Hi George:
I stand corrected. You can indeed bypass the NRTL if you can find a local occupational safety authority to pass on the product's safety. As a general rule, this is quite difficult to implement (i.e., to find an authority who is qualified and willing to investigate the details of a product). Often such authorities will defer to a test house such as an NRTL to come to the site to perform an one-time product investigation. Best regards, Rich > From [email protected] Wed Sep 16 13:03:38 PDT 1998 > Received: from hpsdlo.sdd.hp.com (hpsdlo.sdd.hp.com [15.255.160.64]) by > hpsdlfsg.sdd.hp.com with ESMTP (8.7.6/8.7.3 TIS 5.0/sdd epg) id NAA23788 for > <[email protected]>; Wed, 16 Sep 1998 13:03:37 -0700 (PDT) > Received: from ruebert.ieee.org (ruebert.ieee.org [199.172.136.3]) > by hpsdlo.sdd.hp.com (8.8.6/8.8.5tis+epg) with ESMTP id NAA00192; > Wed, 16 Sep 1998 13:03:34 -0700 (PDT) > Received: by ruebert.ieee.org (8.8.8/8.8.8) > id PAA16568 for emc-pstc-resent; Wed, 16 Sep 1998 15:24:32 -0400 (EDT) > From: [email protected] > Message-Id: <[email protected]> > X-Lotus-Fromdomain: LEXMARK@LEXMTA > To: [email protected] > Date: Wed, 16 Sep 1998 15:23:26 -0400 > Subject: Re: Query: US safety required for ITE? > Mime-Version: 1.0 > Content-Type: text/plain; charset=us-ascii > Content-Disposition: inline > Sender: [email protected] > Precedence: bulk > Reply-To: [email protected] > X-Resent-To: Multiple Recipients <[email protected]> > X-Listname: emc-pstc > X-Info: Help requests to [email protected] > X-Info: [Un]Subscribe requests to [email protected] > X-Moderator-Address: [email protected] > > Rich, > > I must differ with you on one point below. Refer to > 29 CFR 1910.399 (a)(ii). This is the section just past > the reference to NRTL acceptance cited below. > > In so many words, paragraph (ii) says that if the equipment > is not approved etc. by an NRTL, then it must be inspected > etc by a Federal, state, municipal, or other local > authority responsible for enforcing occupational safety. > > Again, the choice is (1) NRTL blessing, or (2) a beating > by the local authorities to get approval. OSHA does not > REQUIRE NRTL acceptance, but offers it as one alternative. > > George Alspaugh > Lexmark International > > ---------------------- Forwarded by George Alspaugh/Lex/Lexmark on 09/16/98 > 03:13 PM --------------------------- > > Rich Nute <richn%[email protected]> on 09/16/98 02:27:03 PM > > Please respond to Rich Nute <richn%[email protected]> > > To: ron_pickard%[email protected] > cc: emc-pstc%[email protected] (bcc: George > Alspaugh/Lex/Lexmark) > bcc: George Alspaugh/Lex/Lexmark > Subject: Re: Query: US safety required for ITE? > > > Hello from San Diego: > > Ron Pickard asks: > > ... what specific requirements are there that positively > and unequivicably require NRTL Listing... > > To my knowledge, there are two, independent sets of regulations > that require third-party safety certification: > > 1) OSHA (safety of electrical products in workplaces). > -requires NRTL certification. > > 2) NEC (safety of electrical products in installations). > -requires "listing" by a certification house determined > by the local code authority. > > > OSHA (Occupational Safety and Health Administration) > ----------------------------------------------------- > Ron has properly quoted the OSHA regulations: > > "Acceptable." An installation or equipment is acceptable to > the Assistant Secretary of Labor, and approved within the > meaning of this 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;" > > These two statements essentially and practically invoke NRTL > certification of electrical products (used in workplaces). > > > NEC (National Electrical Code) > ------------------------------- > "90-7. Examination of Equipment for Safety. > : > : > : > "It is the intent of this code that factory-installed internal > wiring or the construction of equipment need not be inspected > at the time of installation of the equipment, except to detect > alterations or damage, if the equipment has been listed by a > qualified electrical testing laboratory that is recognized as > having the facilities described above and that requires > suitability for installation in accordance with this Code." > > "110-2. Approval. The conductors and equipment required or > permitted by this Code shall be acceptable only if approved." > > "Approved: Acceptable to the authority having jurisdiction." > > "Listed: Equipment or materials included in a list published > by an organization acceptable to the authority having > jurisdiction and concerned with product evaluation, that > maintains periodic inspection of production of listed equipment > or matierals, and whose listing states either that the equipment > or matieral meets appropriate designated standards or has been > tested and found suitable for use in a specified manner." > > "Equipment: A general term including material, fittings, > devices, appliances, fixtures, apparatus, and the like used as a > part of, or in connection with, an electrical installation. > > The Code requires the city, county, or state building code authority > to identify the laboratories whose certification marks are acceptable > to them. In my experience, the various building code authorities > each have their own criteria for laboratories. The City of Los > Angeles not only accepts a number of independent laboratories, it > runs its own testing laboratory and certification program! (Nearby > municipalities accept City of Los Angeles certifications.) The > State of Oregon has its own set of criteria by which it accepts > laboratories. (It accepts labs that are not NRTLs.) > > So, there is no general "rule" that an NRTL is also accepted under > the NEC in a particular jurisdiction (i.e., city, county, or state.) > (However, most of us assume that this is the case.) > > > Best regards, > Rich > > ------------------------------------------------------------- > Richard Nute Product Safety Engineer > Hewlett-Packard Company Product Regulations Group > All-In-One Division Tel : +1 619 655 3329 > 16399 West Bernardo Drive FAX : +1 619 655 4979 > San Diego, California 92127 e-mail: [email protected] > ------------------------------------------------------------- > > > > --------- > This message is coming from the emc-pstc discussion list. > To cancel your subscription, send mail to [email protected] > with the single line: "unsubscribe emc-pstc" (without the > quotes). For help, send mail to [email protected], > [email protected], [email protected], or > [email protected] (the list administrators). > > --------- This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to [email protected] with the single line: "unsubscribe emc-pstc" (without the quotes). For help, send mail to [email protected], [email protected], [email protected], or [email protected] (the list administrators).
