George,

To add to your statements;---  

It is not just cities that may require NRTL marking on equipment, but also
the insurance carriers of the various businesses where the equipment is
installed.   In many cities the Fire Department inspects for NRTL markings
on business premises; they don't normally do this in homes.

Also, the city codes may include (and usually do) equipment installed in
business locations, not just for the home consumer.   After all they might
be held liable for poor plumbing and electrical installations, and they
don't want to be held liable.
  
Tania Grant,   tgr...@lucent.com <tgr...@lucent.com>  
Lucent Technologies, Communications Applications Group


----------
From:  geor...@lexmark.com [SMTP:geor...@lexmark.com]
Sent:  Monday, August 16, 1999 2:07 PM
To:  emc-p...@majordomo.ieee.org
Subject:  U.S. National Product Safety "Laws"


Here is my understanding of this issue relative to ITE.  I post this both
to inform, and solicit comments which could improve my understanding.

The only U.S. Federal law I am aware of pertaining to product safety is
that covered in 29 CFR 1900 (the OSHA section).  Electrical equipment
to be used in the U.S. workplace must either (1) comply with a detailed
list of construction requirements, or (2) be "accepted, certified, listed,
labelled, or otherwise determined to be safe by a nationally recognized
testing laboratory" [29 CFR 1900.399 (a) (ii)].  There are seventeen OSHA
approved NRTLs, half of which can test to UL 1950.

Summary:  For workplace ITE, an NRTL certification is the easiest option.
Note that this is an option, not the only path.  Note also that UL and
other NRTLs are private companies, not U.S. government agencies.

What about non-workplace ITE for consumers?  These are outside the OSHA
requirements.  Some of the major cities in the U.S. (e.g. New York, Los
Angeles, Chicago) have local electrical codes that include the electrical
requirements for household eletrical equipment.  However, these are usually
in the absence of any NRTL listing, which is generally acceptable.

Summary:  Again, an NRTL certification is the easiest path to market home
electrical products in all parts of the U.S.

One CAN find electrical products on the market that bear no agency markings
that are being sold in ways that do not conform to OSHA requirements or city
electrical codes.  However, these tend to be very cheap low end products
like Christmas lighting, extension cords, etc.

The Consumer Products Safety Commission (CPSC) is a Federal agency.  It does
not establish product safety requirements.  However, its mission is to
identify
and remove from the marketplace any products found prone to expose hazards.
It is an "after-the-fact" enforcement agency that can apply pressure for a
a product recall.

Moral:  A manufacturer can either negotiate the "mine field" of specific
OSHA (for workplace) or city (for home use) electrical requirements, or go
with an NRTL certification.

George Alspaugh
Corporate Product Safety
Lexmark International Inc.



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