To Rich et al (fancy way of saying "and others"):
I was a little reluctant to fan the embers of this discussion the other day,
but do not regret doing so based on the healthy discussion that followed. In
any event, I shall blame Doug's append for peaking my interest. I assume we
can all agree that:
1. We do not want to market unsafe products that may cause harm.
2. No one is looking for "loopholes" in the safety standards.
3. The NEC and OSHA requirements "probably" do apply to any
electrical device that is operated from voltages above SELV.
4. The NEC and OSHA requirements are worded like legal documents,
and thus, far from clear in their meaning.
Having said this, I have added some remarks (in brackets [ ] ) to your last
note below, hoping that these do not not extend the discussion, but are my
final thoughts.....
Best regards,
George Alspaugh
__________________________________________________________________________
Hi George:
> I've read these sections of the CFR many times, and always interpreted them
> to apply to end user equipment, as you imply. However, I am beginning to
see
> that this may be somewhat like quoting the Bible out of context. The
context
> in this section of the CFR (before and after) overwhelmingly refers to
"house"
> wiring types of equipment.
I don't agree that the text overwhelmingly refers to wiring
(i.e., in OSHA words, "utilization system").
First, it would be derelict of OSHA to ignore the utilization
equipment used by employees. One of the major construction
site hazards was failure of insulation in portable electric
tools. OSHA was the prime mover towards double-insulated
electric tools! While our government often makes mistakes,
they do NOT ignore "utilization equipment."
[I believe that there are a dozen ways "utilization equipment"
could be better stated to clarify the intended meaning. How about
"any electrical equipment, devices, appliances, and other products
that are connected to electrical power systems at voltages deemed
to be hazardous." Note that in homes and offices there are products
requiring 220V (e.g. air conditioners, dryers, heaters) in addition
to those operated from 115V.]
Second, the text refers to "equipment" and to "utilization
equipment," both of which are defined terms. The definitions
must be substituted EVERYWHERE the words appear in the text.
When I apply the definitions, I cannot conclude as you do that
the text refers "overwhelmingly" to wiring.
[I suggest if one goes to the cheapest discount store in their area,
and look at the table/floor lamps offered for sale, they will find
some with no NRTL markings. I will also suggest that these were NOT
approved by a Federal, state, or local government authority. Are
these "utilization equipment"? If so, how can they be offered for
sale?]
> Is it only me, or do others have problems reading into this that it does
apply
> to end user products such as ITE or blenders? With so many pages dedicated
to
> describing the exact requirements for the construction of an "installation"
to
> provide power to "equipment", why are there no pages dedicated to describing
the
> requirements of the "equipment"? IEC 60950 contains 180 pages of such
> requirements.
The OSHA standard for electrical "equipment" is that it be "approved."
"Approved" means "acceptable."
"Acceptable" has three definitions, one of which is certified
by an NRTL, one of which is testing to NEC provisions, and
one of which is testing by the manufacturer.
In this way, OSHA skirts having to publish individual product
safety standards. As near as I can tell, OSHA did this overtly
and after having thought it out rather extensively. OSHA
realized that it could NEVER cover all electrical products with
standards.
> Note that covered equipment (whatever that may be) can be acceptable by
virtue
> of the proper labelling/lisitng, or simply inspected and found to be safe by
> one of the referenced authorities. Several have pointed out that such
> authorities typically require a NRTL listing/marking. If your "proof" is to
be
> interpreted as you (and I) have been interpreting it, then every single
> electrical device sold in the U.S. would HAVE to have an NRTL marking. I
know
> that a few years ago we were using internal PCs that bore no such markings.
> I will not mention the brand name here. I suspect that one could find many
> electrical products under $10 that do not display such markings either.
Yes, ALL electrical equipment used by employees in the workplace
must be "approved" (which means "acceptable" by one of the three
definitions).
(Obviously, OSHA ignores low-voltage and battery-operated equipment
such as flashlights and calculators. I haven't located the "out"
for these kinds of equipments.)
If an OSHA inspector should find an electrical product that is not
certified by an NRTL, I'm sure the employer will be notified!
You can, of course, ask OSHA if the standards apply to ITE. I have
no doubt of the answer. [I would tend to agree. It is the wording
used, rather than the intent of, the NEC/OSHA requirements that lead
to such debates.]
Best regards,
Rich
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