Thanks for the input on the interpretations from OSHA.
I went out to the WEB site and took a look at some of the letters concerning
"approved" equipment.
The first thing that suprised me was the broad brush strokes that OSHA takes
with this standard.
I am still wondering why the NEC code panel did not clarify the definition of
utilization equipment by defining it as
"all equipment which utilizes electric energy". This should pretty much cover
it.
In the first interpretation it is written
"All electrical equipment, except those kinds which no NRTL accepts, certifies,
lists, labels, or otherwise detemines
safe, must be "approved", as that term is defined at 29 CFR 1910.399. Except as
indicated in the following this
means that a NRTL must accept,certify,label,list, or otherwise detemine the
equipment is safe for it to be considered
"approved"....
Now this sounds like what the NEC code panel meant. However, it is not what 29
CFR says. Do these
"interpretations" supersede the CFR because this seems to be more than an
interpretation?
It also appears that it is up to the NRTLs to detemine what is approved and not
approved by "accepting..." a
piece of equipment. I know a lot a listeners belong to this group. How many
NRTL's could not find a safety"spec"
for a piece of electrical equipment? If they don't have one, why not make one
up? This just seems a little
suspicious to me.
The altenative for "unapproved" equipment is discussed later in the letter. This
essentially leaves it up to a Federal
Agency or State, municipal or other local athority for enforcing the
occupational safety provisions of the NEC ...
I suspect that many of the "specs" that the NRTLs use are much broader than the
provisions of the NEC. I am not
yet familar with these provisions but do they include such things as quarterly
audits, recertification,
notification of changes.... ?
In another letter, a slightly different approach is taken for a computer. The
computer used in the work place is
actually considered an "appliance". Appliances are then defined in 1910.399 as
utilization equipment such as a
clothes washer, air conditioner, food mixer, deep fryer, etc... .
In general, I understand the intent is to protect the persons using the
equipment. However, this type of equipment
is generally used to perform some job function by the worker(therefore
categorizing the computer as an appliance).
This makes sense. . However, there is equipment that is not "used" to perform
job functions.
The following example is not great but maybe somebody else can think of
something bettter. Lets say there is clock installed
on the wall with a removeable power cord. Its only purpose is for visual
indication of the time. It has been constructed
and installed according to the NEC provisions. Why does a NRTL need to approve
it?. The installation will still need to be inspected by a local authority to
determine if it was installed properly. Hmmmm
I imagine that sooner or latert 29 CFR will be updated to reflect the
proliferation of electronic equipment in our
work place. It just seems like a big jump from NEC to an NRTL "label" to
ensure safety in the work place. What about self declaration like CE?. It is
much easier(at least cheaper) to maintain a TCF internally than to coordinate
periodic audits.
And then there is liability... (maybe another time)
JIm Stafford
HPS
Product Engineer
{ these comments do not necessarily reflect the views of my employer}
