Well, my two cents says that it's not ONLY the voltage 
supply that decides safety by third parties.  The safety 
effort we go through tests for hazards and shocks 
(all types): electrical, flame (really important), chemical, 
mechanical, ... to the end user.  

I would ask how and why your people are absolutely 
certain the testing is unnecessary? 

If there were some accident in the workplace with the 
product, God forbid, would your people be willing to 
have the finger pointed at them for selling untested 
equipment?   I think a previous incident years ago 
with a central office in Chicago burning down is a 
prime example. 

And don't get into 1910.399 making it the only 
requirement for testing product because I believe 
it covers only that which has to get connected to 
the mains, i.e. that which requires an electrician to 
connect, if you read it to the absolute letter.  Pluggable 
or battery powered equipment gets more sticky with 
1910.399.  Be careful going down that road. 

OTOH, there have been some cases where successful 
NRTL safety testing didn't make a hill of beans during 
litigation.  But that was a case of deep pockets.  No, 
I'm not a liberty to say which company it was but I'm 
willing to bet it wasn't the only one. 

- Doug McKean 



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