Rich,
Like Doug, I've got to play the devil's advocate for a bit longer to ensure
I understand this issue once the dust settles.
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.
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.
I assume UL 1950 is about the same number ofpages. If the sections you cite
apply
to ITE (or any other electrical end product), where are the equivalent 180 pages
of construction requirements, including such things as leakage current and
creepage/clearance distances.
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.
Regards,
George Alspaugh
---------------------- Forwarded by George Alspaugh/Lex/Lexmark on 08/17/99
12:57 PM ---------------------------
richn%sdd.hp....@interlock.lexmark.com on 08/17/99 12:20:32 PM
To: George_Alspaugh/Lex/Lexmark@LEXMARK
cc: emc-pstc%majordomo.ieee....@interlock.lexmark.com
Subject: Re: U.S. National Product Safety "Laws"
Hi George:
> So here is the challenge. Can anyone "prove" that 29 CFR 1900
> or the NEC specifically requires ITE to meet more than some
> grounding/marking requirements, or be required to be approved by
> an NRTL. Proof is citing clearly stated sections obviously
> applicable to typical ITE products. Sorry, but vague references
> to something "I once saw....." are not allowed.
Here is the proof you requested. Note that the wordings for
"approval," "approved," and "equipment" of both OSHA and the
NEC are identical! I wonder how that happened? :-)
Best regards,
Rich
.......................................................................
OSHA:
=====
1910.303
(a) Approval. The conductors and equipment required or permitted
by this subpart shall be acceptable only if approved.
1910.399
(a) Definitions applicable to 1910.302 through 1910.330 -
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; 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,
and found in compliance with the provisions of the National
Electrical Code as applied in this subpart; or
(iii) With respect to custom-made equipment or related
installations which are designed, fabricated for, and intended
for use by a particular customer, if it is determined to be
safe for its intended use by its manufacturer on the basis of
test data which the employer keeps and makes available for
inspection to the Assistant Secretary and his authorized
representatives.
Refer to 1910.7 for definition of nationally recognized testing
laboratory.
Approved. Acceptable to the authority enforcing this subpart.
The authority enforcing this subpart is the Assistant Secretary
of Labor for Occupational Safety and Health. The definition of
"acceptable" indicates what is acceptable to the Assistant
Secretary of Labor, and therefore approved within the meaning of
this Subpart.
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.
.......................................................................
NEC:
====
110. Requirements for Electrical Installations.
110-2. Approval. The conductors and equipment required by this Code
shall be acceptable only if approved.
(FPN): See Examination of Equipment for Safety, Section 90-7,
and Examination Identification, INstallation, and Use of
Equipment, Section 110-3. See definitions of "Approved,"
"Identified," "Labeled," and "Listed."
100. Definitions.
Approved: Acceptable to the authority having jurisdiction.
Equipment: A general term including material, fittings,
devices, appliances, fixtures, apparatus, and the like used
as part of, or in connection with, an electrical installation.
.......................................................................
---------
This message is coming from the emc-pstc discussion list.
To cancel your subscription, send mail to majord...@ieee.org
with the single line: "unsubscribe emc-pstc" (without the
quotes). For help, send mail to ed.pr...@cubic.com,
jim_bac...@monarch.com, ri...@sdd.hp.com, or
roger.volgst...@compaq.com (the list administrators).
