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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