RE: Value of Using Non-NRTL Engineering Firms? no attachment
Question from Chris - Just looking for a quick statement on the Value of using a Non-NRTL firm for testing and/or certification (Listing). In my opinion If you're just building one or two then the answer might be non-NRTL, depends on cost and time - just get the local jurisdiction's approval. If you're building lots of them and they go in more than one location I'd say NRTL. You only have to do it once. If you would like to sell it as a component or subsystem to others NRTL - unless you have the only one and I need it desperately I would pick the competition who did have the approvals from a NRTL. Gary --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
Value of Using Non-NRTL Engineering Firms? no attachment
Reposting without attachment. Sorry group I'll get the hang of it. For those who have provided response to date, thanks much I wrote - We are working some responses to OSHA and would like to ask for some industry response from the Product Safety group (EMC welcome to respond too). Just looking for a quick statement on the Value of using a Non-NRTL firm for testing and/or certification (Listing). Statement: Non-NRTL laboratories can provide Listings and publish the customers (thus Listing). However, based on OSHA law, NEC requirements, Retailer specification, and other MOU/MRA with Canada/EU, it would not seem to be a significant accomplishment to be Listed or Labeled by a non-NRTL. In a quick paragraph, would you provide your opinion on the value of a Non-NRTL Listing Certification. Thanks Much Chris The following is from Richard Fairfax (reply to one of 4 questions) - OSHA's Director Directorate of Compliance Programs which states that Electrical products in the workplace must be Listed or Labeled by an NRTL to meet OSHA Law. Question 4: Do items identified in 1 through 3 above make the machine non-compliant with OSHA, NEC or both? As defined at 29 CFR 1910.399(a)(1) an installation or equipment is acceptable to the Assistant Secretary of Labor, and approved within the meaning of Subpart S: (i) If it is accepted, or certified, or listed, or labeled, or otherwise determined to be safe by a nationally recognized testing laboratory (NRTL); or (ii) With respect to an installation or equipment of a kind which 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 (NEC) and found in compliance with the provisions of National Electrical Code as applied in this subpart. Therefore equipment must be listed, labeled, or certified by a NRTL. As we understand the conversation of my staff and you, the equipment was not certified by NRTL, it is a violation of OSHA standard 1910.399 (a)(1). To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov. If you have any further questions, please feel free to contact the Office of General Industry Compliance Assistance at (202) 693-1850. Sincerely, Richard E. Fairfax, Director Directorate of Compliance Programs cc: Regional Administrator, Region II --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
Re: Value of Using Non-NRTL Engineering Firms?
Hi Chris: OSHA rules apply to employers. OSHA electrical rules require employers (1) to use only electrical products that have been certified by an NRTL, or (2) in the case of custom products, to test the product in place. If you sell a non-NRTL-certified custom product to an employer who is subject to OSHA rules, then that employer must test the product in place, and file a suitable record of the testing. Few employers choose the test-in-place alternative. A listing by a non-NRTL is useless to an employer subject to OSHA rules. He can't use it for proof that the product meets OSHA rules. At the employer's discretion, you may be able to convince the employer (your customer) that your listing test report will provide a suitable record of testing to OSHA requirements. See OSHA rules, Sub-part S for complete treatment on OSHA electrical rules. See especially 1910.303(a) Approval and the respective definitions. http://www.osha.gov/pls/oshaweb/owastand.display_standard_group?p_toc_level=1p_part_number=1910p_text_version=FALSE Statement: Non-NRTL laboratories can provide Listings and publish the customers (thus Listing) however, based OSHA law, NEC requirements, Retailer specification, and other MOU/MRA with Canada/EU, it would not seem to be a significant accomplishment if not an NRTL. Except for NEC, I would agree with this statement. Best regards, Rich --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: Value of Using Non-NRTL Engineering Firms?
Chris - On the basis of workplace safety, listing by a nonNRTL is largely useless. On the other hand, if the persons providing the listing are a competent engineering firm, using licensed engineers, there may be some credibility to the listing (for instance, the NEC allows waivers of certain requirements, if the installation is under the supervision of a licensed engineer), though it still falls short of the cited bureaucratic dictum. Keep in mind, that butting heads with OSHA will probably only give you a headache. I note that the OSHA response you provided left out 29 CFR §1910.399 (iii), for custom equipment. In this case, an NRTL might not be required. You make no claims that the equipment is custom built and the conspicuous absence of a reference to 29 CFR §1910.399 (iii) in the Director's letter leads me to believe it is not custom built equipment. Hair splitting: OSHA does not create law; only Congress can do so. OSHA's charter from Congress, however, states that it's regulations have the power of law, so there's not much practical difference. Regards, Peter L. Tarver, PE Product Safety Manager Sanmina-SCI Homologation Services San Jose, CA peter.tar...@sanmina-sci.com From: me...@aol.com We are working some responses to OSHA and would like to ask for some industry response from the Product Safety group (EMC welcome to respond too). Just looking for a quick statement on the Value of using a Non-NRTL firm for testing and/or certification (Listing). Statement: Non-NRTL laboratories can provide Listings and publish the customers (thus Listing) however, based OSHA law, NEC requirements, Retailer specification, and other MOU/MRA with Canada/EU, it would not seem to be a significant accomplishment if not an NRTL. In a quick paragraph, would you provide your opinion on the value of a Non-NRTL Listing Certification. Thanks Much Chris PS: Attached is a pdf from Richard Fairfax - OSHA's Director Directorate of Compliance Programs which states that Electrical products in the workplace must be Listed or Labeled by an NRTL to meet OSHA Law. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
Value of Using Non-NRTL Engineering Firms?
Chris asks: In a quick paragraph, would you provide your opinion on the value of a Non-NRTL Listing Certification. Hard to talk about value in such general terms, when the neither the product nor the application is known. However, a few reactions come to mind: 1. UL was a non-NRTL Listing provider for the first 85 years of its existence. Obviously a third party certification organization can provide value to first and second parties in the absence of government accreditation programs. 2. There are 3rd party listing programs for many products or functions under which there is no NRTL accreditation program applicable. Obviously, there is value in listing in these areas also. 3. Not all NRTL laboratories are equally regarded by authorities or by the market - so NRTL accreditation is not the sole basis, nor is it always the primary basis for determining the value of a listing. 4. In its strictest sense, the NRTL accreditation applies to workplace requirements and certain installation codes. In all other applications for electrical products, including household consumer appliances and electronics, there is no legal requirement for NRTL listing, and I'm not clear on whether NRTL based listing would provide any advantage over non-NRTL based listing in the case of a liability suit. I suspect not. I suspect also that if a household consumer of electrical products is concerned about listing, they are looking at certifcation brands, and have little or no understanding of what an NRTL designation is. 5. Having said all of the above, it always behooves a manufacturer to use an NRTL certifier if one is available. My opinions. Greg Galluccio www.productapprovals.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
Re: Value of Using Non-NRTL Engineering Firms?
Hello Again Group, There are several documents available from OSHA's site. Attached is another pdf from OSHA dated 1993 to show more history of OSHA requirements/laws... This letter defines the term approved which is used in several 29CRF documents and also used in the NEC. Again, OSHA confirms must be approved and explains approved can only be findings from an NRTL. Just another document I located. thanks group for your help Chris All electrical equipment must be approved.pdf Description: All electrical equipment must be approved.pdf
Value of Using Non-NRTL Engineering Firms?
We are working some responses to OSHA and would like to ask for some industry response from the Product Safety group (EMC welcome to respond too). Just looking for a quick statement on the Value of using a Non-NRTL firm for testing and/or certification (Listing). Statement: Non-NRTL laboratories can provide Listings and publish the customers (thus Listing) however, based OSHA law, NEC requirements, Retailer specification, and other MOU/MRA with Canada/EU, it would not seem to be a significant accomplishment if not an NRTL. In a quick paragraph, would you provide your opinion on the value of a Non-NRTL Listing Certification. Thanks Much Chris PS: Attached is a pdf from Richard Fairfax - OSHA's Director Directorate of Compliance Programs which states that Electrical products in the workplace must be Listed or Labeled by an NRTL to meet OSHA Law. US DOL Requirements.pdf Description: US DOL Requirements.pdf
