Ken,
I couldn't disagree with you more. As a Professional Engineer in Oregon who previously worked for an NRTL, I can assure you that the current state law does not permit individual PE's to field label equipment - nor has it ever, to my knowledge. Equipment approval activity is limited specifically to labs approved by the state of Oregon. If there is a PE not associated with a state-approved lab that is conducting this work, I would doubt whether it met the requirement of the current law. Intel, Weyerhaeuser and others have argued unsuccessfully for this approach for years. With regard to the original question, NRTL approval (through OSHA) is a first line approval for most of the larger labs. While it may be possible to obtain approval with some jurisdictions without NRTL status, I would be cautious about working with such a lab. NRTL approval can then generally be leveraged to obtain approvals in specific jurisdictions. Some jurisdictions accept the Federal NRTL designation as sufficient for approving products in their area (some, such as Texas, have little oversight of such activity in any case). Others, like Oregon and North Carolina, as well as probably the cities of Los Angeles and Chicago require labs to meet additional requirements, as well as support periodic audits of their activity in the jurisdiction. Even within Oregon, however, the playing field is not perfectly level in the application of the requirement for existing law. The Portland Metropolitan area sees far more enforcement of these requirements than the rural, southeast corner of the state, for instance. This may mean that in addition to issues where the equipment can be installed in a facility in Austin, TX without further evaluation, while Portland, OR may require it, you also have the potential of installing a system in a community within Oregon where these requirements are not universally applied, while you will still run into difficulty within Portland (one of the most consistent jurisdictions in the application of these requirements). In the case of the equipment referenced by Mr. Selva, I would encourage him to obtain the list of labs currently approved by the State of Oregon. This can be obtained on their website ( http://www.cbs.state.or.us/external/bcd/tag/advisory/fieldevalfirms.pdf). This document contains both the list of labs - for listing - and field evaluation firms that are approved by the state. You will note that there are no individuals, such as PE's listed in this document. The engineering firm Edan Engineering is the closest to this mark, but I believe you will find that their pricing will be similar to the other firms and that their activities follow the same requirements placed by state law. Products listed by an approved lab are generally accepted as long as they carry the listing mark from the lab. Products that have already left the manufacturer's site without a listing mark will be required to be field labeled. Recognize that labs are approved for different categories of equipment, so the correct category will have to be approved for the lab that is selected to perform the work. In short, however, I would encourage you to visit the website in question and select the lab to perform this work with extreme care. As someone who has worked in this field for ten years (and is now on the other side of things as the manufacturer), it is very easy to get lost in misinformation about the specific requirements, especially when separated physically by 6-8 time zones and several thousand airmiles. I would categorize the comment about PE's performing equivalent approvals to be in the category of misinformation. Finally, I will mention that for a product that is not exceptionally unique - that is, something that is produced in significant quantity - the view has frequently been - and the law is written such - that this type of product should be listed by an NRTL instead of being field evaluated. If the product in question - a spectrometer, I believe - fall into this category, which I would think is likely, this could be an additional barrier to using field evaluation for the approval of thie equipment. This has been an issue that is coming up more an more in recent years. If you have specific questions about this process or wish to discuss individual labs in Oregon, I would encourage you to contact me directly either via e-mail or at the phone number shown below. Regards, Michael Garretson Sr. Compliance Engineer RadiSys Corporation +1 503 615-1227 "Matsuda, Ken" <MATSUDAK@curti To: "'Pierre SELVA'" <[email protected]>, Forum sinst.com> Safety-emc <[email protected]> Sent by: cc: owner-emc-pstc@ Subject: RE: Safety in Oregon ieee.org 01/29/01 06:44 AM Please respond to "Matsuda, Ken" For Oregon, you can actually have a PE field label your product( in your case for UL's version of 1010---I think it is UL 3101), provided he/she fills out the proper documentation , alot cheaper than an NRTL. Regards, Ken Matsuda -----Original Message----- From: Pierre SELVA [mailto:[email protected]] Sent: Saturday, January 27, 2001 6:48 AM To: Forum Safety-emc Subject: Safety in Oregon Dear colleagues, I would like to know if UL mark (or other certification mark) is required, or mandatory in Oregon state, for safety purpose. This applies to a laboratory equipment (spectrometer). If you know some web links, I'll appreciate them. Thanks a lot for your cooperation, ==================================== Pierre SELVA 2 route de la Grobelle 73000 JACOB BELLECOMBETTE Tel : 33 (0) 6 60 52 04 96 Fax : 33 (0)6 61 37 87 48 e-mail : [email protected] ==================================== ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: [email protected] with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: [email protected] Michael Garretson: [email protected] For policy questions, send mail to: Richard Nute: [email protected] ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: [email protected] with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: [email protected] Michael Garretson: [email protected] For policy questions, send mail to: Richard Nute: [email protected]
