Well, Rich,

I guess that's what happens when I start thinking (typing) too quickly. Oh 
well, I knew what I
wanted to say.

And, I sincerely thank you for this clarification and all of your always 
accurate emails and
thorough attention to details.

Best regards,

Ron Pickard
[email protected]




                                                                                
                                 
                    Rich Nute                                                   
                                 
                    <[email protected]        To:     [email protected]          
                                 
                    .com>                cc:     [email protected] 
(Product Safety Technical           
                                         Committee)                             
                                 
                    09/29/00             Subject:     Re: MRAs                  
                                 
                    02:24 PM                                                    
                                 
                                                                                
                                 
                                                                                
                                 



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.


Best regards,
Rich









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