Doug,
>From my reading of 29 CFR 1910 I believe that it applies to all electrically
powered equipment, not only mains powered.
>From 1910.302(a) and (a)(1): Scope - Covered. The provisions of 1910.302
through 1910.308 of this subpart cover electrical installations and
utilization equipment (my italics) installed or used within or on buildings,
structures, and other premises....
And from 1910.399(a) Definitions applicable to 1910.302 through 1910.330:
Utilization Equipment: Utilization equipment means equipment which utilizes
electric energy for mechanical, chemical, heating, lighting, or similar
useful purpose.
Since it specifies that any equipment which uses electric energy is covered
I have taken this to mean that it also includes 24 and 48 VDC powered
equipment since it of course uses electric energy.
We have had 48VDC powered ITE equipment Listed using UL 1950. The scope of
1950 specifies any mains powered or battery powered equipment with an input
rating up to 600V. (There is no minimum voltage listed).
Kurt
-----Original Message-----
From: Doug [SMTP:[email protected]]
Sent: Saturday, September 30, 2000 1:40 PM
To: [email protected]
Subject: Re: MRAs
Rich Nute wrote:
>
> Hi Ron:
>
> > In the USA, NRTL safety approvals, thus NRTL safety marks, for
equipment intended for the commercial
> > environment, in fact, are required AND mandated through
legislation. This requirement is found in
> > the US's Code of Federal Regulations (29CFR Part 1910 Subpart
S) and is regulated by the US Dept. of
> > Labor (I'm not so sure about the requirements of products
intended for the residential environment).
> > With that being said, UL or other NRTL safety marks are also
required, however, it is up to the
> > manufacturer to decide which NRTL, therefore which NRTL mark,
to use.
>
> Be careful here.
>
> 1. NRTL "approval" is NOT mandated through
> legislation (see points 3 and 4 below).
>
> 2. NRTL certification is NOT for equipment intended
> for the commercial environment, but for equipment
> intended for use by employees in the workplace.
>
> 3. 29 CFR Part 1910, Subpart S applies to employers,
> not to equipment manufacturers.
>
> 4. Subpart S has two alternatives for employers:
>
> a) employees may use equipment with an NRTL mark,
>
> or
>
> b) employees may use equipment the employer has
> tested and found to be safe according to
> various safety codes.
>
> Clearly, the easy way for employers to comply is
> to only buy and use equipment that has an NRTL
> mark. (As manufacturers, it behooves us to obtain
> the voluntary -- for us -- NRTL mark.)
>
> 5. Products intended for all other environments are
> subject to the local electrical code, which
> generally is the NEC, which invokes "listing."
> As a general rule, NRTL certification satisfies
> "listing" under the local electrical code.
Actually, I believe the wording has to do with equipment
attached to mains voltages which restricts points #3, #4,
#5 even more. And this has made for some interesting
discussions concerning 48vdc central offices or 24vdc
cell sites which are isolated from the public mains.
And on another note, IMO, both the US and EC way of doing
product declarations are really the same. The declarations
in both American and European markets are done by the mfr.
- Doug
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