. If you sell 
products to commercial customers, are you meeting their needs? Will your 
products be acceptable to them? If you have a low-voltage device that isn’t 
mains connected, you will need to understand your customer’s needs before you 
make any determination about skipping NRTL approval.

Let’s use the USB mouse example. If you sell a USB mouse that has no NRTL 
approval, you can state that you are selling a product to the general public 
for home use where NRTL approval for a mouse is clearly not required. You can 
then argue that any business that purchases it is making their own decision on 
whether to accept a non-NRTL product. However, it is up to you, your employer 
and your employer’s legal department on whether you should take this approach.

Ted Eckert
The opinions expressed do not necessarily reflect those of my employer, OSHA or 
the U.S. Department of Labor.

From: Richard Nute 
Sent: Monday, February 17, 2020 3:52 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] Re: [PSES] Mandatory certification


Hi Peter:

I can only speak to NRTL certification.

If your product can be used in a workplace, then NRTL certification is 
mandatory.

In most non-workplace locations, safety certification is mandatory.  A local 
authority specifies the acceptable certification houses.  Most local 
authorities specify the NRTL certification houses.

Certification by a NRTL certification house is accepted almost universally in 
the USA.

Best regards,
Rich


-


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 
mailto:emc-p...@ieee.org>>

All emc-pstc postings are archived and searchable on the web at: 
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Re: [PSES] Mandatory certification

[Richard Nute]

 

Hi Peter:

 

I can only speak to NRTL certification. 

 

If your product can be used in a workplace, then NRTL certification is 
mandatory.  

 

In most non-workplace locations, safety certification is mandatory.  A local 
authority specifies the acceptable certification houses.  Most local 
authorities specify the NRTL certification houses.  

 

Certification by a NRTL certification house is accepted almost universally in 
the USA.  

 

Best regards,

Rich

 

 


-

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:
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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:
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Mike Cantwell 

For policy questions, send mail to:
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David Heald: 

Re: [PSES] Mandatory certification

[Regan Arndt]

Hi Peter.
Here is a very good link on NRTL and requirements by OSHA:
*https://www.osha.gov/dts/shib/shib021610.html
*

As for the FCC, see this link, specifically subpart B
https://www.ecfr.gov/cgi-bin/text-idx?SID=c7be03a4f7b02514cea89421fc363794&mc=true&tpl=/ecfrbrowse/Title47/47cfr15_main_02.tpl


Hope this helps.

Regan


On Mon, Feb 17, 2020 at 3:25 PM <06cee064502d-dmarc-requ...@ieee.org>
wrote:

> Hello colleagues,
>
> I have a simple question. For an IT product that falls under 60950-1 and
> CISPR 32, do FCC and NRTL certification mandatory? I have always been under
> the impression that the when it comes to EMI/EMC, testing and
> certification/validation is mandatory but when it comes to product safety
> it is not but I am not 100% sure about my assumption. The product is
> unintentional radiator.
>
> Thanks
> Peter
> -
> 
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