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."
Second, the text refers to "equipment" and to "utilization
equiipment," 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.
> 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.
Best regards,
Rich
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