Chris - On the basis of workplace safety, listing by a nonNRTL is largely useless. On the other hand, if the persons providing the listing are a competent engineering firm, using licensed engineers, there may be some credibility to the listing (for instance, the NEC allows waivers of certain requirements, if the installation is under the supervision of a licensed engineer), though it still falls short of the cited bureaucratic dictum. Keep in mind, that butting heads with OSHA will probably only give you a headache.
I note that the OSHA response you provided left out 29 CFR §1910.399 (iii), for custom equipment. In this case, an NRTL might not be required. You make no claims that the equipment is custom built and the conspicuous absence of a reference to 29 CFR §1910.399 (iii) in the Director's letter leads me to believe it is not custom built equipment. Hair splitting: OSHA does not create law; only Congress can do so. OSHA's charter from Congress, however, states that it's regulations have the power of law, so there's not much practical difference. Regards, Peter L. Tarver, PE Product Safety Manager Sanmina-SCI Homologation Services San Jose, CA [email protected] > From: [email protected] > > We are working some responses to OSHA and would > like to ask for some industry response from the > Product Safety group (EMC welcome to respond too). > > Just looking for a quick statement on the Value > of using a Non-NRTL firm for testing and/or > certification (Listing). > > Statement: Non-NRTL laboratories can provide > "Listings" and publish the customers (thus > "Listing") however, based OSHA law, NEC > requirements, Retailer specification, and other > MOU/MRA with Canada/EU, it would not seem to be a > significant accomplishment if not an NRTL. > > In a quick paragraph, would you provide your > opinion on the value of a Non-NRTL Listing > Certification. Thanks Much > > Chris > > PS: Attached is a pdf from Richard Fairfax - > OSHA's Director Directorate of Compliance > Programs which states that Electrical products in > the workplace must be Listed or Labeled by an > NRTL to meet OSHA Law. > ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: [email protected] with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: [email protected] Dave Heald: [email protected] For policy questions, send mail to: Richard Nute: [email protected] Jim Bacher: [email protected] All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on "browse" and then "emc-pstc mailing list"
